İSTGÜVEN İSTANBUL GÜVENLİK AŞ

PRIVACY NOTICE UNDER THE LAW ON THE PROTECTION OF PERSONAL DATA NO. 6698

İSTGÜVEN İstanbul Güvenlik AŞ ("İSTGÜVEN AŞ" or the "Company") takes all necessary technical and legal measures in accordance with the Law on the Protection of Personal Data No. 6698 ("LPPD") regarding the processing of personal data within the scope of its business activities.

Data subjects may find detailed information in this Privacy Notice regarding the processing of their personal data, the transfer of such data to third parties, the legal grounds for the collection of personal data, and their rights under the LPPD.

 

A – PURPOSES OF PROCESSING PERSONAL DATA

Your personal data may be processed by the Data Controller or by natural or legal persons authorized by the Data Controller under the following circumstances and for the following purposes:

  1. To perform the services carried out within the scope of the duties and responsibilities of Istanbul Metropolitan Municipality ("IMM") in accordance with the Metropolitan Municipality Law No. 5216 and the relevant legislation;
  2. To ensure communication and cooperation between our Company and IMM; to maintain coordination; to carry out joint business activities; to identify the needs of our customers and employees; to fulfill contractual obligations; to ensure occupational health and safety and business continuity; to establish and improve the operation of a shared database; to facilitate communication; and to manage our corporate brand and reputation;
  3. To ensure that the products and services produced and provided by our Company, IMM, and other IMM subsidiaries are delivered effectively to consumers, suppliers, business partners, and public institutions in line with our commercial, public service, and social objectives;
  4. To comply with applicable legislation and fulfill our contractual obligations;
  5. To maintain our statutory commercial books, invoices, tenders, checks, payroll records, and other legally required documentation, and to ensure that the related processes are carried out accurately and effectively;
  6. To take the necessary occupational health and safety measures, plan and conduct training activities, and enable timely intervention in health-related matters in accordance with our legal obligations;
  7. To conduct the necessary quality assurance and compliance audits and fulfill our obligations arising from applicable laws, regulations, and other legal requirements;
  8. To notify data subjects of any amendments to applicable legislation or to the policies adopted by our Company, and to provide other notifications concerning the data subject;
  9. To ensure the full performance of contracts to which our Company is a party and to verify that the other contracting parties fulfill their contractual obligations;
  10. To improve, develop, diversify, and enhance our services and to offer alternative solutions to the natural and legal persons with whom we maintain commercial relationships;
  11. To safeguard the legal security of natural and legal persons engaged in commercial relationships with our Company;
  12. To fulfill our post-service obligations;
  13. To carry out procurement activities and corporate correspondence;
  14. To ensure the security of our employees, visitors, and Company premises through CCTV systems and other security measures, and to control access to and exit from our facilities;
  15. To evaluate recruitment processes for job applicants, maintain personnel files, and implement our Human Resources policies;
  16. To ensure the efficient and effective use of the equipment and assets assigned to our employees;
  17. To promote our Company and its activities, announce events, and inform the public through photographs and videos taken during meetings, seminars, training sessions, social events, award ceremonies, and other corporate events organized by or attended by our Company;
  18. To improve employee morale, motivation, performance, satisfaction, and interaction among employees and with our Company;
  19. To conduct supervision, investigations, and disciplinary procedures in relation to incidents that may occur in the workplace;
  20. To prepare reports, research, and presentations; plan emergency management processes; monitor finance and accounting operations; and ensure the security of our Company;
  21. To create and maintain visitor records;
  22. To provide internet access to visitors at our Company premises;
  23. To generate statistical data, record visitor information, and facilitate follow-up communications when our website is visited;
  24. To identify communications and determine their content when communication is established through our call centers or Company telephone lines, including the processing of voice recordings and call records;
  25. To carry out personnel administration activities more efficiently through ERP, EBYS (Electronic Document Management System), and other digital platforms.


B – TRANSFER OF PERSONAL DATA

  1. Your processed personal data may be transferred, in line with the purposes stated above and under the conditions set forth in the Law on the Protection of Personal Data No. 6698 (LPPD), to the following recipients:
  1. To our business partners, Istanbul Metropolitan Municipality ("IMM"), and IMM Subsidiaries, for the purpose of carrying out, maintaining, and coordinating our public services and commercial activities;
  2. To IMM, IMM Subsidiaries with which we are corporately affiliated, as well as our suppliers and solution partners, for the purposes of establishing and facilitating the operation of a shared database, improving communication, and managing our corporate brand and reputation;
  3. To IMM, the Turkish Court of Accounts, authorized public institutions and organizations, audit firms, private integrator service providers, and independent auditing firms, in accordance with the applicable legislation and relevant contractual obligations, for the purpose of auditing our public service activities;
  4. To legally authorized public institutions and organizations, limited to the scope of their lawful requests and purposes;
  5. To our suppliers for the development and implementation of strategies relating to our public services and commercial activities;
  6. To private and public legal entities for the purpose of enhancing the Company's recognition and reputation, improving its internet infrastructure, and maintaining its digital platforms;
  7. To third parties and organizations requesting references based on a valid legal ground;
  8. To natural and legal persons, as well as public institutions and organizations, with whom we cooperate in carrying out our business activities and public services;
  9. To banks, financial institutions, and our business partners for the execution of banking and financial transactions;
  10. To consultancy firms specializing in finance, commerce, management, human resources, and other professional fields, for the purposes of improving quality standards, reducing costs, and fulfilling our legal obligations;
  11. To our business partners and suppliers for the execution of advertising, marketing, and promotional activities;
  12. To IMM, IMM Subsidiaries, and contracted service providers involved in organizing events, conferences, celebrations, and similar social activities;
  13. To catering companies, event organizers, and other relevant service providers for the provision of meals, gifts, promotional items, and similar benefits to our employees;
  14. To occupational health and safety service providers, hospitals, and healthcare institutions for emergency medical intervention and the fulfillment of our occupational health and safety obligations;
  15. To solution partners, suppliers, and companies providing repair, maintenance, technical support, and servicing activities;
  16. To domestic and international software vendors and technology companies for the establishment, operation, maintenance, and support of databases and information systems, including but not limited to SAP, CRM, ERP, QDMS, Patrol Management Systems, and IOMA;
  17. To domestic and international institutions and organizations providing security, technology, cloud computing, and digital infrastructure services, where necessary for the provision of such services.


C – METHOD AND LEGAL BASIS FOR THE COLLECTION OF PERSONAL DATA

Your personal data is collected by our Company or by natural or legal persons processing data on behalf of our Company through application forms, 153 Solution Center, our website, various agreements, information forms, surveys, job application forms, employment contracts, social media platforms, written, verbal, and electronic notifications received from Istanbul Metropolitan Municipality (IMM), other IMM Subsidiaries, our suppliers, and business partners, call centers, and other verbal, written, or electronic channels not limited to those listed herein. Such personal data is processed based on your explicit consent or on the other legal grounds for data processing set forth in the Law on the Protection of Personal Data No. 6698 (LPPD).


D – RETENTION AND DISPOSAL OF PERSONAL DATA

Our Company retains personal data only for as long as necessary to fulfill the purposes for which it is processed and in a manner proportionate to those purposes.

Where the purpose and/or legal basis for processing personal data no longer exists, such data shall continue to be retained for the period required under the applicable legislation. Once the purpose and legal basis for processing have ceased to exist, and upon the expiration of the statutory limitation periods necessary for the fulfillment of our legal obligations, the relevant personal data will be deleted, destroyed, or anonymized in accordance with the applicable legislation.

The deletion, destruction, or anonymization of personal data that falls within the scope of exceptions arising from the provision of public services shall be carried out in accordance with the relevant legal requirements.


E – RIGHTS OF THE DATA SUBJECT

Pursuant to Article 11 of the Law on the Protection of Personal Data No. 6698 ("Law"), every data subject has the following rights:

  1. To learn whether their personal data is being processed;
  2. To request information if their personal data has been processed;
  3. To learn the purpose of the processing of their personal data and whether it is used in accordance with that purpose;
  4. To know the third parties to whom their personal data has been transferred, whether domestically or abroad;
  5. To request the correction of incomplete or inaccurate personal data and to request that such correction be notified to third parties to whom the personal data has been transferred;
  6. To request the deletion or destruction of personal data where the reasons requiring its processing no longer exist, even though it has been processed in accordance with the Law and other applicable legislation, and to request that such action be notified to third parties to whom the personal data has been transferred;
  7. To object to any result that is detrimental to the data subject arising exclusively from the analysis of processed data through automated systems;
  8. To request compensation for damages suffered as a result of the unlawful processing of personal data.

Data subjects may submit their requests concerning these rights in writing by sending a notarized notice to the address of our Company provided below or by submitting a written application in person upon presentation of a valid identity document.

Requests submitted by data subjects will be evaluated and concluded free of charge as soon as possible and, in any event, within thirty (30) days. However, if the evaluation or resolution of the request requires additional costs, the fee determined by the Personal Data Protection Board shall apply.



F - Veri Sorumlusunun Kimliği

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