Privacy Notice

Personal data is processed by Pudena under this Privacy Notice in accordance with the Law on the Protection of Personal Data numbered 6698 (“KVKK”), secondary regulations, and other legislation regarding the protection of personal data.

1. Online Visitors
2. I. PROCESSED PERSONAL DATA

When you visit our website, the following personal data may be processed:

Identity Information: Name, surname, date of birth,

Contact Information: Address, email address, phone number,

Transaction Security Information: IP address information, username and password, log information, internet entry-exit record information, traffic information.

1. II. PURPOSES OF PROCESSING YOUR PERSONAL DATA

• Your personal data may be processed for the following purposes in compliance with the relevant legislation when you visit our website:
• Planning and execution of corporate communication activities,
• Planning of information security processes, their audit, and execution,
• Conducting sponsorship activities,
• Planning and execution of events and training activities,
• Execution of the Entrepreneur of the Year program,
• Execution of the Female Entrepreneur Leaders program,
• Execution of the Tax Marathon competition,
• Management of ethical rules,
• Establishment and management of the former employee network,
• Announcement of circulars or bulletins,
• Management of marketing and sales activities,
• Conducting analysis and reporting studies,
• Management of our relationships with customers, suppliers, and business partners,
• Evaluation and response to suggestions, requests, and complaints submitted to our company, and conducting improvement studies in accordance with notifications.
• Improvement and diversification of our company’s business processes,
• Conducting quality and standard audits,
• Tracking of financial and accounting affairs,
• Contract management, establishment of legal processes, and tracking of legal processes,
• Evaluation of job applications submitted through our website in case you are a job candidate,
• Execution of communication activities,
• Fulfillment of obligations arising from the Law No. 5651,
• Preservation of your information required by the relevant legislation; copying and backing up to prevent information loss; ensuring the consistency of your information; taking necessary technical and administrative measures for the security of our networks and your information,
• Fulfillment of legal obligations required by regulatory and supervisory authorities or mandatory legal regulations, and execution of legal follow-ups and processes.

1. III. TRANSFER OF YOUR PERSONAL DATA

Your personal data may be shared with official institutions and organizations, our domestic and foreign suppliers with whom we are affiliated, and companies within the Global Pudena network abroad to the extent required by the purposes listed under the title A.II of this Privacy Notice within the scope of the provisions of the Law on the Protection of Personal Data regarding the transfer of personal data.

1. IV. LEGAL BASIS AND COLLECTION METHOD OF PROCESSING PERSONAL DATA

Your personal data is processed during your visit to our website and during the continuation of the said relationship, through electronic channels or by you or third parties through electronic platforms, within the scope of the legal bases specified in Articles 5, 8, and 9 of the Law, and the legality reasons listed below:

• Explicit consent,
• Being clearly stipulated in the laws,
• Necessity of processing personal data of the parties to the contract directly related to the establishment or performance of a contract, provided that it is limited to the purpose of providing the requested product and service and fulfilling the obligations under the contracts you have concluded,
• Being necessary to fulfill the legal obligation,
• Being made public by the data subject himself/herself,
• Being necessary for the establishment, exercise, or protection of a right,
• Being mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

1. PHYSICAL VISITORS

B.I. WHAT PERSONAL DATA DO WE PROCESS?

During your visit to the Pudena premises, the following personal data may be processed: full name, national identification number (NIN), phone number, email address, visitor entry-exit records, camera recordings, and, if you request wireless internet access: IP address, internet log records.

B.II. PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data may be processed for the following purposes in compliance with the relevant legislation during your visit to the Pudena premises:

 

• Monitoring via camera recordings to ensure the security of visitors in our premises.
• Collection of visitor information during door access control.
• Provision of guest wireless internet access.

B.III. TRANSFER OF PROCESSED PERSONAL DATA

In accordance with the provisions of the Personal Data Protection Law (PDPL) regarding the transfer of personal data, your personal data may be shared with domestic official institutions and organizations, courts, law enforcement agencies, related service provider companies, and our business partners to the extent required by the purposes listed under Section B.II of this Privacy Statement.

B.IV. LEGAL BASIS AND METHOD OF COLLECTION OF PERSONAL DATA

Your personal data, collected, stored, and processed within the Pudena network premises when you visit, are based on and processed in accordance with the legal grounds listed below, as well as the purposes mentioned above:

• Explicit provision in the laws.
• Necessity for the performance of a contract to which the data subject is a party or for taking pre-contractual measures upon request for products and services, and for the fulfillment of contractual obligations.
• Obligation to fulfill a legal requirement.
• Data made public by the data subject.
• Necessity for the establishment, exercise, or protection of a right.
• Necessity for the legitimate interests pursued by the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

1. POTENTIAL CUSTOMERS/SUPPLIERS/PARTNERS

C.I. WHAT PERSONAL DATA DO WE PROCESS?

In the context of your relationship with Pudena, the following personal data may be processed:

• Identity Information: Full name, date of birth, place of birth.
• Contact Information: Address details, email address, phone number, social media accounts.

C.II. PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data, in relation to your association with Pudena, may be processed for the following purposes in compliance with the relevant legislation:

• Conducting communication activities.
• Managing the offer process for services and products.
• Carrying out promotional and marketing activities.
• Fulfilling legal obligations arising from regulations.
• Conducting storage and archival activities.
• Handling legal, litigation, and administrative matters.

C.III. TRANSFER OF PROCESSED PERSONAL DATA

In accordance with the provisions of the Personal Data Protection Law (PDPL) regarding the transfer of personal data, your personal data may be shared with domestic judicial authorities or law enforcement agencies in compliance with the purposes listed under Section C.II of this Privacy Statement, upon request in accordance with the relevant legislation.

C.IV. LEGAL BASIS AND METHOD OF COLLECTION OF PERSONAL DATA

In the context of your relationship with Pudena, your personal data is collected and processed through various means including internet, phone, email, physical, written, verbal, and electronic channels from you directly, from the supplier we receive services from, or from partner companies, as well as legal authorities. This processing is based on the legal grounds listed below, and for the purposes mentioned above, in accordance with Articles 5 and 8 of the PDPL:

• Necessity for the performance of a contract to which the data subject is a party or for taking pre-contractual measures upon request for products and services, and for the fulfillment of contractual obligations.
• Data made public by the data subject.
• Necessity for the legitimate interests pursued by the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

1. OUR CUSTOMERS

D.I. WHAT PERSONAL DATA DO WE PROCESS?

In the context of your relationship with Pudena, the following personal data may be processed:

• Identity Information: Full name, ID card, Turkish Republic ID number, nationality, marital status, date/place of birth.
• Contact Information: Address, email, mobile phone number.
• Financial Information: Bank and account details, balance sheet information, invoice and debt information, receivables risk information, financial performance information, credit and risk information, asset information.
• Visual Recording Data: Photograph information.
• Customer Transaction Data: Order and request information, promissory note and check information.
• Professional Experience Data: Resume.
• Risk Management Data: Information processed for managing commercial/technical/administrative risks.
• Legal Transaction Data: Data in the lawsuit files.

D.II. PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data, in relation to your association with Pudena, may be processed for the following purposes in compliance with the relevant legislation:

 

• Conducting service sales processes.
• Carrying out post-sales support services.
• Providing service offers.
• Executing contract processes.
• Conducting communication activities.
• Providing consultancy services.
• Sending celebratory mails or gifts as part of customer relationship management for congratulatory purposes.
• Managing organization and event management activities.
• Executing travel and accommodation processes.
• Identifying target customers and conducting marketing activities.
• Executing finance and accounting processes.
• Payroll/budget reporting process.
• Executing current account opening form process.
• Conducting legal processes.
• Managing Anti-Money Laundering (AML) processes.
• Providing information to authorized individuals, institutions, and organizations.

D.III. TRANSFER OF PROCESSED PERSONAL DATA

Your personal data may be transferred to official institutions and organizations, our suppliers, and our domestic and international business partners as required by the purposes listed under Section D.II of this Privacy Statement, within the scope of the provisions of the Personal Data Protection Law regarding the transfer of personal data.

D.IV. LEGAL BASIS AND METHOD OF COLLECTION OF PERSONAL DATA

Your personal data is collected and processed through various means including the internet, various contracts, electronic mail, verbal, written, or electronic means via communication channels with you, our suppliers, our business partners, and legal authorities. The personal data collected in this context is processed based on the legal grounds stated below, in accordance with Articles 5, 8, and 9 of the Personal Data Protection Law:

• Your explicit consent.
• Clearly stipulated in the legislation applicable to our company, including the Tax Procedure Law, Turkish Code of Obligations, and Turkish Commercial Code.
• Necessity for the performance of a contract to which you are a party or for taking pre-contractual measures upon request for products and services, and for the fulfillment of contractual obligations.
• Necessity for compliance with a legal obligation.
• Data made public by you.
• Necessity for the establishment, exercise, or protection of a right.
• Necessity for the legitimate interests pursued by the data controller, provided that it does not harm your fundamental rights and freedoms.

 

1. AUTHORIZED SUPPLIERS/BUSINESS PARTNERS

E.I. WHAT PERSONAL DATA DO WE PROCESS?

In the context of your relationship with Pudena, the following personal data may be processed:

• Identity Information: Full name, parent names, place of birth, date of birth, driver’s license information, marital status, Turkish Republic ID number, passport number, tax number, nationality, parent names, signature.
• Contact Information: Address, email, phone number.
• Financial Information: Bank account and card information, invoice and debt information.
• Legal Transaction Information: Information in correspondence with judicial authorities, information in lawsuit files.
• Professional Experience Information: Information related to professional qualifications.

E.II. PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data, in relation to your association with Pudena, may be processed for the following purposes in compliance with the relevant legislation:

• Conducting purchase processes for goods and services.
• Conducting communication activities.
• Executing contract processes.
• Conducting audit activities.
• Opening/changing and controlling current accounts.
• Fulfilling legal obligations arising from legislation.
• Conducting legal, litigation, and administrative affairs.
• Conducting accounting processes.
• Providing information to authorized individuals, institutions, and organizations.

E.III. TRANSFER OF PROCESSED PERSONAL DATA

Your personal data may be transferred to official institutions and organizations, our suppliers, and our domestic and international business partners as required by the purposes listed under Section E.II of this Privacy Statement, within the scope of the provisions of the Personal Data Protection Law regarding the transfer of personal data.

E.IV. LEGAL BASIS AND METHOD OF COLLECTION OF PERSONAL DATA

Your personal data is collected and processed through various means including the internet, contracts, electronic mail, verbal, written, or electronic means via communication channels with you, our business partners, and legal authorities. The personal data collected in this context is processed based on the legal grounds stated below, in accordance with Articles 5, 8, and 9 of the Personal Data Protection Law:

• Clearly stipulated in the legislation applicable to our company, including the Tax Procedure Law, Turkish Code of Obligations, and Turkish Commercial Code.
• Necessity for the performance of a contract to which you are a party or for taking pre-contractual measures upon request for products and services, and for the fulfillment of contractual obligations.
• Necessity for compliance with a legal obligation.
• Data made public by you.
• Necessity for the establishment, exercise, or protection of a right.
• Necessity for the legitimate interests pursued by the data controller, provided that it does not harm your fundamental rights and freedoms.

1. YOUR RIGHTS REGARDING THE PROTECTION OF YOUR PERSONAL DATA

You may exercise your rights regarding your personal data by contacting the companies within the Pudena network through the methods listed in the “Contact” section of this Privacy Statement:

• Learn whether your personal data is being processed.
• If processed, request information regarding this processing.
• Learn the purpose of the processing and whether it is being used for that purpose.
• Learn the recipients to whom your personal data has been transferred, domestically or internationally.
• Request correction of incomplete or inaccurate personal data.
• Request deletion or destruction of personal data within the framework of the conditions stipulated in the Personal Data Protection Law.
• Request notification of corrections, deletions, or destructions made in accordance with your rights under the Law on Protection of Personal Data.
• Object to the occurrence of a result against you by analyzing your personal data solely through automated systems.
• Request compensation if you suffer damage due to the processing of your personal data in violation of the relevant legislation.

1. CONTACT FOR RIGHTS AND REQUESTS

You can submit your questions and requests regarding your personal data to Pudena companies within the Pudena network, personally by identifying yourself or through a notary public, by using the methods listed in the “Contact” section, in accordance with the principles and procedures specified in the Regulation on Procedures and Principles of Application to the Data Controller.