PDPL
PERSONAL DATA STORAGE AND DESTRUCTION POLICY
Purpose: As ODS Umbrella and Shading Systems, our priority is to ensure that the personal data of all individuals, including our customers, visitors, suppliers, and employees, is processed in compliance with the Constitution of the Republic of Turkey, international conventions on human rights, and the Law on the Protection of Personal Data No. 6698 (“KVKK”), as well as other relevant regulations. This policy aims to establish rules for processing, storing, and transferring personal data, ensuring the effective exercise of rights of data subjects, and protecting fundamental rights and freedoms, particularly the privacy of private life. It will define the procedures and rules that must be followed by individuals and legal entities processing personal data.
Scope: This policy covers all personal data or sensitive personal data that enables the identification of a real person, whether processed automatically or manually as part of any data recording system. It includes personal data processed by ODS Umbrella and Shading Systems related to customers, visitors, partners, employees, suppliers, third parties, and others. The policy applies to all activities involving the processing of personal data owned by ODS Umbrella and Shading Systems, and it has been prepared in accordance with the KVKK and other relevant legislation and international standards on personal data protection.
Definitions and Abbreviations:
3.1. KVKK: The Law on the Protection of Personal Data (published in the Official Gazette No. 29677 on April 7, 2016).
3.2. Personal Data: Data relating to an identified or identifiable natural person that can be recorded and processed individually (e.g., ID number, IP address, name and surname, contact information – mobile phone, home phone, address, etc.), or reports related to a specific individual (e.g., customer complaint reports, employee performance evaluation reports, interview evaluation reports), records (e.g., audio or visual recordings, photos, user activity logs), documents (e.g., CVs, pay slips, invoices, bank statements, credit card bills, photocopies of IDs), and letters (e.g., invitations, correspondence).
3.3. Sensitive Personal Data: Data that may cause discrimination if processed. These require much stricter protection than other personal data. Sensitive personal data according to Article 6 of the KVKK include: “racial or ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, clothing, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.”
3.4. Personal Health Data: Refers to any health-related data related to an identified or identifiable natural person, such as test results, past illnesses, or medication taken. Personal health data is considered sensitive personal data.
3.5. Processing of Personal Data: Any operation performed on personal data, whether automatically or manually, including collection, recording, storage, modification, organization, disclosure, transfer, retrieval, classification, or blocking of data.
3.6. Employee: Refers to the staff of ODS Umbrella and Shading Systems.
3.7. Data Processor: A natural or legal person who processes personal data on behalf of the data controller, based on authorization given by the data controller.
3.8. Data Controller: A natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system. Under the KVKK, personal data is processed by the “Data Controller” (ODS Umbrella and Shading Systems).
3.9. Service Provider: Refers to companies (suppliers, contractors, customers, etc.) from which ODS Umbrella and Shading Systems receives services or provides services.
3.10. Data Subject: A natural person whose personal data is processed.
ROLES AND RESPONSIBILITIES:
Board of Directors: The Board of Directors is responsible for overseeing the notification, review, and enforcement mechanisms when policies, rules, and regulations are violated. It is authorized to ensure the creation, publication, updating, and termination of this policy.
Employee:
To comply with the policies, regulations, and procedures of ODS Umbrella and Shading Systems.
To ensure that work is performed in accordance with applicable laws and regulations.
To report any actions or practices contrary to this document to Human Resources.
External Service Providers and Business Partners:
External service providers and business partners must comply with the principles of this policy and other relevant regulations. Individuals or organizations failing to comply will have their cooperation terminated. Human rights must be respected when working with subcontractors, suppliers, customers, joint ventures, and other partners. Compliance audits of this policy and related legislation are essential.
LEGAL OBLIGATIONS:
5.1. Obligation to Inform: As the data controller, we are obliged to inform the data subjects when collecting personal data about the following:
The purpose of processing personal data.
Our identity and, if applicable, the identity of our representative.
The recipients to whom the processed personal data may be transferred and the purpose of such transfer.
The method of collecting data and the legal basis for processing.
The rights granted to data subjects under the law.
5.2. Obligation to Ensure Data Security: As the data controller, we are responsible for ensuring the security of personal data by taking the administrative and technical measures prescribed by the relevant regulations. The details of these obligations and the measures taken are specified in Sections 9 and 10 of this policy.
CLASSIFICATION OF PERSONAL DATA
6.2. Special Categories of Personal Data
Personal data concerning individuals’ race, ethnicity, political opinions, philosophical beliefs, religion, sect, or other beliefs, as well as their clothing and attire, membership in associations, foundations, or unions, health, sexual life, criminal convictions, security measures, biometric data, and genetic data are classified as special categories of personal data.
PROCESSING OF PERSONAL DATA
7.1. Principles of Personal Data Processing
We process personal data in accordance with the principles outlined below:
7.1.1. Processing in Compliance with Law and Integrity
We process personal data in a transparent, honest, and lawful manner, ensuring compliance with our obligation to inform.
7.1.2. Ensuring the Accuracy and, if Necessary, Updating of Personal Data
We take the necessary measures in our data processing procedures to ensure that the processed data is accurate and up to date. We also provide the Data Subject with the opportunity to update their data or correct any inaccuracies in the processed data by contacting us.
7.1.3. Processing for Specific, Clear, and Legitimate Purposes
As a company, we process personal data for legitimate purposes that are clearly defined within the scope of the law and the ordinary course of commercial life.
7.1.4. Processing Personal Data in a Relevant, Limited, and Proportionate Manner
We process personal data only for the specific and legitimate purpose for which it was collected, ensuring that it is limited and proportionate. We avoid processing personal data that is irrelevant or unnecessary for the purpose at hand. Unless required by law, we do not process special categories of personal data, or when we do, we obtain explicit consent from the individual concerned.
7.1.5. Retention of Personal Data as Required by Legal Regulations and Our Legitimate Commercial Interests
Several legal regulations require the retention of personal data for a specified period. Therefore, we retain the personal data we process for as long as required by the relevant legal regulations or the purposes for which the personal data was processed.
Once the retention period specified by the regulations has expired, or the purpose of processing no longer exists, we delete, destroy, or anonymize the personal data. The principles and procedures related to retention periods are detailed in Article 9.1 of this Policy.
7.2. Methods of Collecting Personal Data
Personal data may be collected by our Company through various channels, including the central office, branches, agencies, sales offices, or other subcontractors or business partners of ODS Parasol and Shading Systems, physical locations such as offices, call centers, websites, mobile applications, and other electronic transaction platforms, social media, or other public platforms. It can also be obtained through participation in events such as training, conferences, or investigations, or via written, verbal, audio or visual recordings, and other physical or electronic environments, through other group companies or third-party organizations with which we have agreements.
In accordance with the Law on Personal Data Protection (KVKK), we collect your personal data via the following channels, both automatically and manually, in written, verbal, audio, or electronic form, in line with the purposes of data processing under Articles 5.1, 5.2, 6.2, and 6.3 of the KVKK:
Through all sales and marketing networks (ODS Parasol and Shading Systems Offices) operated under the name of ODS Parasol and Shading Systems,
Through social media accounts managed on behalf of ODS Parasol and Shading Systems Brands (“Social Media”),
Through communications via email addresses (“Email”), including SMS (“SMS”) or multimedia messages (“MMS”) sent for other purposes related to ODS Parasol and Shading Systems and its brands, and other communication channels (“Communication Tools”),
Through our call centers managed by ODS Parasol and Shading Systems or the companies that provide services to us (“Call Center”),
Through third parties, such as the group companies, business partners, manufacturers, or service/product providers that ODS Parasol and Shading Systems works with.
The personal data collected can be processed, transferred, and stored in line with the conditions and purposes set out in Articles 5 and 6 of the KVKK, and for the purposes outlined in Article 7.3 of this document.
7.3. Purposes of Processing Personal Data
As a general rule, we process your personal data based on your explicit consent. However, in certain exceptional cases permitted by KVKK, your personal data may be processed without your explicit consent (Articles 5.2 and 6.3 of KVKK). In this context, for purposes such as fulfilling our legal obligations, providing products and services ordered through our websites, processing sales transactions at ODS Parasol and Shading Systems Sales Offices, handling returns, deliveries, addressing inquiries and complaints, and in the event of a dispute, to establish or defend legal rights, as well as for legitimate interests like cost reduction, resource efficiency, and monitoring call center service quality, we may process your personal data without your explicit consent.
Additionally, the personal data you publicly disclose through channels such as contests and social media can be processed without further consent, in accordance with the scope allowed by the KVKK.
We process personal data for the following purposes with your explicit consent:
Conducting our activities,
Providing support services in line with the terms of the contract and service standards,
Identifying and addressing our customers’/visitors’ preferences and needs, and adapting our services accordingly,
Ensuring compliance with legal regulations,
Advertising and marketing activities,
Online advertising, targeting, re-targeting, cross-selling, campaigns, promotions, product/service advertisements, and providing personalized opportunities for customers, including the use of cookies,
Offering commercial proposals based on customer preferences and previous purchases,
Determining how customers become aware of our websites, creating non-anonymous traffic statistics based on individual user registration,
Processing personal data to personalize content and browsing experience on our websites, including the use of cookies,
Tracking customer habits and offering personalized products during visits to ODS Parasol and Shading Systems Sales Offices, and conducting advertising, campaign, and CRM activities for sales and marketing purposes, including using cookies,
Processing personal data for developing new product and service models, including the use of cookies,
Conducting market research and statistical studies,
Organizing surveys, competitions, promotions, and sponsorships,
Identifying suitable products, projects, and services for our customers and customizing them accordingly,
Notifying customers, employees, suppliers, and business partners of changes in the law or internal policies,
Conducting birthday celebrations, raffles, giveaways, or other promotional activities benefiting the customer,
Informing customers about campaigns via email, SMS, and fax,
Sending electronic commercial communications such as newsletters, product/service advertisements, and promotional materials, and organizing corporate communications, including printed bulletins and magazines,
Identifying visitor profiles, evaluating requests, demands, and complaints,
Evaluating job applications,
Maintaining communication with individuals involved in business relationships with the company,
Ensuring compliance management,
Managing vendor/supplier relationships,
Performing legal reporting,
Handling invoicing,
Maintaining communication with customers of ODS Parasol and Shading Systems,
Managing call center processes,
Organizing corporate communications,
Personalizing job advertisements and managing job postings,
Providing personalized job listings and employment-related information,
Sending newsletters or notifications via email.
7.4. Processing of Special Categories of Personal Data
Special categories of personal data are processed by us in accordance with the laws and administrative and technical measures prescribed by the Personal Data Protection Authority (KVK) and with explicit consent, or in cases required by law.
Special categories of personal data related to health and sexual life can be processed by persons or authorized entities under confidentiality obligations, and can be processed for purposes such as public health protection, preventive medicine, medical diagnosis, treatment and care services, health services planning, and management. These data are only processed for our employees as provided by law.
7.5. Processing of Personal Data for Human Resources and Employment Purposes
Personal data shared with us, such as resumes, diplomas, and other documents during job applications, are processed, stored, and transferred for evaluating job applications. The processing, transferring, and storing of personal data shared by job applicants is subject to this Policy.
Identity and communication data are processed for purposes such as creating resumes, communication, job development, and informing. Social media data collected from applicants’ existing social media accounts are processed for operational activities such as job development, marketing, and improving user experience.
ODS Umbrella and Shading Systems store identity, education, and professional information related to candidates under the relevant laws and may transfer data to the department manager upon request.
The deletion, destruction, or anonymization of personal data on this platform is covered in Article 9 of this Policy. If the job application results in a negative outcome, the processing and security of the personal data shared with the employer are the employer’s responsibility.
7.6. Personal Data of Employees
Personal data is collected, processed, and stored in accordance with ODS Umbrella and Shading Systems’ Human Resources Policy, aside from this Policy.
7.7. Processing of Job Applications via ODS Umbrella and Shading Systems Website
Personal data provided by candidates filling out job application forms on our website is recorded. This data includes identity information (name, surname, date of birth, national ID number), contact details (address, email, phone number), educational information (schools attended), work experience, language skills, certificates, and references. Based on the job application, additional health data may be requested to assess whether the candidate is qualified for the role. The requested health data will only be processed for employment purposes in accordance with the relevant legislation.
7.8. Exceptional Cases Where Explicit Consent is Not Required for Processing Personal Data
We may process personal data without explicit consent in the following cases prescribed by law:
Where explicitly required by law;
If processing personal data is necessary for the establishment or performance of a contract;
If processing is required for the establishment, use, or protection of a legal right;
For our legitimate interests, provided it does not infringe on fundamental rights and freedoms. Special categories of personal data can be processed without explicit consent in the exceptional cases specified in Article 7.3 of this Policy.
8. PERSONAL DATA TRANSFER
8.1. Transfer of Personal Data
ODS Umbrella and Shading Systems processes personal data in accordance with the Personal Data Protection Law and decisions or regulations issued by the Personal Data Protection Authority (KVK).
Personal data and special categories of personal data are not transferred to other individuals or legal entities without the explicit consent of the Data Subject, except in cases specified by the law.
In exceptional cases specified by the KVKK and other relevant legislation, personal data may be transferred to authorized administrative or judicial institutions without the explicit consent of the Data Subject, in line with the legal framework.
8.3. Institutions and Organizations to Which Personal Data May Be Transferred
Personal data may be transferred to:
Our suppliers,
Business partners and connections,
Affiliate companies,
Legally authorized public institutions and organizations,
Legally authorized private entities,
Shareholders, in accordance with the principles outlined above.
8.4. Measures Taken to Ensure Legal Transfer of Personal Data
ODS Umbrella and Shading Systems adheres to all constitutional human rights and international agreements, principles, and laws in its operations, respecting the rights of individuals. The protection of personal data is a core principle in our policy. We take all administrative and technical measures required by the nature of the data to ensure the protection of personal data and respect for the fundamental rights and freedoms of individuals.
Any changes to the Personal Data Protection Law or methods set by the Personal Data Protection Authority may result in modifications to this notice.
9. COOKIE POLICY
9.1. What are Cookies?
Cookies are small text files stored on your devices via browsers when you visit websites. This website uses cookies as described here.
9.2. Why Do We Use Cookies?
We use cookies to:
Enhance your visit to our websites, improve functionality, and increase usability,
Recognize you during your next visit and offer personalized content and browsing experience,
Provide personalized offers, targeting and re-targeting ads, cross-selling, campaign, opportunity, and product/service advertisements,
Generate traffic statistics,
Determine how you heard about our website.
9.3. Which Cookies Do We Use?
For more information on the cookies used on this website, please click here.
9.4. How Can You Adjust Your Browser’s Cookie Settings?
Most browsers are set by default to accept cookies, but you can easily change your browser settings to disable them. However, if you disable cookies, you may not be able to access all the features of our websites.
For more information on cookie settings for different browsers, visit the following links:
If you disable cookies via your browser, you will also disable all cookies, including those necessary for the proper functioning of our websites.