- The purpose of this personal data protection policy (“Policy”) is to ensure that Akinon İnternet Yatırım ve Proje Geliştirme Anonim Şirketi (“Akinon”) process personal data in accordance with the applicable personal data protection legislation especially the Personal Data Protection Law No. 6698, related secondary legislation and the European General Data Protection Regulation 2016/679 (GDPR) (“Data Protection Legislation”). For the purpose of the Data Protection Legislation, the following definitions will be taken as the basis:
- Personal Data: Any information relating to an identified or identifiable natural person;
- Processing of Personal Data: Any operation performed on personal data wholly or partly by automated means or non-automated means provided that it is a part of a data filing system; such as collection, recording, storage, protection, alteration, adaptation, disclosure, transfer, retrieval, making it available for collection, categorisation, preventing the use thereof;
- Special Categories of Personal Data: Personal data relating to the race, ethnic origin, political opinion, philosophical belief, religion, religious sect or other belief, appearance, membership to associations, foundations or trade-unions, data concerning health, sexual life, criminal convictions and security measures, and the biometric and genetic data;
- Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data filing system and Akinon;
- Data Processor: The natural or legal person who processes personal data on behalf of the data controller upon its authorisation;
- Data Subject: The natural person, whose personal data are processed;
- Data Filing System: Any recording system used by Akinon in which the Personal Data is structured and processed according to certain criteria;
- Board: The Personal Data Protection Board;
- Authority: The Personal Data Protection Authority;
- Supervisory Authority Concerned: means a supervisory authority that is concerned by the processing of personal data since i) the controller or processor is established on the territory of that supervisory authority; ii) data subjects residing in the territory of that supervisory authority are substantially affected or likely to be substantially affected by the processing, or a complaint has been lodged with that supervisory authority.
- PDPL: The Personal Data Protection Law No. 6698 published in the Official Gazette dated 07.04.2016 and numbered 29677.
- GDPR: EU General Data Protection Regulation numbered 2016/679.
- Through this Policy, Akinon aims to inform the Data Subject regarding the personal data processed by Akinon, and the content of the Policy is as follows:
- The content and categories of the Personal Data collected by Akinon; their usage and transfer options;
- The processing means of the Personal Data;
- The protection means of the Personal Data;
- The rights of the Data Subjects;
- The measures are taken regarding the protection of Personal Data.
- The Principles Regarding The Processing of the Personal Data
- Akinon operates and processes data with the purposes set out in the articles of association registered and announced before the relevant trade registry office.
- Akinon develops web and internet-based commercial projects and software, provides web site, portal electronic commerce site, internet domain name, web space, server services, performs all kinds of research and development activities, statistical data analysis, data and information production to be used with the software.
- Akinon, regarding its purposes, processes the Personal Data enumerated below collected from its board members, employees, employee candidates, website visitors, newsletter subscribers, event and training participants, suppliers, authorised persons of the clients and solution partners, their employees and the end-users (“Data Subject”), within the scope of the Data Protection Legislation. (The Personal Data enumerated below may differ pursuant to the Data Subject groups mentioned above.):
- Name surname, ID Number;
- Date of birth, place of birth, mother-father name, civil status, identity data including serial and sequence number of the identification card; identity register copy; certificate of residence;
- Driving license, class of driving license, vehicle registration plate;
- Bank account number,
- Billing and payment information,
- Information on the business/ personal card,
- Social security number,
- Health data in the general health report,
- Passport photograph,
- Contact data including address, phone number, e-mail address,
- Name and surname of the dependents of employees,
- Workplace entry-exit records of the employees,
- Employee’s registration number,
- Information regarding the military service/ compulsory service; education and foreign language/copies of professional certificates, criminal records regarding criminal convictions and security measures,
- Access records of Wi-Fi users of Akinon and IP Address; username and password,
- Location information,
- Information on how the website, extension, and social media content is used,
- Name and surname and contact data of Data Subject’s emergency person,
- Signature of Data Subject,
- Circular of signature or any document confirming the signature,
- Photographs and video records,
- Association/union membership information of the employee candidate;
- Method, Legal Grounds and Purpose of the Personal Data Processing Within the Scope of the Law
Akinon, processes the Personal Data enumerated above within the commercial or employment relationship with the Data Subjects on the grounds that i) it is expressly provided for by the laws and it is imperative to Akinon to perform its legal obligation, ii) processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract, iii) it is obligatory for the establishment, exercise or protection of any right, iv) processing of personal data is necessary for the legitimate interests of Akinon, provided that the processing shall not violate the fundamental rights and freedoms of the Data Subjects or v) upon the explicit consent of Data Subjects.
Personal Data processing activities are conducted by Akinon; physically and/or electronically by automated or non-automated means, with the following purposes:
- Personal Data collected during employment relationship procedures are processed within the framework of human resources policies and the employment contract with the purposes to conduct, carry out, manage, maintain, evaluate and end employment relationship, maintain and develop efficient employment management, fulfil obligations arising from the employment contract and/or the legislation, conduct and performance human resources procedures, evaluate performance of the employees, using administration ability, make plans on their career and success, pay their wages and social rights, make social welfare, carry out transactions before other institutions and organisations including the related social security institution, ensure development and education, provide resource and ability, develop organisational culture, provide and maintain occupational safety, providing payroll service, meet the workforce need in the future through the personnel candidate pool system, obtain information about the job accumulation, experience, professional seniority of the employee candidate and determine the positions and rights in past work experiences, implement the workplace rules, allocate employees a computer, mobile phone, e-mail address, username and password for work purposes, inspect, examine and follow-up the allocated resources.
- Personal Data collected during customer relationship procedures are processed with the purposes to conduct operational and advertisement/promotion procedures, to provide customer satisfaction, perform the service agreement, carry out necessary exercises to recommend and promote the products and services offered to the customers by customising them according to end-users’ likes, usage habits and needs, conduct evaluation and feedback procedures regarding the services, conduct sales and marketing policies, implementing Akinon Cookies Policies, fulfil legal obligations, provide cloud service, categorising the customer list by profiling, carry out purchasing activities, organise meetings, resolve commercial disputes and execute communication activities.
- Personal Data collected during supplier relationship procedures are processed for purposes to conduct operational and commercial activities and execute communication activities. Personal Data collected during this procedure are processed during the execution and continuation of the contract with the purpose to fulfil obligations arising from the contractual relationship.
- Personal Data collected during events or training are processed with the purposes to provide security, to share or post on social media platforms and to record the training and events attended.
- Personal Data collected during the visit to Akinon website are processed to ensure that the website, platforms and other online services are working correctly, to ensure security, to facilitate navigation, to display information more effectively, to personalise the experience, to improve the design and functionality of the services, to understand how they are used, to monitor website performance, and to track the effectiveness of the online marketing activities.
- Personal Data collected during opt-in newsletter subscription are processed to verify the Data Subjects’ contact information and to provide newsletter service.
Akinon’s purposes of processing and transfer of Data Subject’s Personal Data are limited with the purposes and bases that are stated above.
Akinon collects some cookie information during your visit to the website. Cookies are text files containing small amounts of information that are downloaded to your computer or mobile device when a website is visited and allow a site to recognise your device. The data collected through cookies are generally used for the purposes of improving the experience on the website, increasing the performance and efficiency of the website, detecting user habits, security and advertising/marketing.
Cookies can remain on devices for different periods of time; these are defined as persistent and temporary cookies. Temporary cookies expire when the browser is closed, whereas persistent cookies remain after the browser is closed until the Data Subject deletes them and may then be used by the browser when the website is used again (for example, to recall login details). Cookies only contain data relating to the website visit and do not collect any information about the data already on the Data Subject’s computer or mobile device.
In certain cases, we collect certain personal data through cookies, including IP address, information about how the website is used, internet browser selection, where the website is accessed from (location information) and which device is used. We use the aforementioned personal data that we process through cookies to maintain the basic functions of our website, to facilitate navigation and improve customer experience and for security purposes. In addition, cookies help us collect statistical information about the use of the services to monitor the effectiveness of our online marketing activities and to understand your website usage habits, tastes and preferences and to provide you with advertisements that may be of interest to you.
In this context, we process the following types of cookies. Preferences for the use of these cookies can be changed at any time. On the other hand, disabling mandatory and functional cookies may result in the loss of the facilities provided by our website and some usage functions.