LPPD Disclosure Text on Security Cameras

This Disclosure Text was issued by LOTUS TEKNİK TEKSTİL SAN. VE TİC. A.Ş. (hereinafter, “our Company”) in its capacity as the data controller pursuant to article 10 of the Law no. 6698 on Protection of Personal Data (“LPPD/Law“) and the Communiqué on Principles and Procedures to be Observed in Fulfillment of Disclosure Obligation.

1. Your Personal Data That We Process

Our Company processes personal data of individuals by recording their images with CCTV system for the purposes of ensuring security of premises and maintaining occupational health and safety by means of security cameras at areas inside and outside the service building, reception entrance, and turnstile entrances-exits. Cameras in the Company do not record audio under any circumstances.

1. Methods and Legal Grounds for Processing Your Personal Data

 

Our Company processes personal data, obtained by recording video with the CCTV system installed with respect to its activities, by automated means on the grounds of “express stipulation in the legislation” specified in article 5(2)(a) of the LPPD, “the need for the data controller to fulfill a legal obligation” specified in article 5(2)(ç) of the LPPD, “requirement to process data for establishment, exercise, or protection of a right” specified in article 5(2)(e) of the LPPD, and “requirement of data processing for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired” specified in article 5(2)(f) of the LPPD.

In terms of personal data processing, our Company acts pursuant to the data processing principles and obligations specified within the scope of the applicable legislation, particularly the Constitution of the Republic of Türkiye, international conventions that the Republic of Türkiye entered into, LPPD, secondary legislation enacted on the grounds of LPPD, as well as guidelines and resolutions issued by the Personal Data Protection Authority.

1. Purposes for Processing of Your Personal Data

Abovementioned personal data are processed pursuant to the principles stipulated in article 4 of the LPPD within the scope of the following purposes and limited to such purposes:

1. Fulfillment of responsibilities as employer, conducting disciplinary processes, ensuring occupational safety, management, supervision, and performance of work,
2. Being able to ensure security of employees and visitors,
3. Being able to inform public officials upon request and pursuant to the legislation in respect of matters regarding public security and occupational accidents,
4. Being able to fulfill legal obligations and exercise rights arising from the effective legislation,
5. Being able to fulfill legal obligations if demanded by the competent authority and if it is mandatory to respond within the scope of judicial and administrative investigations,
6. conducting occupational health and safety activities,
7. providing information to competent individuals, institutions, and organizations,
8. conducting emergency management processes,
9. conducting retention and archiving activities,
10. ensuring physical location security.

Accordingly, security camera monitoring angles and monitoring times are implemented adequately for achievement of abovementioned purposes and limited to such purposes.

A data processing activity, which may result in intervention that breaches  privacy and exceeds security purposes, is not conducted.

1. Retention Period for Personal Data Obtained by Camera Surveillance Activity

Recorded personal data shall be retained lawfully and for the maximum period stipulated in the applicable legislation or required for the purpose of their processing and, in any event, as long as the legal periods of limitation. Retention periods for personal data, obtained with cameras in our company, are 3 (three) months for administrative building, 6 (six) months for production site, and 1 (one) year for outside the factory. At the end of such periods, relevant data are disposed in the first periodic disposal interval pursuant to our Company’s disposal policy.

1. Local or Abroad Transfer of Your Personal Data

Personal data regarding camera systems can be transferred to legally competent public institutions, our Group Companies (Tetra Pazarlama ve Dış Ticaret A.Ş. & Multipak Ambalaj San. ve Tic. A.Ş. & Lotus Teknik Tekstil San. ve Tic. A.Ş. & CM Holding A.Ş.), judicial authorities, and law enforcement authorities, provided that adequate and effective measures are taken in accordance with the data transfer and processing conditions specified in articles 8 and 9 of the Law and the security and confidentiality principles stipulated in the legislation with a view to ensure achievement of abovementioned purposes.

Your personal data are not transferred to any local or foreign third party other than those specified above. If it is required to transfer your personal data to any third party except for the circumstances mentioned above, you shall be separately informed about the matter and the LPPD shall be observed.

1. Your Rights as the Data Subject within the Scope of the LPPD

Pursuant to the LPPD and other applicable legislation in effect, you are entitled:

1. To find out whether your personal data was processed;
2. To request pertinent information if your personal data was processed;

• To find out the purpose of processing and whether personal data was purposefully used;

1. To find out local and foreign third parties to whom your personal data was transferred;
2. To request your personal data to be corrected if they were processed incompletely or incorrectly;
3. To request your personal data to be deleted or destroyed pursuant to the terms stipulated in the LPPD legislation;

• To request notification of procedures carried out pursuant to articles v. and vi. to third parties, to whom your personal data was transferred;
• To object to an outcome against you due to the analysis of processed data exclusively by means of automated systems;

1. To request compensation if you incur losses due to unlawful processing of personal data

1. Exceptions to the Application Right

In accordance with article 28/2 of the Law, you shall not be able to exercise your rights specified in article 11 of the Law, without prejudice to the right to claim compensation of losses under the following circumstances.

1. The need for personal data processing for the prevention of committing a crime or for crime investigation,
2. Processing personal data which are made public by the data subject himself/herself,
3. The need for processing personal data for performance of supervision or regulatory duties and disciplinary investigation and prosecution to be carried out by the assigned and authorized public institutions and organizations and by public professional organizations, in accordance with the power conferred on them by the law,
4. The need for processing personal data for protection economic and financial interests of State related to budget, tax and financial matters.

1. General Exception Clause

In the presence of circumstances (epidemic, natural disaster, identification of personnel activities posing threat to national security, etc.) that require your personal data to be “processed within the scope of preventive, protective, and informative activities conducted by public institutions and organizations that are lawfully assigned and authorized to ensure national defense, national security, public security, public order, or economic safety” as specified in clause (ç) of article 28 of the LPPD, our Company shall be obliged to transfer necessary personal data to competent public institutions and organizations.

In such cases, the LPPD shall not be applicable because article 28 of the LPPD is an exception clause. However, in any event, our Company shall act in line with the fundamental principles and the principle of proportionality in data processing activities to be conducted in this scope.

 

1. Recourses within the Scope of Your Rights

 

You can make your applications regarding your aforementioned rights pursuant to the application procedures stipulated in the Communiqué on Principles and Procedures for Application to the Data Controller. In order to exercise your rights within the scope of the LPPD, you should file an application as follows, accompanied by identification documents;

• In case of application in person; written application shall be made to the Company’s address, Ortaköy Mah. İlter Bulvarı No: 27 34592 Silivri, İstanbul / Türkiye, by writing “Information Request Pursuant to the Law on Protection of Personal Data” on the envelope.
• In case of application by service of notice through notary public; written application shall be made to the Company’s address, Ortaköy Mah. İlter Bulvarı No: 27 34592 Silivri, İstanbul / Türkiye, by writing “Information Request Pursuant to the Law on Protection of Personal Data” on the envelope.
• In case of application by E-Mail, written application shall be made to kvkk@lotustekstil.com.tr e-mail account, by writing “Information Request Pursuant to the Law on Protection of Personal Data” in the subject field of the e-mail.

In addition, upon announcement of other methods to be determined by the Board, our Company shall announce how applications shall be received by such methods.