This Disclosure Text was issued to inform you about processing of your personal data in accordance with article 10 of the Law no. 6698 on Protection of Personal Data (“PPD Law/LPPD”) and the Communiqué on Principles and Procedures to be Observed in Fulfillment of Disclosure Obligation.
As Lotus Teknik Tekstil San. Ve Tic. A.Ş. (“Lotus” or “Our Company”), residing at the address Ortaköy Mah. İlter Bulvarı No: 27 34592 Silivri, İstanbul / Türkiye, we process your data in our capacity as the data controller within the scope explained below pursuant to the PPD Law and applicable legislation. Please review the policies and disclosures on our website for further details.
a) Your Personal Data That We Process
Your name, surname, license plate information, purpose of visit, visited person/place information, company name, date of visit data obtained verbally or from written forms at the time of your entrance to our Company, as well as entrance-exit times identified from visual records, made by means of CCTV, are processed.
b) Our Purposes for Processing Personal Data
Your personal data are processed pursuant to the LPPD and applicable legislation for purposes limited to being able to generate visitor records and monitor entrances-exists; prevention and recording of trespassing; ensuring physical security of our Companies and personnel; ensuring order; ensuring physical security of entire technical facilties and campus; conducting disciplinary and/or legal processes as necessary; ensuring safety of life and property for employees and security of the workplace within the scope of the management right of the employer within the scope of deliveries to the workplace, entrances/exits, and visits; ensuring security in respect of visitors in premises and facilities of our Company.
c) Methods and Legal Grounds for Processing Your Personal Data
Your personal data are retained and processed on electronic and physical media for reasonable periods by taking necessary technical and administrative measures on the legal grounds of “the need for the data controller to fulfill a legal obligation” specified in article (5)(2)(ç) of the LPPD and “requirement of data processing for legitimate interests of the data controller” specified in article (5)(2)(f) of the LPPD.
Your personal data are collected by automated and non-automated means through your verbal and/or written declaration made at the time of your entrance to our Company’s premises, CCTV, and other channels.
d) Local and Abroad Transfer of Your Personal Data
Your personal data can be accessed only by relevant authorized individuals within our Company in connection with security and disciplinary and/or legal proceedings; the data can be transferred to independent audit firms pursuant to legal requirements and limitations; and they shall by no means be transferred to third parties other than the mentioned entities.
In case of a potential requirement, your personal data can be disclosed to law enforcement and administrative authorities, as well as competent authorities with a view to achievement of abovementioned purposes under the data transfer and processing conditions specified in article 8 of the LPPD, while they shall not be transferred to third parties and abroad other than the relevant competent authorities under any circumstances.
e) 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 Companies 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 Companies shall act in line with the fundamental principles and the principle of proportionality in data processing activities to be conducted in this scope.
f) Retention, and Destruction of Your Personal Data
Our Company shall retain your personal data for a reasonable period. In this scope, our Company is entitled to retain your personal data as long as the period, stipulated in the legislation for retention of personal data, or as long as the period required for abovementioned purposes in the absence of such a stipulation. Upon expiration of such periods and if our Company does not have any remaining legal grounds to process your personal data, your personal data shall be immediately deleted, destroyed, or anonymized pursuant to the applicable provisions of the LPPD, the “Regulation on Deletion, Destruction or Anonymization of Personal Data”, and our Company Policies. Please review our Personal Data Storage and Disposal Policy for further details.
g) Your Rights Concerning Your Personal Data
In accordance with article 11 of the LPPD, you have the following rights concerning your personal data:
- To find out whether your Personal Data was processed,
- To request pertinent information if your Personal Data was processed,
- To find out the purpose of processing and whether Personal Data was purposefully used,
- To find out local and foreign third parties to whom your Personal Data was transferred,
- To request correction of your personal data if it was incompletely or incorrectly processed, and request notification of this procedure to third parties to whom your personal data was transferred,
- To request deletion or destruction of your personal data in case the reasons for processing no longer exist, and request notification of this procedure to third parties to whom your personal data was transferred, even though your Personal Data was processed pursuant to the Law no. 6698 on Protection of Personal Data and other provisions of applicable law,
- To object to an outcome against you due to the analysis of processed data exclusively by means of automated systems,
- To request compensation if you incur losses due to unlawful processing of Personal Data.
You can submit your requests regarding such rights by means of the Data Subject Application Form on our website. Your application shall be fulfilled at no charge. However, if the requested procedure requires an additional cost, the fees in the tariff determined by the Personal Data Protection Board shall be charged to the applicant.
h. 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 Mail signed by secure electronic signature, 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 Companies shall announce how applications shall be received by such methods.