Clarification Text

OGUZHANCEYHA N.​ ME Personal Data Protection Policy

Oguzhanceyhan.me aims to properly fulfill the requirements for compliance with the Personal Data Protection Law and to establish a data protection and processing policy at international standards, with the work that started long before the entry into force of the Personal Data Protection Law No. 6698 (“KVK Law”).

Oguzhanceyhan.me Personal Data Protection Policy (“Policy”) sets out the principles adopted and taken into account in practice by the website and its operators in the protection and processing of personal data. The policy also provides information about the purposes for which Oguzhanceyhan.me processes personal data, the method of collecting personal data, its legal purpose, to whom the data can be transferred and for what purposes, and the rights of those concerned.

Within the scope of the Personal Data Protection Law, each Oguzhanceyhan.me and the legal entities for the work carried out within the executing company are the "data controllers" for their own business and activities, and the information and principles in the Policy are valid for the entire Oguzhanceyhan.me ecosystem. Oguzhanceyhan.me has approved and accepted this policy, effective as of October 7, 2016.

Ⅰ. SECTION: GENERAL INFORMATION

Oguzhanceyhan.me processes your personal data as follows, within the limits stipulated by the legislation.

Personal Data Collection Method:

Personal data processed may vary depending on the type and nature of the content, digital media, products and services produced. You may share your personal data with automatic or non-automatic methods through our website, social media channels, membership forms, call-center, websites, e-commerce sites, events, conventional and written information forms, brands with which we have a business relationship and cooperation partners. We can collect information verbally, in writing or electronically through institutions/organizations and similar means.

As long as you use our media, products and services, your personal data can be processed and updated when necessary to ensure the accuracy and currency of your data. In addition, in order to benefit from our products and services, to obtain gifts, coupons, personalized promotions given from time to time to increase interest in our website, and to participate in our events, you can visit Oguzhanceyhan.me's website, read our content, follow our social media accounts, become members and Your personal data may also be processed when you fill out our e-bulletin forms, physically visit our office building or use our call centers, and participate in activities such as events, seminars, organizations and trainings we organize.

Purposes and Procedure of Processing Personal Data:

Your personal data:

(i) Providing the content, products and services offered on Oguzhanceyhan.me and carrying out the necessary work to enable you to benefit from them, by our relevant business units,

(ii) Customizing the content, products and services offered according to your tastes, usage habits and needs and recommending them specifically for you,

(iii) Ensuring the legal and commercial security of people who have business relations with us,

(iv) For the purposes of determining and implementing our commercial and business strategies and carrying out human resources policies, and

(v) It is processed for other purposes that will be notified to you at the time of obtaining the information, within the personal data processing conditions and purposes specified in Article 5 and Article 6 of the KVK Law.

The basis for personal data processing activity can be only one of the conditions stated below, or more than one of these conditions can be the basis for the same personal data processing activity.

Having Explicit Consent of the Personal Data Owner

One of the conditions for processing personal data is the explicit consent of the data owner. Explicit consent of the personal data owner must be expressed on a specific subject, based on informed consent and free will. Data is processed within the scope of the explicit consent of the owner and for the purposes specified in the explicit consent. As a rule, if the following other conditions are met, there is no need to obtain the data owner's explicit consent.

Clearly Provided in Laws

If clearly provided for by law, the personal data of the data owner is processed in accordance with the law. In cases where data processing is permitted by law, data is processed limited to the reasons and data categories specified in the relevant law.

Failure to Obtain Explicit Consent of the Person Relevant Due to Actual Impossibility

If it is necessary to process the personal data of a person who is unable to express his/her consent due to actual impossibility or whose consent cannot be recognized as valid, in order to protect the life or physical integrity of himself or another person, the personal data of the data owner may be processed.

Being Directly Involved in the Establishment or Performance of the Contract

Personal data may be processed if it is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract (provided that the person whose data will be processed based on the establishment or performance of the contract is one of the parties to the contract).

Fulfillment of Legal Obligations

If data processing is mandatory for Oguzhanceyhan.me to fulfill its legal obligations, the personal data of the data owner may be processed.

Personal Data Owner's Publicization of Personal Data

If the personal data of the data owner has been made public, the relevant personal data may be processed limited to the purpose of publicization.

Data Processing Is Necessary for the Establishment or Protection of a Right

If data processing is mandatory for the establishment, exercise or protection of a right, the personal data of the data owner may be processed.

Data Processing Is Necessary Due to Legitimate Interests

Personal data of the data owner may be processed if data processing is necessary for the legitimate interests of Oguzhanceyhan.me, provided that it does not harm the fundamental rights and freedoms of the personal data owner.

If the data processed is personal data of special nature as defined in the KVK Law; If there is no explicit consent of the personal data owner, personal data can only be processed in the following cases, provided that adequate measures are taken to be determined by the KVK Board:

(i) Special categories of personal data, other than the health and sexual life of the personal data owner, in cases stipulated by law,

(ii) Special personal data regarding the health and sexual life of the personal data owner can only be processed by persons who are under the obligation of confidentiality for the purpose of protecting public health, preventive medicine, medical diagnosis, execution of treatment and care services, planning and management of health services and their financing, or It can be processed by authorized institutions and organizations. 

Security of Personal Data:

Oguzhanceyhan.me, in accordance with Article 12 of the KVK Law, takes appropriate necessary measures to prevent the unlawful processing of personal data, prevent unlawful access to these data, and ensure their preservation, and prevents the unlawful processing of personal data by third parties.

Transfer of Personal Data:

Your personal data may be transferred to other structures within the Oguzhanceyhan.me ecosystem, our shareholders, legally authorized public institutions and organizations, suppliers and business partners, service recipients or other third parties and/or abroad, in order to fulfill the purposes specified in this Policy, Article 8 of the Personal Data Protection Law. and may be transferred within the framework of the personal data processing conditions and purposes specified in Article 9.

Rights of the Personal Data Owner Listed in Article 11 of the Personal Data Protection Law:

In accordance with Article 11 of the KVK Law:

a) Learning whether personal data is processed or not,

b) Requesting information if personal data has been processed,

c) Learning the purpose of processing personal data and whether they are used for their intended purpose, 

ç) Knowing the third parties to whom personal data is transferred domestically or abroad,

d) Requesting correction of personal data if they are incomplete or incorrectly processed, 

e) Requesting correction of personal data in case of incomplete or incorrect processing and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,

f) Requesting the deletion or destruction of personal data in case the reasons requiring processing no longer exist, even though it has been processed in accordance with the provisions of the Personal Data Protection Law and other relevant laws, and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,

g) Objecting to the emergence of a result against the person by analyzing the processed data exclusively through automatic systems,

g) In case of damage due to illegal processing of personal data, you have the right to request compensation for the damage. 

It is important that the information/data you share is accurate and kept up to date, in terms of being able to use the rights you have on the data within the meaning of the KVK Law and other relevant legislation, and the responsibilities arising from providing incorrect information belong entirely to you.

Ⅱ. CHAPTER – BASIC PRINCIPLES

Oguzhanceyhan.me meets the general principles and conditions specified in the legislation regarding the protection and processing of personal data and acts in accordance with the principles listed below in order to ensure that personal data is processed in accordance with the Constitution and the Personal Data Protection Law.

Ⅱ.1. Personal Data Processing Activities Comply with the Law and the Rules of Honesty 

In accordance with Article 4 of the KVK Law, Oguzhanceyhan.me processes personal data in accordance with the law and the rule of honesty, adopts the principle of "transparency" towards data owners and informs personal data owners. In informing, openness and honesty are taken as basis, clear information is given about the purpose of use of the collected personal data and the data is processed within this framework. The use of personal data in a way that would cause a negative impact on the data owner without any legal justification is avoided.

Ⅱ.2. Ensuring that Personal Data is Accurate and Up-to-Date When Necessary

Oguzhanceyhan.me ensures that the personal data it processes are accurate and up-to-date.

Ⅱ.3. Processing of Personal Data for Specific, Clear and Legitimate Purposes

Oguzhanceyhan.me collects and processes personal data for legitimate and legal reasons. Oguzhanceyhan.me processes personal data within a reasonable framework and to the extent necessary in connection with the activities they carry out.

Ⅱ.4. Being Related to the Purpose for Processing, Limited and Proportionate

Oguzhanceyhan.me avoids processing personal data that is not relevant or necessary for the purpose of processing. In this context, it is essential to minimize data processing activity. 

Ⅱ.5. Preservation for the Period Envisaged in the Relevant Legislation or Necessary for the Purpose for which they are Processed

Oguzhanceyhan.me, in accordance with Article 138 of the Turkish Penal Code and Article 4 and Article 7 of the KVK Law, retains the personal data they process only for the period stipulated in the relevant legislation and laws or for the period required by the purpose of processing personal data. In this context, first of all, it is determined whether the relevant legislation provides for a certain period of time for storing the personal data subject to processing. If a legal period is determined, this period is followed. If the legal period is not determined, the period necessary to achieve the purpose of processing is determined and personal data is stored limited to this period. When the period expires, personal data is deleted, destroyed or anonymized unless there is a legal reason to keep the data for a longer period of time.

Ⅲ. SECTION: ENFORCEMENT AND IMPLEMENTATION

This Policy entered into force on October 7, 2016. If the entire policy or certain articles are updated, the updates will come into force on the date they are published.

Ⅳ. SECTION: DEFINITIONS

Explicit Consent

Consent regarding a specific issue, based on informed consent and expressed with free will.

Anonymization

It is the alteration of personal data in such a way that it loses its nature as personal data and this situation cannot be reversed. Ex: Masking, aggregation, data corruption, etc. Making personal data unable to be associated with a natural person using techniques.

Personal Data Owner 

The real person whose personal data is processed. For example; Readers, Customers, Visitors, Employees and Employee candidates.

Personal Data 

Any information regarding an identified or identifiable natural person. Therefore, processing of information regarding legal entities is not within the scope of the Law. For example; name-surname, TR ID number, e-mail, address, date of birth, credit card number, bank account number, etc.

Special Personal Data 

Data regarding race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, appearance, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data are special data.

Processing of Personal Data 

Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or using personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. Any action performed on data, such as blocking.

 Data Controller

The data controller is the person who determines the purposes and means of processing personal data and manages the place where the data is systematically kept (data recording system). For example, each legal entity.

Data Processor

It is a natural or legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller. For example, the cloud computing company that keeps Oguzhanceyhan.me data (if any), the call-center company that makes calls within the framework of instructions, etc.