PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA
Definitions
KVKK: Turkish Personal Data Protection Law No. 6698
Personal Data: Any information relating to an identified or identifiable natural person/employee, including information contained in personnel files, such as name and identity details, address, telephone number, email address, Turkish ID number, driving licence number, passport number, and similar information.
Protection of Personal Data: Pursuant to the Turkish Personal Data Protection Law No. 6698 (“KVKK”), any information that identifies or makes it possible to identify a natural person is considered personal data. We would like to inform you about the purposes and legal grounds for which your personal data held by HOWEN are processed, the methods used to collect such data, the persons to whom and purposes for which they may be transferred, and your rights under KVKK, whether related to or independent of the foregoing.
1. Data Controller and Categories of Personal Data
Pursuant to the Turkish Personal Data Protection Law No. 6698 (“Law No. 6698”), your data relating to identity information, contact information, information that may be included in the content of messages you send to us, marketing information, and transaction security information may be processed by HOWEN (“Company”), acting as the data controller, within the scope described in detail below.
2. Methods of Collecting Personal Data
The Company, acting in its capacity as the data controller, collects your personal data in accordance with its legal obligations arising from KVKK and other applicable legislation, for the purpose of providing you with high-quality services and conducting its business activities.
Your personal data are collected through written or electronic means based on your explicit consent and within the framework of legal grounds arising from and implemented in accordance with applicable legislation, agreements, requests, and the principles of good faith. This includes the personal data you submit through the contact form on the website, such as your full name, telephone number, email address, address, and other identity and contact information, as well as any personal data that may be included in the content of the message you send to us.
3. Purposes of Processing Personal Data
Your personal data collected through the contact form are processed solely for the purposes of evaluating the messages you submit, responding to your requests, creating, processing, and finalising your requests, fulfilling your requests for information regarding our services, carrying out communication activities, following up on requests and complaints, and managing service processes, depending on the nature of your enquiry submitted through the contact form.
4. Transfer of Personal Data
Your personal data may be transferred to our group companies, business partners, suppliers, legally authorised public institutions, and authorised private persons, provided that your explicit consent has been obtained or where processing is necessary for the legitimate interests of the data controller, provided that such processing does not prejudice the fundamental rights and freedoms of the data subject.
Furthermore, your personal data may be transferred to business partners, legally authorised public institutions, and authorised private persons located abroad, provided that your explicit consent has been obtained. Such data may also be transferred without obtaining your explicit consent where the recipient is located in a country recognised by the Turkish Personal Data Protection Board as providing an adequate level of protection or as a safe country.
As stated above, the Company may share the personal data concerned solely on the basis of your explicit consent or, subject to the implementation of adequate safeguards in accordance with the security and confidentiality principles stipulated under Law No. 6698 and other applicable legislation, both domestically and, where the necessary security measures have been implemented, internationally.
For the purposes of conducting the Company’s activities and due to the information technologies used by our business partners, business contacts, and stakeholders, your personal data may be shared with service providers operating servers located in Türkiye or abroad, individuals and organisations located in Türkiye or abroad from which we receive physical server and/or cloud services, suppliers and other parties processing data on behalf of our Company, public institutions and organisations legally authorised to request such data, and other relevant authorities, without being limited to the foregoing.
5. Source and Legal Basis
Your personal data collected from you electronically, through the website, or by means of written or verbal communication are collected and processed solely for the purposes specified in Article 3 of this Privacy Notice.
Such processing is carried out for the protection of the rights and interests of the data subject, the establishment of a business relationship and the provision of rights and benefits to you, the continuation and development of the Company’s internal activities, and the fulfilment of legal obligations.
The legal grounds for such processing are your explicit consent under Article 5/1 of KVKK and the condition set forth in Article 5/2(f), namely that “processing is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not prejudiced.”
6. Application Procedures and Principles
As a data subject, you may submit requests concerning your rights under Article 11 of Law No. 6698 by completing the Data Subject Application Form in accordance with the procedures and principles specified therein and sending it:
- By email bearing a mobile signature or qualified electronic signature to info@howen.com.tr;
- In person, with a wet-signed written application, to Yeni Bağlıca Mah. 1090 Sok. 2A, İç Kapı No: 1, Etimesgut/Ankara; or
- Through a notary public.
The Company will process and conclude your application free of charge as soon as possible and no later than thirty days, depending on the nature of the request. However, if the process requires an additional cost, the Company may charge the fee specified in the tariff determined by the Turkish Personal Data Protection Board.
Based on the information provided above, the Company will respond to requests from data subjects concerning the following rights:
- To learn whether the Company processes their personal data and, if so, which personal data are processed;
- To obtain information regarding the purposes of the processing activities;
- To learn the third parties to whom the Company transfers personal data in Türkiye or abroad;
- To request the correction of personal data if they have been processed incompletely or inaccurately;
- To request the deletion or destruction of personal data in accordance with the Law;
- Where correction, deletion, or destruction of personal data is requested, to request that the relevant actions be communicated to the third parties to whom the personal data have been transferred;
- To object to any outcome arising to the detriment of the individual as a result of the processed data being analysed exclusively through automated systems; and
- To obtain copies of their personal data.
You may contact us regarding your comments and questions.