Privacy Notice
Privacy Notice on the Protection of Personal Data
1. Purpose and Scope
This Information and Privacy Notice Form has been prepared under KVKK (Turkish Personal Data Protection Law No. 6698) to provide information on the processes by which personal data belonging to natural persons is processed and transferred.
Under Law No. 6698, any up-to-date information about you that you share with our company is considered “personal data.”
The security of your personal data is of great importance to ERY Bilişim A.Ş. Your personal data is stored in compliance with the conditions set out in the applicable legislation, with the necessary security measures in place, and only for the periods required by legal obligations.
2. Data Controller
Pursuant to KVKK, your personal data may be processed by ERY Bilişim A.Ş., acting as data controller, within the scope and for the purposes described below.
3. Personal Data We Process
The categories of personal data that may be processed by our company are as follows:
3.1. Identity Information
First and last name
Mother's and father's names
Date of birth
Place of birth
Marital status
National identity card serial and sequence number
Turkish national ID number
Passport number
Temporary Turkish national ID number
Gender
Turkish national ID card information
Driver's license information
3.2. Contact Information
Address
E-mail address
Contact address
Phone number
3.3. Personnel Information
Payroll information
Disciplinary investigation information
Employment start and end records
Résumé information
Performance evaluation reports
Military service status
3.4. Legal Transaction Information
Information contained in correspondence with judicial authorities
Information contained in case files
Other information processed in connection with legal transactions
3.5. Customer Transaction Information
Invoice information
Promissory note and check information
Order information
Appointment information
Request information
3.6. Physical Premises Security Information
Employee entry and exit records
Visitor entry and exit records
Closed-circuit camera system footage
IP camera recordings
3.7. Transaction Security Information
IP address information
Website login and logout information
Password and passcode information
Other information processed for transaction security purposes
3.8. Risk Management Information
Information processed for the purpose of managing commercial, technical and administrative risks.
3.9. Financial Information
Balance sheet information
Financial performance information
Credit and risk information
Bank account number
IBAN
3.10. Professional Experience Information
Diploma information
Courses attended
In-service training information
Certificates
Information on the most recent employer
Reference information
3.11. Visual and Audio Records
Camera recordings
Photographs
Other records of a visual or audio nature
3.12. Health Information
Information on disability status
Blood type
Personal health information
Information on devices and prostheses used
Laboratory and imaging results
Test results
Medical examination data
3.13. Criminal Conviction and Security Measures Information
Information on criminal convictions
3.14. Family Information
Number of children
Spouse's employment information
Children's education and age information
Birth and death certificate information
3.15. Employment Information
Branch and department information
Type of employment
Occupation
Professional ID card information
3.16. Website Usage Data
Date on which the application form was completed
IP address
Information on website usage
3.17. Request and Complaint Management Information
Personal data relating to the receipt and evaluation of any request or complaint addressed to our company.
3.18. Reputation Management Information
Information collected to protect the company's commercial reputation, the evaluation reports prepared on the basis of this information, and information on the actions taken.
3.19. Incident Management Information
Personal data processed in order to take the necessary legal, technical and administrative measures against incidents that occur, for the purpose of protecting the commercial rights and interests of the company and the rights and interests of its customers.
3.20. Signature and Social Security Information
Wet-ink or electronic signatures on documents that constitute personal data
Fingerprints and distinguishing marks
Insurance information
Automatic-enrollment private pension system (BES) information
Social Security Institution data
3.21. Vehicle Information
License plate number
Make
Model
Model year
Engine and chassis number
Vehicle registration date
Copy of the vehicle registration certificate
No-claims information
3.22. Compliance, Audit and Inspection Information
Personal data processed for the purpose of compliance with policies
Audit and inspection information
Personal data processed during internal or external audit activities
4. Purposes of Processing Personal Data
Your personal data may be processed for the following purposes:
Carrying out emergency management processes
Carrying out information security processes
Carrying out selection and placement processes for employee candidates, interns and students
Carrying out application processes for employee candidates
Fulfilling obligations toward employees arising from employment contracts and legislation
Carrying out fringe benefit and entitlement processes for employees
Carrying out audit and ethics activities
Carrying out training activities
Managing access authorizations
Ensuring that activities are carried out in compliance with legislation
Carrying out finance and accounting operations
Carrying out processes that build loyalty to the company, its products and its services
Ensuring the security of physical premises
Carrying out assignment processes
Following up on and carrying out legal affairs
Carrying out internal audit, investigation and intelligence activities
Carrying out communication activities
Planning human resources processes
Carrying out and supervising business activities
Carrying out occupational health and safety activities
Receiving and evaluating suggestions for improving business processes
Carrying out activities to ensure business continuity
Carrying out logistics activities
Carrying out procurement processes for goods and services
Carrying out after-sales support services for goods and services
Carrying out sales processes for goods and services
Carrying out production and operation processes for goods and services
Carrying out customer relationship management processes
Carrying out activities aimed at customer satisfaction
Organization and event management
Carrying out marketing analysis studies
Carrying out performance evaluation processes
Carrying out risk management processes
Carrying out retention and archiving activities
Carrying out strategic planning activities
Following up on requests and complaints
Ensuring the security of movable property and resources
Carrying out supply chain management processes
Administering the compensation policy
Carrying out marketing processes for products and services
Ensuring the security of the data controller's operations
Carrying out investment processes
Carrying out talent and career development activities
Providing information to authorized persons, institutions and organizations
Carrying out management activities
Creating and tracking visitor records
5. Recipients of Personal Data and Purposes of Transfer
In accordance with Articles 8 and 9 of KVKK, ERY Bilişim A.Ş. may transfer the personal data of employee candidates, employees, shareholders/partners, potential buyers of products or services, interns, supplier employees, supplier representatives, persons receiving products or services, visitors, and family members and relatives to the categories of persons specified below.
5.1. Natural Persons or Private-Law Legal Entities
Data may be transferred to natural or legal persons with whom ERY Bilişim A.Ş. has a relationship or carries out transactions in the course of its activities, limited to the business and transaction carried out.
5.2. Business Partners
Data may be transferred to the business partners and partner banks with which ERY Bilişim A.Ş. has a relationship for purposes such as the promotion and marketing of its products and services, after-sales support and the like, limited to the purpose of establishing and carrying out the business partnership.
5.3. Affiliates
Data may be transferred to legal or natural persons that have a partnership relationship with ERY Bilişim A.Ş., limited to the purpose of planning, carrying out and supervising strategies relating to the company's commercial activities.
5.4. Authorized Public Institutions and Organizations
Data may be transferred to the Social Security Institution, tax offices, and public institutions and organizations authorized under the relevant legislation to obtain information and documents from ERY Bilişim A.Ş., limited to the purpose requested by those public institutions and organizations within the scope of their legal authority.
5.5. Contracted Service Providers and Cooperating Organizations
Data may be transferred to organizations from which services are obtained under contract or with which we cooperate, limited to the terms of the contract or cooperation protocol and to matters falling within their fields of activity.
6. Transfer of Data Abroad
Your personal data may be transferred abroad by ERYERP in line with the principles set out in Article 4/2 of KVKK, either by obtaining your explicit consent or, where the circumstances set out in Articles 5/2 and 6/3 of the Law exist, without obtaining explicit consent, and in accordance with the rules specified in Article 9 of the Law.
Your personal data may be transferred to persons and organizations established in foreign countries that the Personal Data Protection Board (the “Board”) has determined and announced as having adequate protection.
With respect to countries determined and announced as not having adequate protection, transfers may be made only in cases where the data controllers in Türkiye and in the relevant foreign country have undertaken in writing to provide adequate protection and the Board's permission for the transfer in question can be obtained.
7. Legal Grounds for Processing Personal Data
Your personal data may be processed because it is expressly stated or provided for in the relevant legislation, in particular the laws listed below, and in order to fulfill our legal obligations:
Tax Procedure Law No. 213
Turkish Commercial Code No. 6102
Turkish Code of Obligations No. 6098
Labor Law No. 4857
Occupational Health and Safety Law No. 6331
Social Insurance and General Health Insurance Law No. 5510
Turkish Penal Code No. 5237
Personal Data Protection Law No. 6698
Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through Such Publications
In addition, your personal data may also be processed on the basis of your explicit consent and the legitimate interest of our company.
8. Processing of Your Special Categories of Personal Data
The following data, which is regarded as special categories of personal data under Personal Data Protection Law No. 6698 and the relevant legislation:
Race
Ethnic origin
Political opinion
Philosophical belief
Religion, sect or other beliefs
Appearance and dress
Membership of associations, foundations or trade unions
Health information
Sexual life
Data relating to criminal convictions and security measures
Biometric data
Genetic data
may be processed where the conditions set out in Article 6 of the Law are met or where you have given your explicit consent.
9. Exceptions Provided for by Law
Under the relevant legislation, your personal data may be processed without your explicit consent in the following cases:
Processing the personal data of the parties to a contract is necessary, provided that it is directly related to the conclusion or performance of that contract,
It is expressly provided for by law,
Data processing is mandatory for our business to fulfill its legal obligation,
Data processing is mandatory for the establishment, exercise or protection of any right on your behalf,
Data processing is mandatory for the legitimate interests of our company, provided that it does not harm your fundamental rights and freedoms,
The other procedures and principles specified in the relevant legislation are present.
10. Your Rights as a Data Subject
As data subjects, you have the following rights under Article 11 of KVKK:
To learn whether personal data is being processed,
To request information about the processing if your personal data has been processed,
To learn the purpose for which personal data is processed and whether it is used in accordance with that purpose,
To know the third parties to whom personal data is transferred, in Türkiye or abroad,
To request the rectification of personal data that has been processed incompletely or inaccurately,
To request that the action taken in this regard be notified to the third parties to whom the personal data has been transferred,
To request the erasure or destruction of personal data where the reasons requiring its processing have ceased to exist, even though it was processed in accordance with KVKK and the provisions of other relevant laws,
To request that the action taken in this regard be notified to the third parties to whom the personal data has been transferred,
To object to any result to the person's own detriment arising from the analysis of the processed data exclusively by means of automated systems,
To claim compensation for damage suffered as a result of the unlawful processing of personal data.
11. How to Apply
To exercise the rights listed above, you may send our Company, through the contact channels below, an application containing the information necessary to establish your identity and your explanations as to which of the rights specified in Article 11 of KVKK you wish to exercise.
E-mail: info@erysystem.com
Address for Applications by Mail or in Person:
Ahi Evran OSB Mahallesi
Erkunt Caddesi
ASO Teknopark No: 3/64
Sincan / Ankara
Depending on the nature of your application, our Company will resolve it free of charge as soon as possible and within thirty days at the latest. However, if a fee is prescribed by the Personal Data Protection Board, the fee in the tariff set by our Company may be charged.
12. Changes to the Privacy Notice
Our Company reserves the right to make changes to this Privacy Notice in line with any amendments that may be made to KVKK and the methods to be determined by the Personal Data Protection Board.