Data Privacy (Legal Disclaimer)

THE POLICY OF PROTECTION AND PROCESSING OF PERSONAL DATA OF TITANIT ULTRA SERT KAPLAMA SANAYİ VE TİCARETİ LİMİTED ŞİRKETİ

1) Privacy Policy

Titanit Ultra Sert Kaplamalar Sanayi ve Ticaret Limited Şirketi (“Titanit”), with herein the Personal Data Protection and Processing Policy (“Policy”), and with the terms of use of its website at the address of https://www.titanit.com.tr/ (“Website”) ‘; aims to protect the confidentiality of the information related to the User in principle, regardless of whether it sends or provide information, images, videos, pictures, photos to the Website or not, on the condition that it informs Website users (“User”), in the capacity of the real entity, the legal entity and / or corporation and institutional, who visit the Website.

Protecting your personal data, which you share with us, in accordance with the Law No. 6698 on The Law on Protection of Personal Data (“LPPD”) and using this information in accordance with LPPD are among our most important priorities. That’s why we want to explain the process of your personal data and your rights in this regard in more detail.

2) Personal Data That Can Be Collected

Titanit shall, depending on the desire of the Users , be able to collect communication details such as users’ identity details, e-mail addresses and telephone numbers or other information that can be necessary in order to provide services subject to website and those that can be deemed as personal data in accordance with The Law on Protection of Personal Data and all relevant legislation out of its Website. The users shall expressly consent to the processing of the data, to be processed for the stated purposes, and that they can, in line with their own desire , share with Titanit within the scope specified in herein the Policy.

In accordance with The Law on Protection of Personal Data, your personal data shall be, only within the framework described below, processed, recorded, stored, updated, and shared with third parties where it is permitted by the Legislation.

3) For what purpose personal data shall be processed

Your personal data collected shall be processed, within the conditions and purposes of personal data processing which is stated in the articles 5 and 6 of The Law on Protection of Personal Data, in the line of the aims to ensure the legal and commercial security of Titanit and those who have a business relationship with Titanit; and to ensure the execution of Titanit human resources processes; and to determine and implement the commercial and business strategies of Titanit.

4) Transfer of Your Personal Data

Titanit shall also be entitled to process personal data and share them with third parties, without the consent of the User, in accordance with Articles 5 and 8 of The Law on Protection of Personal Data and /or in the event of presence of exceptions in the related legislation. The main of these situations are listed below:

  • It is clearly provided by laws,
  • That it is compulsory to protect the life or body integrity of a person himself or herself or someone else who is unable to explain his consent due to actual impossibility or whose consent is not given legal validity,
  • That the processing of personal data is necessary provided that it is directly related to the establishment or performance of any contract between the user and Titanit,
  • That it is compulsory in order to fulfill legal obligations,
  • That it is publicized by the user himself or herself,
  • That the data processing is mandatory for the establishment, use or protection of a right,
  • Data processing for the legitimate interests of Titanit is mandatory, provided that it does not harm the user’s fundamental rights and freedoms.
  • That data processing is mandatory for the legitimate interests of Titanit on the condition that it does not harm the user’s fundamental rights and freedoms.

In order that we can perform the services we offer you, we may , directly or indirectly, share your personal data with such parties , whose services we benefit, as collaborators, outsourcing service providers, hosting service providers (“hosting” services), as well as our shareholders with our domestic / foreign subsidiaries.

These parties listed above may be able to store your personal data on servers located anywhere in the world, on the condition that they provide the terms regarding the transfer of the personal data abroad specified in the Article 9 of the Law on Protection of Personal Data.

All your personal data you have shared with us shall be kept confidential in the database located in the body of Titanit, in accordance with Article 12 of the Law on Protection of Personal Data, and shall not be shared with third parties for commercial purposes.

5) Transfer of Personal Data Abroad

The personal data can only be transferred by Titanit to those foreign countries declared by the Personal Data Protection Board that they have sufficient data in terms of protection of personal data or, in the event of non-existence of sufficient protection, to those foreign countries for which an adequate protection is guaranteed by the data responsible authorities in Turkey and the related countries and which are allowed by the Personal Data Protection Board.

6) Precautions Regarding Protection of Personal Data

In accordance with Article 12 of the Law on Protection of Personal Data, Titanit undertakes to keep your personal data confidential, to take all necessary technical and administrative measures to ensure confidentiality and security and to take necessary care.

When storing personal data, Titanit uses generally accepted security technology standards such as firewalls and Secure Socket Layer (SSL) encryption. Furthermore, Titanit takes hash, encryption, transaction logging, access management and physical security measures to ensure that information systems containing personal data are protected against unauthorized access and illegal data processing.

Although Titanit takes the necessary information security measures, and in the event that personal data is damaged or obtained by third parties as a result of attacks on the website and the system, Titanit immediately notifies you and the Personal Data Protection Board about such a case.

7) Rights of the Personal Data Owner

In the event that you, as personal data owners, submit your requests regarding your rights to Titanit in this Procedure with the methods set out below, our Company will conclude the request free of charge as soon as possible and within thirty days at the latest. However, provided that the transactions require a cost, it is possible to request a fee to be determined, according to a tariff, by the Personal Data Protection Board in accordance with the Article 13 of the Law on Protection of Personal Data. In this context, personal data owners have claims;

  • To learn whether personal data is processed,
  • If personal data is processed, to request information about it,
  • To learn the purpose of processing personal data and whether they are used in accordance with its purpose or not,
  • To know the third parties to whom personal data are transferred domestically or abroad,
  • In the event that personal data are incompletely or incorrectly processed, to request them to be corrected and to demand transactions, to be made in this scope, to be notified the third parties to whom the personal data is transferred,
  • Despite being processed in accordance with the provisions of the Law on Protection of Personal Data and other relevant laws, to request the deletion or destruction of personal data in case the reasons requiring its processing disappear, and to demand transactions, to be made in this scope, to be notified the third parties to whom the personal data is transferred,
  • To object to the emergence of a result to the detriment of the person himself by analyzing the processed data exclusively through automated systems,
  • In the event that the owners incur losses as a result of illegal processing of the data, to demand the related losses to be recouped.

In accordance with the paragraph 1 of the Article 13 of the Law on Protection of Personal Data, you have to submit your request to use your rights stated above to our Company “in written” or through other methods that are determined by the Personal Data Protection Board.

You can forward your request to the address written below by registered letter with advice of receipt, by stating which right, you use, set forth in the article 11 of the Law on Protection of Personal Data, along with the necessary information to determine your identity and your explanations regarding the right you want to use.

Data Supervisor you can apply under the provisions of the Law on Protection of Personal Data:

Titanit Ultra Sert Kaplamalar Sanayi ve Ticaret Ltd. Şti.

Mehmet Nesihi Özmen Mah. Kasım Sok. No: 12/9 Güngören, İstanbul

8) Cookies

Cookies that can be defined as small data files that are saved on your computer during your website visit on the Internet are used. Cookies are small text files that are sent to and stored on computers of users to enable web pages to recognize regular users of websites and facilitate accesses of users to the site, and to collect and compile bulk data to improve and develop the content of the sites.

Cookies used on the Website do not store and disclose the Personal Data of Users. Furthermore, the information transmitted through cookies is not used for any promotional or marketing purposes. Titanit monitors the usage of the Website to increase the usefulness and effectiveness of the Website via cookies. The information that is obtained through cookies shall not be sold to third parties and / or shared with any one or party. Users can delete the previously loaded cookies, block the cookies to be installed in the future or enable the browser to warn them during the loading of the cookies, by making the necessary settings in the internet browser that users are using. However, we would like to state that the cookies in question may be necessary for the Website to function properly and to perform certain functions.

9) Deleting, Destroying or Anonymizing Your Personal Data

Your personal data that has been processed for the purposes specified herein the Policy is deleted, destroyed or kept being used following being anonymized by us when the purpose requiring the process of personal data in accordance with the first paragraph of Article 7 of the Law on Protection of Personal Data disappears and, when the periods that are specified by the laws are ended according to the Article 82 of the Turkish Commercial Code, with No. 6102, and to the Article 138 of the Turkish Penal Code.

10) Registration to the Data Controllers Registry

Before starting data processing, Titanit must be registered with the Data Controllers Registry within the period to be determined and announced by the Personal Data Protection Board.

The following information should be submitted in the registration application to the Data Controllers Registry:

  • Identity and address information of Titanit and its representative, if any, as the data controller.
  • The purpose of process of personal data.
  • Explanations on the person group and groups that are subject of data and the categories of data belonging to the said persons.
  • Recipients or groups of recipients to whom personal data can be transferred.
  • Personal data intended to be transferred to foreign countries.
  • Measures taken regarding personal data security.
  • The maximum time required for the purpose for which personal data are processed.

In case of any change in the information presented in the registration notification, such changes shall immediately be notified to the Administration of Personal Data Protection Corporation.

11) Changes in the Policy

Those who benefit from the services provided on the Website are deemed to have read and accepted all these terms. Titanit reserves the right to change the provisions of herein the Policy without prior notice. Herein the Policy came into force on the date of 07.10.2016. In the event that any change is made in this Policy, the Policy becomes effective on the date it is presented to ­Users through any method.

This document has been prepared to inform company website users, investors, customers and suppliers in accordance with the Law on Protection of Personal Data.

Implementation Process (Transition Provisions & Enforcement) of the Law on Protection of Personal Data

07.04.2016

Except for the transfer of personal data abroad, the rights of the persons concerned, the regulations on crimes and misdemeanors, other articles shall come into force as of the publication date of the law.

07.10.2016

Personal data protection board shall be established within 6 months as of the publication date of the law.

The transfer of personal data abroad, the rights of persons concerned, regulations on crimes and misdemeanors shall come into force 6 months after the publication of the law.

07.04.2017

The consents that were obtained, in accordance with the law, before the publication date of the Law shall be deemed as being the consent obtained in accordance with the Law unless the relevant person has objected it within 1 year.

The secondary legislation (regulations) regarding the law shall come into force within 1 year from the date of publication.

07.04.2018

Data processed before the publication date of the Law (07.04.2016) shall be made accordant with the relevant provisions of the Law within 2 years from the publication date.