HASAN ARSLANPİR TUĞRA MOBİLYA
PERSONAL DATA PROTECTION AND PROCESSING POLICY
PURPOSE OF THE POLICY AND CONFIDENTIALITY COMMITMENT
Protecting your fundamental rights and freedoms and privacy, especially the privacy of your private life, in the processing of your personal data, and ensuring the security of your personal data in this context, is among the top priorities and goals of Hasan Arslanpir Tuğra Mobilya (Tuğra Mobilya). In this context, within the framework of this Hasan Arslanpir Tuğra Mobilya Personal Data Protection and Processing Policy (Policy), the principles adopted in the execution of personal data processing activities carried out by Tuğra Mobilya and the basic principles adopted in terms of the compliance of Tuğra Mobilya data processing activities with the relevant secondary regulations and practices, especially the Personal Data Protection Law No. 6698, are explained, and Tuğra Mobilya provides the necessary transparency by informing you, as personal data owners.
In this context, Tuğra Mobilya undertakes to process and protect your personal data with full awareness of responsibility in accordance with the relevant legislation, this Policy and the procedures to be applied in accordance with the Policy.
SCOPE OF THE POLICY
This Policy applies to all personal data of all natural persons whose personal data are processed, whether automatically or by non-automatic means, provided that they are part of any data recording system.
This Policy covers and applies to all data processing activities of Tuğra Mobilya regarding personal data it processes.
This Policy does not apply to data that does not qualify as personal data.
This Policy may be amended from time to time with the approval of the [Board of Directors] if required by the relevant legislation or if deemed necessary by Tuğra Mobilya.
In the event of a conflict between the relevant legislation and this Policy, the relevant legislation shall prevail.
BASIC PRINCIPLES OF PERSONAL DATA PROCESSING
Processing Personal Data in Accordance with the Law and Honesty Rules Tuğra Mobilya processes Personal Data in accordance with the law and honesty rules and based on the principle of proportionality. In this context, Tuğra Mobilya processes Personal Data to the extent required by Tuğra Mobilya's business activities and limited to them.
Ensuring That Personal Data is Accurate and Up-to-Date When Necessary Tuğra Mobilya takes all necessary measures to ensure that Personal Data is complete, accurate and up-to-date during the period it is processed. In this context, Tuğra Mobilya establishes the necessary mechanisms to ensure the accuracy and currency of Personal Data and updates the relevant Personal Data in accordance with the Data Subject's requests for changes to Personal Data under the GDPR Regulations.
Processing Personal Data for Specific, Clear and Legitimate Purposes Before Personal Data is Processed, Tuğra Mobilya determines for what purpose Personal Data will be processed. In this context, Tuğra Mobilya clearly reveals the purposes of processing Personal Data and processes Personal Data within the scope of these activities in line with its business activities. In this direction, Data Subjects are informed in accordance with the GDPR Regulations and, where necessary, the Explicit Consent of the persons in question is obtained.
Personal Data Should Be Related to, Limited to and Measured to the Purpose for Which They Are Processed Tuğra Mobilya collects Personal Data only to the extent and nature required by its business activities and processes it limited to the specified purposes. In this direction, Tuğra Mobilya refrains from processing Personal Data that is not related to the achievement of the determined purposes or is not needed.
Retention of Personal Data for the Period Stipulated in the Relevant Legislation or Required for the Purpose for Which They Are Processed Tuğra Mobilya retains Personal Data for the minimum period required for the purpose for which it is processed and stipulated in the relevant legal legislation. In this context, Tuğra Mobilya first determines whether the relevant legislation foresees a period for the storage of personal data and, if a period is determined, acts in accordance with this period.
Personal Data is Destroyed at the end of the determined retention periods in accordance with periodic Destruction periods or Data Subject application and with the determined Destruction methods (deletion and/or destruction and/or anonymization). In this case, it is ensured that the third parties to whom Tuğra Mobilya transfers Personal Data also delete, destroy Personal Data.
or make it anonymous.
[Committee] is responsible for the operation of the destruction processes. In this context, the necessary procedure is created by the [Committee].
PERSONAL DATA PROCESSED BY TUĞRA MOBİLYA AND PROCESSING PURPOSES
In Tuğra Mobilya, by informing the Relevant Persons in accordance with the GDPR Regulations, in line with the Personal Data processing purposes of Nazilli Private Reference Hospital, based on and limited to at least one of the Personal Data processing conditions specified in Articles 5 and 6 of the KVKK, mainly to the Principles specified in Article 4 of the KVKK regarding the Processing of Personal Data. Personal Data is processed in accordance with the general principles specified in the KVKK.
PERSONAL DATA STORAGE PERIOD AND DESTRUCTION
Tuğra Mobilya retains Personal Data for the period required for the purpose for which they are processed and the minimum period stipulated in the relevant legal legislation. In this context, Tuğra Mobilya first determines whether the relevant legislation foresees a period for the storage of Personal Data, and if a period is determined, it acts in accordance with this period. If there is no legal period, Personal Data is stored for the period required for the purpose for which it is processed. Personal Data is never stored by Tuğra Mobilya, taking into account the possibility of future use.
Tuğra Mobilya creates a Personal Data storage and Destruction policy in accordance with the Personal Data processing inventory and carries out all Destruction (deletion and/or destruction and/or anonymization) activities in accordance with the GDPR Regulations and the relevant Personal Data storage and Destruction policy. Personal Data is Destroyed at the end of the storage periods determined within the scope of the prepared Personal Data storage and Destruction policy in accordance with periodic Destruction periods or Data Subject application and with the determined Destruction methods (deletion and/or destruction and/or anonymization). [Committee] is responsible for the operation of the destruction processes. In this context, the necessary procedure is created by the [Committee].
TRANSFER OF PERSONAL DATA
Tuğra Mobilya may transfer Personal Data of Relevant Persons to third parties located in Turkey and/or abroad in accordance with GDPR Regulations by taking the necessary security measures in line with its legal Personal Data processing purposes. In this case, the necessary protective regulations are added to the contracts concluded with third parties.
Even if the Data Subject does not have Explicit Consent, Personal Data may be transferred to third parties by the Company with the fulfillment of administrative and technical measures in accordance with the GDPR Regulations, if one or more of the following conditions are met:
The relevant activities regarding the transfer of Personal Data are expressly stipulated in the laws,
The transfer of Personal Data by Tuğra Mobilya is directly related to and necessary for the establishment or performance of a contract,
The transfer of Personal Data is mandatory for Tuğra Mobilya to fulfill its legal obligation,
Transfer of Personal Data by Tuğra Mobilya in a limited way for the purpose of disclosure, provided that Personal Data has been made public by the Data Subject,
The transfer of Personal Data by Tuğra Mobilya is mandatory for the establishment, use or protection of the rights of Tuğra Mobilya or the Data Subject or third parties,
It is mandatory for Tuğra Mobilya to engage in Personal Data transfer activities for legitimate interests, provided that the fundamental rights and freedoms of the Data Subject are not harmed,
It is mandatory for the person who is unable to disclose his consent due to actual impossibility or whose consent is not legally valid to protect his own or another person's life or bodily integrity.
In addition to the above, Personal Data may be transferred to foreign countries that have been declared by the Board to have adequate protection ("Foreign Country with Adequate Protection") if any of the above conditions are met. If there is no adequate protection, it can be transferred to foreign countries where the Data Controllers in Turkey and the relevant foreign country guarantee sufficient protection in writing in accordance with the data transfer conditions stipulated in the legislation and with the permission of the Board ("Foreign Country with a Data Controller Who Guarantees Sufficient Protection").
TRANSFER OF SPECIAL CATEGORIES OF PERSONAL DATA
Special Categories of Personal Data may be transferred by Tuğra Mobilya in accordance with the principles specified in this Policy and by taking all necessary administrative and technical measures, including the methods to be determined by the Board, and if the following conditions exist:
Special Categories of Personal Data other than health and sexual life are processed without the Explicit Consent of the Data Subject if it is expressly stipulated in the laws, in other words, there is an explicit provision in the relevant law regarding the Processing of Personal Data. Otherwise, the existence of the Data Subject's Explicit Consent is required for the processing of Special Categories of Personal Data other than health and sexual life.
Special Categories of Personal Data related to health and sexual life are processed by persons (e.g. workplace physician working under the Company's payroll) or authorized institutions and organizations under the obligation of secrecy for the purpose of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing without the Explicit Consent of the Data Subject. Otherwise, the existence of the Data Subject's Explicit Consent is required for the processing of Special Categories of Personal Data other than health and sexual life.
In addition to the above, Special Categories of Personal Data may be transferred to Foreign Countries with Adequate Protection if any of the above conditions are met. If there is no adequate protection, it can be transferred to Foreign Countries with a Data Controller Who Guarantees Sufficient Protection in accordance with the data transfer conditions stipulated in the legislation.
TUĞRA MOBİYA'S OBLIGATION TO INFORM
Tuğra Mobilya informs the Relevant Persons before the Personal Data is processed, in accordance with Article 10 of the KVKK and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform. In this context, Tuğra Mobilya informs the Relevant Persons in accordance with the GDPR Regulations regarding who processes their Personal Data as the Data Controller, for what purposes, with whom and for what purposes it is shared, by what methods it is collected and its legal reason, and the rights that the Relevant Persons have within the scope of processing their Personal Data.
The necessary GDPR Procedures are created by the [Committee] in order to report all new Personal Data processing processes to the [Committee].
If the Data Processor is a third party other than Tuğra Mobilya, it is guaranteed by a written contract that the third party will act in accordance with the above-mentioned obligations before the Personal Data Processing is started. Each employee is obliged to go through the process in this Policy and GDPR Procedures in case Personal Data is transferred by Tuğra Mobilya to a third party.
RIGHTS OF THE DATA SUBJECTS
Data Subjects have the following rights:
To learn whether their Personal Data is processed,
If their Personal Data has been processed, to request information regarding this,
To learn the purpose of processing their Personal Data and whether they are used in accordance with their purpose,
To know the third parties to whom their Personal Data is transferred domestically or abroad,
To request correction of their Personal Data if it is incomplete or incorrectly processed and to request that the transaction made in this context be notified to third parties to whom their Personal Data is transferred,
To request the deletion or destruction of their Personal Data in the event that the reasons requiring its processing have disappeared, although it has been processed in accordance with the Law and other relevant legal provisions, and to request that the transaction made in this context be notified to third parties to whom their Personal Data is transferred,
To object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
To demand compensation for the damage in case they suffer damage due to the unlawful processing of their Personal Data.
Data Subjects may submit their requests regarding the rights listed in this section of this Policy to Tuğra Mobilya through the methods determined by the Board. Tuğra Mobilya may benefit from the Data Subject Application Form. However, in any case, current application methods and application content should be checked from the relevant legislation before the application, and applications should be made in accordance with the said procedures and principles.
If the Data Subjects submit their requests regarding the rights listed above to Tuğra Mobilya in writing, Tuğra Mobilya concludes the request free of charge within 30 (thirty) days at the latest, in accordance with the GDPR Regulations, depending on the nature of the request. If there is an additional cost for the Data Controller to conclude the requests, the fees in the tariff determined by the Board may be requested by the Data Controller.
PERSONAL DATA MANAGEMENT AND SECURITY
Tuğra Mobilya establishes a [Committee] to fulfill its obligations within the scope of GDPR Regulations, to ensure the preparation and implementation and supervision of the necessary GDPR Procedures for the implementation of this Policy, and to make suggestions regarding their operation.
Tuğra Mobilya takes all necessary administrative and technical measures to ensure the security of Personal Data in accordance with the GDPR Regulations. In this context, Personal Data Processing activities are monitored by technical systems according to technological possibilities and application costs. Personnel knowledgeable in technical matters regarding Personal Data Processing activities are employed.
Tuğra Mobilya employees are informed and trained regarding the protection and lawful processing of Personal Data.
The necessary GDPR Procedures are created to ensure the access of employees who need to access Personal Data in Tuğra Mobilya to the Personal Data in question, and the [Committee] is responsible for its creation and implementation.
Tuğra Mobilya employees can access Personal Data only within the scope of their defined authority and in accordance with the relevant GDPR Procedures.
Tuğra Mobilya employees immediately notify the [Committee] if they suspect that the security of Personal Data is not sufficiently ensured or if they detect such a security vulnerability.
Detailed GDPR Procedures regarding the security of Personal Data are created by the [Committee].
Each person who is allocated a Tuğra Mobilya product is responsible for the security of the products allocated for their use.
Each Tuğra Mobilya employee is responsible for the security of the physical files in their area of responsibility.
In case there are security measures requested or additionally requested for the security of Personal Data within the scope of GDPR Regulations, all employees are obliged to comply with the additional security measures and ensure the continuity of these security measures.
All Personal Data processed within Tuğra Mobilya is considered as "Confidential Information" by Tuğra Mobilya.
Tuğra Mobilya employees have been informed that their obligations regarding the security and confidentiality of Personal Data will continue even after the termination of the business relationship, and Tuğra Mobilya employees have been committed to comply with these rules.
PERSONAL DATA PROTECTION AND PROCESSING POLICY
PURPOSE OF THE POLICY AND CONFIDENTIALITY COMMITMENT
Protecting your fundamental rights and freedoms and privacy, especially the privacy of your private life, in the processing of your personal data, and ensuring the security of your personal data in this context, is among the top priorities and goals of Hasan Arslanpir Tuğra Mobilya (Tuğra Mobilya). In this context, within the framework of this Hasan Arslanpir Tuğra Mobilya Personal Data Protection and Processing Policy (Policy), the principles adopted in the execution of personal data processing activities carried out by Tuğra Mobilya and the basic principles adopted in terms of the compliance of Tuğra Mobilya data processing activities with the relevant secondary regulations and practices, especially the Personal Data Protection Law No. 6698, are explained, and Tuğra Mobilya provides the necessary transparency by informing you, as personal data owners.
In this context, Tuğra Mobilya undertakes to process and protect your personal data with full awareness of responsibility in accordance with the relevant legislation, this Policy and the procedures to be applied in accordance with the Policy.
SCOPE OF THE POLICY
This Policy applies to all personal data of all natural persons whose personal data are processed, whether automatically or by non-automatic means, provided that they are part of any data recording system.
This Policy covers and applies to all data processing activities of Tuğra Mobilya regarding personal data it processes.
This Policy does not apply to data that does not qualify as personal data.
This Policy may be amended from time to time with the approval of the [Board of Directors] if required by the relevant legislation or if deemed necessary by Tuğra Mobilya.
In the event of a conflict between the relevant legislation and this Policy, the relevant legislation shall prevail.
BASIC PRINCIPLES OF PERSONAL DATA PROCESSING
Processing Personal Data in Accordance with the Law and Honesty Rules Tuğra Mobilya processes Personal Data in accordance with the law and honesty rules and based on the principle of proportionality. In this context, Tuğra Mobilya processes Personal Data to the extent required by Tuğra Mobilya's business activities and limited to them.
Ensuring That Personal Data is Accurate and Up-to-Date When Necessary Tuğra Mobilya takes all necessary measures to ensure that Personal Data is complete, accurate and up-to-date during the period it is processed. In this context, Tuğra Mobilya establishes the necessary mechanisms to ensure the accuracy and currency of Personal Data and updates the relevant Personal Data in accordance with the Data Subject's requests for changes to Personal Data under the GDPR Regulations.
Processing Personal Data for Specific, Clear and Legitimate Purposes Before Personal Data is Processed, Tuğra Mobilya determines for what purpose Personal Data will be processed. In this context, Tuğra Mobilya clearly reveals the purposes of processing Personal Data and processes Personal Data within the scope of these activities in line with its business activities. In this direction, Data Subjects are informed in accordance with the GDPR Regulations and, where necessary, the Explicit Consent of the persons in question is obtained.
Personal Data Should Be Related to, Limited to and Measured to the Purpose for Which They Are Processed Tuğra Mobilya collects Personal Data only to the extent and nature required by its business activities and processes it limited to the specified purposes. In this direction, Tuğra Mobilya refrains from processing Personal Data that is not related to the achievement of the determined purposes or is not needed.
Retention of Personal Data for the Period Stipulated in the Relevant Legislation or Required for the Purpose for Which They Are Processed Tuğra Mobilya retains Personal Data for the minimum period required for the purpose for which it is processed and stipulated in the relevant legal legislation. In this context, Tuğra Mobilya first determines whether the relevant legislation foresees a period for the storage of personal data and, if a period is determined, acts in accordance with this period.
Personal Data is Destroyed at the end of the determined retention periods in accordance with periodic Destruction periods or Data Subject application and with the determined Destruction methods (deletion and/or destruction and/or anonymization). In this case, it is ensured that the third parties to whom Tuğra Mobilya transfers Personal Data also delete, destroy Personal Data.
or make it anonymous.
[Committee] is responsible for the operation of the destruction processes. In this context, the necessary procedure is created by the [Committee].
PERSONAL DATA PROCESSED BY TUĞRA MOBİLYA AND PROCESSING PURPOSES
In Tuğra Mobilya, by informing the Relevant Persons in accordance with the GDPR Regulations, in line with the Personal Data processing purposes of Nazilli Private Reference Hospital, based on and limited to at least one of the Personal Data processing conditions specified in Articles 5 and 6 of the KVKK, mainly to the Principles specified in Article 4 of the KVKK regarding the Processing of Personal Data. Personal Data is processed in accordance with the general principles specified in the KVKK.
PERSONAL DATA STORAGE PERIOD AND DESTRUCTION
Tuğra Mobilya retains Personal Data for the period required for the purpose for which they are processed and the minimum period stipulated in the relevant legal legislation. In this context, Tuğra Mobilya first determines whether the relevant legislation foresees a period for the storage of Personal Data, and if a period is determined, it acts in accordance with this period. If there is no legal period, Personal Data is stored for the period required for the purpose for which it is processed. Personal Data is never stored by Tuğra Mobilya, taking into account the possibility of future use.
Tuğra Mobilya creates a Personal Data storage and Destruction policy in accordance with the Personal Data processing inventory and carries out all Destruction (deletion and/or destruction and/or anonymization) activities in accordance with the GDPR Regulations and the relevant Personal Data storage and Destruction policy. Personal Data is Destroyed at the end of the storage periods determined within the scope of the prepared Personal Data storage and Destruction policy in accordance with periodic Destruction periods or Data Subject application and with the determined Destruction methods (deletion and/or destruction and/or anonymization). [Committee] is responsible for the operation of the destruction processes. In this context, the necessary procedure is created by the [Committee].
TRANSFER OF PERSONAL DATA
Tuğra Mobilya may transfer Personal Data of Relevant Persons to third parties located in Turkey and/or abroad in accordance with GDPR Regulations by taking the necessary security measures in line with its legal Personal Data processing purposes. In this case, the necessary protective regulations are added to the contracts concluded with third parties.
Even if the Data Subject does not have Explicit Consent, Personal Data may be transferred to third parties by the Company with the fulfillment of administrative and technical measures in accordance with the GDPR Regulations, if one or more of the following conditions are met:
The relevant activities regarding the transfer of Personal Data are expressly stipulated in the laws,
The transfer of Personal Data by Tuğra Mobilya is directly related to and necessary for the establishment or performance of a contract,
The transfer of Personal Data is mandatory for Tuğra Mobilya to fulfill its legal obligation,
Transfer of Personal Data by Tuğra Mobilya in a limited way for the purpose of disclosure, provided that Personal Data has been made public by the Data Subject,
The transfer of Personal Data by Tuğra Mobilya is mandatory for the establishment, use or protection of the rights of Tuğra Mobilya or the Data Subject or third parties,
It is mandatory for Tuğra Mobilya to engage in Personal Data transfer activities for legitimate interests, provided that the fundamental rights and freedoms of the Data Subject are not harmed,
It is mandatory for the person who is unable to disclose his consent due to actual impossibility or whose consent is not legally valid to protect his own or another person's life or bodily integrity.
In addition to the above, Personal Data may be transferred to foreign countries that have been declared by the Board to have adequate protection ("Foreign Country with Adequate Protection") if any of the above conditions are met. If there is no adequate protection, it can be transferred to foreign countries where the Data Controllers in Turkey and the relevant foreign country guarantee sufficient protection in writing in accordance with the data transfer conditions stipulated in the legislation and with the permission of the Board ("Foreign Country with a Data Controller Who Guarantees Sufficient Protection").
TRANSFER OF SPECIAL CATEGORIES OF PERSONAL DATA
Special Categories of Personal Data may be transferred by Tuğra Mobilya in accordance with the principles specified in this Policy and by taking all necessary administrative and technical measures, including the methods to be determined by the Board, and if the following conditions exist:
Special Categories of Personal Data other than health and sexual life are processed without the Explicit Consent of the Data Subject if it is expressly stipulated in the laws, in other words, there is an explicit provision in the relevant law regarding the Processing of Personal Data. Otherwise, the existence of the Data Subject's Explicit Consent is required for the processing of Special Categories of Personal Data other than health and sexual life.
Special Categories of Personal Data related to health and sexual life are processed by persons (e.g. workplace physician working under the Company's payroll) or authorized institutions and organizations under the obligation of secrecy for the purpose of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing without the Explicit Consent of the Data Subject. Otherwise, the existence of the Data Subject's Explicit Consent is required for the processing of Special Categories of Personal Data other than health and sexual life.
In addition to the above, Special Categories of Personal Data may be transferred to Foreign Countries with Adequate Protection if any of the above conditions are met. If there is no adequate protection, it can be transferred to Foreign Countries with a Data Controller Who Guarantees Sufficient Protection in accordance with the data transfer conditions stipulated in the legislation.
TUĞRA MOBİYA'S OBLIGATION TO INFORM
Tuğra Mobilya informs the Relevant Persons before the Personal Data is processed, in accordance with Article 10 of the KVKK and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform. In this context, Tuğra Mobilya informs the Relevant Persons in accordance with the GDPR Regulations regarding who processes their Personal Data as the Data Controller, for what purposes, with whom and for what purposes it is shared, by what methods it is collected and its legal reason, and the rights that the Relevant Persons have within the scope of processing their Personal Data.
The necessary GDPR Procedures are created by the [Committee] in order to report all new Personal Data processing processes to the [Committee].
If the Data Processor is a third party other than Tuğra Mobilya, it is guaranteed by a written contract that the third party will act in accordance with the above-mentioned obligations before the Personal Data Processing is started. Each employee is obliged to go through the process in this Policy and GDPR Procedures in case Personal Data is transferred by Tuğra Mobilya to a third party.
RIGHTS OF THE DATA SUBJECTS
Data Subjects have the following rights:
To learn whether their Personal Data is processed,
If their Personal Data has been processed, to request information regarding this,
To learn the purpose of processing their Personal Data and whether they are used in accordance with their purpose,
To know the third parties to whom their Personal Data is transferred domestically or abroad,
To request correction of their Personal Data if it is incomplete or incorrectly processed and to request that the transaction made in this context be notified to third parties to whom their Personal Data is transferred,
To request the deletion or destruction of their Personal Data in the event that the reasons requiring its processing have disappeared, although it has been processed in accordance with the Law and other relevant legal provisions, and to request that the transaction made in this context be notified to third parties to whom their Personal Data is transferred,
To object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
To demand compensation for the damage in case they suffer damage due to the unlawful processing of their Personal Data.
Data Subjects may submit their requests regarding the rights listed in this section of this Policy to Tuğra Mobilya through the methods determined by the Board. Tuğra Mobilya may benefit from the Data Subject Application Form. However, in any case, current application methods and application content should be checked from the relevant legislation before the application, and applications should be made in accordance with the said procedures and principles.
If the Data Subjects submit their requests regarding the rights listed above to Tuğra Mobilya in writing, Tuğra Mobilya concludes the request free of charge within 30 (thirty) days at the latest, in accordance with the GDPR Regulations, depending on the nature of the request. If there is an additional cost for the Data Controller to conclude the requests, the fees in the tariff determined by the Board may be requested by the Data Controller.
PERSONAL DATA MANAGEMENT AND SECURITY
Tuğra Mobilya establishes a [Committee] to fulfill its obligations within the scope of GDPR Regulations, to ensure the preparation and implementation and supervision of the necessary GDPR Procedures for the implementation of this Policy, and to make suggestions regarding their operation.
Tuğra Mobilya takes all necessary administrative and technical measures to ensure the security of Personal Data in accordance with the GDPR Regulations. In this context, Personal Data Processing activities are monitored by technical systems according to technological possibilities and application costs. Personnel knowledgeable in technical matters regarding Personal Data Processing activities are employed.
Tuğra Mobilya employees are informed and trained regarding the protection and lawful processing of Personal Data.
The necessary GDPR Procedures are created to ensure the access of employees who need to access Personal Data in Tuğra Mobilya to the Personal Data in question, and the [Committee] is responsible for its creation and implementation.
Tuğra Mobilya employees can access Personal Data only within the scope of their defined authority and in accordance with the relevant GDPR Procedures.
Tuğra Mobilya employees immediately notify the [Committee] if they suspect that the security of Personal Data is not sufficiently ensured or if they detect such a security vulnerability.
Detailed GDPR Procedures regarding the security of Personal Data are created by the [Committee].
Each person who is allocated a Tuğra Mobilya product is responsible for the security of the products allocated for their use.
Each Tuğra Mobilya employee is responsible for the security of the physical files in their area of responsibility.
In case there are security measures requested or additionally requested for the security of Personal Data within the scope of GDPR Regulations, all employees are obliged to comply with the additional security measures and ensure the continuity of these security measures.
All Personal Data processed within Tuğra Mobilya is considered as "Confidential Information" by Tuğra Mobilya.
Tuğra Mobilya employees have been informed that their obligations regarding the security and confidentiality of Personal Data will continue even after the termination of the business relationship, and Tuğra Mobilya employees have been committed to comply with these rules.
