2M KABLO PERSONAL DATA PROTECTION LAW (KVKK) Clarification Text

Dear Valuable Guests,

As per the Personal Data Protection Law (KVKK) our companies, the 2M Kablo Sanayi ve Ticaret A.S and 2M Kablo Pazarlama ve Dıs Ticaret A.S. which reside in the addresses of “Gaziosmanpaşa OSB District, 4th Avenue, No:18 Çerkezköy, Tekirdağ and Halil Rıfat Paşa District Yüzer Havuz Street. Perpa A Block No: 9/21-22 Şişli İstanbul", are the data supervisors.

As the 2M Kablo Sanayi ve Ticaret A.S and 2M Kablo Pazarlama ve Dıs Ticaret A.S. ("2M KABLO"); the privacy and the security of your personal data are among our most important priorities. In this scope, with the aim of fulfilling our liability of clarification which arises from the 10^th Article of the Personal Data Protection Law with no. 6698 (Law with no. 6698), we present the below instructions to the attention of 3.You, our valuable customers, persons/guests who use our web site.

Our aim is to inform you about the identity of the data supervisor, mode of collecting the personal data, aims and methods of processing, legal reasons of data collection, to whom and with which aim the personal data could be relayed and the subject of the rights of data owners in the clearest way.

This clarification is valid for the applicants for job applicants to 2M Kablo, the ones who want to get information about the 2M KABLO products and services, real persons, customer and customer candidates, suppliers, employee candidates, former employees, who search for the web site and 2M KABLO with the requests, suggestions, and complaints concerning the products and services, subcontractor and subcontractor employees or corporate customer representatives.

1. What is the legal basis of our collecting personal data?

For providing the confidentiality of private lives of persons, for the privacy of protection of the data which have inconveniency of being captured by the third persons, the Personal Data Protection law with no 6698 and dated as 07.04.2016, which was published in the Official Gazette, entered into force. Our company is subjected to this law, all data processed in all the work processes that are carried on, are accepted as personal data by being evaluated within this scope and are put under protection as required by law. Our company pays the maximum attention in the subject of taking all technical and administrative precautions with the aim of preventing Access to the personal data collected within the framework of confidentiality of private life and principle of respect towards the basic rights and liberties in accordance with the Personal Data Protection with law no. 6698 and the secondary regulations

Your personal data which are collected can be processed on condition that the Personal Data Protection Law’s being:

Predicted in the laws clearly, (article.5/2.a)
Requirement of the personal data’s belonging to the parties of the contract provided that the contract’s being established or being relevant with its execution directly, (a.5/2.c)
It's being obligatory for the data supervisor’s fulfilling his legal liability(a.5/2.ç)
The data processing’s being obligatory for the establishment, usage, or protection of a right (a. 5/2.d)
On condition that not giving harm to the basic rights and liberties of the related person, within the conditions of the obligation of the data processing for the legitimate benefits of the data supervisor, (a. 5/2.f), communication, membership, and similar online forms which are involved in the internet sites belonging to the company ( besides the information required for the mentioned forms, your information which has the feed-back and similar contexts which you enclose with your own consent), your information which you share through means such as our call centres, the e-mails, phone, internet site, various contracts, forms and minutes that are kept in the paper medium, with automatic or non-automatic methods, as oral, written or electronically, in a proper way.

2. For what purpose we process and use the personal data?

2M KABLO may save, preserve, update and disclose, assign, classify your personal data in the cases and process to the extent permitted by the legislation and within the compass of the personal data processing conditions stated in 5/2.a, 5/2.c, 5/2.ç, 5/2.d, 5/2.f and the 6^th articles of the Personal Data Protection Law (KVK) with the aims that are stated in the below;

The data that may be shared by the guests/users who use/access the web site of 2M KABLO during this usage/access are;

Cable Request Form (Name-Surname, Phone, e-mail, location, message)
Communication Form(Name-Surname, phone, e-mail, location, message)
Newsletter membership (Email)
Job application form (Name-Surname, Phone, e-mail, CV document)

Processing and usage aims of your personal data are as follows;

Carrying out the commercial relations, determining and applying the commercial and business strategies,
Confirming the identity information of the operant/the one who gets it to be operated.
Saving the address for communication and other necessary information, communicating with the data owners,
Execute the liabilities undertaken as per all the related agreements which we have drawn up within the related articles of the distance sales contract and the Law on the Protection of the Consumer from the contracts,
Issue all the records and documents which shall form the basis to the process in the electronic (internet/mobile etc.) or paper environment,
Presenting product/service offers, fictionalize and realize the product sale, marketing, and briefing activities, realizing all kinds of the briefing, advertising and introduction, promotion, sale and marketing activities, preparation, delivery of the orders and carrying out the necessary processes, realizing the special advertisement, campaign and other promotion sale and marketing activities oriented towards the customer profiles in case of the existence of their open consent, making the classification studies in line with the obtained data, making survey applications, data and statistical and risk analyses, conducting an internal audit, reporting, marketing researches, and profiling studies, sending bulletin and invitation cards,
may evaluate the customer complaints and suggestions concerning our products and services, increase the service quality,
the evaluation of the job applications and can manage the human resources and employment policies within this scope,
providing the physical security and audit of the business places and factories belonging to the 2M KABLO.
fulfilling our liabilities arising from the Personal Data Protection Law (KVKK) and using our rights arising from the legislation and can conduct the activities executed by the company in compliance with the related legislation and company policies,
presenting a better service to our users in our internet site and improving our services,

3. Is your personal data transferred to 3^rdPersons?

The sharing of your personal data with third persons is realized within the framework of open consent of the personal data owners and as a rule, the personal data are not transferred to the third persons without having the consent of the approval of the personal data owners. Your personal data can be shared by the courts and other public institutions and the program partner corporates, institutions which we cooperate for carrying out the activities of the 2M KABLO and/or its affiliated institutions, its subsidiaries, joint ventures, and all the branches and offices of these due to our legal liabilities and without being limited with these, and for presenting you a better service to you and for providing the customer satisfaction, with the companies and domestic/foreign other third parties and the related business partners of us which we work with within the scope of various marketing activities, in line with your open consent or in line with the provisions of the legislation.

Your personal data collected can be transferred to our business partners, affiliated companies, suppliers, public institutions which are legally authorized in compliance to the conditions of the personal data transferring, stated in the 8^th and the 9^th articles of the Personal Data Protection Law (KVKK) with the aims of:
being able to carry out our activities which are executed, in compliance to the related legislation and policies properly,
presenting a better service to our users in our internet site and improving our services,
realizing product/service offer, all kinds of the briefing, advertisement-introduction, promotion, sale, and marketing activities,
being able to make development studies by us or our group of companies oriented towards our customers’ fields of interest and preferences,
preparation, delivery of your orders by our business units and the performance of the necessary processes,
providing the legal and commercial security of the persons who have built a business relationship or who have already been in a business relationship with 2M KABLO.
making the necessary studies by our business units for having you benefited depending upon the product, service, or commercial activity;
determining and applying the commercial and business strategies.

4. Which methods do we use in the collection of personal data?

These methods may vary and differ depending upon the type and quality of the relationship between 2M KABLO and the data owner, the communication channels that are used, and the mentioned aim information. In the capacity of data supervisor by 2M KABLO, within the framework of our legal liabilities arising from the Personal Data Protection Law (KVKK) and the related other legislation; through the methods in the service processes which are executed in the commercial areas within the internet site, mobile applications, operator, call center, security/information offices, social media channels, in different channel direct or authorized communication channels and physical channels; your personal data, including in the personal data with special quality may be collected through oral, written or electronic methods within the legal causes that occur or are executed depending upon the related legislation, agreement, request, commercial tendency and honesty rules which find application opportunity in the point of presenting our services of good quality by using these channels and executing our business and commercial activities;

The membership form that you have filled electronically or physically,
The social networks that provide for you to member login during the membership or logging in to our websites,
Communication forms that take place in our websites or in the websites that belong to the third parties which you have filled to communicate with us,
Online shopping applications, cookies that are used to identify you, our mobile applications,
E-mails, fax, and letters that you have sent to our company with various agreements you have signed with our company,
Third-party company (companies) that process data for our company or support our company at any levels of the membership program,
Our personnel, customer service channels,
Social media channels, usage of search engines like Google, etc.,
Membership agreements and miscellaneous other agreements, campaigns, applications, forms, offers,
Data in our factories, branches, and offices by 2M KABLO,
Data acquired by the participants that participated in operations made by 2M KABLO expo, activity, market research with the media organs with the data acquired by the websites of the members of the local authorities, blog that belongs to 2M KABLO, contest, questionnaire, game, campaign or similar purposes.
All sorts of private data that are declared via hand-delivery or in electronic format, contact information that are acquired by means of the firms that operate in the area of human resources, past work experience, skills and talents, reference information,
Contact information of the customers that use 2M KABLO products over every sort of communication channels like phone calls and recordings, e-mails customer prospects that will use 2M KABLO products,

5. What are the Rights that the Data Owner has within the Scope of the PPDA (PROTECTION OF THE PRIVATE DATE ACT)?

Accordingly to the PPDA, you can use your rights stated below about your private data by making an application to 2M KABLO:

Finding out if private data has been processed or not,
Finding out the purpose of processing private data and if these are used relevantly,
Knowing about the domestic and international third parties with whom the private data have been shared with,
Requesting the correction of the private data in case they are inadequately or wrongly processed,
Requesting the deletion or disposal of the private data,
Appealing against a result to the detriment of the user by means of the analysis of the private data via the automatic systems exclusively,
Requesting the recovery of the losses in case of loss because of the processing data in defiance of the Private data act.

Within this scope, the requests that will be transmitted to 2M KABLO, will be resulted in thirty (30) days free of charge.

You can transmit the application you have written with wet signature to use your rights stated above or the application form; at the https://www.2mkablo.com Gaziosmanpaşa OSB District 4t^hAvenue No:18 A 59500 Çerkezköy – Tekirdağ address with the documents that are declaratory of your identity by hand, via notary or the related form to the 2mkablo@hs01.kep.tr address with a safe electronic signature.

6. How long is our Personal Data Storage?

As per the Personal Data Protection Law, despite their being processed in compliance with the Personal Data Protection Law and the related other provisions of the other acts, in case of the removal of the causes required to be processed, the personal data are deleted, removed or as ex officio or upon the request of the related person by the data supervisor and have it become anonymous. Within the scope of this provision, 2M KABLO shall delete, remove or have it become anonymous since the removal of the causes which require the obtained processed data.