CORPORATE GENERAL CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA

Nema Basım Yayın San. Tic. Ltd. Şti. As (“Nema Basım”); we have prepared this clarification text in order to inform you, our Visitors, Online Visitors, Customers, Potential Customers, Supplier Employees and Supplier Authorities, regarding the processing, storage, and transfer of your personal data within the framework of the Law on Protection of Personal Data No. 6698 (“LPPD”) and related legislation and legal regulations.

1) What Are Our Categories of Personal Data We Process and For What Purposes Do We Process Them?

Your personal information might be processed by Nema Basım Yayın San. Tic. Ltd. Sti. in accordance with the principles;
(i) To be compliant with the law and honesty rules,
(ii) To be accurate and up-to-date when necessary,
(iii) To Process for specific, clear and legitimate purposes,
(iv) To be relative, limited and proportional to the purpose for which they are processed,
(v) To be stored for the period stipulated in the relevant legislation and required for the purpose for which they are processed,
which are stipulated in article 4.2 of the LPPD, within the scope of our ongoing business relations with our business partners (it is possible for a person to fall into more than one category) for the purposes specified below.

A. Our Visitors

Transaction security information of our online visitors using our website (e.g. your IP address information) and (if you notify us of them) identification information, contact information (e.g. your email address);
a) creating and tracking visitor records,
b) ensuring physical space security.

B. Our Online Visitors

Transaction security information of our online visitors using our website (e.g. your IP address information) and (if you notify us of them) identification information, contact information (e.g. your email address);
a) executing activities in accordance with the legislation,
b) executing information security processes,
c) tracking requests/complaints,
d) conducting communication activities,
e) informing authorized persons, institutions and organizations,
f) enabling you to access our website via the internet.

C. Our Customers

Identity information, contact information, customer transaction information (e.g. order information), physical location security information, financial information (e.g. balance sheet information), legal transaction information of our real person customers or of legal entity customers’ officials and/or of their customers, will be processed for the purposes of
a) execution of activities in accordance with the legislation
b) execution of finance and accounting affairs,
c) execution/audit of business activities,
d) execution of logistics activities,
e) execution of goods/services after-sales support services,
f) execution of goods/service sales processes,
g) execution of marketing-analysis studies
h) execution of contract processes,
i) informing authorized persons, institutions and organizations,
j) ensuring physical space security,
k) resolving legal disputes,
l) carrying out storage and archiving activities,
m) carrying out risk management processes,
n) advertising / campaign / promotion processes,
o) company / product / services commitment processes,
p) carrying out communication activities.

D. Our Potential Customers

Identity information, contact information, customer transaction information, physical location security information, marketing information of employees and/or customers of our real person customers or legal entity customers; will be processed for the purposes of;
a) management of goods/service sales processes,
b) execution of contract processes,
c) ensuring physical space security,
d) execution of advertisement/ campaign/ promotion processes,
e) execution of marketing analysis studies.

E. Our Supplier Employee

Identity information, contact information, physical space safety information, professional experience information of our supplier employee (e.g., on-the-job training information); will be processed for the purposes of;
a) executing communication activities,
b) executing/inspecting business activities,
c) ensuring physical space security,
d) executing supply chain management processes,
e) executing logistics activities,
f) executing activities in accordance with the legislation,
g) executing occupational health/safety activities.

F. Our Supplier Authority

Identity information, contact information, physical space security, customer transaction information, financial information, marketing information, legal transaction information of our real person suppliers or legal entity supplier authorities; will be processed for the purposes of;
a) execution/audit of business activities,
b) execution of goods/service procurement processes,
c) execution of finance and accounting affairs,
d) execution of contract processes,
e) execution of investment processes,
f) provision of physical space security,
g) follow-up and execution of legal affairs.

2) What are the Collection Methods of Your Personal Data?

Your personal data specified above in categories; is collected by physical means such as order forms, contracts, visitor forms or by automatic or non-automatic means through information systems and electronic devices (e.g., telecommunication infrastructure, computers, and telephones), our website and other documents declared by the person concerned.

3) What is the Legal Reason for Collecting Your Personal Data?

Your personal data is processed by Nema Basım Yayın San. Tic. Ltd. Şti.; in line with the realization of the above-described objectives, on the basis of legal reasons as specified in Article 5 of the LPPD, providing that
(i) It is expressly provided for by law,
(ii) Requiring the processing of the personal data of the parties to the contract, on condition that it is directly related to the establishment or performance of a contract;
(iii) Being mandatory for the data controller to fulfill its legal obligation,
(iv) Data processing to be mandatory for the establishment, use or protection of a right,
(v) Data processing to be mandatory for the legitimate interests of the data controller on condition that it does not harm the fundamental rights and freedoms of the data subject.
When the data processing activity cannot be based on one of the above legal reasons, your personal data is processed based on your explicit consent.

4) Do We Transfer Your Personal Data to a Third Party?

a) Personal data of our visitors may be shared with law enforcement and judicial authorities, upon request, in order to resolve legal disputes and in accordance with the relevant legislation.
b) Personal data of our online visitors may be shared with judicial authorities and authorized public institutions and organizations, if requested, in order to resolve legal disputes and in accordance with the relevant legislation.
c) Personal data belonging to our customers is transferred to the authorized public institutions and organizations for the purpose of carrying out the activities in accordance with the legislation, following and executing the legal affairs, informing the authorized persons, institutions and organizations within the scope stipulated by the legal regulations; and to our group companies, banks and our financial advisors to the required extent in order to conduct/audit business activities, carry out risk management processes, and perform our services properly. In addition, the personal data in question may be transferred to the law firm and judicial authorities from which we receive services so that they can be used as evidence in legal disputes that may arise in the future.
d) Personal data belonging to our potential customers may be transferred to the law firm and judicial authorities from which we receive services so that they can be used as evidence in future legal disputes.
e) Personal data belonging to our supplier employee, is transferred to authorized public institutions and organizations for the purposes of carrying out activities in accordance with the legislation, following and executing legal affairs, informing authorized persons, institutions and organizations, and conducting / auditing business activities, and to group companies, banks and our financial advisor to the required extent in order to perform the service properly within the scope stipulated by the legal regulation. In addition, the personal data in question may be transferred to the law firm and judicial authorities from which we receive services so that they can be used as evidence in legal disputes that may arise in the future.
f) Personal data belonging to our supplier authority, is transferred to authorized public institutions and organizations for the purpose of carrying out activities in accordance with the legislation, following and executing legal affairs, informing authorized persons, institutions and organizations, and conducting/supervising business activities, and to group companies, banks and our financial advisor to the required extent in order to perform the service properly, within the scope stipulated by legal regulations. In addition, the personal data in question may be transferred to the law firm and judicial authorities from which we receive services so that they can be used as evidence in legal disputes that may arise in the future.

5) Do We Transfer Your Personal Data Abroad?

As Nema Basım Yayın San. Tic. Ltd. Sti., we do not transfer your personal data abroad.

6) How Can You Exercise Your Rights Regarding Your Personal Data?

You can send your requests within the scope of Article 11 of the LPPD, which regulates the rights of the persons concerned, to us via the “Application Form to the Data Controller” prepared for your convenience in accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller”, located at the “www.nemabasim.com” address of Nema Basım Yayın San. Tic. Ltd. Şti.
Data Controller: Nema Basım Yayın San. Tic. Ltd. Şti.
Address: Aydınlı – Birlik OSB Mahallesi 3. Sokak No: 4/1 Tuzla
Mail: kvkk@nemabasim.com