EMPLOYEE CLARIFICATION TEXT ON PERSONAL DATA
 
I.​PREAMBLE
 
This clarification text has been created by Aqua Grup Turizm Emlak İnşaat Kuyumculuk Ticaret A.Ş. (hereinafter referred to as "Aqua Group") in order to inform you about how your personal data will be stored, recorded, processed, and transferred in accordance with Personal Data Protection Law No. 6698. This clarification text is part of the importance we place on you, our employees ("PDPL").
 
As is well known, the data controller has a responsibility and duty to disclose information on the following during the collection of personal data within the purview of Article 10 of the PDPL:
 
a) Identity of the data controller and its representative, if any,
b) The purpose for which personal data will be processed,
c) To whom and for what purpose the processed personal data may be transferred,
ç)The method and legal reason for collecting personal data,
d) Other rights listed in Article 11
 
Since Aqua Group is the data controller, you may submit any requests you have regarding your data—which will be covered below—by sending a written notice to the address of
 
Karagedik, 1104. Sk. No: 16/11, 48300 Fethiye/Muğla
 
or by emailing to veri@supervillam.com.
 
 
I.​DEFINITIONS
 
The terminology defined within the scope of PDPL and their definitions are provided to your attention below in order for the parties to understand the clarifying language fully and without the need for further explanation.
 
In this context;
 
Explicit Consent: It refers to the consent regarding a specific subject, based on information and expressed with free will.
 
Anonymisation: It refers to making personal data impossible to be associated with an identified or identifiable natural person under any circumstances, even by matching with other data.
 
Relevant Person: It refers to the real person whose personal data is processed.
 
Personal Data: It refers to any information relating to an identified or identifiable real person.
 
Processing of Personal Data: It refers to all kinds of operations performed on personal data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that it is part of any data recording system.
 
Board: It refers to the Personal Data Protection Board.
 
Institution: It refers to the Personal Data Protection Authority.
 
Data Processor: It refers to the natural or legal person who processes personal data on behalf of the data controller based on the authorisation granted by the data controller.
 
Data Recording System: It refers to the recording system in which personal data is structured and processed according to certain criteria.
 
Data Controller: It refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.
 
I. EXPLICIT CONSENT
 
Explicit consent, as defined by the PDPL, is assent that is given regarding a particular subject, is informed, and is given voluntarily. It denotes your approval of the processing of your general, particular, and sensitive personal data. In this situation, declarations of assent and acceptance that are freely offered, sufficiently clear, and supported by information are considered as explicit consent.
 
It has been made apparent that, with some exceptions, processing of personal data is not permitted without express authorization in accordance with Article 5/1 of the PDPL. Once more, it has been established that personal data cannot be transmitted without express authorization under the purview of Article 8/1 of the PDPL.
 
In this regard, we kindly ask for your permission to process, store, record, anonymize where appropriate, and share your personal data with third parties over the course of our business relationship, barring any extenuating circumstances.
 
As you have been told, please check the boxes to show your permission. Your general and private data will really be treated within the parameters of consent, as mentioned in this text.
 
 
I. YOUR PERSONAL DATA AND PURPOSES OF PROCESSING
 
As a valued employee, you are a member of the Aqua Group family. The manner we handle the personal information you have provided to us is another indication of the value we place on you in this situation. Your personal information is saved, recorded, processed, and transferred in this context via the permission form:
 
i. Identity Information (Name, Surname, Date of Birth, Nationality, Photocopy of Identity Card, Turkish ID Number, Place of Birth, Gender, Marital Status, Turkish ID card information),
i. Contact Details (Telephone, E-mail, Residence address),
i.  Financial and Legal Data (All kinds of contracts made with you, salary details, payrolls,   premium progress payments, premium amounts, file and debt information regarding execution files, bank passbook and salary account information, minimum living allowance information, private health insurance amount),
i. Your personal data of special nature (health report, criminal record, disability status/definition/percentage, chest X-ray, hearing and vision tests, pregnancy status and report, health and maternity leave information, association/foundation memberships, trade union information),
i. Educational information (Curriculum Vitae, Primary, Secondary, High School, High School, Bachelor's, Master's and Doctorate degrees, certificates, courses taken, education and skills),
i.     Photographs, camera and audio recordings, interview recordings,
               Performance information (Monthly performance record, bonus record and follow-up records),
i. Other data related to labour law (severance, notice pay information, workplace file, annual leave, week holiday sheets, National Holiday and General Holiday work schedules),
i. Other information (driving licence, status of being a relative of a martyr, intern status, bus service ridden, bus stop data),
 
 
Your personal data are stored, recorded, processed by Aqua Group for the following purposes and transferred upon your consent:
 
a. For the fulfilment of the employment contract (approval of employees' leave, monitoring of outstanding leave, making leave arrangements, dismissal of employees, ensuring that payroll transactions are carried out, making salary payments to employees and the like),
b. For the purpose of fulfilling the requirements under the Labour Law, Occupational Health and Safety Law, Social Security Law and related legislation and other laws and legislation,
c. For delivery to judicial and administrative authorities if necessary and upon written application,
d. For the resolution of disputes arising from customer agreements (making the rightful/unjustified distinction of the customer in customer complaints, increasing customer satisfaction, understanding customer needs and ensuring the improvement of customer-related processes, evaluating the quality of service to the customer and providing training to employees)
e. For the purpose of administration of the company, execution of the business, implementation of company policies (transfer to our affiliated companies, partners, shareholders, transfer to archive companies in order to be stored during the storage periods in order to protect the company's data storage capacity, transfer to the company(s) working on the relevant subject for reasons such as transportation, vehicle supply, business card printing, car park registration),
 
I.​TRANSFER OF PERSONAL DATA
 
In the event that consent is given to third parties for the work that business units must carry out in order for the relevant persons to benefit from the goods and services provided by our website and our company, as well as for the management of business processes, planning, and execution of commercial and / or business strategies, your personal data may be shared with third parties.
 
In order to facilitate communication during training sessions and international travel, organise international trips, and send bulk emails, it may also be shared with foreign third parties.
 
For the aforementioned objectives, it may also be sent to our company authorities, affiliates, commercial partners, suppliers, shareholders, legally recognised governmental agencies and organisations, as well as private entities.
 
I.​PROCEDURE FOR COLLECTION AND PROCESSING OF PERSONAL DATA, LEGAL GROUNDS
 
Your personal information must be kept for the time period specified in the applicable law or necessary for the processing activity in accordance with the general principles of determining the campaign strategies, when required by law, within the scope and integrity of contract fulfilment, in order to fulfil the aforementioned purposes.
 
Evaluations are conducted in this context in connection to each data processing process and the purpose of the process within the parameters of the rules of the applicable law in order to establish the retention periods in line with the general principles. Personal data are therefore kept on file until the minimum time frames required by law and the statute of limitations have passed.
 
Your personal data is anonymized, removed, and/or disposed of in line with the PDPL when the specified time periods have passed and if the reason for processing it no longer exists.
 
Your personal information is gathered and processed in this direction using any verbal, written, or electronic means in order to provide the services we offer in compliance with the law and in line with the aforementioned purposes as well as to fully and accurately carry out our company's obligations arising from the contract and the law.
 
Your personal data will be collected, processed and shared within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the PDPL and in line with the legal reasons and purposes stipulated in this clarification text.
 
I.​DATA STORAGE
Your personal data that you have submitted to us are processed for the purposes described in this text within the scope of the principle of purpose limitation, limited to the period required to be processed in accordance with the practices and customs of commercial life; After the expiration of the periods, they are deleted, destroyed or anonymised.
 
In addition to these; In cases clearly stipulated in the laws, your data, which is mandatory for our company to fulfil its legal obligation as data controller, which is publicised by the data subject himself/herself, which must be processed for the legitimate interests of our company as data controller, provided that it does not harm the fundamental rights and freedoms of the data subject, can only be used for the realisation of the purposes enumerated in this sentence in the event that the periods specified under this heading expire.
 
For these reasons, your stored personal data will not be allowed to be accessed for any other purpose and can only be used within the scope of essential situations. Your personal data will be duly deleted, destroyed or anonymised in case of expiry of the aforementioned compulsory situations.
 
I.​RIGHTS OF THE DATA OWNER
 
You can make all your requests regarding the personal data recorded, stored, collected, processed and transferred by us to the e-mail address veri@supervillam.com as stated above.
 
In this context, your requests will be finalised free of charge within thirty (30) business days at the latest in accordance with the KVKK and taking into account the nature of the request.
 
However, if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board may be requested.
 
Pursuant to Article 11 of the LPPD, relevant persons (data owners) are entitled;
 
i.  To learn whether personal data about them are processed or not,
i.  To request information if personal data has been processed,
i.  To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
i.  To know the third parties to whom personal data are transferred domestically or abroad,
i. To request correction of personal data in case of incomplete or incorrect processing and to request notification of these changes to third parties to whom personal data are transferred,
i. To request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear, although it has been collected, processed and transferred in accordance with the provisions of the Law and the relevant legislation, and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
i. To object to the emergence of a result to the detriment of the person himself/herself by analysing the processed data exclusively through automated systems,
i. To demand compensation for damages in case of damage due to unlawful processing of personal data
 
Changes to the information on this form may be possible in accordance with emerging legal and technical trends.