PERSONAL DATA PROTECTION AND PRIVACY POLICY

INFORMATION NOTICE ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

1. Identity of the Data Controller 
As Özerden Ambalaj Sanayi A.Ş. (“Özerden”), we place great importance on providing our services in the best possible way. Accordingly, we would like to inform you regarding the personal data that we obtain in our capacity as the data controller, within the scope of the Personal Data Protection Law No. 6698 ("KVKK").

2. Processing of Personal Data and Purposes of Processing  
According to Article 3/d of the KVKK, personal data refers to “any information relating to an identified or identifiable natural person.” The personal data, such as identification information, contact details, residence address, date of birth, gender, and email address, are stored by Özerden in compliance with the relevant legislation.  

These personal data are processed for the following purposes:

Verifying the identity of visitors,
Recording address and other necessary information for communication,
Complying with information storage, reporting, and informing obligations as per relevant legislation,
Ensuring safety and security in accordance with the relevant legislation and regulations,
Managing human resources processes,
Fulfilling Özerden’s legal obligations.

As stated in Article 5/a of the KVKK, if it is expressly stipulated by law, and according to Article 5/c, if the processing of personal data is necessary for the establishment or performance of a contract, the data subject's explicit consent is not required.  

Özerden will not use personal data for purposes other than those specified here, nor will it transfer or disclose them to third parties without explicit consent or legal grounds provided by relevant legislation.

3. Transfer of Personal Data 
Personal data may be transferred to the following third parties, limited to the purposes stated above, and in accordance with Articles 8 and 9 of the KVKK:

Legally authorized public institutions and organizations,
Group companies,
Independent audit companies, under confidentiality agreements, as required by legal obligations and within legal limitations for the purpose of carrying out their activities and services.

Personal data cannot be transferred abroad without the explicit consent of the data subject, except in the following cases:  

Personal data may be transferred abroad without explicit consent, provided that one of the conditions stated in the second paragraph of Article 5 or the third paragraph of Article 6 of the KVKK is met, and adequate protection is ensured in the foreign country where the data will be transferred. If there is no adequate protection, personal data can be transferred abroad without explicit consent, provided that the data controllers in Turkey and the relevant foreign country guarantee adequate protection in writing and obtain permission from the Board.

4. Method and Legal Basis of Collecting Personal Data
As the “Data Controller” and “Data Processor,” Özerden may collect personal information in compliance with the fundamental principles provided by the KVKK and based on the legal grounds of fulfilling the contract, complying with legal obligations, and protecting legitimate interests as outlined in Article 5/2 of the KVKK. This information may be collected directly from you verbally or in writing, via phone, email, or other channels, and from our website, camera recordings, or support services provided by our business partners, using automated or non-automated methods. Özerden may collect, record, store, retain, update, change, reorganize, disclose, transfer, hand over, classify, anonymize, and process personal data to continue the services provided to the data subject and in other manners as specified by law, without exceeding the legal time limits.

5. Your Rights Regarding Personal Data
According to Article 11 of the KVKK, data subjects have the following rights:

To learn whether personal data is processed,
To request information if personal data has been processed,
To learn the purpose of the processing and whether personal data is used in accordance with its purpose,
To know the third parties to whom personal data is transferred, within Turkey or abroad,
To request the correction of personal data if it is incomplete or inaccurately processed,
To request the deletion or destruction of personal data within the framework of the conditions set forth in Article 7 of the KVKK,
To request notification of the transactions made under paragraphs (d) and (e) to third parties to whom personal data has been transferred,
To object to the processing of personal data that results in an unfavourable outcome for the individual through analysis solely by automated systems,
To request compensation for damages incurred as a result of unlawful processing of personal data.

In accordance with Article 13 of the KVKK, data subjects may always submit their questions, requests, or complaints regarding the application of the relevant law in writing by mail, electronically, or through other means specified in the KVKK. Requests regarding personal data can be submitted with the necessary identifying information and an explanation of which of the rights listed in Article 11 of the KVKK is being exercised, to the email address info@ozerden.com with a secure electronic signature, or by notary to the address Reşitpaşa Mah. Eski Büyükdere Cad. Windowist Blok No: 26 /12 Sarıyer / İstanbul, Attention: ÖZERDEN KVKK Management Unit. We would like to emphasize that these procedures are necessary to share information exclusively with the data subject. ÖZERDEN will respond to requests as quickly as possible, depending on the nature of the request. Please click here for application procedures.

Requests made under Article 13 of the KVKK will be processed free of charge and resolved within 30 (thirty) days at the latest, depending on the nature of the request. If the request is denied, the reason(s) for the denial will be provided in writing or electronically. If the request requires a cost, the tariff set by the Personal Data Protection Board will be applied.

PRIVACY POLICY:
This communication and its attachments may contain confidential information and are intended solely for the individual(s) or organization(s) to whom it is addressed. If you have received this communication in error, please keep it confidential, notify the sender immediately, and delete it and its attachments without reading or copying them from your system. ÖZERDEN AMBALAJ SANAYİ ANONİM ŞİRKETİ does not make any representation as to the accuracy, completeness, or currency of the information contained in this communication and its attachments and does not accept any liability arising from the transmission, receipt, storage, or use of this information in any manner. ÖZERDEN AMBALAJ SANAYİ ANONİM ŞİRKETİ cannot be held responsible for any changes to or late arrival of this communication and its attachments, for containing viruses, or for any damage they may cause to your computer system.