AZEL LAW & CONSULTANCY FIRM – COOKIE POLICY
INTRODUCTION
This AZEL Law & Consultancy Office – Cookie Policy (“Cookie Policy”); has been prepared in order to ensure that the personal data of the visitors of the website (“Website”) consisting of the domain names https://www.azelhukuk.com and sub-domains connected to this domain name, belonging to AZEL (“AZEL Law & Consultancy”), operating at the address Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA Çankaya/Ankara, processed through cookies, are processed in accordance with the relevant legislation, especially the Constitution of the Republic of Turkey and international conventions to which our country is a party regarding human rights, and the Law No. 6698 on the Protection of Personal Data (“KVKK”), and to ensure that the data subjects whose data are processed can exercise their rights effectively. All personal data shared with AZEL Law & Consultancy will be processed lawfully, in connection with and proportionate to the purposes of the activities and services of AZEL Law & Consultancy.
- Definitions
The terms “personal data”, “sensitive personal data” and ‘data processing’ used in this Cookie Policy are used in accordance with the definitions set out in the Personal Data Protection Law (KVKK). The concept of ‘personal data’ as set out in the KVKK refers to any information relating to an identified or identifiable natural person; the concept of ‘processing of personal data’ refers to the collection, stored, retained, modified, reorganised, disclosed, transferred, acquired, made accessible, classified or restricted from use.
- Principles of Processing Personal Data
In accordance with Article 4 of the KVKK, personal data belonging to the data subject will be processed by the data controller AZEL Law & Consultancy for the purposes specified below, in compliance with the rules of lawfulness and fairness, being accurate and, where necessary, up-to-date, for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
- What is a Cookie?
A cookie is a small text file that can be used to access information about visitor activities on the Website, to perform analysis, and to collect data in order to ensure the Website functions properly. It is important to note that cookies do not collect information regarding files stored on visitor devices. The cookies subject to this Cookie Policy may be used, provided that the visitor currently accepts cookies, through the cookies placed on the visitor's device, or if the visitor has previously visited the Website or given consent to these cookies. Although the use of cookies is not mandatory in order to use the Website, the visitor may block and/or customise cookies via their browser. However, if cookies are blocked, the visitor will not be able to benefit from certain features of the Website. Furthermore, depending on the browser settings, these cookies may not be deleted automatically; therefore, as detailed in the Cookie Policy, it is of great importance that the visitor checks their browser settings to determine where cookies are stored and how they can be deleted.
These include, without limitation, a number of technologies used for purposes similar to cookies, such as pixel tags, which are transparent graphical images on the Internet; mobile device identifiers used to store information regarding the use of a mobile device in third-party environments through instruments such as IDFA and advertising ID; and segmentation/reporting products, which are programmes and/or products that operate through certain ready-made codes added to the Website or mobile devices using various methods, and which report, make sense of, and store users' actions on the Website or mobile device thanks to these codes.
- Cookie Types and Purposes of Use
- Strictly Necessary Cookies : These types of cookies ensure the proper functioning of the Website
These are cookies that are necessary for the website to function. Such cookies are required for the Website to continue operating in some way and to be maintained without causing any issues.
The use of cookies is mandatory. This type of cookie does not collect data for the purpose of marketing to the visitor, remembering the visitor's whereabouts on the internet, or tracking the visitor. Since the data collected via these types of cookies must be used and protected on the Website, it is not possible to disable mandatory cookies.
- Analytics Cookies: These types of cookies are used to identify visitors,
These are cookies that enable counting for analytical purposes and determining how the Website is navigated while being used. These cookies help to improve the operating methods of the Website and assist visitors in easily finding what they are looking for.
- Functional Cookies: These types of cookies are used when the Website is revisited
used to recognise the visitor if placed. These cookies help to personalise the Website specifically for the visitor and, accordingly, to remember visitor preferences.
- Marketing Cookies : These types of cookies are used to track visitors and the visitor's interest
they can be useful in terms of offering content and campaigns relevant to their fields, as well as being used to deliver targeted ads or to limit the number of times an ad is viewed.
Comprehensive information regarding the cookies used within the website and their purposes of use is shown in the table below;
| Cookie Type | Cookie Name | Source | Purpose | Retention Period |
Performance |
_ga |
Google Analytics |
This cookie is used by Google Analytics to evaluate the purpose of a visitor's visit, generate reports on website activity for website administrators, and aims to improve the visitor experience. | 540 Days |
Analytic |
_gcl_au |
Google Analytics |
This cookie is used by Google AdSense on websites to experiment with advertisement efficiency through the use of its services. | 540 Days |
Analytic |
NID |
Google Analytics |
Used to play YouTube videos embedded in the website | 6 months |
Analytic |
_gat_UA |
Google Analytics |
Used by Google to throttle the user's request rate during periods of heavy website traffic. | 1 Minute |
Analytic |
_gid |
Google Analytics |
Used by Google to store information on how visitors use the Website. | 1 Day |
Analytic |
IDE |
Google Analytics | Used by Google for real-time analytics bid data. | 2 years |
Analytic |
1p jar |
google.com |
It processes information regarding how the visitor uses the Website and the analytics the user may have seen prior to visiting the Website. | 1 month |
Analytic |
ANID |
google.com |
Used for analytics provided by the Website and stored by Google. | 2 years |
Analytic |
_Secure-3PAPISID |
google.com |
It builds a profile of website visitors' interests in order to show relevant and personalised analytics through retargeting. | 2 years |
Analytic |
_Secure-3PSID |
google.com |
It builds a profile of website visitor interests to show relevant and personalised analytics through retargeting. | 2 years |
Analytic |
_Secure-3PSIDCC |
google.com |
It is used to store visitor preferences and ensure their security. | 1 year |
- Disabling and Deleting Cookies
Visitors can disable all or some of the cookies by enabling the relevant setting in their browsers. However, if visitors use their browser settings to disable all cookies, including strictly necessary ones, they will be unable to access all or part of the Website. It must be emphasised that disabling a cookie or cookie category does not delete the cookie from the visitor's device. This action must also be carried out via the visitor's browser.
Visitors who wish to change their cookie settings must check the “options” or “preferences” section in their browsers. For further information, it is very important to examine the “help” option of various browsers, notably Internet Explorer, Firefox, Chrome, Android, Safari, and iOS.
- Transfer of Your Personal Data
AZEL Law & Consultancy acts in accordance with the regulations set out in the KVKK regarding the transfer of personal data. Except for the exceptions stipulated in the legislation or set out below, personal data and special categories of personal data are not transferred by us to other natural or legal persons without the explicit consent of the Data Subject. In the exceptional cases stipulated by the KVKK and other legislation, utmost care is taken to comply with the form and limitations prescribed in the legislation during the transfer of personal data to authorised administrative or judicial institutions or private organisations.
Your personal data;
- to authorised official institutions and organisations and legally authorised private entities for the purpose of fulfilling a legal obligation;
- For the purpose of carrying out or ensuring the follow-up of judicial processes, personal data may be transferred to relevant judicial authorities, including lawyers, within the framework of the procedures and principles stipulated in the relevant legislation and in compliance with the personal data transfer conditions and purposes specified in Articles 8 and 9 of the KVKK.
- Method of Collection and Legal Basis for Personal Data/Special Category Personal Data
Your personal data can be obtained by automated means when you visit the Website. The legal grounds for the processing of your personal data in question by AZEL Law & Consultancy are the cases that constitute exceptions to explicit consent specified in articles 5/2/a, 5/2/c, 5/2/ç, 5/2/e and 5/2/f, and article 6/3 of the KVKK [Law on the Protection of Personal Data]. Your personal data is collected by AZEL Law & Consultancy in accordance with all kinds of legislation in force for the specified legal reasons.
- Data Subject Rights
The data subject has the right, by applying to AZEL Law & Consultancy acting as the data controller, to: learn whether their personal data is being processed or not; request information thereon if their personal data has been processed; learn the purpose of the processing of their personal data and whether they are used in accordance with their purpose; be informed about the third parties to whom their personal data is transferred domestically or abroad; request the correction of their personal data in case of incomplete or incorrect processing; request the deletion or destruction of their personal data within the framework of the conditions set forth in Article 7 of the PDPL; request the notification of the operations carried out pursuant to Article 11(d) and Article 11(e) of the PDPL to third parties to whom their personal data has been transferred; object to the emergence of a result against the person themselves by analysing the processed data exclusively through automated systems; and demand the compensation of the damage in case of suffering damage due to the unlawful processing of personal data.
Pursuant to the Communique on the Procedures and Principles of Application to the Data Controller, applications to be made by you must contain your name, surname, signature if the application is in writing, secure electronic signature or mobile signature if it is electronic, Turkish Identity Number, residential address or workplace address for notification purposes, e-mail address for notification purposes, telephone number, and information regarding the subject of the request, if any. In order to exercise the rights mentioned above, the data subject is obliged to clearly and understandably state the matter requested in the application containing the explanation regarding the relevant right, and to attach the relevant information and documents to the application.
The aforementioned applications;
- to the address of AZEL Law & Consultancy at “Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA Çankaya/Ankara” in person, by hand, in writing,
- By submitting a request through a notary public to the address of AZEL Law & Consultancy at “Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA Çankaya/Ankara”,
- Notifications to AZEL Law & Consultancy may be made via the previously notified e-mail address registered in the AZEL Law & Consultancy system to the e-mail address info@azelhukuk.com.
AZEL LAW & CONSULTANCY – PRIVACY NOTICE FOR CONTACT PERSONS
INTRODUCTION
This Privacy Notice for Those Who Contact Us (“Privacy Notice”); AZEL (“AZEL Law & Consultancy”), has been prepared to ensure that the personal data of visitors who contact us is processed in accordance with the Constitution of the Republic of Turkey, international treaties to which our country is a party concerning human rights, and the Law on the Protection of Personal Data No. 6698 (“KVKK”) and other relevant legislation, and to ensure that data subjects can effectively exercise their rights. All personal data shared with AZEL Law & Consultancy will be processed lawfully, in a manner that is relevant to and proportionate to our activities and services.
- Definitions
The concepts of personal data, special categories of personal data and data processing used in this Clarification Text are used in accordance with the definitions made in the KVKK. The concept of “personal data” envisaged in the KVKK refers to any information relating to an identified or identifiable natural person; whereas the concept of “processing of personal data” refers to any operation performed on data, such as obtaining, recording, storing, preserving, altering, reorganising, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automatic means or by non-automatic means provided that it is part of any data recording system.
- Principles of Processing Personal Data
In accordance with Article 4 of the KVKK, personal data belonging to the data subject will be processed by the data controller AZEL Law & Consultancy for the purposes specified below, in compliance with the rules of lawfulness and fairness, being accurate and, where necessary, up-to-date, for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
- Processed Personal Data
AZEL Law & Consultancy processes your Identity Information (Name, Surname) and Contact Information (E-Mail Address, Message) for the purposes stated below, provided that it meets either the explicit consent of the data subject or any of the conditions for lawfulness.
- Purposes of Processing Personal Data
AZEL Law & Consultancy processes your personal data for the purposes listed below:
- The implementation of information security processes,
- Ensuring activities are carried out in compliance with legislation,
- Monitoring and execution of legal affairs,
- Carrying out communication activities,
- Carrying out/auditing of business activities,
- Organisation and event management,
- Carrying out storage and archiving activities,
- Execution of contract processes,
- Carrying out sponsorship activities,
- Execution of strategic planning activities,
- Tracking of requests and complaints,
- Execution of investment processes,
- Carrying out talent/career development activities,
- Notifying the competent authorities, institutions and organisations,
- Carrying out management activities,
It shall be processed in accordance with the personal data processing conditions specified in Articles 5 and 6 of the KVKK. In the event of any change in the personal data processing purposes, AZEL Law & Consultancy reserves the right to amend this Clarification Text at any time.
- Transfer of Your Personal Data
AZEL Law & Consultancy acts in accordance with the regulations stipulated in the KVKK regarding the transfer of personal data. Except for the exceptions set out in the legislation or below, your personal data is not transferred by us to other real persons or legal entities without the Explicit Consent of the Data Subject. In exceptional cases stipulated by the KVKK and other legislation, utmost care is taken to comply with the forms and limitations prescribed in the legislation during the transfer of personal data to authorised administrative or judicial institutions or private organisations.
Your personal data;
- to authorised official institutions and organisations and legally authorised private entities for the purpose of fulfilling a legal obligation;
- For the purpose of carrying out or ensuring the follow-up of judicial processes, personal data may be transferred to relevant judicial authorities, including lawyers, within the framework of the procedures and principles stipulated in the relevant legislation and in compliance with the personal data transfer conditions and purposes specified in Articles 8 and 9 of the KVKK.
- Method of Collection and Legal Basis for Personal Data/Special Category Personal Data
Your personal data can be obtained by semi-automated methods via the “Contact Form” available on our website.
The legal grounds for the processing of your personal data by AZEL Law & Consultancy are the exceptions to explicit consent specified in Article 5/2/c, 5/2/ç, 5/2/d, 5/2/e and 5/2/f of the PDPL. Your personal data is collected by AZEL Law & Consultancy for the purposes specified in Article 4 and Article 5 of this Clarification Text.
- Data Subject Rights
The data subject has the right, by applying to AZEL Law & Consultancy acting as the data controller, to: learn whether their personal data is being processed or not; request information thereon if their personal data has been processed; learn the purpose of the processing of their personal data and whether they are used in accordance with their purpose; be informed about the third parties to whom their personal data is transferred domestically or abroad; request the correction of their personal data in case of incomplete or incorrect processing; request the deletion or destruction of their personal data within the framework of the conditions set forth in Article 7 of the PDPL; request the notification of the operations carried out pursuant to Article 11(d) and Article 11(e) of the PDPL to third parties to whom their personal data has been transferred; object to the emergence of a result against the person themselves by analysing the processed data exclusively through automated systems; and demand the compensation of the damage in case of suffering damage due to the unlawful processing of personal data.
Pursuant to the Communique on the Procedures and Principles of Application to the Data Controller, applications to be made by you must contain your name, surname, signature if the application is in writing, secure electronic signature or mobile signature if it is electronic, Turkish Identity Number, residential address or workplace address for notification purposes, e-mail address for notification purposes, telephone number, and information regarding the subject of the request, if any. In order to exercise the rights mentioned above, the data subject is obliged to clearly and understandably state the matter requested in the application containing the explanation regarding the relevant right, and to attach the relevant information and documents to the application.
The aforementioned applications;
- to the address of AZEL Law & Consultancy at “Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA Çankaya/Ankara” in person, by hand, in writing,
- By means of a notary, by sending a request to the address of AZEL Hukuk & Danışmanlık “Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA Çankaya/Ankara”,
- It can be made to the email address info@azelhukuk.com via the email address previously notified by AZEL Law & Consultancy and registered in the system of AZEL Law & Consultancy.
AZEL LAW & CONSULTING - CLIENT INFORMATION NOTICE
INTRODUCTION
This Clarification Text for Clients (“Clarification Text”) has been prepared by AZEL (“AZEL Law & Consultancy”), located at and operating from Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA Çankaya/Ankara, in order to ensure that the personal data of our clients is processed in accordance with the relevant legislation, primarily the Constitution of the Republic of Turkey, international conventions to which our country is a party regarding human rights, and the Law No. 6698 on the Protection of Personal Data (“KVKK”), and to enable the data subjects whose data is processed to exercise their rights effectively. All personal data shared with AZEL Law & Consultancy shall be processed in a lawful manner, connected and proportional to our purposes of activity and services.
- Definitions
The concepts of personal data, special categories of personal data and data processing used in this Clarification Text are used in accordance with the definitions made in the KVKK. The concept of “personal data” envisaged in the KVKK refers to any information relating to an identified or identifiable natural person; whereas the concept of “processing of personal data” refers to any operation performed on data, such as obtaining, recording, storing, preserving, altering, reorganising, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automatic means or by non-automatic means provided that it is part of any data recording system.
- Principles of Processing Personal Data
In accordance with Article 4 of the KVKK, personal data belonging to the data subject will be processed by the data controller AZEL Law & Consultancy for the purposes specified below, in compliance with the rules of lawfulness and fairness, being accurate and, where necessary, up-to-date, for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
- Processed Personal Data
AZEL Law & Consultancy processes your Identity Information (Name Surname, Mother's and Father's Name, Gender Information, Date of Birth, Place of Birth, Photograph, Signature, Photocopy of Identity Card/TR Identity Card, Identity Card Serial and Sequence No, TR Identity No), Contact Information (Residence/Other Address Information, E-Mail Address, Home/Mobile Phone Number), Financial Information (IBAN Number), Criminal Convictions and Security Measures (Criminal Record, Information Regarding Criminal Conviction, Information Regarding Security Measures), Legal Transaction Information (Documents in Correspondence with Judicial Authorities, Information in the Case File), Visual and Audio Records (Photograph) for the purposes specified below, in the event that it satisfies either the explicit consent of the data subject or any of the grounds for lawfulness.
- Purposes of Processing Personal Data
AZEL Law & Consultancy processes your personal data for the purposes listed below:
- The implementation of information security processes,
- Carrying out Audit/Ethical Activities,
- The implementation of access rights,
- Ensuring activities are carried out in compliance with legislation,
- The execution of finance and accounting operations,
- Execution of processes related to commitment to the company/products/services,
- Monitoring and execution of legal affairs,
- Carrying out communication activities,
- Fulfilment of obligations arising from the contract of mandate and legislation,
- The execution of business continuity assurance activities,
- The carrying out and auditing of business activities,
- Carrying out after-sales support services for goods/services,
- Execution of goods/services production and operation processes,
- Management of client satisfaction and loyalty processes,
- Carrying out storage and archiving activities,
- Execution of contract processes,
- Execution of strategic planning activities,
- Tracking of requests and complaints,
- To manage processes related to payment transactions and other financial business and operations,
- Ensuring the security of data controller operations,
- Notifying the competent authorities, institutions and organisations,
- It will be processed for the purposes of carrying out management activities, in accordance with the personal data processing conditions specified in Articles 5 and 6 of the PDP Law.
Should there be any changes to the personal data processing purposes, AZEL Law & Consultancy reserves the right to amend this Clarification Text at any time.
- Transfer of Your Personal Data
AZEL Law & Consultancy acts in accordance with the regulations stipulated in the LPPD regarding the transfer of personal data. In exceptional cases stipulated by the LPPD and other legislation, maximum care is taken to comply with the form and limitations set out in the legislation during the transfer of personal data to authorised administrative or judicial institutions or private organisations.
AZEL Law & Consultancy does not transfer the personal data of its clients, processed in accordance with Law No. 6698, abroad.
Your personal data;
- to authorised official institutions and organisations and legally authorised private entities for the purpose of fulfilling a legal obligation;
- to the relevant judicial authorities, including lawyers, for the purpose of conducting or following up judicial proceedings;
- In order to maintain accounting records, to real or legal persons in charge of accounting;
- for the purpose of carrying out their payments to contracted banks; within the framework of the procedures and principles stipulated in the relevant legislation and in accordance with the personal data transfer conditions and purposes specified in Article 8 and Article 9 of the KVKK
will be able to be transferred accordingly.
- Method and Legal Basis for the Collection of Personal Data / Special Categories of Personal Data
Your personal data may be collected by non-automated methods, provided that they are part of a data recording system, through documents and all kinds of written documents transmitted to us by the Client themselves during the processes of establishing and executing the business relationship with AZEL Law & Consultancy, particularly via the physical delivery of documents, notifications from administrative and judicial authorities, and rarely via other communication channels. Your personal data is collected in accordance with the personal data processing conditions specified in the Law and in line with the legal grounds stated in this text.
The legal grounds for the processing of your personal data in question by AZEL Law & Consultancy are your explicit consent given pursuant to Article 5/1 of the PDP Law (KVKK), and the exceptions to explicit consent specified in Articles 5/2/a, 5/2/c, 5/2/ç, 5/2/e, and 5/2/f, as well as Article 6/3 of the PDP Law. Your personal data is collected by AZEL Law & Consultancy for the purposes specified in Articles 4 and 5 of this Clarification Text, in accordance with all kinds of legislation in force, primarily the Turkish Code of Obligations No. 6098, the Attorneys’ Law No. 1136, and the Turkish Commercial Code No. 6102, based on the stated legal grounds.
- Destruction of Data
AZEL Law & Consultancy retains your processed personal data for the periods stipulated by legislation. However, in the event that no specific period is laid down in the legislation regarding the retention period of your personal data; your personal data is retained for the period required for its processing in accordance with the practices of AZEL Law & Consultancy and commercial customs, bound up with the services offered by AZEL Law & Consultancy while processing that data, and following this period, only for the periods demonstrated to be necessary for the purpose of serving as evidence in potential legal disputes. Upon the expiry of the specified periods, pursuant to Article 7 of the KVKK (Personal Data Protection Law), your aforesaid personal data is deleted, destroyed or anonymised on the first destruction date.
- Data Subject Rights
Data subjects have the right, by applying to AZEL Law & Consultancy acting as the data controller, to: learn whether their personal data is being processed, request information thereof if it has been processed; learn the purpose of the processing of their personal data and whether they are used in accordance with such purpose; be informed about the third parties to whom their personal data is transferred domestically or abroad; request the rectification of their personal data in case of incomplete or incorrect processing; request the erasure, destruction or anonymisation of their personal data within the framework of the conditions stipulated in Article 7 of the PDP Law (KVKK); request notification of the operations carried out pursuant to Article 11(d) and Article 11(e) of the PDP Law to third parties to whom their personal data has been transferred; object to the occurrence of a result to the detriment of the person themselves by means of analysis of the processed data exclusively through automated systems; and demand compensation for the damage in case of suffering damage due to the unlawful processing of personal data.
Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, applications to be made by you must contain your name and surname, signature if the application is in writing, secure electronic signature or mobile signature if it is electronic, Turkish ID number, residential address or workplace address for notification purposes, e-mail address for notification purposes if any, telephone number, and information regarding the subject matter of the request. The data subject is obliged to clearly and understandably state the matter requested in the application containing the explanation regarding the relevant right in order to exercise the aforementioned rights, and to attach the relevant information and documents to the application.
The aforementioned applications;
- to the address of AZEL Hukuk & Danışmanlık at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA in person, by hand, in writing,
- by submitting a request through a notary public to the address of AZEL Hukuk & Danışmanlık, Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA,
- This can be done by sending it via email to info@azelhukuk.com.
For a third party to make a request on behalf of the data subject, there must be a notarised special power of attorney issued by the data subject in favour of the person who will make the application, specifically for this matter. In addition, the application must include identity and address information, and documents verifying identity must be appended to the application. Applications made by unauthorised third parties on behalf of someone else will not be taken into consideration. In order to exercise the rights mentioned above, the data subject must clearly and comprehensibly specify the matter requested in the application, which shall include explanations regarding the right they wish to exercise and utilise. Information and documents regarding the application must be attached to the application.
Within this scope, your requests properly submitted to AZEL Law & Consultancy will be concluded within thirty days at the latest. If the conclusion of your said requests requires an additional cost, a fee will be charged to the applicant by AZEL Law & Consultancy in accordance with the tariff determined by the Personal Data Protection Board (“Board”). However, in the event that your application is answered via a recording medium such as a CD or a flash drive by AZEL Law & Consultancy, a fee may be requested not exceeding the cost of the recording medium. AZEL Law & Consultancy may request necessary information and documents from you in order to determine whether you are the actual owner of the personal data subject to the request, and may direct questions to you regarding your application in order to clarify the matters stated in your application.
AZEL Law & Consultancy will notify you of its response to your request in writing or via electronic media. In accordance with Article 14 of the KVKK (Personal Data Protection Law), in the event that your application is rejected, you find the response provided by AZEL Law & Consultancy insufficient, or no response is given to your application within the statutory period, you may lodge a complaint with the Board within 30 (thirty) days from the date you learn of AZEL Law & Consultancy's response or, in the event of no response, from the expiry date of our response period, and in any event within 60 (sixty) days from the application date.
AZEL LAW & CONSULTANCY - SUPPLIER PRIVACY NOTICE
INTRODUCTION
This Supplier Privacy Notice (“Privacy Notice”) has been prepared by AZEL (“AZEL Law & Consultancy”), operating at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA Çankaya/Ankara, in order to ensure that the personal data of our Suppliers who have entered into a contractual or other commercial relationship with our Office is processed in compliance with the relevant legislation—primarily the Constitution of the Republic of Turkey, international conventions to which our country is a party regarding human rights, the Law on the Protection of Personal Data No. 6698 (“KVKK”), the Occupational Health and Safety Law No. 6331, and the Code of Obligations No. 6098—through automated and non-automated methods via documents and information shared with us for the purposes of creating accounting records, ensuring the performance of the contract, and conducting the commercial relationship, and to ensure that the data subjects whose data is processed can effectively exercise their rights. All personal data shared with AZEL Law & Consultancy shall be processed lawfully, connectedly, and proportionately with our activity and service purposes.
- Definitions
The concepts of personal data, special categories of personal data and data processing used in this Clarification Text are used in accordance with the definitions made in the KVKK. The concept of “personal data” envisaged in the KVKK refers to any information relating to an identified or identifiable natural person; whereas the concept of “processing of personal data” refers to any operation performed on data, such as obtaining, recording, storing, preserving, altering, reorganising, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automatic means or by non-automatic means provided that it is part of any data recording system.
- Principles of Processing Personal Data
In accordance with Article 4 of the KVKK, personal data belonging to the data subject will be processed by the data controller AZEL Law & Consultancy for the purposes specified below, in compliance with the rules of lawfulness and fairness, being accurate and, where necessary, up-to-date, for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
- Processed Personal Data
AZEL Law & Consultancy;
- Personal data of real person business partners/suppliers included in Identity Information (Name, Surname, Title, Turkish Identity Number, Tax Identification Number), Tax Office, Certificate of Activity, Tax Certificate, and bank account number information, Contact Information (Registered Electronic Mail [KEP] Address, phone, e-mail, address), Financial Information (Payment Information, Debt information, Invoice, self-employment receipt, Cheque, Promissory note and similar Negotiable instruments, IBAN Information)
- Personal data belonging to officials of corporate business partners/suppliers, namely Identity Information (Name, Surname, Turkish ID Number) and Contact Information (Telephone, e-mail, address), is processed for the purposes stated below and in accordance with Article 5/2 of the Personal Data Protection Law (KVKK).
- Purposes of Processing Personal Data
AZEL Law & Consultancy processes your personal data for the purposes listed below:
- The implementation of information security processes,
- Monitoring and execution of legal affairs,
- Execution of goods/services purchasing processes,
- Carrying out communication activities,
- The execution of business continuity assurance activities,
- The carrying out and auditing of business activities,
- Carrying out storage and archiving activities,
- Execution of contract processes,
- The execution of finance and accounting operations,
- Ensuring activities are carried out in compliance with legislation,
- Ensuring supply processes,
- Ensuring the security of movable property and resources,
- Ensuring the security of data controller operations,
- Notifying the competent authorities, institutions and organisations,
- It will be processed for the purposes of carrying out management activities, in accordance with the personal data processing conditions specified in Articles 5 and 6 of the PDP Law.
Should there be any changes to the personal data processing purposes, AZEL Law & Consultancy reserves the right to amend this Clarification Text at any time.
- Transfer of Your Personal Data
AZEL Law & Consultancy acts in accordance with the regulations stipulated in the LPPD regarding the transfer of personal data. In exceptional cases stipulated by the LPPD and other legislation, maximum care is taken to comply with the form and limitations set out in the legislation during the transfer of personal data to authorised administrative or judicial institutions or private organisations.
AZEL Law & Consultancy does not transfer Supplier personal data abroad, processed in accordance with Law No. 6698.
Your personal data;
- to authorised official institutions and organisations and legally authorised private entities for the purpose of fulfilling a legal obligation;
- to the relevant judicial authorities, including lawyers, for the purpose of conducting or following up judicial proceedings;
- In order to maintain accounting records, to real or legal persons in charge of accounting;
- For the purpose of making their payments, they may be transferred within the framework of the procedures and principles stipulated in the relevant legislation regarding contracted banks, and in accordance with the personal data transfer conditions and purposes specified in Article 8 and Article 9 of the KVKK.
- Method and Legal Basis for the Collection of Personal Data / Special Categories of Personal Data
Your personal data may be collected through non-automatic methods, provided that they are part of a data recording system, via documents and all kinds of written documentation submitted to us by the Supplier itself during the processes of establishing and executing a business relationship with AZEL Law & Consultancy, particularly through the physical delivery of documents, notifications received from administrative and judicial authorities, and rarely through other communication channels. Your personal data is collected in accordance with the personal data processing conditions specified in the Law and in line with the legal reasons stated in this text.
The legal grounds for the processing of your personal data in question by AZEL Law & Consultancy are your explicit consent given pursuant to Article 5/1 of the LPPD (Law on the Protection of Personal Data) and the exceptions to explicit consent specified in Articles 5/2/a, 5/2/c, 5/2/ç, 5/2/e and 5/2/f and Article 6/3 of the LPPD. Your personal data is collected by AZEL Law & Consultancy based on the specified legal grounds, in compliance with all kinds of legislation in force, primarily the Turkish Code of Obligations No. 6098 and the Turkish Commercial Code No. 6102, and for the purposes specified in Articles 4 and 5 of this Clarification Text.
- Destruction of Data
AZEL Law & Consultancy retains your processed personal data for the periods stipulated by legislation. However, in the event that no specific period is laid down in the legislation regarding the retention period of your personal data; your personal data is retained for the period required for its processing in accordance with the practices of AZEL Law & Consultancy and commercial customs, bound up with the services offered by AZEL Law & Consultancy while processing that data, and following this period, only for the periods demonstrated to be necessary for the purpose of serving as evidence in potential legal disputes. Upon the expiry of the specified periods, pursuant to Article 7 of the KVKK (Personal Data Protection Law), your aforesaid personal data is deleted, destroyed or anonymised on the first destruction date.
- Data Subject Rights
Data subjects have the right, by applying to AZEL Law & Consultancy acting as the data controller, to: learn whether their personal data is being processed, request information thereof if it has been processed; learn the purpose of the processing of their personal data and whether they are used in accordance with such purpose; be informed about the third parties to whom their personal data is transferred domestically or abroad; request the rectification of their personal data in case of incomplete or incorrect processing; request the erasure, destruction or anonymisation of their personal data within the framework of the conditions stipulated in Article 7 of the PDP Law (KVKK); request notification of the operations carried out pursuant to Article 11(d) and Article 11(e) of the PDP Law to third parties to whom their personal data has been transferred; object to the occurrence of a result to the detriment of the person themselves by means of analysis of the processed data exclusively through automated systems; and demand compensation for the damage in case of suffering damage due to the unlawful processing of personal data.
Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, applications to be made by you must contain your name and surname, signature if the application is in writing, secure electronic signature or mobile signature if it is electronic, Turkish ID number, residential address or workplace address for notification purposes, e-mail address for notification purposes if any, telephone number, and information regarding the subject matter of the request. The data subject is obliged to clearly and understandably state the matter requested in the application containing the explanation regarding the relevant right in order to exercise the aforementioned rights, and to attach the relevant information and documents to the application.
The aforementioned applications;
- to the address of AZEL Hukuk & Danışmanlık at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA in person, by hand, in writing,
- By submitting a request through a notary public to the address of AZEL Hukuk & Danışmanlık, Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA,
- This can be done by sending it via email to info@azelhukuk.com.
For a third party to make a request on behalf of the data subject, there must be a notarised special power of attorney issued by the data subject in favour of the person who will make the application, specifically for this matter. In addition, the application must include identity and address information, and documents verifying identity must be appended to the application. Applications made by unauthorised third parties on behalf of someone else will not be taken into consideration. In order to exercise the rights mentioned above, the data subject must clearly and comprehensibly specify the matter requested in the application, which shall include explanations regarding the right they wish to exercise and utilise. Information and documents regarding the application must be attached to the application.
Within this scope, your requests properly submitted to AZEL Law & Consultancy will be concluded within thirty days at the latest. If the conclusion of your said requests requires an additional cost, a fee will be charged to the applicant by AZEL Law & Consultancy in accordance with the tariff determined by the Personal Data Protection Board (“Board”). However, in the event that your application is answered via a recording medium such as a CD or a flash drive by AZEL Law & Consultancy, a fee may be requested not exceeding the cost of the recording medium. AZEL Law & Consultancy may request necessary information and documents from you in order to determine whether you are the actual owner of the personal data subject to the request, and may direct questions to you regarding your application in order to clarify the matters stated in your application.
AZEL Law & Consultancy will notify you of its response to your request in writing or via electronic media. In accordance with Article 14 of the KVKK (Personal Data Protection Law), in the event that your application is rejected, you find the response provided by AZEL Law & Consultancy insufficient, or no response is given to your application within the statutory period, you may lodge a complaint with the Board within 30 (thirty) days from the date you learn of AZEL Law & Consultancy's response or, in the event of no response, from the expiry date of our response period, and in any event within 60 (sixty) days from the application date.
AZEL LAW & CONSULTANCY - CLARIFICATION TEXT FOR VISITORS
INTRODUCTION
This Clarification Text for Visitors (“Clarification Text”) has been prepared by AZEL (“AZEL Law & Consultancy”), operating at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA, in order to ensure that the personal data of our visitors is processed in compliance with the relevant legislation, notably the Constitution of the Republic of Turkey, international conventions to which our country is a party regarding human rights, and the Law No. 6698 on the Protection of Personal Data (“KVKK”), and to enable the data subjects whose data is processed to effectively exercise their rights. All personal data shared with AZEL Law & Consultancy shall be processed lawfully, and in connection and proportion with our activities and service purposes.
- Definitions
The concepts of personal data, special categories of personal data and data processing used in this Clarification Text are used in accordance with the definitions made in the KVKK. The concept of “personal data” envisaged in the KVKK refers to any information relating to an identified or identifiable natural person; whereas the concept of “processing of personal data” refers to any operation performed on data, such as obtaining, recording, storing, preserving, altering, reorganising, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automatic means or by non-automatic means provided that it is part of any data recording system.
- Principles of Processing Personal Data
In accordance with Article 4 of the KVKK, personal data belonging to the data subject will be processed by the data controller AZEL Law & Consultancy for the purposes specified below, in compliance with the rules of lawfulness and fairness, being accurate and, where necessary, up-to-date, for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
- Processed Personal Data
AZEL Law & Consultancy processes your Transaction Security Information (IP Address, Other Traffic Data) for the purposes stated below, provided that it meets either the explicit consent of the data subject or any of the grounds for lawfulness.
- Purposes of Processing Personal Data
AZEL Law & Consultancy processes your personal data for the purposes listed below:
- The implementation of information security processes,
- Carrying out audit/ethics activities,
- Ensuring activities are carried out in compliance with legislation,
- Carrying out storage and archiving activities,
- Ensuring the security of data controller operations,
- Notifying the competent authorities, institutions and organisations,
- For the purposes of creating and tracking visitor records, they will be processed in accordance with the personal data processing conditions specified in Articles 5 and 6 of the PDPL. In the event of any changes to the personal data processing purposes, AZEL Law & Consultancy reserves the right to amend this Clarification Text at any time.
- Transfer of Your Personal Data
AZEL Law & Consultancy acts in accordance with the regulations stipulated in the KVKK regarding the transfer of personal data. Except for the exceptions set out in the legislation or below, your personal data is not transferred by us to other real persons or legal entities without the Explicit Consent of the Data Subject. In exceptional cases stipulated by the KVKK and other legislation, utmost care is taken to comply with the forms and limitations prescribed in the legislation during the transfer of personal data to authorised administrative or judicial institutions or private organisations.
Your personal data;
- to authorised official institutions and organisations and legally authorised private entities for the purpose of fulfilling a legal obligation;
- For the purpose of carrying out or ensuring the follow-up of judicial processes, personal data may be transferred to relevant judicial authorities, including lawyers, within the framework of the procedures and principles stipulated in the relevant legislation and in compliance with the personal data transfer conditions and purposes specified in Articles 8 and 9 of the KVKK.
- Method of Collection and Legal Basis for Personal Data/Special Category Personal Data
Your personal data can be collected by automated methods via the online website, cookies created by our website, third-party tracking cookies, and site usage measurement systems.
The legal grounds for the processing of your personal data by AZEL Law & Consultancy are the exceptions to explicit consent specified in Article 5/2/c, 5/2/ç, 5/2/d, 5/2/e and 5/2/f of the PDPL. Your personal data is collected by AZEL Law & Consultancy for the purposes specified in Article 4 and Article 5 of this Clarification Text.
- Data Subject Rights
The data subject has the right, by applying to AZEL Law & Consultancy acting as the data controller, to: learn whether their personal data is being processed or not; request information thereon if their personal data has been processed; learn the purpose of the processing of their personal data and whether they are used in accordance with their purpose; be informed about the third parties to whom their personal data is transferred domestically or abroad; request the correction of their personal data in case of incomplete or incorrect processing; request the deletion or destruction of their personal data within the framework of the conditions set forth in Article 7 of the PDPL; request the notification of the operations carried out pursuant to Article 11(d) and Article 11(e) of the PDPL to third parties to whom their personal data has been transferred; object to the emergence of a result against the person themselves by analysing the processed data exclusively through automated systems; and demand the compensation of the damage in case of suffering damage due to the unlawful processing of personal data.
Pursuant to the Communique on the Procedures and Principles of Application to the Data Controller, applications to be made by you must contain your name, surname, signature if the application is in writing, secure electronic signature or mobile signature if it is electronic, Turkish Identity Number, residential address or workplace address for notification purposes, e-mail address for notification purposes, telephone number, and information regarding the subject of the request, if any. In order to exercise the rights mentioned above, the data subject is obliged to clearly and understandably state the matter requested in the application containing the explanation regarding the relevant right, and to attach the relevant information and documents to the application.
The aforementioned applications;
- to the address of AZEL Law & Consultancy at “Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA” in person, by hand, in writing,
- By sending a request through a notary to AZEL Hukuk & Danışmanlık at the address “Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA”,
- It can be made to the email address info@azelhukuk.com via the email address previously notified by AZEL Law & Consultancy and registered in the system of AZEL Law & Consultancy.
AZEL LAW & CONSULTANCY FIRM - JOB APPLICANT INFORMATION NOTICE
INTRODUCTION
This Clarification Text for Employee Candidates (“Clarification Text”) has been prepared by AZEL (“AZEL Law & Consultancy”), operating at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA, in order to ensure that the personal data of our candidate employees is processed in accordance with the relevant legislation, notably the Constitution of the Republic of Turkey, international conventions to which our country is a party regarding human rights, and the Law No. 6698 on the Protection of Personal Data (“KVKK”), and to enable the data subjects whose data is processed to effectively exercise their rights. All personal data shared with AZEL Law & Consultancy will be processed lawfully, in connection with and proportionate to our activities and service purposes.
- Definitions
The concepts of personal data, special categories of personal data and data processing used in this Clarification Text are used in accordance with the definitions made in the KVKK. The concept of “personal data” envisaged in the KVKK refers to any information relating to an identified or identifiable natural person; whereas the concept of “processing of personal data” refers to any operation performed on data, such as obtaining, recording, storing, preserving, altering, reorganising, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automatic means or by non-automatic means provided that it is part of any data recording system.
- Principles of Processing Personal Data
In accordance with Article 4 of the KVKK, personal data belonging to the data subject will be processed by the data controller AZEL Law & Consultancy for the purposes specified below, in compliance with the rules of lawfulness and fairness, being accurate and, where necessary, up-to-date, for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
- Processed Personal Data
AZEL Law & Consultancy processes the personal data comprising Identity (Name Surname, Date of Birth, Photograph), Contact (Address Number, E-Mail Address, Phone Number), Professional Experience (Previous Work Experience, Diploma Information, Educational Status, In-Service Training Information, Information on Training/Courses/Exams/Certificates Received, Transcript Information, Foreign Language Information, Reference Information, Information Contained in the Résumé), Military Service Status (Discharge or Postponement Status) in accordance with the explicit consent of the data subject or the fulfilment of any of the lawful grounds for processing for the purposes specified below.
- Purposes of Processing Personal Data
AZEL Law & Consultancy processes your personal data for the purposes listed below:
- The implementation of information security processes,
- Carrying out Candidate Employee Selection and Placement Processes,
- Conducting the Application and Interview Processes of Job Candidates,
- Carrying out Audit/Ethical Activities,
- The implementation of access rights,
- Ensuring activities are carried out in compliance with legislation,
- Carrying out communication activities,
- Carrying out storage and archiving activities,
- Execution of contract processes,
- The implementation of the remuneration policy,
- Ensuring the security of data controller operations will be processed in accordance with the personal data processing conditions specified in Articles 5 and 6 of the KVKK.
Should there be any changes to the personal data processing purposes, AZEL Law & Consultancy reserves the right to amend this Clarification Text at any time.
- Transfer of Your Personal Data
AZEL Law & Consultancy acts in accordance with the regulations stipulated in the LPPD regarding the transfer of personal data. In exceptional cases stipulated by the LPPD and other legislation, maximum care is taken to comply with the form and limitations stipulated in the legislation during the transfer of personal data to authorized administrative or judicial institutions or private organizations.
AZEL Law & Consultancy may transfer the personal data of Employee Candidates, which it processes in accordance with Law No. 6698, abroad due to the use of Gmail or Outlook, based on the legal grounds that the transfer is necessary for the establishment or performance of a contract to be made between the data controller and another natural or legal person in favour of the data subject, and that the transfer of personal data is necessary for the establishment, exercise or protection of a right.
Your personal data;
- to authorised official institutions and organisations and legally authorised private entities for the purpose of fulfilling a legal obligation;
- For the purpose of carrying out or tracking judicial processes, personal data may be transferred to relevant judicial authorities, including lawyers, in accordance with the personal data transfer conditions and purposes specified in Articles 8 and 9 of the PDP Law.
- Method of Collection and Legal Basis for Personal Data/Special Category Personal Data
Your personal data can be obtained through non-automatic methods, provided that they are part of a data recording system, via documents and all kinds of written documents submitted to us by the job applicant themselves during the processes of establishing and executing a business relationship with AZEL Law & Consultancy, particularly via e-mail, physical delivery of documents, notifications from administrative and judicial authorities, and rarely through other communication channels. Your personal data is collected in accordance with the personal data processing conditions specified in the Law and in line with the legal grounds specified in this text.
The legal grounds for the processing of your personal data in question by AZEL Law & Consultancy are: the explicit consent given by you pursuant to Article 5/1 of the LPPD, and the exceptions to explicit consent specified in Articles 5/2/a, 5/2/c, 5/2/ç, 5/2/e and 5/2/f, and Article 6/3 of the LPPD. Your personal data are collected by AZEL Law & Consultancy for the purposes specified in Article 4 and Article 5 of this Clarification Text, in accordance with all kinds of legislation in force, primarily the Occupational Health and Safety Law No. 6331, the Labour Law No. 4857, the Turkish Code of Obligations No. 6098, the Social Insurance and General Health Insurance Law No. 5510, and the Occupational Health and Safety Law No. 6331 [Note: 331 is a typo in the original text referring to 6331], based on the stated legal grounds.
- Destruction of Data
AZEL Law & Consultancy retains your processed personal data for the periods determined by legislation. However, if no separate period is determined in the legislation regarding the retention period of your personal data; your personal data is retained for the period required by AZEL Law & Consultancy's practices and commercial customs in connection with the services offered by AZEL Law & Consultancy while processing that data, and after this period, only for the periods demonstrated to be necessary for the purpose of serving as evidence in potential legal disputes. Following the expiration of the specified periods, in accordance with Article 7 of the KVKK, your said personal data is deleted, destroyed or anonymised on the first disposal date.
- Data Subject Rights
Data subjects have the right, by applying to AZEL Law & Consultancy acting as the data controller, to: learn whether their personal data is being processed, request information thereof if it has been processed; learn the purpose of the processing of their personal data and whether they are used in accordance with such purpose; be informed about the third parties to whom their personal data is transferred domestically or abroad; request the rectification of their personal data in case of incomplete or incorrect processing; request the erasure, destruction or anonymisation of their personal data within the framework of the conditions stipulated in Article 7 of the PDP Law (KVKK); request notification of the operations carried out pursuant to Article 11(d) and Article 11(e) of the PDP Law to third parties to whom their personal data has been transferred; object to the occurrence of a result to the detriment of the person themselves by means of analysis of the processed data exclusively through automated systems; and demand compensation for the damage in case of suffering damage due to the unlawful processing of personal data.
Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, applications to be made by you must contain your name and surname, signature if the application is in writing, secure electronic signature or mobile signature if it is electronic, Turkish ID number, residential address or workplace address for notification purposes, e-mail address for notification purposes if any, telephone number, and information regarding the subject matter of the request. The data subject is obliged to clearly and understandably state the matter requested in the application containing the explanation regarding the relevant right in order to exercise the aforementioned rights, and to attach the relevant information and documents to the application.
The aforementioned applications;
- to the address of AZEL Hukuk & Danışmanlık at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA in person, by hand, in writing,
- By submitting a request through a notary public to the address of AZEL Law & Consultancy at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA,
- This can be done by sending it via registered electronic mail to info@azelhukuk.com.
For a third party to make a request on behalf of the data subject, there must be a notarised special power of attorney issued by the data subject in favour of the person who will make the application, specifically for this matter. In addition, the application must include identity and address information, and documents verifying identity must be appended to the application. Applications made by unauthorised third parties on behalf of someone else will not be taken into consideration. In order to exercise the rights mentioned above, the data subject must clearly and comprehensibly specify the matter requested in the application, which shall include explanations regarding the right they wish to exercise and utilise. Information and documents regarding the application must be attached to the application.
Within this scope, your requests properly submitted to AZEL Law & Consultancy will be concluded within thirty days at the latest. If the conclusion of your said requests requires an additional cost, a fee will be charged to the applicant by AZEL Law & Consultancy in accordance with the tariff determined by the Personal Data Protection Board (“Board”). However, in the event that your application is answered via a recording medium such as a CD or a flash drive by AZEL Law & Consultancy, a fee may be requested not exceeding the cost of the recording medium. AZEL Law & Consultancy may request necessary information and documents from you in order to determine whether you are the actual owner of the personal data subject to the request, and may direct questions to you regarding your application in order to clarify the matters stated in your application.
AZEL Law & Consultancy will notify you of its response to your request in writing or in electronic format. In accordance with Article 14 of the KVKK (Law on the Protection of Personal Data), in the event that your application is rejected, you find the response provided by AZEL Law & Consultancy insufficient, or no response is given to your application within the statutory period; you may lodge a complaint with the Board within 30 (thirty) days from the date you learn of AZEL Law & Consultancy's response or, in the event of no response, from the expiry date of our response period, and in any case within 60 (sixty) days from the date of application.
AZEL LAW & CONSULTANCY - EMPLOYEE PRIVACY NOTICE
INTRODUCTION
This Employee Clarification Text (“Clarification Text”); prepared by AZEL (“AZEL Law & Consultancy”), operating at the address Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA Çankaya/Ankara, in order to ensure that the personal data of our employees is processed in accordance with the relevant legislation, primarily the Constitution of the Republic of Turkey, international conventions to which our country is a party regarding human rights, and the Law No. 6698 on the Protection of Personal Data (“KVKK”), and to enable the data subjects whose data is processed to exercise their rights effectively. All personal data shared with AZEL Law & Consultancy will be processed lawfully, in connection with and proportionate to our activities and service purposes.
- Definitions
The concepts of personal data, special categories of personal data and data processing used in this Clarification Text are used in accordance with the definitions made in the KVKK. The concept of “personal data” envisaged in the KVKK refers to any information relating to an identified or identifiable natural person; whereas the concept of “processing of personal data” refers to any operation performed on data, such as obtaining, recording, storing, preserving, altering, reorganising, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automatic means or by non-automatic means provided that it is part of any data recording system.
- Principles of Processing Personal Data
In accordance with Article 4 of the KVKK, personal data belonging to the data subject will be processed by the data controller AZEL Law & Consultancy for the purposes specified below, in compliance with the rules of lawfulness and fairness, being accurate and, where necessary, up-to-date, for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
- Processed Personal Data
AZEL Law & Consultancy processes your Identity Information (Name Surname, Mother's and Father's Name, Gender Information, Date of Birth, Place of Birth, Photograph, Signature, Photocopy of Identity Card, Identity Card Serial and Sequence No, TR Identity Card Photocopy, TR Identity Number), Contact Information (Residence/Other Address Information, E-Mail Address, Home/Mobile Phone Number), Personnel Information (Detailed Population Registration Copy, Residence Certificate, SSI Registration Number, Photograph, Fixed/Indefinite Term Employment Contract and its appendices, if any, Military Discharge or Deferment Certificate, Entry-Exit Records, Employment Certificate, Personnel Job Application and Information Form, Curriculum Vitae, Disability Report, Occupational Safety Minutes, Signed Payroll and Account Slip, Release, SSI Service Breakdown, Written Defences, Disciplinary Investigation, Timekeeping Records, Performance Evaluation Reports, Minutes, Work Accident Notifications), Financial Information (IBAN Number, Bank Account Opening, Bank Passbook Photocopy, Salary Information), Criminal Conviction and Security Measures (Criminal Record, Information Regarding Criminal Conviction, Information Regarding Security Measures), Legal Transaction Information (Documents in Correspondence with Judicial Authorities, Information in the Lawsuit File), Professional Experience Information (Diploma Information, Transcript Information, In-Service Training Information, Compulsory Internship Information, Photocopies of Documents Regarding Corporate Training/Courses/Exams/Certificates Received, Advocacy License (Original or Certified), Previous Work Experience, Foreign Language Information), Transaction Security (Log records, Entry-Exit Records, IP Address, Target IP/Domain Name Records, Electronic Access/Activity Records), Visual and Audio Records (Photograph) for the purposes specified below, provided that it meets the explicit consent of the data subject or any of the grounds for lawfulness.
- Purposes of Processing Personal Data
AZEL Law & Consultancy processes your personal data for the purposes listed below:
- The implementation of information security processes,
- Execution of employee satisfaction and engagement processes,
- Fulfilling the obligations of employees arising from employment contracts and legislation,
- Administration of employee benefits and perks processes,
- Carrying out Audit/Ethical Activities,
- Carrying out educational activities,
- The implementation of access rights,
- Ensuring activities are carried out in compliance with legislation,
- The execution of finance and accounting operations,
- Carrying out assignment processes,
- Monitoring and execution of legal affairs,
- Carrying out communication activities,
- Administration of leave and annual leave processes,
- The carrying out and auditing of business activities,
- The execution of business continuity assurance activities,
- Execution of performance evaluation processes,
- Execution of risk management processes,
- Carrying out storage and archiving activities,
- Execution of contract processes,
- Execution of strategic planning activities,
- Tracking of requests and complaints,
- The implementation of the remuneration policy,
- Ensuring the security of data controller operations,
- Carrying out talent/career development activities,
- Notifying the competent authorities, institutions and organisations,
- It will be processed for the purposes of carrying out management activities, in accordance with the personal data processing conditions specified in Articles 5 and 6 of the PDP Law.
Personal data relating to criminal convictions and security measures are processed as it is mandatory for the fulfilment of legal obligations in the fields of employment, occupational health and safety, social security, social services and social assistance.
Should there be any changes to the personal data processing purposes, AZEL Law & Consultancy reserves the right to amend this Clarification Text at any time.
- Transfer of Your Personal Data
AZEL Law & Consultancy acts in accordance with the regulations stipulated in the LPPD regarding the transfer of personal data. In exceptional cases stipulated by the LPPD and other legislation, maximum care is taken to comply with the form and limitations stipulated in the legislation during the transfer of personal data to authorized administrative or judicial institutions or private organizations.
AZEL Law & Consultancy states that the transfer of employees’ personal data, which it processes in accordance with Law No. 6698, is: the transfer is necessary for the performance of a contract between the data subject and the data controller, or for the implementation of pre-contractual measures taken at the data subject’s request; the transfer is necessary for the conclusion or performance of a contract to be entered into between the data controller and another natural or legal person for the benefit of the data subject; and the transfer is necessary on the legal grounds of establishing, or the exercise or protection of a right; may transfer personal data abroad due to the use of Gmail, Outlook or Google Drive.
Your personal data;
- to authorised official institutions and organisations and legally authorised private entities for the purpose of fulfilling a legal obligation;
- to the contracted insurance companies in order to fulfil the obligation to ensure enrolment in the Compulsory Personal Pension Scheme;
- to the relevant judicial authorities, including lawyers, for the purpose of conducting or following up judicial proceedings;
- In order to maintain accounting records, to real or legal persons in charge of accounting;
- For the purpose of carrying out employee salary payments, personal data may be transferred to contracted banks in accordance with the personal data transfer conditions and purposes specified in Articles 8 and 9 of the KVKK.
- Method of Collection and Legal Basis for Personal Data/Special Category Personal Data
Your personal data can be obtained through non-automatic methods, provided that they are part of a data recording system, via documents and all kinds of written documents transmitted to us by the employee themselves during the establishment and execution processes of the business relationship with AZEL Law & Consultancy, particularly written contracts, personnel files, e-mails, physical delivery of documents, camera systems, notifications from administrative and judicial authorities, and rarely through other communication channels. Your personal data is collected in accordance with the personal data processing conditions specified in the Law and in line with the legal grounds specified in this text.
The legal grounds for the processing of your personal data in question by AZEL Law & Consultancy are: the explicit consent given by you pursuant to Article 5/1 of the LPPD, and the exceptions to explicit consent specified in Articles 5/2/a, 5/2/c, 5/2/ç, 5/2/e and 5/2/f, and Article 6/3 of the LPPD. Your personal data are collected by AZEL Law & Consultancy for the purposes specified in Article 4 and Article 5 of this Clarification Text, in accordance with all kinds of legislation in force, primarily the Occupational Health and Safety Law No. 6331, the Labour Law No. 4857, the Turkish Code of Obligations No. 6098, the Social Insurance and General Health Insurance Law No. 5510, and the Occupational Health and Safety Law No. 6331 [Note: 331 is a typo in the original text referring to 6331], based on the stated legal grounds.
- Destruction of Data
AZEL Law & Consultancy retains your processed personal data for the periods determined by legislation. However, if no separate period is determined in the legislation regarding the retention period of your personal data; your personal data is retained for the period required by AZEL Law & Consultancy's practices and commercial customs in connection with the services offered by AZEL Law & Consultancy while processing that data, and after this period, only for the periods demonstrated to be necessary for the purpose of serving as evidence in potential legal disputes. Following the expiration of the specified periods, in accordance with Article 7 of the KVKK, your said personal data is deleted, destroyed or anonymised on the first disposal date.
- Data Subject Rights
Data subjects have the right, by applying to AZEL Law & Consultancy acting as the data controller, to: learn whether their personal data is being processed, request information thereof if it has been processed; learn the purpose of the processing of their personal data and whether they are used in accordance with such purpose; be informed about the third parties to whom their personal data is transferred domestically or abroad; request the rectification of their personal data in case of incomplete or incorrect processing; request the erasure, destruction or anonymisation of their personal data within the framework of the conditions stipulated in Article 7 of the PDP Law (KVKK); request notification of the operations carried out pursuant to Article 11(d) and Article 11(e) of the PDP Law to third parties to whom their personal data has been transferred; object to the occurrence of a result to the detriment of the person themselves by means of analysis of the processed data exclusively through automated systems; and demand compensation for the damage in case of suffering damage due to the unlawful processing of personal data.
Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, applications to be made by you must contain your name and surname, signature if the application is in writing, secure electronic signature or mobile signature if it is electronic, Turkish ID number, residential address or workplace address for notification purposes, e-mail address for notification purposes if any, telephone number, and information regarding the subject matter of the request. The data subject is obliged to clearly and understandably state the matter requested in the application containing the explanation regarding the relevant right in order to exercise the aforementioned rights, and to attach the relevant information and documents to the application.
The aforementioned applications;
- to the address of AZEL Hukuk & Danışmanlık at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA in person, by hand, in writing,
- By submitting a request through a notary public to the address of AZEL Law & Consultancy at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA,
- This can be done by sending it via registered electronic mail to info@azelhukuk.com.
For a third party to make a request on behalf of the data subject, there must be a notarised special power of attorney issued by the data subject in favour of the person who will make the application, specifically for this matter. In addition, the application must include identity and address information, and documents verifying identity must be appended to the application. Applications made by unauthorised third parties on behalf of someone else will not be taken into consideration. In order to exercise the rights mentioned above, the data subject must clearly and comprehensibly specify the matter requested in the application, which shall include explanations regarding the right they wish to exercise and utilise. Information and documents regarding the application must be attached to the application.
Within this scope, your requests properly submitted to AZEL Law & Consultancy will be concluded within thirty days at the latest. If the conclusion of your said requests requires an additional cost, a fee will be charged to the applicant by AZEL Law & Consultancy in accordance with the tariff determined by the Personal Data Protection Board (“Board”). However, in the event that your application is answered via a recording medium such as a CD or a flash drive by AZEL Law & Consultancy, a fee may be requested not exceeding the cost of the recording medium. AZEL Law & Consultancy may request necessary information and documents from you in order to determine whether you are the actual owner of the personal data subject to the request, and may direct questions to you regarding your application in order to clarify the matters stated in your application.
AZEL Law & Consultancy will notify you of its response to your request in writing or via electronic media. In accordance with Article 14 of the KVKK (Personal Data Protection Law), in the event that your application is rejected, you find the response provided by AZEL Law & Consultancy insufficient, or no response is given to your application within the statutory period, you may lodge a complaint with the Board within 30 (thirty) days from the date you learn of AZEL Law & Consultancy's response or, in the event of no response, from the expiry date of our response period, and in any event within 60 (sixty) days from the application date.
AZEL LAW & CONSULTANCY FIRM - TRAINEE CANDIDATE PRIVACY NOTICE
INTRODUCTION
This Clarification Text for Trainee Candidates (“Clarification Text”) has been prepared by AZEL (“AZEL Law & Consultancy”), located at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA, operating with the tax identification number 9050374269, in order to ensure that the personal data of our candidate trainees is processed in accordance with the Constitution of the Republic of Turkey, international conventions to which our country is a party regarding human rights, and relevant legislation, primarily the Law No. 6698 on the Protection of Personal Data (“KVKK”), and that the data subjects whose data is processed can effectively exercise their rights. All shared personal data will be processed by AZEL Law & Consultancy in a lawful manner, connected and proportional to our activities and service purposes.
- Definitions
The concepts of personal data, special categories of personal data and data processing used in this Clarification Text are used in accordance with the definitions made in the KVKK. The concept of “personal data” envisaged in the KVKK refers to any information relating to an identified or identifiable natural person; whereas the concept of “processing of personal data” refers to any operation performed on data, such as obtaining, recording, storing, preserving, altering, reorganising, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automatic means or by non-automatic means provided that it is part of any data recording system.
- Principles of Processing Personal Data
In accordance with Article 4 of the KVKK, personal data belonging to the data subject will be processed by the data controller AZEL Law & Consultancy for the purposes specified below, in compliance with the rules of lawfulness and fairness, being accurate and, where necessary, up-to-date, for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
- Processed Personal Data
AZEL Law & Consultancy processes your personal data, specifically Identity (Name Surname, Date of Birth, Photograph), Contact (Address Number, E-Mail Address, Phone Number), Professional Experience (Previous Internship Experience, Diploma Information, Educational Status, Mandatory Internship Information, In-Service Training Information, Information on Education/Courses/Exams/Certificates Received, Transcript Information, Foreign Language Information, Reference Information, Information Contained in the CV), for the purposes stated below, provided that it meets the explicit consent of the data subject or any of the grounds for lawfulness.
- Purposes of Processing Personal Data
AZEL Law & Consultancy processes your personal data for the purposes listed below:
- The implementation of information security processes,
- Execution of intern selection and placement processes,
- Management of intern candidates' application and interview processes,
- Carrying out audit/ethics activities,
- The implementation of access rights,
- Ensuring activities are carried out in compliance with legislation,
- Carrying out communication activities,
- Carrying out storage and archiving activities,
- Ensuring the security of data controller operations will be processed in accordance with the personal data processing conditions specified in Articles 5 and 6 of the KVKK.
Should there be any changes to the personal data processing purposes, AZEL Law & Consultancy reserves the right to amend this Clarification Text at any time.
- Transfer of Your Personal Data
AZEL Law & Consultancy acts in accordance with the regulations stipulated in the LPPD regarding the transfer of personal data. In exceptional cases stipulated by the LPPD and other legislation, maximum care is taken to comply with the form and limitations stipulated in the legislation during the transfer of personal data to authorized administrative or judicial institutions or private organizations.
AZEL Law & Consultancy may transfer the personal data of Trainee Candidates processed in accordance with Law No. 6698 abroad due to the use of Gmail or Outlook, based on the legal grounds that the transfer is necessary for the establishment or performance of a contract to be made between the data controller and another natural or legal person for the benefit of the data subject, and that the transfer of personal data is necessary for the establishment, exercise or protection of a right.
Your personal data;
- to authorised official institutions and organisations and legally authorised private entities for the purpose of fulfilling a legal obligation;
- For the purpose of carrying out or tracking judicial processes, personal data may be transferred to relevant judicial authorities, including lawyers, in accordance with the personal data transfer conditions and purposes specified in Articles 8 and 9 of the PDP Law.
- Method of Collection and Legal Basis for Personal Data/Special Category Personal Data
Your personal data may be obtained by AZEL Law & Consultancy through non-automatic methods, provided that they are part of a data recording system, via documents and all kinds of written documents submitted to us by the intern candidate themselves during the establishment and execution processes of the business relationship, particularly via e-mail, physical delivery of documents, notifications from administrative and judicial authorities, and rarely through other communication channels. Your personal data is collected in accordance with the personal data processing conditions specified in the Law and in line with the legal reasons specified in this text.
The legal grounds for the processing of your personal data in question by AZEL Law & Consultancy are: the explicit consent given by you pursuant to Article 5/1 of the LPPD, and the exceptions to explicit consent specified in Articles 5/2/a, 5/2/c, 5/2/ç, 5/2/e and 5/2/f, and Article 6/3 of the LPPD. Your personal data are collected by AZEL Law & Consultancy for the purposes specified in Article 4 and Article 5 of this Clarification Text, in accordance with all kinds of legislation in force, primarily the Occupational Health and Safety Law No. 6331, the Labour Law No. 4857, the Turkish Code of Obligations No. 6098, the Social Insurance and General Health Insurance Law No. 5510, and the Occupational Health and Safety Law No. 6331 [Note: 331 is a typo in the original text referring to 6331], based on the stated legal grounds.
- Destruction of Data
AZEL Law & Consultancy retains your processed personal data for the periods determined by legislation. However, if no separate period is determined in the legislation regarding the retention period of your personal data; your personal data is retained for the period required by AZEL Law & Consultancy's practices and commercial customs in connection with the services offered by AZEL Law & Consultancy while processing that data, and after this period, only for the periods demonstrated to be necessary for the purpose of serving as evidence in potential legal disputes. Following the expiration of the specified periods, in accordance with Article 7 of the KVKK, your said personal data is deleted, destroyed or anonymised on the first disposal date.
- Data Subject Rights
Data subjects have the right, by applying to AZEL Law & Consultancy acting as the data controller, to: learn whether their personal data is being processed, request information thereof if it has been processed; learn the purpose of the processing of their personal data and whether they are used in accordance with such purpose; be informed about the third parties to whom their personal data is transferred domestically or abroad; request the rectification of their personal data in case of incomplete or incorrect processing; request the erasure, destruction or anonymisation of their personal data within the framework of the conditions stipulated in Article 7 of the PDP Law (KVKK); request notification of the operations carried out pursuant to Article 11(d) and Article 11(e) of the PDP Law to third parties to whom their personal data has been transferred; object to the occurrence of a result to the detriment of the person themselves by means of analysis of the processed data exclusively through automated systems; and demand compensation for the damage in case of suffering damage due to the unlawful processing of personal data.
Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, applications to be made by you must contain your name and surname, signature if the application is in writing, secure electronic signature or mobile signature if it is electronic, Turkish ID number, residential address or workplace address for notification purposes, e-mail address for notification purposes if any, telephone number, and information regarding the subject matter of the request. The data subject is obliged to clearly and understandably state the matter requested in the application containing the explanation regarding the relevant right in order to exercise the aforementioned rights, and to attach the relevant information and documents to the application.
The aforementioned applications;
- to the address of AZEL Hukuk & Danışmanlık at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA in person, by hand, in writing,
- By submitting a request through a notary public to the address of AZEL Law & Consultancy at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA,
- This can be done by sending it via registered electronic mail to info@azelhukuk.com.
For a third party to make a request on behalf of the data subject, there must be a notarised special power of attorney issued by the data subject in favour of the person who will make the application, specifically for this matter. In addition, the application must include identity and address information, and documents verifying identity must be appended to the application. Applications made by unauthorised third parties on behalf of someone else will not be taken into consideration. In order to exercise the rights mentioned above, the data subject must clearly and comprehensibly specify the matter requested in the application, which shall include explanations regarding the right they wish to exercise and utilise. Information and documents regarding the application must be attached to the application.
Within this scope, your requests properly submitted to AZEL Law & Consultancy will be concluded within thirty days at the latest. If the conclusion of your said requests requires an additional cost, a fee will be charged to the applicant by AZEL Law & Consultancy in accordance with the tariff determined by the Personal Data Protection Board (“Board”). However, in the event that your application is answered via a recording medium such as a CD or a flash drive by AZEL Law & Consultancy, a fee may be requested not exceeding the cost of the recording medium. AZEL Law & Consultancy may request necessary information and documents from you in order to determine whether you are the actual owner of the personal data subject to the request, and may direct questions to you regarding your application in order to clarify the matters stated in your application.
AZEL Law & Consultancy will notify you of its response to your request in writing or via electronic media. In accordance with Article 14 of the KVKK (Personal Data Protection Law), in the event that your application is rejected, you find the response provided by AZEL Law & Consultancy insufficient, or no response is given to your application within the statutory period, you may lodge a complaint with the Board within 30 (thirty) days from the date you learn of AZEL Law & Consultancy's response or, in the event of no response, from the expiry date of our response period, and in any event within 60 (sixty) days from the application date.
AZEL LAW & CONSULTANCY - TRAINEE PRIVACY NOTICE
INTRODUCTION
This Clarification Text for Interns (“Clarification Text”); has been prepared by AZEL (“AZEL Law & Consultancy”), operating at the address Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA, in order to ensure that the personal data of our interns is processed in accordance with the relevant legislation, notably the Constitution of the Republic of Turkey, international conventions to which our country is a party regarding human rights, and the Law No. 6698 on the Protection of Personal Data (“KVKK”), and to enable the data subjects whose data is processed to effectively exercise their rights. All personal data shared with AZEL Law & Consultancy shall be processed in a lawful manner, connected and proportional to our purposes of activity and services.
- Definitions
The concepts of personal data, special categories of personal data and data processing used in this Clarification Text are used in accordance with the definitions made in the KVKK. The concept of “personal data” envisaged in the KVKK refers to any information relating to an identified or identifiable natural person; whereas the concept of “processing of personal data” refers to any operation performed on data, such as obtaining, recording, storing, preserving, altering, reorganising, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automatic means or by non-automatic means provided that it is part of any data recording system.
- Principles of Processing Personal Data
In accordance with Article 4 of the KVKK, personal data belonging to the data subject will be processed by the data controller AZEL Law & Consultancy for the purposes specified below, in compliance with the rules of lawfulness and fairness, being accurate and, where necessary, up-to-date, for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
- Processed Personal Data
AZEL Law & Consultancy processes your Identity Information (Name Surname, Turkish ID No, Photograph, Signature, Photocopy of Turkish ID Card, Place of Birth, Date of Birth, Gender, Bar Association Registration No), Contact Information (Address Information, E-Mail Address, Home/Mobile Phone No), Personnel Information (Compulsory Internship Information, Education Information, CV, Transcript Information), Legal Transaction Information (Documents in Correspondence with Administrative Authorities), Professional Experience Information (Diploma Information, Transcript Information, Education Information, Compulsory Internship Information, Photocopies of Documents Regarding Corporate Training/Courses/Exams/Certificates Received, Previous Internship Experience, Foreign Language Information), Transaction Security (Log records, Check-in/Check-out Records, IP Address, Target IP/Domain Name Records, Electronic Access/Activity Records), Visual and Audio Records (Photograph) for the purposes specified below, provided that it meets the explicit consent of the data subject or any of the grounds for lawfulness.
- Purposes of Processing Personal Data
AZEL Law & Consultancy processes your personal data for the purposes listed below:
- The implementation of information security processes,
- Execution of intern selection and placement processes,
- Execution of intern candidates' application processes,
- Carrying out audit/ethics activities,
- Carrying out educational activities,
- The implementation of access rights,
- Ensuring activities are carried out in compliance with legislation,
- Carrying out assignment processes,
- Monitoring and execution of legal affairs,
- Carrying out communication activities,
- The carrying out and auditing of business activities,
- The execution of business continuity assurance activities,
- Execution of performance evaluation processes,
- Carrying out storage and archiving activities,
- Ensuring the security of data controller operations,
- Carrying out talent/career development activities,
- Notifying the competent authorities, institutions and organisations,
- It will be processed for the purposes of carrying out management activities, in accordance with the personal data processing conditions specified in Articles 5 and 6 of the PDP Law.
Should there be any changes to the personal data processing purposes, AZEL Law & Consultancy reserves the right to amend this Clarification Text at any time.
- Transfer of Your Personal Data
AZEL Law & Consultancy acts in accordance with the regulations stipulated in the LPPD regarding the transfer of personal data. In exceptional cases stipulated by the LPPD and other legislation, maximum care is taken to comply with the form and limitations stipulated in the legislation during the transfer of personal data to authorized administrative or judicial institutions or private organizations.
AZEL Law & Consultancy may transfer the personal data of interns processed in accordance with Law No. 6698 abroad due to the use of Gmail, Outlook or Google Drive, based on the legal grounds that the transfer is necessary for the performance of a contract between the data subject and the data controller or for the implementation of pre-contractual measures taken upon the request of the data subject, that the transfer is necessary for the establishment or performance of a contract to be concluded between the data controller and another natural or legal person in favour of the data subject, and that the transfer of personal data is necessary for the establishment, exercise or defence of a legal right.
Your personal data;
- to authorised official institutions and organisations and legally authorised private entities for the purpose of fulfilling a legal obligation;
- For the continuity of the traineeship process, to the affiliated bar association;
- In order to carry out or monitor judicial processes, it may be transferred to the relevant judicial authorities in accordance with the personal data transfer conditions and purposes specified in Articles 8 and 9 of the PDPL.
- Method of Collection and Legal Basis for Personal Data/Special Category Personal Data
Your personal data may be obtained through non-automatic methods, provided that they are part of a data recording system, via documents and all kinds of written documents submitted to us by the intern themselves during the establishment and execution processes of the employment relationship with AZEL Law & Consultancy, particularly via e-mail, physical delivery of documents, notifications from administrative and judicial authorities, and rarely through other communication channels. Your personal data is collected in accordance with the personal data processing conditions specified in the Law and in line with the legal grounds specified in this text.
The legal grounds for the processing of your personal data in question by AZEL Law & Consultancy are: the explicit consent given by you pursuant to Article 5/1 of the LPPD, and the exceptions to explicit consent specified in Articles 5/2/a, 5/2/c, 5/2/ç, 5/2/e and 5/2/f, and Article 6/3 of the LPPD. Your personal data are collected by AZEL Law & Consultancy for the purposes specified in Article 4 and Article 5 of this Clarification Text, in accordance with all kinds of legislation in force, primarily the Occupational Health and Safety Law No. 6331, the Labour Law No. 4857, the Turkish Code of Obligations No. 6098, the Social Insurance and General Health Insurance Law No. 5510, and the Occupational Health and Safety Law No. 6331 [Note: 331 is a typo in the original text referring to 6331], based on the stated legal grounds.
- Destruction of Data
AZEL Law & Consultancy retains your processed personal data for the periods determined by legislation. However, if no separate period is determined in the legislation regarding the retention period of your personal data; your personal data is retained for the period required by AZEL Law & Consultancy's practices and commercial customs in connection with the services offered by AZEL Law & Consultancy while processing that data, and after this period, only for the periods demonstrated to be necessary for the purpose of serving as evidence in potential legal disputes. Following the expiration of the specified periods, in accordance with Article 7 of the KVKK, your said personal data is deleted, destroyed or anonymised on the first disposal date.
- Data Subject Rights
Data subjects have the right, by applying to AZEL Law & Consultancy acting as the data controller, to: learn whether their personal data is being processed, request information thereof if it has been processed; learn the purpose of the processing of their personal data and whether they are used in accordance with such purpose; be informed about the third parties to whom their personal data is transferred domestically or abroad; request the rectification of their personal data in case of incomplete or incorrect processing; request the erasure, destruction or anonymisation of their personal data within the framework of the conditions stipulated in Article 7 of the PDP Law (KVKK); request notification of the operations carried out pursuant to Article 11(d) and Article 11(e) of the PDP Law to third parties to whom their personal data has been transferred; object to the occurrence of a result to the detriment of the person themselves by means of analysis of the processed data exclusively through automated systems; and demand compensation for the damage in case of suffering damage due to the unlawful processing of personal data.
Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, applications to be made by you must contain your name and surname, signature if the application is in writing, secure electronic signature or mobile signature if it is electronic, Turkish ID number, residential address or workplace address for notification purposes, e-mail address for notification purposes if any, telephone number, and information regarding the subject matter of the request. The data subject is obliged to clearly and understandably state the matter requested in the application containing the explanation regarding the relevant right in order to exercise the aforementioned rights, and to attach the relevant information and documents to the application.
The aforementioned applications;
- to the address of AZEL Hukuk & Danışmanlık at Aziziye Mah. Kuloğlu Sk. No:27/1 Çankaya/ANKARA in person, by hand, in writing,
- By submitting a request through a notary public to the address of AZEL Law & Consultancy at Aziziye Mah. Kuloğlu Sk. No:27/ Çankaya/Ankara,
- This can be done by sending it via registered electronic mail to info@azelhukuk.com.
For a third party to make a request on behalf of the data subject, there must be a notarised special power of attorney issued by the data subject in favour of the person who will make the application, specifically for this matter. In addition, the application must include identity and address information, and documents verifying identity must be appended to the application. Applications made by unauthorised third parties on behalf of someone else will not be taken into consideration. In order to exercise the rights mentioned above, the data subject must clearly and comprehensibly specify the matter requested in the application, which shall include explanations regarding the right they wish to exercise and utilise. Information and documents regarding the application must be attached to the application.
Within this scope, your requests properly submitted to AZEL Law & Consultancy will be concluded within thirty days at the latest. If the conclusion of your said requests requires an additional cost, a fee will be charged to the applicant by AZEL Law & Consultancy in accordance with the tariff determined by the Personal Data Protection Board (“Board”). However, in the event that your application is answered via a recording medium such as a CD or a flash drive by AZEL Law & Consultancy, a fee may be requested not exceeding the cost of the recording medium. AZEL Law & Consultancy may request necessary information and documents from you in order to determine whether you are the actual owner of the personal data subject to the request, and may direct questions to you regarding your application in order to clarify the matters stated in your application.
AZEL Law & Consultancy will notify you of its response to your request in writing or via electronic media. In accordance with Article 14 of the KVKK (Personal Data Protection Law), in the event that your application is rejected, you find the response provided by AZEL Law & Consultancy insufficient, or no response is given to your application within the statutory period, you may lodge a complaint with the Board within 30 (thirty) days from the date you learn of AZEL Law & Consultancy's response or, in the event of no response, from the expiry date of our response period, and in any event within 60 (sixty) days from the application date.