PDPP

Personal Data Protection Policy

This policy explains the principles of HUQQA GIDA İŞLETMELERİ SAN. ve TİC. A.Ş. (hereinafter referred to as “HUQQA”) regarding the processing of personal data that should be known by real persons whose personal data we process, such as suppliers, visitors and users of websites (https://www.huqqa.com, https://themarketbosphorus.com, https://qurabiye.com).

Definitions

Within the scope of this policy;

HUQQA: HUQQA GIDA İŞLETMELERİ SAN. ve TİC. A.Ş., the owner of the Sites
Data subject/real person: Personal data subject

Recording medium: Any medium containing personal data that is fully or partially automated or processed non-automatically, provided that it is part of any data recording system
Site: the websites located at huqqa.com, themarketbosphorus.com and/or qurabiye.com
Data Processor: The natural or legal person who processes personal data on behalf of the data controller based on the authorization granted by the data controller.

Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system
Law No. 5651: Law on the Regulation of Publications on the Internet and Combating Crimes Committed Through These Publications

Law No. 6698 / KVKK: Refers to the Law on the Protection of Personal Data
Obtaining and Processing Your Personal Data

1. Processing Personal Data of Website Users (Online Visitors), WIFI Service Users and Call Center Users

1.1. Processing Personal Data of Website Users (Online Visitors)

In order to make requests and suggestions, users who use the Site; They can transmit information such as name, surname, e-mail, e-mail, telephone, gender, date of birth, address, message, sector and subject of the form by filling out the form on the “Contact” page on the link at huqqa.com, themarketbosphorus.com and/or qurabiye.com.
Users accept that they share this personal data with the Website completely of their own volition and that this data is requested only for the evaluation of the requests and suggestions they submit.
In addition, traffic information of users visiting the Website is processed in accordance with Law No. 5651.

1.2. Processing of Personal Data of WIFI Service Users

HUQQA processes mobile phone number and traffic information from its visitors who physically visit its campus and want to use WIFI in order to provide this service and to comply with the Law No. 5651 and the relevant Secondary legislation.

1.3. Processing Personal Data of Call Center Users

Personal data of users who call HUQQA are collected and maintained by HUQQA. Personal data in the form of name, surname, telephone and e-mail address are received from users who call HUQQA during the call. These data are used for the planning and execution of the activities necessary to carry out the necessary work to benefit you from the products and services offered by our company and to carry out the relevant business processes, to plan and execute the activities necessary for the recommendation and promotion of the products and services offered by the company by customizing them according to your tastes, usage habits and needs, It is processed for the purposes of carrying out the necessary work by our relevant business units for the realization of the commercial activities carried out by our company and the execution of related business processes, planning and execution of our company’s commercial and / or business strategies, ensuring the legal, strategic and commercial business security of our company and related persons who have a business relationship with our company.

Your personal data that you have shared by calling HUQQA are collected and stored by our company in order to process your requests, suggestions and complaints and to inform you about the result of the process and to improve the services and products offered in this context.

2. Processing of Personal Data in Procurement Processes

HUQQA processes personal data belonging to natural person suppliers, supplier employees and/or supplier officials and personal data belonging to natural persons, legal entity employees and/or officials to whom HUQQA supplies products, services or goods for the purpose of monitoring and execution of product, service or goods supply processes.

2.1. Personal data processed in procurement processes

HUQQA processes the following personal data within the scope of procurement processes:
Identity information such as name, surname, Turkish ID number; financial information such as bank information; contact information such as address, e-mail, mobile phone, special categories of personal data such as photographs, signatures in documents such as signature declaration, circulars, etc. regarding the real person supplier and/or supplier recipient.

Identity information such as name, surname, Turkish ID number regarding the supplier and / or supply area authority; special quality personal data such as photograph, signature in documents such as power of attorney / circular; contact information such as address, e-mail, mobile phone
Identity information such as name, surname, Turkish ID number; personal information such as SSI payroll, OHS documents; special categories of personal data such as health report, criminal record; educational/professional experience and experience information such as educational status, certificates; financial information such as bank details; contact information such as address, e-mail, mobile phone

2.2. Purpose of Processing Personal Data in Procurement Processes

Fulfillment of obligations arising from legislation such as Occupational Health and Safety Law, SSI, Labor Law, Turkish Commercial Code, Tax Procedure Law,

Follow-up and execution of contract processes for the supply of goods, products or services,
Ensuring compliance with corporate company rules.

2.3. Methods of Collection and Processing of Personal Data of the Supplier and/or the Supplier

The supplier and/or the supplier’s authorized person, the supplier and/or the supplier’s employee or the natural person supplier and/or the supplier itself,

Documents such as Circular/Power of Attorney,

Communication channels such as e-mail, telephone, website,

Contract,

Reference Check Form.

3. Processing Personal Data of Physical Visitors

3.1. Personal data of natural persons who physically visit HUQQA premises

HUQQA takes video recordings with cameras inside and outside the building to ensure the safety of its employees and visitors. Visitors are informed that camera recordings are made inside the building.

3.2. Personal Data of Natural Persons Physically Visiting the Restaurants

HUQQA belongs to real people who visit restaurants;
Name and surname information,
Phone numbers,
Payment information,
Image recording

HUQQA processes personal data in the form of personal data/special categories of personal data.

HUQQA takes video recordings with cameras inside and outside the building in order to ensure the safety of its employees and visitors. Visitors are informed that camera recordings are made inside the building.

3.3. Purpose of Processing Personal Data of Visitors

HUQQA processes personal data of persons visiting HUQQA head office for the following purposes:
Ensuring Venue Security,

Obtaining identity information and documents in accordance with the applicable legislation,
Issuing visitor entrance cards and creating visitor numbers,

Keeping a record of visit entry and exit times,

Creating a weapon surrender report for visitors arriving with weapons,

Sharing the interior and exterior sketch of the building and necessary security information with the visitor card.

Planning and execution of emergency management processes (terrorism, fire),

To perform security screening of people/products coming to the building,

Notify law enforcement in the event of a crime or violation of the law,

HUQQA uses the personal data of people who visit restaurants;

To confirm and plan reservations,

To ensure invoice issuance,

Ensuring safety,

is functioning for its own purposes.

3.3. Methods of Collection and Processing of Personal Data of Visitors

Official identity documents of the visitor (Turkish ID card, driver’s license, passport, lawyer ID card, etc.)
CCTV footage,

Booking requests by phone, through QFB applications,

3.4. Ensuring the Security of Visitors’ Personal Data and Personal Data Sharing

Both identity information and CCTV records of visitors are kept in systems that are only accessible to authorized persons. These personal data can be shared with public institutions and organizations that are legally authorized to request the data upon request.

4. Processing Personal Data of Social Responsibility Project Participants and Training Participants

4.1. In social responsibility projects and trainings organized by HUQQA, the personal data of project partners, project participants and training participants (such as volunteer employees, parents, students) are as follows:

Identity information
Contact info
Education information
Financial Information

4.2. Purpose of Processing Personal Data of Project Partner, Project Participants and Training Participants
To increase the awareness of the company,

Creating social benefit and awareness,

Planning and execution of corporate communication activities,

Event management,

Planning and execution of social responsibility and/or civil society activities,

Planning and execution of sponsorship activities,

Fulfillment of the Company’s legal obligations.

4.3. Methods of Collection and Processing of Personal Data of Project Partner, Project Participants and Training Participants

This personal data is collected from the project partner and/or project participants and/or training participants themselves on a project and training basis.

Security and Transfer of Your Personal Data and Exercise of Your Rights on Your Personal Data
All personal data you have shared with us will be stored confidentially in the database at HUQQA in accordance with Article 12 of the Law No. 6698 on the Protection of Personal Data and will not be shared with third parties for commercial purposes.

HUQQA takes at least the following measures to ensure the security of the personal data it processes, to prevent unlawful access and to prevent unlawful data processing:

It takes hashing, encryption, transaction recording, access management and physical security

Measures to ensure that information systems hosting personal data are protected against unauthorized access and unlawful data processing.

The network on which the website and all systems hosting personal data are located is protected by firewall.

HUQQA stores personal data of online and physical visitors in accordance with the legislation and may share it with relevant public institutions and organizations upon request. Personal data relating to suppliers and/or procurement recipients may be shared with the companies and affiliates within HUQQA and also with the relevant public institutions in relation to the goods, products or services provided. Personal data relating to the participants and/or project partners of social responsibility projects organized by HUQQA may be shared in printed, visual and social media based on the explicit consent of the relevant person.

Your Rights on Your Personal Data

The rights you have in accordance with Article 11 of Law No. 6698 on your personal data that you have shared with us within the scope of the purposes and methods of processing personal data specified in this Personal Data Protection Policy are as follows:

To learn whether personal data is processed or not,

Request information if their personal data has been processed,

To learn the purpose of processing personal data and whether they are used for their intended purpose,
To know the third parties to whom personal data is transferred domestically or abroad,

To request correction of personal data in case of incomplete or incorrect processing,

6698 No. 6698 and other relevant provisions of the law and other relevant provisions, but to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear,

To request notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data are transferred,

To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,

In case of damage due to unlawful processing of personal data, to demand the compensation of the damage.

In order to exercise these rights, you can always contact us using the “Application Form” on our website and the methods specified in this form.

Keeping Your Personal Data Accurate and Up-to-Date

The relevant groups of persons whose personal data we process have acknowledged and declared that they are aware that the accuracy and timeliness of the personal data they share through the Website and / or provided by themselves, received due to the contractual relationship, is important in terms of their ability to exercise the rights they have on their personal data in terms of KVKK and other relevant legislation, and that the responsibility arising from providing incorrect information will be entirely their own.

Personal Data Retention Period

The retention period of personal data regarding online visitors is 2 years in accordance with Law No. 5651. The retention period for CCTV records of physical visitors is 90 days. Personal data related to identity information is stored within the framework of the periods stipulated in the relevant legislation. Personal data regarding suppliers and/or suppliers are stored for 10 years after the termination of the legal relationship in accordance with the legislation.

Deletion, Destruction or Anonymization of Your Personal Data

Your personal data processed for the purposes specified in this Personal Data Protection Policy will continue to be anonymized and used by us when the purpose of processing is no longer required according to Art. 7/f.1 of Law No. 6698 and when the periods determined by the Laws expire according to Art. 17 and Art. 138 of the Turkish Penal Code.

When the retention periods stipulated in the relevant legislation or required by the purpose of processing expire, during the 6-month period foreseen for periodic destruction; HUQQA anonymizes the personal data it processes from the anonymization methods specified in the Guidelines on Deletion, Destruction or Anonymization of Personal Data published by the Personal Data Protection Board, using one or more techniques that are most appropriate to its business processes and activities and continues to use the data in this way.

Changes and Updates to the Policy

HUQQA may make changes or updates to this Policy in line with legal regulations and Company Policy. The relevant persons are informed about the new Policy text reflecting all these changes and updates via the website.

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