ABOUT THE PROCESSING OF PERSONAL DATA CLARIFICATION TEXT
As Sungur Law Firm (hereinafter referred to as “Sungur Law”, “We”), we attach importance to the protection of private life and confidentiality of personal data, keep the personal data we obtain from real persons confidential within the scope of our activities, and take all kinds of technical and administrative measures to protect personal data and ensure data security.
In this context, we would like to inform you, as visitors to our website and our business partners, clients and prospective clients, about the processing of your personal data in accordance with the Law No. 6698 on the Protection of Personal Data (“Law No. 6698”) and related legislation, as Sungur Law, as the data controller.
1) General Principles Regarding the Processing of Personal Data
While Sungur Law carries out personal data processing activities, it is listed in Article 4 of the Law No. 6698;
- Compliance with the law and good faith,
- Being accurate and up to date when necessary,
- Processing for specific, explicit and legitimate purposes,
- Being relevant, limited and proportionate to the purpose for which they are processed,
- It complies with the principles of retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
According to the Law No. 6698, data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are sensitive personal data.
Sungur Law takes additional measures stipulated by the Law No. 6698 and the Personal Data Protection Board in the processing of special categories of personal data.
2) Terms of Processing of Personal Data
Sungur Law processes personal data with explicit consent or in accordance with other data processing conditions in the following cases:
- Explicitly stipulated in the law,
- It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his/her consent due to actual impossibility or whose consent is not legally valid,
- Provided that it is directly related to the conclusion or performance of a contract, it is necessary to process personal data of the parties to the contract,
- It is mandatory for the data controller to fulfill its legal obligation,
- It has been made public by the person concerned,
- Data processing is mandatory for the establishment, exercise or protection of a right,
- Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
3) Purposes of Processing Personal Data
Sungur Law processes personal data for the purposes listed below within the framework of the legal reasons set out in Articles 5 and 6 of the Law No. 6698:
- Data processing is necessary for the protection of our legitimate interests, provided that it does not harm your fundamental rights and freedoms within the scope of Article 5/2 (f) of the Law No. 6698, in order to classify and evaluate the IP addresses of our visitors who visit our website, user data, for website analytics and improvements, and to understand how the features and functions of the website are used in order to improve the user experience,
- The personal data of our clients or the personal data of the representatives/officials/employees of our corporate clients are directly related to the establishment or performance of a contract in accordance with Article 5/2 (c) of the Law No. 6698 within the framework of the consultancy service or litigation processes we carry out with our clients, for the purposes of providing services to our clients and representing our clients, establishing a power of attorney relationship with our clients or concluding a service contract with our clients and performing duties,
- In addition, the personal data of our clients or the personal data of the representatives/officials/employees of our corporate clients, for the purpose of managing our business relations with our clients, communicating with them, informing our clients about legal developments and innovations, and provided that data processing is necessary for the protection of our legitimate interests, provided that it does not harm your fundamental rights and freedoms in accordance with Article 5/2 (f) of the Law No. 6698,
- In addition, personal data is necessary for the purpose of managing our relations with our business partners and suppliers, establishing communication, informing them of legal developments and innovations, and for the protection of our legitimate interests within the scope of Article 5/2 (f) of the Law No. 6698,
- The personal data of prospective clients, representatives/officials/employees of prospective corporate clients who request an offer to receive services from us; personal data of the relevant persons, stakeholders, academicians and colleagues that we meet at events or obtain from publicly available sources in accordance with the law, are processed for the management of communication within the scope of the software we use, to communicate with these persons and to inform these persons about legal innovations and developments and events, for the legal reasons that data processing is necessary for the protection of our legitimate interests, provided that it does not harm fundamental rights and freedoms within the scope of Article 5/2(f) of the Law No. 6698.
If the processing activity carried out for the aforementioned purposes does not meet any of the other data processing conditions stipulated under the Law No. 6698, Sungur Law obtains explicit consent from the relevant person regarding the relevant data processing process.
In addition, our website contains links to some of our social media accounts. These social networks may also collect and process your personal data. We have no control over this collected data and data processing activities. If you access such social media accounts, we encourage you to review the privacy statements and terms of use published by the relevant social media provider organizations.
In addition, the personal data of our website visitors, clients, business partners, prospective clients and stakeholders may be disclosed to the official authorities without your explicit consent, if requested by the official authorities in accordance with the relevant legislation and in cases where disclosure to the official authorities is required in accordance with the provisions of the mandatory legislation in force. It may also be possible to use the personal data of our website visitors, clients, business partners, client candidates and stakeholders to the extent necessary in relation to a legal dispute or potential disputes and to share them with courts and other authorized institutions and organizations. In this context, personal data may be processed without your explicit consent within the scope of Article 5/2 (ç) of the Law No. 6698 in order to fulfill our legal obligations and within the scope of Article 5/2 (e) of the Law No. 6698 in order to establish or protect our rights.
4) Transfer of Personal Data
Only if it is necessary to fulfill the above-mentioned purposes of processing personal data, your personal data you transmit to us or your personal data obtained by us may be shared with third party companies and authorized public institutions and organizations from which we receive services / support / consultancy domestically within the scope of fulfilling the above purposes.
Your personal data may be shared with the competent authorities within the scope of requests from the authorities authorized to request your information within the framework of the legislation and in case of disputes.
Our computer systems and infrastructures are kept in Turkey and transfer of your personal data abroad is not possible as a rule.
5) Collection of Personal Data
Your personal data is collected verbally, in writing or electronically, through documents and information that you will transmit to us electronically or physically, by automated or non-automated means.
6) Storage and Destruction of Personal Data
Pursuant to the Law No. 6698, personal data are kept accurate and up to date, and retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed. This period is determined separately for each category of personal data, and after the expiration of this period, the relevant personal data are deleted, destroyed or anonymized at the end of the periodic destruction periods determined in accordance with the Regulation on Deletion, Destruction or Anonymization of Personal Data.
When the relevant persons request the deletion or destruction of their personal data by applying to us, Sungur Hukuk;
- Deletes, destroys or anonymizes the personal data subject to the request if all the conditions for processing personal data have disappeared. Finalizes the request of the data subject within thirty days at the latest and informs the data subject.
- If all the conditions for processing personal data have disappeared and the personal data subject to the request have been transferred to third parties, it notifies the third party of this situation; ensures that the necessary actions are taken before the third party.
- If all the conditions for processing personal data have not been eliminated, it may reject this request by explaining its reasoning in accordance with the third paragraph of Article 13 of the Law No. 6698 and notify the relevant person in writing or electronically within thirty days at the latest.
7) Rights of Data Subjects over their Personal Data
According to the Constitution of the Republic of Turkey, everyone has the right to request the protection of personal data concerning him/her. In this context, the rights of the data subject on personal data are listed below in Article 11 of the Law No. 6698:
- To learn whether his/her personal data is being processed,
- Request information if their personal data has been processed,
- To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
- To know the third parties to whom their personal data are transferred domestically or abroad,
- To request correction of personal data in case of incomplete or incorrect processing,
- To request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the Law No. 6698,
- Request notification of such deletion, destruction or correction to third parties to whom personal data are transferred,
- To object to the occurrence of a result to the detriment of the data subject by analyzing the processed data exclusively through automated systems,
- To demand the compensation of the damage in case of damage due to the processing of personal data in violation of the Law No. 6698.
In the event that the relevant persons submit their requests regarding the above-mentioned rights in accordance with the application procedures stipulated in the Communiqué on Application Procedures and Principles to the Data Controller, Sungur Law will finalize this request free of charge as soon as possible and within 30 (thirty) days at the latest.
The relevant person may submit his/her requests within the scope of the above-mentioned rights in writing through the contact information below or by using secure electronic signature, mobile signature or the e-mail address previously notified by the relevant person and registered in Sungur Law’s system. In the application made;
- Name, surname and signature if the application is in writing,
- Turkish Republic ID number for citizens of the Republic of Turkey, nationality, passport number or ID number, if any, for foreigners,
- Residential or workplace address for notification,
- Electronic mail address, telephone and fax number for notification, if any,
- Subject of request
and the relevant information and documents must be attached to the application. In order for third parties to make an application request on behalf of the relevant persons, there must be a special power of attorney issued by the relevant person through a notary public on behalf of the person who will make the application.
Sincerely,
Sungur Law Office
Izpark Plaza Orta Mah.
Vezirköprü Cad. Ordu Sok. No:23 A Blok
Kat:2 D:11 Kartal-Istanbul
Tel: (0216) 385 20 93 5
E-Mail: info@sungurhukuk.com.tr