Beysu Konakları | Beysukonaklarisitesi

PERSONAL DATA LIGHTING TEXT / PERSONAL DATA PROTECTION AND DISPOSAL POLICY

1- Purpose and Scope of the Policy

In order to comply with the Law on Protection of Personal Data No. 6698 published in the Official Gazette dated 07.04.2016 and numbered 29677 and the relevant legal regulations, the procedures and principles adopted and to be applied are regulated by this Personal Data Protection Policy, within the scope of the disclosure obligation of the data controller.

It is carried out within the framework of the legal regulations in force regarding the processing and protection of personal data. BEYSU KONAKLARI SITE MANAGEMENT Personal Data Protection Policy has been prepared in accordance with current regulations. This Policy has been created by integrating with the rules set forth by the relevant legislation and BEYSU KONAKLARI SITE MANAGEMENT practices. Personal data specified below; When necessary, it will be transferred to the physical archives and information systems of our Site, which can be processed within the framework of the provisions of the relevant legislation. As a result, Personal data will be protected in both digital and physical environments for an appropriate period of time, taking into account the legal periods defined in the institutional procedures.

In this Personal Data Processing Policy;  Regarding the personal data processed by BEYSU KONAKLARI SITE MANAGEMENT; -Data category, -Personal data processing purposes and legal reason, -Recipient/recipient groups transferred, -Data subject groups, -Maximum storage period required for the purposes for which personal data is processed, -Personal data intended to be transferred to foreign countries, -Data security The technical and administrative measures taken regarding this issue are explained in detail.

BEYSU KONAKLARI SITE MANAGEMENT,  Complying with the KVKK and other relevant regulations, and processing, using, destroying, transferring personal data in accordance with the Law and other regulations, and in accordance with the procedures and processes set forth in this Policy. will behave.

Definitions

Concept

Definition

Personal Data:

Any information relating to an identified or identifiable natural person.

Personal health data:

It means all kinds of information about the physical and mental health of an identified or identifiable natural person, and information about the health service provided to the person.

Special Qualified Personal Data:

The data and biometric data related to the race, dress and dress, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures are special personal data.

Open Consent:

Consent on a specific subject, based on the information of the person concerned and expressed with the free will of the person concerned.

Buyer Group:

The category of natural or legal person to whom personal data is transferred by the data controller.

Anonymization:

Making personal data incapable of being associated with an identified or identifiable natural person under any circumstances, even by matching with other data.

De-identification:

Personal data; Processing it in a way that cannot be associated with the person concerned, provided that technical and administrative measures are taken so that it cannot be associated with an identified or identifiable natural person, and without combining it with other data stored in a different environment.

Open data:

Anonymized data, which is made available to everyone on the internet free of charge or not exceeding the cost of preparation, does not have any intellectual property rights on it and can be used freely for any purpose, can be read by machines and thus can work with other data and systems,

Open health data:

Health data turned into open data,

Masking:

Processes such as erasing, scratching, painting and starring certain areas of personal data in a way that cannot be associated with an identified or identifiable natural person.

Destruction of personal data:

Deletion, destruction or anonymization of personal data.

Annihilation:

The process of making personal data inaccessible, irretrievable and unusable by anyone in any way.

Periodic Disposal:

The deletion, destruction or anonymization process, which will be carried out ex officio at repetitive intervals and specified in the personal data storage and destruction policy, in the event that all of the personal data processing conditions in the law are eliminated.

Blackout:

It is the process of scratching, painting and icing all of the personal data in such a way that it cannot be associated with an identified or identifiable natural person.

Destruction of personal data:

The process of making personal data inaccessible, unrecoverable and reusable by anyone,

Deletion of personal data:

The process of making personal data inaccessible and unusable for the relevant users in any way,

Direct Identifiers:

By themselves, identifiers that directly reveal, reveal and distinguish the person with whom they are in a relationship.

Indirect Identifiers:

Identifiers that combine with other identifiers to reveal, reveal and distinguish the person with whom they are in a relationship.

Law:

Law on Protection of Personal Data dated 24.03.2016 and numbered 6698.

Related User:

Persons who process personal data within the organization of the data controller or in line with the authorization and instruction received from the data controller, excluding the person or unit responsible for the technical storage, protection and backup of the data.

Recording Media:

Any environment where personal data is processed wholly or partially automatically or by non-automatic means provided that it is a part of any data recording system.

Personal Data Processing Inventory:

Personal data processing activities carried out by data controllers depending on their business processes; The inventory, which is created by associating the personal data with the purposes of processing, the data category, the transferred recipient group and the data subject group, by explaining the maximum time required for the purposes for which the personal data is processed, and the measures taken regarding data security.

Processing of Personal Data:

Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or using personal data completely or partially by automatic or non-automatic means provided that it is a part of any data recording system. Any operation performed on the data, such as blocking.

Board:

Personal Data Protection Board.

Record:

Data controllers registry (VERBIS) kept by the Personal Data Protection Authority.

Data Recording System:

The registration system in which personal data is processed and structured according to certain criteria.

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.

Data Processor:

They are natural or legal persons outside the organization of the data controller who process personal data on behalf of the data controller based on the authority granted by the data controller.

Contact Person:

It is the person responsible for ensuring the communication between the data controller and the relevant person or the Personal Data Protection Authority. If the data controller is a legal person residing in Turkey, he/she has to appoint a contact person and process the information of this contact person assigned during registration in the Data Controllers Registry to VERBIS.

Personal Data Owner:

The natural person whose personal data is processed (Relevant Person).

Third Party:

Third-party real persons (For example, employees or officials of the company from which the service is received) in order to ensure the security of commercial transactions between our site and the above-mentioned parties or to protect the rights of the said persons and to obtain benefits.

Visitor:

Real persons who have entered the physical areas owned by our institution for various purposes or visited our websites

2- Principles of Processing Personal Data

It carries out personal data processing activities within the framework of the principles and principles listed below in accordance with Article 4 of the KVKK, which regulates the procedures and principles regarding the processing of personal data.

a. Compliance with Law and Integrity

BEYSU KONAKLARI SITE MANAGEMENT processes the personal data of site residents, employees and visitors   in accordance with the KVKK and other laws and regulations that must be complied with as per the work done.

b. Being Accurate and Up-to-Date

BEYSU KONAKLARI SITE MANAGEMENT carries out the necessary procedures and takes technical and administrative measures to update the personal data, if the personal data provided by the data owner is not changed without permission and untrue, and if there is a change in the processed data, if requested by the data owner.

c. Processing for Specific, Explicit and Legitimate Purposes

Personal data processed by BEYSU KONAKLARI SITE MANAGEMENT are processed in accordance with the declared processing purpose and within the framework declared.

D. Connected, Limited, and Measured for the Purpose of Processing

BEYSU KONAKLARI SITE MANAGEMENT does not process personal data that does not overlap with the activities of the site, is not required within the framework of the site activities and exceeds the purpose of processing.

to. Retention for the Time Required for the Purpose of Processing or Envisioned in the Relevant Legislation

Your data, which is processed in accordance with the KVKK within the framework of KVKK, in connection with our activities and service purposes undertaken by the Property Ownership Law No. 634 and other relevant legislation, and in a measured manner, as required by the nature of the personal data envisaged in the relevant legislation or processed, which must be kept within the framework of the legislation. are preserved for a period of time.

3- Personal Data Processing Conditions and Exceptional Circumstances

Personal data of general nature to be processed in accordance with the KVKK, in connection with our activities and service purposes, undertaken by BEYSU KONAKLARI SITE MANAGEMENT with the Law No. 634 on Condominium Ownership and other relevant legislation;

Provided that the explicit consent of the data owner is obtained, or
expressly stipulated in the law,
Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract.
Obligatory for the data controller to fulfill its legal obligation
made public by the person concerned,
Data processing is mandatory for the establishment, exercise or protection of a right,
Provided that it does not harm the fundamental rights and freedoms of the data subject, it can be processed without the explicit consent of the data owner, if there is one of the cases where data is mandatory for the legitimate interests of the data controller.

 in accordance with KVKK, in connection with our activities and service purposes undertaken by the Condominium Law No. 634 and other relevant legislation, BEYSU KONAKLARI SITE MANAGEMENT (Site Management)_cc781905-5cde-3194-bb358_bad5 Special categories of personal data to be processed within the framework of its activities;

It will not be processed unless the explicit consent of the data owner is obtained,
Except for sensitive personal data related to health and sexual life, it can be processed without the explicit consent of the data owner in cases stipulated by the laws,

4- Personal Data Classification

Personal Data

data set

Explanation

Credential:

Employee/ Resident/ Visitor 

Written on your identity card; Name, surname, mother's name, father's name, place of birth, date of birth, marital status, religion, blood group, registered province, district and neighborhood and the information written on your identity card without being limited to these.

Contact Information:

Employee/ Resident/ Visitor 

Contact data such as home phone number, mobile phone number, residential or other address information, e-mail address.

Personal Information:

Worker

 Copy of Identity Card/Driver's License/Passport/ID,

Identity registration sample, Certificate of Residence, Health report, Photocopy of diploma, Criminal record record, Passport photograph, Document stating family status, Military status document, Employment Contract / Service Contract, SSI employment entry declaration, Your criminal record (criminal record), Your health status Information and documents related to permit dataMilitary information, Driver's license information

Bank Account Information:

Employee/ Resident

 Bank account number, IBAN number, other information.

Background Information:

Employee / Employee Candidate

 Your education information, school information about your education, certificate information, education status and information about your education, written in your CV or requested by BEYSU KONAKLARI SITE MANAGEMENT or given by you,

Place, date and duration of your work experience, information about your previous job and task, all kinds of information about your work experience written in your CV or requested by BEYSU KONAKLARI SITE MANAGEMENT or given by you,

Your photo written in your CV or requested by BEYSU KONAKLARI SITE MANAGEMENT or given by you,

Your driver's license written in your CV or requested by BEYSU KONAKLARI SITE MANAGEMENT or given by you and the information in your driver's license,

Information about your references and references written in your CV or requested by BEYSU KONAKLARI SITE MANAGEMENT or given by you.

Visitor Information:

Visitor

 Name, surname, visiting hours, license plate, if any, of visitors to our site, and other information.

5- Purpose and Methods of Personal Data Processing

BEYSU KONAKLARI SITE MANAGEMENT, which works on site management services, needs the processing of Personal data when both directly fulfilling its legal obligations and indirectly required by these obligations and the services provided. In this sense, your personal data is processed by BEYSU KONAKLARI SITE MANAGEMENT in accordance with the legislation, in connection with our activities and service purposes undertaken by the Law No. 634 on Condominium Ownership and other relevant legislation, and in accordance with the legislation.

Regarding the Personal Data of the Residents  

In order to fulfill the security and management requirements;

Communicating with the residents of the site, sharing the legal processes Creating an invoice record
Providing follow-up
To inform about the site via e-mail or sms (breakdown, complaint, election etc.)
For dues and energy consumption collection
Resident proof of residence
On-site parking layout
Provide visitor tracking
Ensuring the card printing process
Access control to the site / social facility
Keeping and deleting vehicle registration OGS registration
To generate statistics

Maintaining site registration and utility records
Input definition between blocks
your business addresses
Water, natural gas and electricity consumption
Deed information of your residence on our site
The rental contract of your house you have rented on our site.
Name and surname of your permanent guests
Name and surname of your employees
Identity information of subcontractors from whom you directly receive services for your residence

 Also, high resolution video recording is made with cameras in order to ensure security within our site;

All of the cameras are visible in common areas (entrances, fences and roads inside the site), there is no hidden camera.
Camera recordings are also made in the management office and social facilities.

Regarding Personal Data of Visitors

Images of people visiting our site within the framework of camera viewing and recording activities carried out in order to ensure order and security within the site,
In order to ensure the security of BEYSU KONAKLARI SITE MANAGEMENT, video surveillance and recording of vehicles entering the parking lot,
In order to identify the relevant person in case of any dispute/tort or other situation, visitor forms signed during the visit to our site and visitor list records kept in the site system and visitor information can be processed.

Regarding Personal Data of Employee Candidates

BEYSU KONAKLARI SITE MANAGEMENT and initiating, executing and terminating recruitment processes in workplaces, recording recruitment processes and monitoring and improving recruitment processes and procedures,
Checking the suitability for the job by forwarding job applications and resumes to the appropriate departments and units and proceeding to the interview process,
Determining and examining whether you provide the sufficient and necessary qualifications for the job you are applying for at the time of job application, during the job application process and during any process to be made during the job application,
Searching for your references and getting references about you,
Being able to contact you as a result of the evaluation made at the end of the job application process,
If a suitable position is opened later, you can be informed about the job opportunity by making the necessary evaluations again,
BEYSU KONAKLARI's CV information, identity information, contact information and other personal data of the employee candidates are processed in line with the purposes and methods of monitoring and recording with cameras in order to ensure order and security within the SITE.

 In Terms of Employee Personal Data

Your personal data may be processed by BEYSU KONAKLARI SITE MANAGEMENT for similar purposes and reasons such as but not limited to the purposes and legal reasons stated below.

Fulfillment of the purpose necessary for the performance of the employment contract, in particular     

Leave approval of employees, viewing balance leaves, making leave arrangements
Execution of employee exit procedures
Ensuring payroll processing
Making salary payments to employees

In order to fulfill the requirements within the scope of Labor Law, Occupational Health and Safety Law, Social Security Law and related legislation and other laws and regulations, in particular;   

Creation of personnel file
SSI notifications, İŞKUR notifications, police station notification, incentive and legal liability notification 
Ensuring the opening of a compulsory private pension insurance account
Checking the entry and exit records of the employees and determining the match of the camera records with the door entry and exit records for R&D
Calculating incentives for R&D
Payment of employee salary lien deductions to executive files
Making legal notifications of work accident
Occupational health and safety procedures
To comply with other information retention, reporting and disclosure obligations stipulated by the legislation, relevant regulatory institutions and other authorities.
Fulfillment of court orders

In addition,   especially for the purpose of ensuring security within the site;     _cc781905-5cdeb-581905ccb-1363594bd 136bad5cf58d_

Ensuring workplace safety
Camera viewing and recording in order to ensure order and security within the site,
It is determined that the electronic devices provided by BEYSU KONAKLARI SITE are used in accordance with the purpose of supply and monitoring them in order to ensure their safety.

6-Ensuring the Security of Personal Data

As BEYSU KONAKLARI SITE MANAGEMENT, we carry out the necessary administrative and technical measures within the framework of the necessary technological infrastructure to ensure the security of your personal data that we process within the framework of the Site activities in accordance with the KVKK and relevant legislation; Accordingly, we take precautions against data breaches, unauthorized access, data loss, unauthorized modification of data and other threats, and perform the necessary controls. Despite all these precautions and measures, if a data breach still occurs, we notify the relevant persons and the KVK Institution as soon as possible without delay and within 72 hours at the latest.

In this context, we identify current risks and threats, train our employees to raise awareness, and determine policies and procedures regarding personal data security. Administrative and technical measures taken by our institution to ensure “data security” pursuant to Article 12 of the KVK Law are listed below and necessary controls are carried out in order to properly implement these measures.

A-Technical Measures Taken to Ensure the Legal Storage of Your Personal Data and the Prevention of Unlawful Processing and Access.

Personal data storage, processing and access activities are controlled by established technical systems.
The technical measures taken are reported to the person concerned.
We work with personnel who are knowledgeable in technical matters.
Software and hardware including virus protection and firewall systems and firewalls are used.
In order to ensure the safe storage of personal data, backup programs are used in accordance with the law.
Accesses to data storage areas where personal data are stored are logged within the framework of Law No. 5651, and inappropriate accesses or access attempts are instantly communicated to the concerned.

B- Administrative Measures Taken to Ensure the Lawful Storage of Personal Data and the Prevention of Unlawful Processing and Access

Employees are informed and trained about the protection of personal data and the legal storage and processing of personal data.
Personnel who will process, store and access personal data have been identified in the personal data processing inventory and have been appointed as the contact person.
In order to meet the legal compliance requirements determined on the basis of departments, awareness is created specifically for the relevant departments and rules of practice are determined; Necessary administrative measures to ensure the control of these issues and the continuity of the application are implemented through on-site policies and trainings.
Employees are informed that the personal data they learn cannot be disclosed to others in violation of the provisions of the Personal Data Protection Law No. 6698 and cannot be used for purposes other than processing, and that this obligation will continue after they leave their job, and necessary commitments are taken from them in this direction.
Except for the instructions of BEYSU KONAKLARI SITE MANAGEMENT and the exceptions brought by the law, records that impose the obligation not to process, disclose or use personal data are placed in the contracts and documents governing the legal relationship between employees, and the awareness of the employees is created in this regard.

In addition to these, in accordance with the data security principles stipulated within the scope of KVKK, we ensure personal data minimization in order not to process unnecessary data, provide our employees with the necessary training to ensure the security of personal data and prevent violations, and take the necessary measures for the security of personal data stored in the physical environment as well as electronic media.

7- Domestic Use and International Transfer of Personal Data

Personal Data of Site Residents and Visitors

Your personal data obtained by BEYSU KONAKLARI SITE MANAGEMENT, primarily within the framework of the provisions of the KVK Law and other legislation and for the purposes described above; It can be transferred to the relevant institutions within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law.

Your processed personal data; For the purposes listed in Article 2; In accordance with the KVKK and the legislation in force, it can be shared within our Management, but not limited to the ones listed; Our service connections, subcontractors, suppliers, management officials and in line with the purpose of the service we provide, or in cases stipulated by the legislation regarding regulatory, supervisory institutions and official authorities, may be transferred within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law. Within our site, video recordings are made with an appropriate location and number of cameras for security purposes; Depending on the purpose listed in article 2, this collected data is not transferred to third parties, except for the request of judicial authorities and security forces within the scope of KVKK.

Personal Data of Employees

Security and personal data to employees in order for our Site to fulfill its obligations before the law, Labor Law, Occupational Health and Safety Law, Social Insurance and General Health Insurance Law, Regulation of Publications Made on the Internet and Fighting Against Crimes Committed Through These Publications, Turkish Commercial Code Relevant institutions or organizations to the extent permitted and required by the Law on the Protection of Personal Data No. 6698, the Law on Notification of Identity and, but not limited to, other legislation; It can be shared with public legal entities such as Personal Data Protection Authority, Ministry of Finance, Ministry of Customs and Trade, Ministry of Labor and Social Security, Turkish Employment Agency (İş-Kur), Information Technologies and Communications Authority. For example; Personal data of employees are shared with the Social Security Institution in order to pay employee and employer premiums.

In addition, personal data of employees; Fulfilling the purpose required for the performance of the employment contract, especially;     

We can process it in the Logo accounting program for the purpose of executing the payroll transactions and updating the relevant data. These data are stored in the application's own data recording medium.

In particular, in order to fulfill the requirements within the scope of the Labor Law, the Occupational Health and Safety Law, the Social Security Law and related legislation and other laws and regulations;

We can share health data with our workplace physician so that he or she can perform treatment and health checks.
We can transfer payroll information to site auditors so that they can perform audit activities.

In order to ensure security in the site  in particular;

We can transfer the workplace to the building management for the supervision of entrances and exits for workplace safety.

In particular, due to fulfilling our legal obligations;

In order for us to exercise our right of defense, we may share it with our lawyers and relevant institutions within the framework of our obligation to fulfill legal requests such as court orders or requests for evidence, provided that it is in accordance with the law and procedure.

For the purpose of administering the site, conducting the business, implementing the site policies, in particular;    

In order to preserve the data storage capacity of the site, it can be transferred to archive companies so that it can be stored during the retention periods.

8- Retention Periods of Personal Data

Personal data processed in the organization within the framework of its activities are kept for the period stipulated in the relevant legislation. In this context, personal data;

Law No. 6698 on the Protection of Personal Data,
Turkish Code of Obligations No. 6098,
Arrangement of Publications on the Internet No. 5651 and These Publications
Law on Combating Crimes Committed by
Occupational Health and Safety Law No. 6331,
Law on Access to Information No. 4982,
Law No. 3071 on the Use of the Right to Petition,
Labor Law No. 4857,
Regarding Health and Safety Measures to be Taken in Workplace Buildings and Attachments
It is stored as long as the storage periods stipulated in the framework of other secondary regulations in force in accordance with these laws.

Data Source

Storage Time

Source

Personal Data Protection Board Transactions

10 years