KVKK Clarification Text

COMPANY POLICY

GÜVENÇ BOYA A.Ş. takes all necessary administrative and technical measures, within the framework of the principle of utmost care, for the protection of the confidentiality of the personal data collected through the methods described in the KVKK T01 General Information Text Regarding Personal Data and the KVKK T03 Information Text for Personnel, and Stores it physically and/or electronically in accordance with the precautions.

GÜVENÇ BOYA A.Ş. processes, stores or shares all personal data it collects in accordance with the relevant legislation and company policies and under the conditions specified in the above-mentioned disclosure texts. If GÜVENÇ BOYA A.Ş. shares information with the institutions or organizations it cooperates with, it takes the necessary measures to ensure that these companies comply with the confidentiality standards and conditions of GÜVENÇ BOYA A.Ş.

GÜVENÇ BOYA A.Ş. takes the necessary measures to ensure that all its employees act in accordance with the privacy policy and show the necessary sensitivity in this regard. Our employees are informed about the protection of both their own personal data and the personal data of stakeholders through trainings.

The commitments included in this policy are valid for the information shared through GÜVENÇ BOYA A.Ş.’s website and other channels. In case of linking to other websites on this site or other channels, the privacy principles and terms of use of the linked websites are valid, and GÜVENÇ BOYA A.Ş. is not responsible.

GÜVENÇ BOYA A.Ş. reserves the right to change the matters regulated in this policy without prior notice in order to keep the principles regarding the privacy policy up to date and in line with the relevant legislation and company policies.

GÜVENÇ BOYA A.Ş Cookie Policies

What is a Cookie: A cookie or known as a “cookie” is a small text file or information that is saved on your computer or mobile device (such as a smartphone, tablet) when you visit our sites (guvencboya.com.tr) using mobile and desktop devices. Cookies usually contain the names of the websites they come from, their lifetime (how long they stay on your device), and values that are randomly given numbers.
What We Use It For: We use cookies for the purposes of personalizing our sites to be easier to use, tailoring them to your interests and needs, and displaying smart advertisements to our users. Websites can read and write these cookie files, so that important information about you is remembered (such as remembering your preference settings) in order to be recognized and to offer you a more suitable website. Cookies also help speed up your future activity on our sites. In addition, we may use cookies to collect statistical information about the use of our sites in order to understand how visitors use our sites and to improve the design and usability of our sites.
Which Types We Use: We use two types of cookies throughout our sites, session cookies and persistent cookies. Session cookies are temporary cookies and are only valid until you close your browser. Persistent cookies stay on your hard drive until you delete them or they expire (how long the cookies stay on your device will depend on the “lifetime” of the cookies).

Third Party Cookies (3th Party Cookies)

Our business partners, advertising platforms, social media platforms and these service providers, which provide analytical information collection services and are used throughout our site, may allow them to save cookies on your devices when you visit our sites so that they can provide their services. For more information about these cookies and for detailed information on how to control these cookies, please review the privacy policies or cookie policies of these third party institutions and organizations.

Cookie Used	What Does It Do?	Lifetime	Details
Monitoring/Analysis	Provides anonymous (anonymous) aggregated data about where you browse and what you do on www.guvencboya.com.tr	Persistent, session and 3rd party	Google Analytics YouTube Views Gemius Comscore
Social Media / Sharing	It allows you to share comments, pages, bookmarks and helps provide easier access to social networks and social tools.	3rd party	Facebook Twitter YouTube
Cross-site tracking	It enables the approximate address (city, county, zip code) to be determined by the user’s IP address and to present the most appropriate ones to the user according to the user’s content and advertisement preferences.	Session, 3rd party	Mobile Advertising platforms
Google Analytics	Such cookies enable the collection of all statistical data, thereby improving the presentation and use of the Site. By adding social statistics and interest data to these statistics, Google helps us better understand users.	Persistent, session and 3rd party	Google Analytics

1. How to control or delete cookies: Many internet browsers are set to automatically accept cookies by default. You can change these settings to block cookies or to alert you when cookies are sent to your device. There are several ways to manage cookies. For detailed information on how to adjust your browser settings, please refer to your browser’s instruction or help screen. If you disable the cookies we use, this action may affect your user experience on our company’s website; for example, you may not be able to view certain parts of the site, or you may not be able to access information customized for you when you visit again. If you use different devices to view the site (e.g. computer, smartphone, tablet, etc.), you should make sure that each browser on each of these devices is set to match your cookie preferences.

SOCIAL MEDIA USE POLICY

GÜVENÇ BOYA A.Ş. maintains its own pages / channels on the following social media platforms:

Facebook

There is only a Facebook page for the company. Additional rules can be added if there are other platforms (Twitter, Instagram, Linkedln, Youtube). The opening and management authority of the pages rests with the General Manager. Other than that, the accounts and pages opened are not related to our company. In case of detection, GÜVENÇ BOYA A.Ş. can take legal action. Photos and videos taken during company activities (Factory general, production activity, fairs, etc., social activities, etc.) are shared on the pages. Apart from this, celebration / commemoration messages for national and religious holidays can be published.

On social media pages, the necessary parameters and privacy settings are made by the General Manager.

The images of our employees in the photographs and videos can only be published if their explicit consent is obtained, other than that, images of our customers, suppliers and visitors are not included. In the posts, the names of our employees are not labeled, and no personal data is shared without their permission.

Apart from this, the rules that our employees and subcontractor employees should pay attention to in the use of social media are explained below:

• In social networks, GÜVENÇ BOYA A.Ş. or if an opinion is expressed on a subject related to the sector, it must be stated that you have a personal opinion.
• The company must protect its own reputation and its colleagues. Any discreditable comments will be avoided.
• No credible comments will be made about customers, competitors, suppliers, public or private institutions and organizations.
• GUVENC PAINT INC. No information about its employees, customers, suppliers and other stakeholders will be shared.
• On social networks, they should not share photos or tag other people’s names without their consent.
• Comments that are discriminatory, harassing, racist, religious or sexual, offensive and offensive will not be written.
• No commercial products will be advertised or propaganda of any political party will be made on the company’s social media pages.
• The person, office, meeting, details of the working content, places etc. within the company will not be tagged on social media. For example, it will not be written on Facebook that “We are in training for XXX purposes together with X, Y and Z at XXX Hotel”. It may create risks in terms of privacy, security and competition.
• If there is any doubt about a content that is considered to be shared, the Human Resources Officer will be consulted.
• Care should be taken when uploading any content (text, image, video, etc.) to social media platforms. Trademarks or copyrights may be violated without knowing it.
• Employees are personally responsible for the content they share and publish on social media.
• In case of misunderstanding of written messages on social media, spelling rules will be followed.
• Unauthorized persons should never introduce themselves as the official spokesperson for the firm.
• Negative messages written by others about the company will not be written negatively, and they will be treated with common sense and courtesy.
• Be aware that what is shared on the Internet cannot be completely removed, even if it is removed or deleted.

Our employees can consult the Human Resources Officer about the parameters and privacy settings on their personal social media pages.

PERSONAL DATA RETENTION AND DISPOSAL POLICY

POLICY PURPOSE:

This policy has been prepared on the basis of the Regulation on the Deletion, Destruction or Anonymization of Personal Data, in order to define our company’s approach to the storage and management of the personal data received and processed.

DEFINITIONS:

Destruction: Deletion, destruction or anonymization of personal data

Recording medium: Any medium containing personal data that is fully or partially automated or processed non-automatically, provided that it is a part of any data recording system.

Periodic destruction: 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 case all the conditions for processing personal data in the law are no longer valid.

Data registration system: It refers to the registration system in which personal data is processed and structured according to certain criteria.

REASONS FOR STORAGE AND DISPOSAL, STORAGE AND DISPOSAL TIMES:

Our company securely stores the personal data it processes, in physical and/or electronic media, within the storage periods determined by the Personal Data Inventory and publicly announced in the VERBIS (Data Controllers Registry) in order to fulfill its legally mandatory and commercial activities. In the Personal Data Inventory, it is defined in which environments each personal data is processed, stored and by which methods it is destroyed. Personal data is stored in accordance with the Law on Protection of Personal Data No. 6698, the Labor Law No. 4857, the Occupational Health and Safety Law No. 6331 and all legislative requirements concerning our company activities.

In determining the personal data retention periods, the legal reason for the processing of personal data or the purpose of the processing is taken into account. If personal data is data that is collected and processed in accordance with legal conditions, the storage period is defined in the Personal Data Inventory as the period specified in the relevant legislation. For other data, the periods that will enable the relevant activities to be carried out in accordance with the purpose of processing are determined and defined in the Personal Data Inventory. While retention periods are sometimes defined as “month”, “year”, for some personal data “…. At the end of” can be defined as “until ………… is done”. For this reason, for each personal data, a different retention period may apply for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

Personal data is stored by taking the “Data Security Measures” publicly announced in VERBIS. In addition to administrative measures such as preparing an authorization matrix for employees, conducting trainings, making confidentiality agreements with employees and data processors, technical data security measures such as the use of up-to-date antivirus systems, use of firewalls, backups, etc. are taken.

In the destruction of personal data, deletion, destruction, anonymization process, re-access, recovery, use or association of personal data with the data owner is not possible, according to the method chosen.

Personal data whose storage period has expired is destroyed according to the determined destruction methods and the process is recorded using the Data Destruction Record. These records are kept for at least 3 years.

Responsible persons determined by “Personal Data Inventory” and “Authorization Matrix for Personal Data and Management of Authorities Table” are responsible for the storage and destruction of personal data. Those who take part in the destruction processes are recorded in the Data Destruction Record.

Our company reviews personal data every 3 months (March, June, September and December), detects data whose storage period has expired, and in the first periodical destruction process following the date of deletion, destruction or anonymization of personal data, personal data deletes, destroys or anonymizes data. This period shall not exceed six months.

Personal data owners can request information about their data by using the communication methods in our General Clarification Text on Personal Data. If this request is the deletion of personal data:

1. If all the personal data processing conditions have been removed, the personal data subject to the request will be destroyed. The request of the person concerned is finalized within 30 days at the latest and informed in writing / electronically.
2. If all the personal data processing conditions have been eliminated and the data subject to the request has been transferred to the data processors, our company will notify the Data Processor of the situation and ensure the destruction.
3. If all of the personal data processing conditions have not been eliminated, it is rejected by our company by explaining the reason, and the rejection is notified in writing / electronically within 30 days at the latest.

GENERAL LIGHTING TEXT

1. 1. About the Law on the Protection of Personal Data:
   This “General Information Text”, GÜVENÇ TEKSTİL BOYA A.Ş. (“GÜVENÇ BOYA”), pursuant to the Law on Protection of Personal Data No. 6698 (“KVKK”), in the capacity of Data Controller, within the framework of Article 10 titled “Informing Obligation of Data Controller” and 11 titled “Rights of Relevant Person” in KVKK. ; It is provided to inform you about the purpose for which your personal data will be processed, to whom and for what purpose your processed personal data can be transferred, the method and legal reason for the collection of your personal data, and your other rights listed in Article 11 of the KVKK and to obtain your consent on the following matters. and we care about protecting your safety. Accordingly, we take the necessary technical and administrative security measures to protect your personal data against unauthorized access, damage, loss or disclosure.
   2. Your Personal Data We Collect and Our Processing Purposes:
   GÜVENÇ BOYA processes your personal data that you share through the website (www.guvencboya.com.tr and other channels included in this lighting text, again limited to the purposes specified in this clarification text. GÜVENÇ BOYA, full address Akçeşme Mahallesi 2020 Sokak No:10 Merkezefendi / DENİZLİ and its tax number is Gökpınar Tax Office – Tax No: 450 033 7867. In terms of KVKK, our company operates as a “Data Supervisor”. As GÜVENÇ PAINT, in the capacity of Data Supervisor, within the framework of our legal obligations arising from all legal regulations to which it is subject and in the transactions we make in order to continue our company activities, you are deemed to have been informed. We collect flood data.
   1. Personal Data Collected from Our Customers: Name-surname, e-mail address, telephone number, TR Identity Number (from our individual customers in order to issue invoices), security camera footage in case of visiting our company, photographs etc. in case of a visit to our company. Personal Data Collected from Our Suppliers: Product or service During the purchasing process, the name-surname, contact information (Phone, e-mail) of the supplier representative and employees, other personal data of the supplier personnel who provide the service according to the nature of the service, security camera footage in case of visiting our company, etc. Personal Data We Collect from Employee Candidates Making Job Application: Identity, communication, professional experience (Education, education and work history), criminal record, identity and contact data of references, nationality, place and date of birth, gender, marital status, military status, health / disability status, etc. The candidate may also have shared other personal data not requested by our company in his/her CV, these data will not be used or processed by GÜVENÇ BOYA. Customers Using the Order Tracking Application on the Website (sipariş.guvencboya.com.tr): Customer username (e). -mail address), password information. Persons Who Want to Use the Internet Connection in Our Company: TR Identity Number and IP NO. Other: Name-surname, contact information etc. obtained from other parties contacted during the execution of business activities. All Visitors: During the Covid-19 epidemic, The risk status accessed by body temperature measurement data and HES code query of all persons entering the workplace
   Our Processing Purposes: (all available on a categorical basis in our VERBIS record)     Our processing purposes, including but not limited to:
   1. Fulfilling our legal obligations regulated in the legislation Understanding the needs of our customers and presenting the right offer Improving communication with customers and providing more effective and high quality service Carrying out marketing and sales processes Providing information to authorized persons, institutions and organizations Making billing and collection Managing the job application processes and evaluating the candidate (for job applicants) Purchasing (For Suppliers) To carry out our business processes (Other parties)
   This personal data; In order for you to benefit from the services we offer as GÜVENÇ BOYA, all necessary information security measures are required, based on your express consent or in other cases stipulated in the 2nd paragraph of Article 5 of the KVKK, primarily the legal legislation to which we are subject, provided that it is not used outside the purposes and scope specified in this Information on the Protection of Personal Data. It will be processed and stored during the legal storage period or as required by the processing purpose, and will be destroyed or anonymized at the end of the period required by the processing purpose.
   3. In Which Ways We Collect Your Personal Data:
   Personal data provided to GÜVENÇ BOYA directly by you: All information and documents you have forwarded, requests for proposals, contracts, orders, job application forms or CVs, etc. Personal data collected during the execution of business processes:  Correspondence, e-mail correspondence, telephone or face-to-face Personal data collected from fair organizations, customer or supplier visitors, etc.: Information and documents collected in sectoral fair organizations or mutual visits, meetings. Personal data we collect through cookies and similar technologies: Your personal data, provided that it is in accordance with the Law, www. It can be collected electronically by automatic means through guvencboya.com.tr. When you visit our website, the following information is automatically recorded and this data can be used for anonymous statistical trend and demographic analysis: Client IP Address: Real IP address of the user requested connection, User Agent Information: Internet browser information from which connection is requested (eg Explorer/ (such as chrome) Operating System Version Information: The version information of the operating system of the computer requested for connection (eg Windows10/xp) The date and time of your visit to our website. Personal data collected during your visits to GÜVENÇ BOYA: From the security entrance, security camera sign In areas, the images taken with the security camera, the license plate number of your vehicle, your name and surname etc. are recorded. In addition, if you use GÜVENÇ BOYA’s wifi connection, Client IP Address: Your real IP address information of the user for whom the connection is requested is recorded.
   4. Who We Share Your Personal Data With:
   GÜVENÇ BOYA, pursuant to your express consent or in particular the legislation to which we are subject, KVKK art. In other cases stipulated in 5/f.2, it may share and transfer it with the relevant parties, provided that adequate precautions are taken within the framework of the security and confidentiality principles specified in the KVKK. Your personal data that you have shared with us will not be shared with third parties except for the purposes of processing and sharing stipulated in the KVKK or without your explicit consent. The job application forms of the employee candidates, the information they convey through our website or the CVs they send by hand / e-mail, to another person without their explicit consent. If the personal data collected from other parties needs to be transferred for the purpose of processing, it may be transferred to authorized persons, institutions or organizations by obtaining the explicit consent of the data owner in cases requiring explicit consent, or as required by law or as a requirement for non-consensual processing.
   5. Rights of the Data Owner (Relevant Person)
   As the data owner, as the data owner, to learn whether your personal data is processed or not, to request information if processed, to learn the purpose of the processing and whether it is used in accordance with the purpose, to know the third parties to which it has been transferred, in the country or abroad. You have the right to object to the emergence of an unfavorable result due to the analysis of the transactions made exclusively by automatic systems, and to request the compensation of the damage in case of damage due to the processing contrary to the KVKK. Your requests within this scope must be in writing within the scope of the Personal Data Protection Law. For this, you can apply to our Company’s address in person with the application form (Request and Evaluation Form for Personal Data), which contains the documents identifying your identity and your explanations regarding the right you want to use, and submitted by our Company on the website (www.guvencboya.com.tr). If your application for these purposes requires an additional cost, you may have to pay the fee amount in the tariff to be determined by the Personal Data Protection Board. Your requests in your application will be finalized as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. Contact Us: If you have any questions or concerns regarding the General Information Text or our other data protection practices, or if you have an access request, please contact us. You can reach us at Akçeşme Mahallesi 2020 Sokak No:10 Merkezefendi / DENİZLİ or by calling 0258 371 12 55.
   6. Effectiveness and Changes
   This clarification text entered into force as of 09.03.2021. In case of changes in the Law No: 01 or the Personal Data Inventory, the revision number and date will be changed and the stakeholders will be informed again.