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KVKK Company Policy

EMA SHOES INC.

PROTECTION AND PROCESSING OF PERSONAL DATA POLICY

This Personal Data Protection and Processing Policy Within the framework of Law No. 6698 on Protection of Personal Data, Ema Ayakkabı A.Ş. (“ Company ”), the official website of the Company, www.emaayakkabi.com (“ Website ”), user, visitor, member and other persons (“ User or Contact Person)”) Provides information about our company policy regarding the procedures and principles of our company regarding the processing and transfer of personal data that the User shares or produces with the Company. On these principles and procedures, as the Company, we take all administrative and technical measures in line with the policy we have implemented for the protection and processing of Personal Data.

 

1. Purpose of the Personal Data Protection and Processing Policy:

Protection and Processing of Personal Data Policy (“ Policy”) Aims to regulate the principles and principles determined by our company in line with the scope specified in the Law of Protection of Personal Data No. 6698 regarding the processing and processing of personal data of our company, which carries out shoe production and sales activities. It should also be noted that in this context, it is to protect the fundamental rights and freedoms of individuals, especially the confidentiality of private life regulated in Article 20 of the Constitution, and to inform Personal Data Owners about the obligations of our Company and the procedures and principles to be applied in accordance with the Law on Protection of Personal Data No. 6698. The primary and important purpose of our policy is to protect the privacy of personal data holders and the security of their data.

 

2. Scope of the Personal Data Protection and Processing Policy:

Provided that this Policy consists of natural persons existing within the company, a number of company rights holders are new real persons that can be acquired from other companies and outside the company;

• Company Shareholders,

• Company Business Partners,

• Company officials,

• Company employees,

• Company Interns,

• Former Employees of the Company,

• Employee Candidates,

• Visitors,

• Company Customers,

• Potential Customers,

• It is prepared for Third Parties and will be applied within the scope of all natural persons except for those specified.

The Company informs about the Personal Data Protection Law No. 6698 by publishing this Policy on the website www.emaayakkabi.com . As we have stated above, this Policy will not be applicable to legal entities, regardless of the adjective or name. In addition, “Personal Data Processing Policy for Employees” will be implemented for our employees.

This Policy shall apply to the real persons mentioned above, in case our Company processes Personal Data of these concerned persons under the Law No. 6698 on Protection of Personal Data in whole or in part by automatic or non-automated means provided that they are part of any data recording system. This Policy will not be applied if the data is not covered by the “ Personal Data ” in the definitions below, or if the Personal Data processing activity carried out by our Company is not in the above mentioned ways.

 

3. Definitions Under the Law on Protection of Personal Data No. 6698:

While this Policy is being implemented by our Company, the main definitions to be used in the implementation of the Law are;

Open Consent

It is the consent of a particular subject, which is based on information and explained with free will.

Anonymize

It is to make Personal Data not to be associated with a certain or identifiable natural person under any circumstances even by matching with other data.

Company

Ema Ayakkabı A.Ş.

Company official

Ema Shoes Inc. are board members and other authorized natural persons.

Company Shareholder

Ema Shoes Inc. its shareholders are real persons.

Company Partner, Shareholder, Official, Employee of Business Partners

All real persons, including real persons, shareholders and officials, working with real persons who have all kinds of business relationships with our company and real and legal persons (such as business partners, suppliers) with whom our company has all kinds of business relationships.

Employee Candidate

They are real persons who have applied for a job to our company in any way or have opened their CV and related information to our company for review.

Company Customer

Regardless of whether they have any contractual relationship with our company, they are real persons who use or have used the products and services offered by our Company.

 

Potential Customer

Natural persons who have requested or are interested in using our products and services or have been evaluated in accordance with the rules of commercial custom and honesty that they may have.

Third Person

Ema Ayakkabı A.Ş., prepared for Company Employees Other persons who are not covered by the Data Protection and Processing Policy and do not fall under any Personal Data Owner category in this Policy.

Visitor

All natural persons who have entered the physical settlements of our company for various purposes or visit our websites for any purpose

Law

 

Refers to the Law No. 6698 on Personal Protection.

Secondary Legislation

Under the law, any regulation, circular, notification, policy decision or similar administrative decision or general opinion issued or taken by the Personal Data Protection Authority.

Related Users

It refers to persons who process personal data within the organization of the data controller or in accordance with the authorization and instruction received from the data controller, except for the person or unit responsible for the technical storage, protection and backup of the data.

Personal Data / Data

It refers to all kinds of information about a specific or identifiable natural person.

Processing of Personal Data

Acquisition, recording, storage, preservation, modification, reorganization, disclosure, transfer, acquisition, making available, classification of Personal Data, which is fully or partially automated, or non-automated provided that it is part of any data recording system, or It refers to all kinds of operations performed on the data such as preventing its use.

committee

Refers to the Personal Data Protection Board.

Institution

Refers to the Personal Data Protection Authority.

Special Qualified Personal Data

People's race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, disguise and outfit, association, foundation or union membership, health, sexual life, criminal conviction and security measures and biometric and genetic data.

Record

It refers to the Data Controllers Registry, a registration system in which data officers have to register and declare information about data processing activities.

Data Processor

Refers to the natural or legal person who processes Personal Data on his behalf, based on the authority granted by the Data Controller.

Data Recording System

It refers to the recording system in which Personal Data is processed according to certain criteria.

Data Protection Commission

Refers to the Company's Personal Data Protection Commission.

Data Owner

Data Owner defined as “Relevant Person” in the law refers to the real person whose Personal Data is processed. Data Owners include customers, internet users, individuals in the communication, electronic mail and marketing database lists, employees, contract parties and suppliers.

Data Responsible

It refers to the natural or legal person who determines the purposes and means of processing the Personal Data and is responsible for the establishment and management of the data recording system.

Draft Regulation on Data Officials Registry

The Draft Regulation on Data Controllers Registry has been prepared in accordance with Article 16 of the Law. It has not come into force yet.

Deletion

It refers to making personal data inaccessible and unusable for Related Users in any way.

Deletion and Destruction Policy

It refers to the policy that the Company has prepared within the framework of the Regulation on the Deletion, Destruction or Anonymization of Personal Data, which regulates the procedures and principles regarding deletion and destruction.

Annihilation

It refers to making personal data in no way accessible, retrieved and reusable by anyone.

 

4. Enforcement of the Personal Data Protection and Processing Policy:

Ema Shoes Inc. It is made available to the relevant persons upon the request of Personal Data Holders as of the date of its publication on the Company's website ( www.emaayakkabi.com ).

 

5. Protection of Personal Data within the Scope of Our Company Policy:

a. Security of Personal Data;

In accordance with Law No. 6698 on Protection of Personal Data, our Company takes all necessary technical and administrative measures to prevent the illegal processing and access of Personal Data and to ensure the appropriate level of security in order to maintain Personal Data.

b. Audit;

Our company conducts and performs the necessary inspections to establish the data security described above and to ensure the regularity and continuity of the measures taken.

c. Privacy;

Our company takes all the necessary technical and administrative measures according to the technological possibilities and implementation costs so that the relevant data responsible and data processors do not disclose their Personal Data in violation of the provisions of the Law and Policy, and use them for purposes other than processing. In this context, information and training activities about the Law and Policy are carried out with our Company employees.

d. Unauthorized Disclosure of Personal Data;

In the event that Personal Data processed by our Company is obtained by others in ways that are not in accordance with the law, our Company takes the necessary steps to report this situation to the relevant Personal Data Owner and KVK Board as soon as possible. If deemed necessary by the KVK Board, this may be announced on the KVK Board's website or by any other method deemed appropriate by the KVK Board.

e. Observing Legal Rights of Personal Data Owners;

Our company observes all legal rights of Personal Data Owners through the implementation of the Policy and Law and takes all necessary measures to protect these rights.

f. Protection of Special Qualified Personal Data;

As stated in the definitions section, people's race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, disguise and outfit, association, foundation or union membership, health, sexual life, criminal conviction and security measures and biometrics and genetic data are Special Qualified Personal Data. It is taken into consideration that the Special Qualified Personal Data by our company are data that may cause the person concerned to be victimized or subject to discrimination if learned by others, therefore all necessary precautions are taken to protect such personal data processed in accordance with the law.

 

6. General Principles in Processing Personal Data within the Scope of Our Company Policy:

Personal Data is processed by our Company in accordance with the Law No. 6698 on Protection of Personal Data and the procedures and principles stipulated in this Policy. Our company acts in accordance with the following principles while processing Personal Data.

a. Principle of Compliance with Legal Rules and Integrity Rules;

Our Company's Personal Data is processed in accordance with the Law on the Protection of Personal Data No. 6698 and the regulation that is affiliated to this law, in accordance with the law of integrity and is used in accordance with the principle of integrity.

b. The Principle of Being Accurate and Updated;

Our Company ensures that the Personal Data it processes are accurate and up-to-date, taking into account the fundamental rights and legitimate interests of Personal Data Holders. In this context, the issues such as determining the sources from which the data are obtained, verifying their accuracy, and evaluating whether they should be updated are carefully taken into consideration.

c. Processing Principle for Identifiable, Clear and Legitimate Purposes;

Our company clearly and precisely determines the purpose of data processing and ensures that this goal is legitimate. The purpose is legitimate means that the Personal Data processed by our Company must be linked to and required by the business or service it provides.

d. The Principle of Being Connected, Limited, and Metered for the Purpose They Are Processed;

Our company ensures that the processed Personal Data is suitable for the achievement of the specified objectives and avoids the processing of Personal Data that is not related or needed to achieve the purpose. It fulfills one of the processing conditions of the Personal Data regulated by the Law, as if it is the first time that it begins to process data to meet the potential needs that may arise later. It also limits the processed data to only what is required to achieve the purpose.

e. The Principle of Preservation for the Time Envisaged in the Relevant Law or Required for the Purpose of Processing;

Our company complies with these periods if there is a period foreseen in the relevant legislation for data retention; otherwise, it retains Personal Data only as long as necessary for the purpose for which it was processed. If there is no valid reason for further storage of a Personal Data by our Company, that data is deleted, destroyed or anonymized.

 

7. Terms of Processing Personal Data within the Scope of Our Company Policy:

Our company does not process Personal Data without the express consent of the data subject. Our company may process Personal Data without the explicit consent of the data subject in the presence of one of the following conditions.

a. In the case of Clear Foresight in Related Laws

Our company may process Personal Data Owners' Personal Data in the cases required by law, even without express consent.

b. In the event that the person who is unable to explain his consent due to actual impossibility or whose legal consent is not granted his consent is compulsory to protect himself or someone else's life or body integrity;

Personal Data may be processed by our company without explicit consent, in order to protect the life or bodily integrity of persons, where consent cannot be disclosed or valid. In order to protect the person's life or body integrity, Personal Data of Personal Data Owner may be processed during medical intervention. In this context, data such as blood group, diseases and surgeries, medications used can be processed through the relevant health system.

c. In the event that it is necessary to process the Personal Data of the Parties of the Contract, provided that it is directly related to the Establishment or Performance of a Contract;

Personal Data may be processed by our company regarding the establishment or performance of a contract.

d. In the event that the Data Officer is Required to Fulfill his Legal Obligation;

If our company requests and discloses personal data from official institutions and organizations for the solution or clarification of an event, the data officer may share the personal data requested to fulfill his legal obligation.

e. That the Person is Publicized by Himself;

In other words, Personal Data, which is publicly disclosed by the Personal Data Owners by our company, can be processed due to the acceptance of the legal benefit to be protected in the processing of such data, which is made public by the Personal Data Owners and thus becomes publicly known.

f. Data Processing Is Necessary For The Establishment, Use Or Protection Of A Right;

Data processing is mandatory for the establishment, use or protection of a right In cases where data processing is mandatory for the use or protection of a legally legitimate right, personal data owners may process their personal data without explicit consent.

g. The Data Processing is Necessary for the Legitimate Interest of the Data Controller, provided that it does not damage the Fundamental Rights and Freedoms of the Person concerned;

Our Company can process Personal Data Owners Personal Data in cases where Personal Data is required to provide legitimate interests, provided that they do not harm the fundamental rights and freedoms of Personal Data Holders protected under the Law and Policy. Our company shows the necessary sensitivity to comply with the basic principles regarding the protection of Personal Data and to maintain the balance of interests of our Company and Personal Data Owners.

 

8. Terms of Processing Special Qualified Personal Data within the Scope of Our Company Policy;

Our Company's Special Qualified Personal Data does not operate without the express consent of the person concerned. However, Personal Data other than health and sexual life can be processed without the express consent of the person concerned, in cases provided for by law. Personal Data related to health and sexual life is processed by our Company only for the purpose of protecting public health, preventive medicine, conducting medical diagnosis and treatment and care services, planning and managing health services and financing, without the explicit consent of the person concerned. Our company meticulously fulfills the necessary follow-up process and precautions and requirements that may be taken by our company in order to take adequate measures determined by the Board in the processing of Personal Data of Special Quality.

 

9. Deletion, Destruction or Anonymization of Personal Data within the Scope of Our Company Policy:

Although the personal data of our company have been processed in accordance with the provisions of the Law and other relevant laws, in the event that the reasons that need to be processed disappear, the personal data will be deleted, destroyed or anonymously by the data officer or upon the request of the person concerned. The provisions in other laws regarding the deletion, destruction or anonymization of personal data are reserved. The procedures and principles regarding the deletion, destruction or anonymization of personal data are regulated by a regulation.

 

10. Transfer of Personal Data within the Scope of Our Company Policy:

• If the Personal Data owner is compulsory to protect the life or body integrity of the owner or someone else and the Personal Data owner is unable to explain his consent due to the actual impossibility, or his consent is not given legal validity,

• If it is necessary to transfer the Personal Data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

• If Personal Data transfer is mandatory for our company to fulfill its legal obligation,

• If Personal Data is publicized by Personal Data owner,

• If Personal Data transfer is mandatory for the establishment, use or protection of a right,

• If Personal Data transfer is mandatory for our Company's legitimate interests, provided that it does not harm the fundamental rights and freedoms of the Personal Data owner.

 

11. Transfer of Personal Data Abroad Within the Scope of Our Company Policy:

Our company may transfer Personal Data and Personal Qualified Personal Data of Personal Data Owners to third parties abroad by taking necessary security measures for the purposes of Personal Data processing. For this, the Personal Data by our Company, taking into account the issues listed in the relevant law; In case KVK Board by foreign countries that have been declared to be without sufficient protection or the lack of adequate protection of an adequate protection of responsible data in Turkey and in the relevant foreign country that has committed in writing and transferred to foreign countries where the KVK Board's permission. Countries with these characteristics are announced by the KVK Board.

 

12. Classification of Personal Data within the Scope of Our Company Policy:

In accordance with the Law on Protection of Personal Data No. 6698, our company processes and classifies Personal Data in a number of definitions. Explanations about these classes are listed below.

a. Credentials of the Personal Data Owner

It is the data regarding the personal information of the personal data owner. These data are;

• Name and surname,

• Turkish Identity Number,

• Marital status,

• Nationality information,

• Parent's name-surname,

• Place of birth - date,

• Gender

• Driving license,

• Birth certificate

• Passport

• Tax number,

• SGK number,

• Signature information,

• Included as vehicle license plate and other information.

b. Contact Information of the Personal Data Owner;

It is the data regarding the personal information of the personal data owner. These data are;

• Phone number,

• Address,

• E-mail address,

Fax number,

• It is included as IP address and other information.

c. Transaction Security Information of Personal Data Owner;

These are personal data that are processed regarding the technical, administrative, legal and commercial security of both the Personal Data Owner and the Company during the transactions made in the internal and external operation of the Company.

d. Financial Information of Personal Data Owner;

Information and documents showing all kinds of financial results that arise in accordance with the employee-employer relationship with the Company's Personal Data owner. Besides;

• Personal data processed regarding records,

• Bank account number,

• Branch code,

• Bank card information,

• IBAN number,

• Credit card information,

• Financial profile,

• Credit rating,

• Asset data,

• Included as income information and other information.

e. Visual and Audio Information of the Personal Data Owner;

Photo and camera recordings are sound recordings, any data containing these data and other information.

f. Personal Data Owner's Personal Information;

These are all kinds of personal data processed to obtain information that will be the basis for protecting the personal rights of real persons who have a working relationship with the Personal Data Owner.

g. Location Information of Personal Data Owner;

Information determining the location of the Personal Data owner by the Personal Data owner while using the Company tools within the framework of the activities and operations of the company or cooperating companies and institutions; GPS location is travel data and other information.

h. Information of Family Members and Relatives of the Personal Data Owner;

Family members of the Personal Data holder (e.g. spouse, mother, father, child), relatives and emergency situations within the framework of the activities and operations of the company or cooperating companies and institutions, or in order to protect the legal and other interests of the Company and the Personal Data owner. are credentials and contact information about others, as defined above.

I. Physical Space Security Information of Personal Data Owner;

Personal data regarding the records and documents received during the stay in the physical space at the entrance to the physical space;

• Camera recordings,

• Fingerprint records

• Records and other data received at the security point.

j. Legal Transaction Information of Personal Data Owner;

These are the data processed within the scope of the legal obligations of the Company, as well as the determination, follow-up and performance of its debts.

k. Special Qualified Personal Information of the Personal Data Owner;

These are the data specified in accordance with Article 6 of the Law on Protection of Personal Data No. 6698. (Health data, biometric data, religion and membership association information, etc.)

l. Request / Complaint Management Information of Personal Data Owner;

These are the data regarding the Personal Data holder regarding the receipt and evaluation of any request or complaint addressed to our company.

 

13. Purposes of Processing Personal Data within the Scope of Our Company Policy:

In order to fulfill the lighting obligation in article 10 of the Law No. 6698 on the Protection of Personal Data, our company informs the data owners about the purposes for which the Personal Data will be processed, for whom and for what purpose the processed data can be transferred.

Your personal data; The best planning and implementation of our human resources policies, the correct planning and execution of our commercial partnerships and strategies, ensuring the legal, commercial and physical security of our company and our partners, ensuring the corporate functioning of our company, and working to make the best use of the products and services offered by our company. ; The products and services offered by our company are tailored to your demands, needs and wishes, recommended to you, ensuring the highest level of data security, creating databases, developing the services offered on our Company's website, contacting those who submit their requests and complaints to our Company,

 

14. Purposes of Transferring Personal Data within the Scope of Our Company Policy:

The data of the Personal Data owner, the best planning and implementation of our human resources policies, the correct planning and execution of our commercial partnerships and strategies, the provision of the legal, commercial and physical security of our Company and our business partners, ensuring the corporate functioning of our Company, the products and services offered by our Company work to make good use of it; The products and services offered by our company are tailored to your demands, needs and wishes, recommended to you, ensuring the highest level of data security, creating databases, developing the services offered on our Company's website, contacting those who submit their requests and complaints to our Company,

 

15. Persons to whom Personal Data will be Transferred within the Scope of our Company Policy

Personal Data owner's data;

• To our shareholders,

• To our business partners,

• Our suppliers,

• To our affiliates,

• To the companies and institutions we cooperate with,

• In order to fulfill our contractual or legal obligations, it can be transferred to companies (external security, health, occupational safety, law etc.), authorized institutions and organizations.

 

16. Personal Data Collection Method and Legal Reason Under Our Company Policy

Personal Data for the purpose of control of compliance with Article 1, which regulates the purpose of the Law No. 6698 on Protection of Personal Data, and Article 2, which regulates the scope of the law;

• All kinds of verbal,

• Written,

• By electronic and technical methods,

• Call center, our company's website,

• In various ways such as mobile application,

• Legislation in order to realize the aims included in the policy,

• Contract,

• It meets in order to fulfill its responsibilities arising from the law completely and correctly within the framework of demand and optional legal reasons.

After these collection methods, the data assigned by our Company or our Company are processed by the processors.

 

17. Deletion, Destruction or Anonymization of Personal Data within the Scope of Our Company Policy:

Without prejudice to the provisions contained in other laws regarding the deletion, destruction or anonymization of Personal Data, although our Company has operated in accordance with the Law No. 6698 on Protection of Personal Data and other legal provisions, the Personal Data ex officio or the data owner deletes, destroys or anonymizes upon request.

With the deletion of personal data, this data is destroyed in such a way that it can not be used and brought back in any way. Accordingly, personal data is erased from the tools such as documents, files, CDs, floppy disks and hard disks that cannot be recycled.

The destruction of Personal Data, on the other hand, means the destruction of materials suitable for storing data such as documents, files, CDs, floppy disks, and hard disks so that the information cannot be restored and used.

By anonymizing the data, it is meant to make Personal Data unrelated to an identified or identifiable natural person even if it is matched with other data.

 

18. Duration of Retention of Personal Data within the Scope of Our Company Policy:

Our company stores Personal Data in accordance with the periods stipulated in the Personal Data Protection Law No. 6698 and other legislation. If there is no time regulation in the Personal Data Protection Law No. 6698 regarding how long the Personal Data should be stored and other legislation, the Personal Data is processed for a period of time until the purpose of processing the Personal Data is processed, deleted, destroyed or anonymous. is made.

 

19. Disclosure of Personal Data Owner within the Scope of Our Company Policy:

Our company enlightens Personal Data Owners during the acquisition of personal data within the framework of Article 10 of the Law No. 6698 on Protection of Personal Data. In this context, the Company's identity is clarified about the identity of the Company, for what purpose the personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method and legal reason for collecting personal data and the rights of the Personal Data Owner.

 

20. Rights of the Personal Data Owner in accordance with the KVKK Law within the scope of our Company Policy:

Our company informs everyone about your rights in accordance with the 10th article of the Personal Data Protection Law No. 6698; It provides guidance on how to exercise such rights and performs the necessary internal functioning, administrative and technical arrangements for all these. In accordance with Article 11 of the Law, our company provides personal data;

• Learning whether personal data is processed,

• Requesting information regarding personal data if it has been processed,

• Learning the purpose of processing personal data and whether it is used in accordance with its purpose,

• To know the third parties to whom personal data are transferred domestically or abroad,

• Requesting correction of personal data if it is incomplete or incorrectly processed,

• Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the Law,

• Requesting notification of the transactions made in accordance with the clauses (d) and (e) of Article 11 of the Law to third parties to whom personal data are transferred,

• To object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems,

• It explains that they have the right to demand the compensation of the damage if the personal data is damaged due to the illegal processing of the data.

You can send your requests regarding the implementation of the Law on the Protection of Personal Data No. 6698 to our Company by using the Personal Data Protection Application Data Form, in writing or with secure electronic signature, or by sending it to the address on the application form by the Personal Data Protection Board (the " Board "). . Our company concludes your requests in the application free of charge as soon as possible and within thirty days at the latest depending on the nature of the request. However, in case the transaction in question also requires a cost, the fee in the tariff determined by the Board may be charged.

Our company may accept the request or refuse it by explaining its reason; It notifies the answer to the person concerned in writing or electronically. Our company fulfills its requirement in case the request in the application is accepted. In case the application is caused by our company's fault, the fee collected is returned to the data subject.

In case the application is rejected, the answer is insufficient or the application is not answered in due time; The data subject has the right to complain to the Board within thirty days, and in any case sixty days from the date of application.

 

21. Under the scope of our company policy, where the policy and the law will not be fully or partially implemented:

Our Company Policy and Law provisions will not be applied in the following cases:

• Processing of personal data by real persons within the scope of activities related to him or his family members living in the same residence, provided that they are not given to third parties and obligations regarding data security are complied with.

• Processing personal data for purposes such as research, planning and statistics by anonymizing with official statistics.

• Processing personal data for art, history, literature or scientific purposes or within the scope of freedom of expression, provided that they do not violate national defense, national security, public security, public order, economic security, privacy or personal rights, or constitute a crime.

• Processing personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to provide national defense, national security, public security, public order or economic security.

• Processing of personal data by judicial authorities or enforcement authorities regarding investigations, prosecutions, trials or enforcement proceedings.

Article 10, which regulates the obligation of illumination of the data controller, in accordance with the purpose and basic principles of the Protection of this Policy and the Personal Data Law No. 6698, Article 11, which regulates the rights of the person concerned, except for the right to demand the compensation of the damage, and 16, which regulates the obligation to register to the Data Controllers Registry. substances will not be applied in the following cases.

• Personal data processing is necessary for crime prevention or criminal investigation.

• Processing of personal data publicized by the person concerned.

• The fact that personal data processing is necessary for the disciplinary investigation or prosecution by the authorized and authorized public institutions and organizations and the professional institutions that are public institutions based on the authority given by the law.

• Personal data processing is necessary for the protection of the State's economic and financial interests in relation to budget, tax and financial matters.

 

22. Classification of Personal Data Owners Under Our Company Policy:

Only natural persons can benefit from the protection of this Policy and Law; Personal Data Holders in this context are grouped as follows:

 

Employee Candidate

 

They are real persons who have applied for a job to our company in any way or have opened their CV and related information to our company for review.

 

Group Company Customer

 

Ema Shoes Inc. Personal Data obtained through

 

Company Partner, Partners

Shareholder, Officer, Employee

 

All real persons, including real persons, shareholders and officials, working with real persons who have all kinds of business relationships with our company and real and legal persons (such as business partners, suppliers) with whom our company has all kinds of business relationships.

 

Company Customer

Regardless of whether they have any contractual relationship with our company, they are real persons who use or have used the products and services offered by our Company.

 

Potential Customer

They are real persons who have requested or are interested in using our products and services or have been evaluated in accordance with the rules of commercial practice and integrity that they may have.

 

Company Shareholder

Ema Shoes Inc. are the shareholders.

 

Company official

Ema Shoes Inc. are board members and other authorized persons.

 

Third Person

Ema Ayakkabı A.Ş., prepared for Company Employees Other persons who are not covered by the Personal Data Protection and Processing Policy and do not fall under any category of Personal Data Owner in this Policy.

 

Visitor

All natural persons who have entered the physical settlements of our company for various purposes or visit our websites for any purpose

 

Matching Personal Data and Personal Data Owners Under Our Company Policy:

The matching of the classified Personal Data given above and their scope with the classified Personal Data Owners is presented below.

 

 

Identity Information

 

Company Shareholder; Company official; Company Customer; Group Company Customer; Potential Customer; Company Partner, Shareholder, Official, Employee of Business Partners; Employee Candidate; Visitor, Third Parties

 

 

Communication information

 

Company Shareholder; Company official; Company Customer; Group Company Customer; Potential Customer; Company Partner, Shareholder, Official, Employee of Business Partners; Employee Candidate; Visitor, Third Parties

 

Transaction Security Information

Company Shareholder; Company official; Company Customer; Group Company Customer; Potential Customer; Company Partner, Shareholder, Official, Employee of Business Partners; Employee Candidate; Visitor, Third Parties

 

Financial Information

Company Shareholder; Company official; Company Customer; Group Company Customer; Potential Customer; Company Partner, Shareholder, Official, Employee of Business Partners; Employee Candidate; Visitor, Third Parties

Audiovisual Information

Company Shareholder; Company official; Company Customer; Group Company Customer; Potential Customer; Company Partner, Shareholder, Official, Employee of Business Partners; Employee Candidate; Visitor, Third Parties

 

Personal Information

 

Company Partner, Shareholder, Official, Employee of Business Partners; Candidate for Employees, Third Parties

 

Location Information

 

Company Partner, Shareholder, Official, Employee of Business Partners

 

Family Members and Their Close Knowledge

Company Customer; Group Company Customer; Potential Customer;

Company Partner, Shareholder, Official, Employee of Business Partners; Employee Candidate; Visitor, Third Parties

Physical Space and Security Information

Company Shareholder; Company official; Company Partner, Partners

Shareholder, Officer, Employee; Employee Candidate; Visitor, Third Parties

 

Legal Transaction Information

 

Group Company Customer; Potential Customer; Company Partner, Business

Shareholder, Official, Employee of the Shareholders; Third Parties

 

Special Qualified Personal Information

Company Shareholder; Company official; Company Customer; Group Company Customer; Potential Customer; Company Partner, Shareholder, Official, Employee of Business Partners; Employee Candidate; Visitor, Third

Persons

 

Request / Complaint Management Information

Company Shareholder; Company official; Company Customer; Group Company Customer; Potential Customer; Company Partner, Shareholder, Official, Employee of Business Partners; Employee Candidate; Visitor, Third

Persons

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