FOTONİKS ASKERİ ELEKTRONİK VE ELEKTRO OPTİK SİS. SAN. TİC. A.Ş.

PRIVACY NOTICE

• Purpose
  This Privacy Notice has been prepared by FOTONIKS Askeri Elektronik ve Elektro Optis.Sis.San.Tic.A.Ş. (hereinafter referred to as the "Company") as the data controller, in accordance with Article 10 of the Personal Data Protection Law No. 6698 and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Obligation to Inform. It aims to inform you, as a data subject, in the capacity of employee candidate, employee, executive, shareholder, supplier, customer, visitor, and/or other relevant persons, regarding the data processing activities carried out by the Company.
• Tanımlar

Explicit Consent: Consent that is related to a specific issue, based on information, and expressed with free will
Data Subject: The person whose personal data is processed
Personal Data: Any information relating to an identified or identifiable natural person
Processing of Personal Data: Any operation which is performed upon personal data, wholly or partly by automatic means, or by non-automatic means which form part of a data filing system, such as collection, recording, storage, retention, alteration, rearrangement, disclosure, transfer, acquisition, making available, classification, or prevention of use
KVKK: Personal Data Protection Law No. 6698
Special Categories of Personal Data: Data relating to a person’s 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, as well as biometric and genetic data
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

3. Data Controller
As FOTONİKS Askeri Elektronik ve Elekto Optik Sis. San. Tic.A.Ş., we hereby inform you that the personal data you have provided or will provide to our Company in your capacity as an employee candidate, employee, executive, shareholder, supplier, customer, visitor and/or other relevant person, is being processed by us as the data controller within the scope of the Law on the Protection of Personal Data (KVKK) and other applicable legislation.

4. Purposes of Personal Data Processing and Categories of Processed Personal Data

Purposes of Personal Data Processing
Your personal data is processed for the purpose of carrying out the Company’s operations, in compliance with the limitations set forth in the Law on the Protection of Personal Data (KVKK) and other applicable legislation. In this context, your personal data is processed for the following purposes:

• Execution and supervision of business operations
• Obtaining necessary contact information to conduct business operations
• Creating necessary records in software systems used within the Company for business operations
• Execution of contractual processes
• Fulfillment and follow-up of mutual contractual and legal obligations
• Fulfillment of obligations arising from employment contracts and legislation, including the Labor Law No. 4857, the Occupational Health and Safety Law No. 6331, and the Social Insurance and General Health Insurance Law No. 5510; management of employee benefits and related processes
• Execution of occupational health and safety activities
• Fulfillment and follow-up of obligations arising from legal regulations
• Monitoring and management of legal affairs
• Execution of finance and accounting operations
• Execution of human resources processes
• Provision of information and documents to authorized public institutions and judicial authorities in cases specified by law
• Execution of data storage and archiving activities
• Ensuring the physical security of company premises
• Creation and monitoring of visitor logs

Categories of Processed Personal Data
The categories of personal data to be processed and/or currently being processed by our Company may vary depending on the group of individuals concerned. However, in accordance with the KVKK and other relevant legislation, and for the purposes and legal grounds specified in this Clarification Text, the following personal data may be processed:

• Identity Data: Name, surname, Turkish ID number, mother’s name, father’s name, place and date of birth, signature, etc.
• Contact Data: Residential address, workplace address, landline number, mobile phone number, email address, registered email (KEP) address, fax number, etc.
• Customer Transaction Data: Call center records, order and request information, information on transaction receipts, invoice details, promissory notes, check information, etc.
• Legal Transaction Data: Information in correspondence with judicial authorities, information in case files, etc.
• Physical Security Data: CCTV footage recorded within the company premises and entry/exit log data
• Financial Data: Financial records and payment information regarding services received or provided by the Company, balance of receivables and payables, balance sheet details, financial performance data, credit and risk information, etc.
• Employee-Related Data: In addition to the above data categories, the following may also be processed for employee candidates and employees: personnel records, professional experience information, transaction security data, vehicle data, family and next-of-kin information, reference details, visual records, health data, and data regarding criminal convictions and security measures.

5. Method and Legal Basis for Collecting Personal Data
Your personal data will be collected, either through automated or non-automated methods, verbally, in writing, or electronically, in order to fulfill the purposes specified under section (4) of this text, using the following means:

• Verbal communication of personal data by the data subject or their representative to our Company
• Physical delivery of written documents to our Company
• Sending documents to our Company via our corporate email or registered email (KEP) address
• Submission of data to our Company by filling out forms in written or electronic format
• Sending documents via fax to our fax number

Your personal data will be processed for the purposes stated in this document based on the legal grounds specified in Article 5(2) of the Personal Data Protection Law (KVKK), namely:

• (a) It is expressly provided for by law
• (c) It is necessary for the performance or conclusion of a contract to which the data subject is a party
• (ç) It is necessary for the data controller to fulfill its legal obligations
• (e) It is necessary for the establishment, exercise, or protection of a right
• (f) Provided that it does not harm the fundamental rights and freedoms of the data subject, it is necessary for the legitimate interests of the data controller

In cases where processing of special categories of personal data is required within the scope of our Company’s activities, such data may be processed after providing the necessary information to you, and if required, obtaining your explicit consent in accordance with Article 6(3)(a) of the KVKK.

6. Transfer of Processed Personal Data to Third Parties and Purpose of Transfer
Your personal data may be transferred, without seeking your explicit consent pursuant to Article 8(2)(a) of the Law on the Protection of Personal Data (KVKK), to the parties listed below and for the purposes outlined here and in section (4) of this text:

• For the execution of contractual processes and the fulfillment of mutual contractual and legal obligations, your data may be shared with notaries, enforcement offices, courts, and/or authorized public institutions and organizations if necessary.
• For the purpose of legal proceedings, your data may be shared with our attorneys to the extent necessary, within the scope of confidentiality obligations.
• For the execution of business activities, your data may be shared to the extent necessary and under confidentiality obligations with domestic suppliers/software license holders responsible for the maintenance and installation of software programs used within our Company.
• For financial and accounting purposes, your data may be shared with the banks we work with and our financial advisors if necessary.
• For the fulfillment of our legal obligations under relevant legislation, your data may be shared with auditing firms and relevant institutions and organizations, provided they are based in Turkey.
• For the execution of contractual, procurement, and sales processes, your data may be shared with our domestic logistics service providers/contracted courier companies.
• For the fulfillment of legal obligations and provision of information to authorized persons, institutions, and organizations, your data may be shared with authorized public authorities.

In cases where the transfer of special categories of personal data is required within the scope of our Company’s activities, such data may be transferred after providing necessary information and, if required, obtaining your explicit consent in accordance with Articles 6(3)(a) and 8(1) of the KVKK.

7. Your Rights as a Data Subject

Pursuant to Article 11 of the Law on the Protection of Personal Data (KVKK), you may submit a request to our Company in person, provided that you can verify your identity, to:

• Learn whether your personal data is being processed and, if so, request information regarding such processing,
• Learn the purpose of processing your personal data and whether they are used in accordance with the intended purpose,
• Learn whether your personal data is transferred domestically or abroad and to whom they are transferred,
• Request the correction of your personal data if they are incomplete or incorrectly processed and request that such corrections be notified to third parties to whom the data has been transferred,
• Request the deletion or destruction of your personal data within the scope of the conditions set forth in Article 7 of the KVKK and request that such operations be notified to third parties to whom the data has been transferred. However, the Company will determine the most appropriate method of disposal (deletion, destruction, or anonymization) based on the specific circumstances. You may also request information regarding the justification for the selected method,
• Object to any outcome that may arise to your detriment as a result of the exclusive analysis of your personal data through automated systems,
• Request compensation if you suffer damage due to the unlawful processing of your personal data.

Your application will be concluded free of charge within thirty (30) days at the latest, depending on the nature of your request. However, if the process requires additional costs for the Company, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board, as per the “Communiqué on the Principles and Procedures for the Request to Data Controller.”

To exercise your rights regarding the processing of your personal data, you may submit your request by filling out the “Data Subject Application Form” available at fotoniks.com.tr, or in accordance with Article 11 and the first paragraph of Article 13 of the KVKK and the Communiqué mentioned above, via the following methods:

• By visiting our Company in person at: Oğulbey Mah. Kumludere Cad. No: 8, Gölbaşı / Ankara,
• Through our registered electronic mail (KEP) address: fotoniks@hs01.kep.tr ,
• By sending a written application via notary public or registered mail with return receipt, to verify your identity and prevent disclosure to unauthorized parties,
• By sending an e-mail to kvkk@fotoniks.com.tr using a secure electronic signature, mobile signature, or your e-mail address previously registered in our systems,
• Or through other methods that may be determined by the Personal Data Protection Board in the future.