TURKON LOGISTICS PERSONAL DATA BUSINESS POLICY

Dear Customers, Business Partners and Visitors; As Turkon Logistics (Turkon Logistics Corporation) (from now on, "Turkon Logistics or "Company"), we attach great importance to the protection of your personal data. In this context, we would like to inform you about your personal data and processing processes in the capacity of "data controller", in accordance with the Personal Data Protection Law No.6698 ("PDPL"). With this Policy, it is aimed to sustain the principle of “conducting company activities in transparency” of our companies operating in the same / similar sector and whose data processing processes are the same. In this context, the basic principles adopted in terms of compliance of our companies' data processing activities with the regulations in the Personal Data Protection Law No.6698 ("PDP Law") are determined and the practices carried out by our companies are explained. This policy is intended for natural persons whose personal data are processed by our Companies in automatic or non-automatic ways provided that it is part of a data recording system.
The policy has been made public by our companies on the website.

In case of conflict with the current legislation, especially the Law, and the regulations included in this Policy, the provisions of the legislation are applied.

Our companies reserve the right to make changes in the Policy in line with legal regulations.

YOUR PERSONAL DATA WE PROCESS
Turkon Logistics operates in the transportation sector and can process the following personal data, depending on the legal, commercial and / or contractual relationship between the Group companies and their customers (related persons of legal entities and real persons): 

• Identity Information: This data category refers to the data types such as T.R. identification number, tax identification number, place and date of birth, marital status, gender, signature.

• Contact Information: This data category refers to data types such as address, telephone number, e-mail address, fax number. 

• Sensitive Personal Information: This category of data refers to data types such as (i) health data received from personnel within the scope of personal and occupational safety, (ii) biometric data (fingerprints) belonging to persons, (iii) criminal records regarding criminal convictions belonging to persons.

• Visual and Audio Information: This category of data refers to data types such as photographs and video recordings, images of persons recorded in camera recordings made for security purposes in our Company's physical environment, and voices of persons recorded during call center calls.

• Personal Information: This category of data refers to the types of data that includes the identity and contact information of the personnel, as well as the occupation, education and financial information within the scope of the personal file legally required within the framework of the employment contract established with the personnel.

Contract Information: This category of data refers to all data such as signature, real person company information and transported goods, which are entered into the database as a result of the contractual connection established with the business partners, suppliers and external sources with which our companies have legal or commercial relations.

Financial Information: This category of data is the processed personal data regarding the information, documents and records showing all kinds of financial results created according to the type of legal relationship our Companies have established with the Personal Data Owner Relevant Person and refers to data types such as bank account number, receipt, payment information, fee, IBAN number.

• Location Information: This category of data refers to the entire location data of the employees of our companies that are processed for internal audit purposes.

• Performance Information: This category of data is all of the data generated by the processes such as evaluations, tests and audits performed for internal audit and for the purpose of increasing operability for the personnel inside the company and for the purpose of the performance audit of the business partners outside the company.

• Transaction Security Information: This category of data refers to your personal data (such as log records, IP information, access information, identity verification information) that are processed in order to ensure our technical, administrative, legal and commercial security during the conduct of Company activities.

THE METHOD OF COLLECTING YOUR PERSONAL DATA AND ITS LEGAL REASON

The establishment and execution of contracts within the scope of the commercial and / or contractual relationship between you and Turkon Logistics , within the framework of the following purposes and as set out in Article 5/2 of Law No. 6698; and within the scope of legal regulations and legitimate interests, your Personal Data can be collected and processed by our Companies directly from you (through contract, order form, offer form, e-mail correspondence, business card sharing, website messages, social media messages, shares of our branches and other business partners). For security purposes, your identification details and security camera photos are registered and stored during your visits to our workplaces, restricted to this activity.

In addition, your identity and contact data on your business cards are processed by archiving your business cards (the data on the business card is considered to be publicized) shared by you within the scope of our marketing and promotional activities at various events or fair participations by our Companies. The aim here is to operate the necessary processes for the establishment of a transport contract between the two companies. In events and fairs, our illumination texts and, if necessary, our permits are also physically presented to you.

PURPOSE OF PROCESSING YOUR PERSONAL DATA

Your Personal Data is processed for the following purposes:

 • For existing Business Relationships;

• Execution of Goods / Service Purchase Processes
• Execution of Goods / Service Sales Processes
• Execution of Customer Relationship Management Processes
• Conducting Activities for Customer Satisfaction
• Ensuring Physical Space Security
• Finance and Accounting Transactions
• Conducting Activities in Compliance with the Legislation
• Carrying out transactions and activities within the scope of commercial / contractual relationship and fulfilling financial and legal obligations
• Tracking of Requests / Complaints
• Fulfilling Legal Obligations
• Execution of Legal Processes
• Promotion and Marketing Activities
• Realization of management and business activities • Preservation of your information that must be kept in accordance with the relevant legislation; copying and backing up to prevent information loss; ensuring the consistency of your information; taking necessary technical and administrative measures for the security of our databases and information.

• For Potential Business Relationships;

Your identity and contact information directly obtained from you through your visits to our website, your posts in the Social Media Accounts of Turkon Logistics, your requests and complaints conveyed to our call center, and the business cards you share at the fairgrounds or events (the data on the business card is deemed publicized) are processed in accordance with the Article 5/2 of the Law for the creation of an offer for the transportation service, the establishment of the contract, and the management of your requests and complaints; for marketing purposes, if you are not a tradesman or tradesman, your information is processed based on your express consent in order for you to be aware of the products and services of our company and within the framework of the goal of presenting a number of special products to you. 

 • For Suppliers / Business Partners;

Within the scope of your commercial relationship with our Turkon Logistics Companies, personal data of your company officials and employees can be processed as stated in Article 5 of the Law, regarding the establishment and execution of our contracts, fulfillment of legal obligations and within the context of the legitimate interests of our company in accordance with the basic principles stipulated in the Law, within the terms of personal data processing, and within the framework of the following purposes:

• Conducting Activities in Compliance with the Legislation
• Execution of Contract Processes
• Execution of Finance and Accounting Affairs
• Execution and follow-up of legal processes
• Conducting Company Internal Operations
• Strategy planning & business partners / supplier management
• Ensuring Physical Space Security
• Execution of Logistics Activities
• Managing Supply Chain Management Processes
• Preservation of your information that must be kept in accordance with the relevant legislation; copying and backing up to prevent information loss; ensuring the consistency of your information; taking necessary technical and administrative measures for the security of our databases and information. 

• For Visitors;

Within the scope of your visits to Turkon Logistics, our website and other workplaces of our companies, in addition to ensuring the security of our company and you, your identity and visual data obtained by security cameras and visitor log books in physical environments and your identity and communication data obtained within the scope of internet access offered to you during your visit to our workplace are processed for the following purposes, depending on the fulfillment of our legal obligations and our legitimate interests. 

• Conducting Audit and Security Activities
• Execution of Information Security Processes
• Creating and Tracking Visitor Records
• Ensuring Physical Space Security
• Informing Authorized Persons, Institutions and Organizations
• Ensuring the Security of Data Controller Operations
• Providing Internet Access and Ensuring Access Security

• For Employee Candidates;

By using your personal data received by you through our internet address www.turkonlogistics.com, from our e-mail addresses, by mail or within the scope of job applications you made to our company headquarters or with the application forms you fill out, our Company carries out data processing activity for the establishment of a right specified in Article 5 of the Law regarding personnel recruitment and employment processes and for establishment and execution of our Contracts within the scope of the legitimate interests of our Company and within the following purposes. 

• Conducting Employee Candidate / Intern / Student Selection and Placement Processes
• Execution of Employee Candidates' Application Processes
• Carrying out human resources operations and especially recruitment processes,
• Carrying Out Business Continuity Activities and Ensuring Physical Space Security

• For Employees;

Turkon Logistics carry out data processing activities within the scope of the following purposes in order to create a personal file for reasons arising from the relevant legislation, to conclude a service agreement with you and for the management rights and legitimate interests of our Companies.

• Execution of Information Security Processes
• Execution of Employee Satisfaction and Loyalty Processes
• Fulfilling Obligations Arising from Employment Contract and Legislation For Employees
• Execution of Benefits and Benefits Processes for Employees
• Conducting Audit / Ethical Activities
• Conducting Training Activities
• Execution of Access Authorities
• Conducting Activities in Compliance with Legislation
• Execution of Finance and Accounting Affairs
• Ensuring Physical Space Security
• Execution of Recruitment Processes
• Following and Execution of Legal Affairs
• Planning of Human Resources Processes
• Execution / Supervision of Business Activities
• Conducting Occupational Health / Safety Activities
• Receiving and Evaluating Suggestions for the Improvement of Business Processes
• Conducting Business Continuity Activities
• Execution of Performance Evaluation Processes
• Informing Authorized Persons, Institutions and Organizations
• Carrying Out Management Activities
• Realizing the Required Legal Notifications to Official Institutions, Benefiting from Incentives at Official Institutions, Notifying Relevant Authorities within the Scope of Official Institutions Audits
• Execution of Human Resources Operations and Personnel Activities,
• Ensuring Employee Control and Performing the Required Data Processing Activity within the Scope of the Employer's Management Right
• Preservation of your information that must be kept in accordance with the relevant legislation; copying, backing up to prevent information loss; ensuring the consistency of your information; taking necessary technical and administrative measures for the security of our databases and information

PARTIES TO WHICH PERSONAL DATA IS TRANSFERED AND TRANSFER PURPOSES

Turkon Logistics will be able to transfer your personal data to the following domestic buyer groups within the scope of the Law and other legislation for the purposes specified in this Policy:

• Our suppliers and business partners we work with to provide or deliver the services offered to you,
• Our business partners, supplier companies and banks, financial institutions, insurance companies, insurance experts, broker companies, who cooperate and / or receive services for the provision, promotion and similar purposes,
• Our Group Companies with whom we use a common database for many activities and receive joint services,
Advertising agencies from which we get service for the management of our website and social media accounts,
• Lawyers, auditors, consultants and service providers,
• Your attorneys, guardians and representatives authorized by you,
• The institutions or organizations authorized to request your personal data, such as regulatory and supervisory agencies, courts and enforcement offices, and their designated persons.

 RIGHTS IN THE 11TH ARTICLE OF THE LAW

You have the right

• To learn whether your Personal Data is processed,
• To request information if your Personal Data has been processed,
• To learn the purpose of processing Personal Data and whether they are used appropriately for their purpose,
• To know the third parties to whom your Personal Data is transferred at home or abroad,
• To request correction of your Personal Data if it is incomplete or incorrectly processed,
• To request deletion or destruction of your Personal Data within the framework of the conditions stipulated in the Personal Data Protection Law No.6698 ("PDP Law") legislation,
• To request notification of the transactions made under Articles 5 and 6 to third parties to whom your Personal Data has been transferred,
• To object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems,
• To demand the removal of a damage you suffer due to unlawful processing of Personal Data.

ENSURING THE SECURITY AND PRIVACY OF PERSONAL DATA

So as to prevent the unlawful disclosure, access, transfer of personal data or any security deficiencies that may occur in other ways, depending on the nature of the data to be protected, the Company takes all necessary precautions within the bounds of possibility.
In this context, all necessary (i) administrative and (ii) technical measures are taken by the Company, (iii) an audit system is established within the company and (iv) in case of unlawful disclosure of personal data, action is taken in accordance with the measures stipulated in the PDP Law.

DISPOSAL OF PERSONAL DATA

Although legally processed in compliance with the Article 7 of the Law, in case the reasons requiring processing disappear, the Company deletes, destroys or anonymizes the personal data, ex officio or upon the request of the Related Person, in accordance with the Data protection and destruction policy, legislation and the guide published by the Authority.
Turkon Logistics have prepared a DISPOSAL POLICY in which the methods of destruction of personal data are determined and published within the company. All disposal processes are carried out in accordance with this policy.

ISSUES ON THE PROTECTION OF PERSONAL DATA

Pursuant to Article 12 of the PDP Legislation, Turkon Logistics shall take the required technical and administrative steps to prevent illegal processing of personal data, to avoid unauthorized access to data, to guarantee data security and to carry out the necessary inspections within this framework.
Turkon Logistics take technical and administrative measures according to technological possibilities and application costs so as to ensure that personal data are processed legally.

TECHNICAL MEASURES
The main technical measures taken by Turkon Logistics to ensure the legal processing of personal data are listed below:

• Personal data processing activities carried out within our companies are audited by established technical systems.
• The technical measures taken are periodically reported to the relevant person as per the internal audit mechanism.
• Departments on technical issues have been established and knowledgeable personnel are employed in this regard.
• New technological developments are followed and technical measures are taken on systems, especially in the field of cyber security, the measures taken are periodically updated and renewed.
• Access and authorization technical solutions are put into use within the framework of legal compliance requirements specified in each department within our companies.
• Access authorizations are limited and authorities are regularly reviewed. Access restrictions are imposed on former employees and accounts are closed.
•The technical measures taken in line with the operation of our companies are reported to the relevant users and the issues that pose a risk are re-evaluated and the necessary technological solutions are produced.
• Software and hardware including virus protection systems, data vulnerability security and firewalls are installed.
• Professional personnel are employed in technical matters.
• All information systems, including the applications where personal data are collected, are regularly subjected to external impact tests to detect security gaps and the gaps found according to the results of this test are fulfilled.

ADMINISTRATIVE MEASURES
Administrative measures taken by Turkon Logistics for the legal processing of personal data:

• Employees of our companies, dealers and authorized service personnel are informed and trained on the protection of personal data and the processing of personal data in accordance with the law.
• All personal data processing operations conducted by our companies are carried out in compliance with the personal data inventory and its annexes, generated by a thorough review of all business units.
• The personal data processing activities carried out by the relevant departments within our companies and the obligations to be fulfilled to ensure that these activities comply with the personal data processing conditions sought by the PDPL are bound by our companies to written policies and procedures; and each business unit has been informed about this issue and the specific issues to be taken into consideration have been determined.
• The control and management of personal data security of departments within our companies are organized by Information Security Committees. Awareness is raised to meet the legal requirements determined on the basis of business units and necessary administrative measures are implemented through internal policies, procedures and trainings to ensure the supervision of these issues and the continuity of implementation.
• Service agreements and related documents between Turkon Logistics and its employees include information and data security records, and additional protocols are made. Efforts have been made to create the necessary awareness for employees on this issue.
• Legal compliance, access to personal data within the company and authorization processes are implemented, taking into account personal data processing processes, specific to each department within the Turkon Logistics.

Our companies conduct privacy impact analysis assessment in the following situations:

• In new projects involving personal data
• Before selecting the supplier to whom personal data are transferred
• Before the activities to be carried out within the scope of marketing activities
• In case of any change in the activities mentioned above

You can send your request to our companies to use your rights within the scope of the above mentioned PDPL by filling out the application form on the website of Turkon Logistics , along with the documents that will determine your identity, (i) to the address of our Group Companies - Ord. Prof. Dr. Fahrettin Kerim Gökay Cad. No: 33 Altunizade / İSTANBUL - with wet signature in hand or with return receipt or (ii) to the e-mail addresses, tlinfo@turkon.com or turkonholding@hs02.kep.tr, by send a copy of the form with a secure electronic signature.
In the event that data owners (relevant persons) submit their requests regarding their personal data to our Company in writing, as the data controller, the company carries out the necessary processes to ensure that the request is concluded as soon as possible and within thirty (30) days at the latest, in accordance with Article 13 of the PDP Law.

Within the framework of ensuring data security, the company may request information to determine whether the applicant is the owner of the personal data subject to the application. Our company may also ask questions about the application of the Relevant Person in order to ensure that the application is concluded in accordance with the request.
In cases where the application of the relevant person is likely to hinder the rights and freedoms of other people, where it requires disproportionate effort, and in which the information is public information, the request may be rejected by explaining the reason.

ENFORCEMENT OF THE POLICY
This Policy, regulated by Turkon Logistics, was put into effect on 01/01/2019. This Policy is published on the website of Turkon Logistics (www.turkonlogistics.com) and made available to the relevant persons upon the request of personal data owners.
Turkon Logistics Inc.
Address - Ord. Prof. Dr. Fahrettin Kerim Gökay Cad. No: 33 Altunizade / İSTANBUL
Web Address - www.turkonlogistics.com