KVKK
1. Data Controller The Data Controller, KEREM PLASTİK ELEKTRİK SANAYİ VE TİCARET LİMİTED ŞİRKETİ with registered office inArnavutköy, Ömerli Mah. Uzunçayır Cad. No: 13 Hadımköy İstanbul Türkiye +90 212 7713500 2. Categories of data processed The personal data (“Personal Data” or “Data”) provided by the Data subject or that the Company collects during his or her browsing on the Website, are processed by the Company. a) Data provided by the Data subject: this mainly relates to the Data collected during the interactions with the Company through the forms in the Website or when subscribing to the Newsletter. Or when accessing the Reserved Area dedicated to clients, providers, and Keremplast® personnel. This Data includes name, lastname, e-mail, company, country, reason to contact and private message if the visitors have. b) Other Data processed: this mainly relates to the Data collected when browsing on the Website, such as IP address, the operating system of the browser used, the contents clicked and the webpages visited. 3. Purpose of the Processing, legal base and consequences for failing to provide the Data The Data are processed by the Company for the following purposes: a) to provide the services offered through the Website and, in particular, in the Reserved Area (e.g. to place orders, access SharePoint, access the area reserved to personnel, upload of information relating to applications). A possible failure to provide the Personal Data for the fulfilment of the specified purposes will make impossible to send requests or information through the forms or to access to the sections of the Reserved Area for clients, providers and Keremplast® personnel; b) to comply with legal obligations; Personal Data will also be processed to contact the Data subjects for purposes relating to the services and to assess further possibilities of commercial collaboration (also in relation to specific characteristics of the Data subject or the company he/she belongs to), as well as to aggregate the Data for statistical purposes. Such processing will be carried out on the basis of the legitimate interest of the Company to enhance the Website and the offering of its products and services and better understand how they are used and by whom. The processing of the Personal Data may also take place to manage possible disputes or in the context of possible corporate events (sale of company or going concern) and in the execution of the due diligence exercise. Such possible processing could be carried out on the basis of a legitimate interest of the Company, which intends to safeguard its interest and rights as acknowledged by the applicable laws as well as carry out the most suitable business operations in order to improve the offered products and services. In any case, the Company may from time to time send certain marketing communications via email to its business contacts. The content of such communications via email includes relevant corporate news (e.g. the acquisition of a certain company), information on new products, services and offers. The Company will proceed with this processing in order to keep informed its business contacts of the main and relevant news/offers regarding the Plastfit products/services/events. Such communications will be sent on the basis of the legitimate interest of the Company and after an assessment of the reasonable expectation of receiving such kind of communications by the relevant addressee (which is a business contact of the Company). In any case, the relevant addressee will be able to opt-out at any time through the unsubscribe mechanism provided within the emails. 4. Processing modalities and Data retention period The data are processed mainly at the Company by electronic and manual means suitable to guarantee the security and confidentiality. In particular, they may be processed with the following modalities: collection of data from the Data subject; collection of data from registers, list of documents or public documents; record and processing through traditional means (paper); record and processing through IT means; automated and non-automated organisation of the archives. The Personal Data will be retained in accordance with applicable legal provisions, for as long as necessary to fulfil the purposes for which they are processed. The criteria to determine the retention period of the Data take into account the allowed processing period and the applicable tax laws, statute of limitations period and the nature of the legitimate interests where they constitute the legal basis of the process. Pursuant to the applicable legislation, the Personal Data could be retained for a longer period than that originally provided, in case of eventual disputes or requests of the relevant Authorities. As for Personal Data processed in the framework of marketing activities, the communications for the purposes set out under paragraph 2, lett. e), may be carried out by means of e-mail, sms, mms, mail as well as any other current and future communication mean, provided that the Data subject may object to the processing through one or all such means of communication or in any case revoke the consent. As for Personal Data processed in the framework of marketing activities, they will be retained in accordance with currently applicable legal provisions, for as long as necessary to fulfil the purposes for which they are processed. Lacking specific rules which regulate the retention period for the purposes listed in this Policy, the Company will use Personal Data for the abovementioned marketing purposes for an appropriate period of time in accordance with the interests that the Data subject has shown in the promotional initiatives, such period being 5 years. In any case the Company will adopt any arrangement in order to avoid a use of the Data for an indefinite period of time, and from time to time will verify, in an appropriate manner, the existence of the Data subject interest in relation to the processing for marketing purposes, as specified above. 5. Data communication and transfer The Personal Data will be made available to those authorized to process them within the Company only where necessary and for the purposes for which the processing is allowed. Solely for the purposes indicated, the Personal Data may be communicated by the Company to the competent Judicial Authorities, where necessary, and to the following categories of subjects: bank and credit institutions; insurance companies; legal advisors; tax advisors, auditors and accountants; shipping companies; credit recovery companies; companies that detect financial risks and that perform fraud prevention activities; public administrations and supervisory and control Authorities; companies that provide IT services; companies that provide security and surveillance services; controlling companies and/or connected to the Company. With reference to the Personal Data communicated to them, entities belonging to the categories listed above may operate, depending on the cases, as data processors (and in this case they will receive appropriate instructions from the Company) or as separate data controller. In the latter case, the Personal Data will be communicated only with the express consent of the Data subjects, except where the communication is mandatory or necessary pursuant to law or for the pursue of purposes for which the consent from the Data subject is not required. Such rights may be exercised sending: a communication via e-mail to info@keremplast.com
