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This Information Notice has been prepared by Eşbah Yapı Yatırım A.Ş., the data controller, within the scope of Article 10 of the Law on the Protection of Personal Data No. 6698 (“Law”) and the Communiqué on the Principles and Procedures to be Followed in the Fulfillment of the Obligation to Inform.
This Information Notice provides details regarding the purposes for processing personal data and the camera surveillance system within the structure of Eşbah Yapı Yatırım A.Ş. (the “Data Controller”), and informs you about the security measures taken to protect personal data, privacy, fundamental rights, and the legitimate interests of individuals present in surveillance areas.
1. Who is the Data Controller?
In accordance with the Law, your personal data is processed by the “data controller.” The data controller is Eşbah Yapı Yatırım A.Ş., located at İkitelli Osb Mah. Atatürk Bulvarı No:104/A Başakşehir, Istanbul (Tax Office: İkitelli, Tax No: 3800535590). As the data controller, we may record, store, update, process, disclose and transfer your personal data to third parties in accordance with the Law and other applicable legislation.
2. For What Purposes Will Your Personal Data Be Processed?
Your personal data shared with the Data Controller as a supplier or customer will be processed by Eşbah Yapı Yatırım A.Ş. in accordance with the data processing conditions stated in Articles 5 and 6 of the Law, for the following purposes:
-Emergency Management, Building Security,
-BA/BS Notification and Reconciliation Process,
-Banking Transactions,
-Litigation and Enforcement Proceedings,
-Company Operations,
-Compliance with Legal Regulations,
-Invoicing Process,
-Termination Procedures,
-Communication Activities, Customer Communication,
-Official Institution and Authority Processes,
-Marketing and Promotion Activities,
-Purchasing and Procurement Activities,
-Contract Management, Payment Process, Termination Procedures,
-Contract Management, Conducting Commercial Activities, Check Transactions,
-Collection of Requests and Complaints.
Visitors (including customers, suppliers, and public service personnel) who come to our headquarters or construction sites for various reasons are requested to provide “Identification” and “Contact Information.” In such cases, personal data will be processed in accordance with Articles 5 and 6 of the Law for the following purposes:
-Emergency Management, Building Security,
-Company Operations,
-Compliance with Legal Regulations,
-Creation and monitoring of visitor records.
Phone numbers and email addresses are used for marketing and promotion purposes with prior Electronic Commercial Communication Consent. If this consent is withdrawn, these data will only be archived for limited use related to promotional activity documentation.
3. What Are the Methods and Legal Grounds for Collecting and Processing Personal Data?
Your personal data may be collected and processed by Eşbah Yapı Yatırım A.Ş. via the following means:
-Web-Based Software,
-Computer Systems,
-Original Documents,
-Form Registrations,
-Software Programs,
-Software Programs (Domestic),
-Handwritten Documents,
-Application Forms,
-Hard Copy Records,
-Excel Files,
-Accounting Software,
-Request Forms.
Visual data is collected via security cameras.
The legal basis for processing visitor data as mentioned in Article 3 of this notice is Article 5/2(c) of the Law: “Processing is necessary for compliance with a legal obligation to which the data controller is subject,” and Article 5/2(f): “Processing is necessary for the legitimate interests of the data controller, provided that such interest does not harm the fundamental rights and freedoms of the data subject.”
Processing may rely on the following legal grounds: Legitimate Interests of the Data Controller, Explicit Consent, Establishment/Use/Protection of a Right, Legal Requirements, and Fulfillment of Legal Obligations.
The following principles are followed when processing personal data:
-Lawfulness and fairness,
-Accuracy and up-to-date when necessary,
-Specific, explicit, and legitimate purposes,
-Relevant, limited and proportionate to the purpose,
-Retention for the period required by relevant legislation or the purpose of processing.
4. Transfer of Personal Data
Your personal data may be transferred within the scope of the purposes mentioned above and for compliance with legal obligations, in accordance with Articles 8 and 9 of the Law regarding the domestic and international transfer of personal data.
Below are the domestic and international recipient groups and transfer purposes:
-Your personal data may be transferred to authorized public institutions and organizations, suppliers, legal advisors, financial consultants, and accounting departments based on purposes such as monitoring legal operations, payment processes, service provision to the data subject, and transmission to data processors.
-International Transfers: If you communicate via instant messaging or online communication channels, your name, surname, and contact information may be transferred to foreign-based platforms such as WhatsApp LLC and Facebook Inc, which provide IT and communication services. Other personal data will not be transferred abroad under any circumstances.
5. Your Rights Under Article 11 of the Law
You may fill in the “Data Subject Application Form” available at www.esbah.com.tr and www.esbahilan.com.tr, or prepare your own written and signed application and submit it via the channels listed below. All requests under Article 11 of the Law will be evaluated promptly and comprehensively. Your request will be answered and finalized within 30 days at the latest.
Under Article 11, you have the right to:
-Learn whether your personal data is being processed,
-Request information regarding the processing,
-Learn the purpose of processing and whether they are used in line with that purpose,
-Request correction if your personal data is incomplete or incorrect,
-Request deletion or destruction of personal data within the scope of Article 7,
-Request that correction or deletion operations are notified to third parties,
-Object to negative results based solely on automated processing,
-Request compensation for damage due to unlawful processing.
You can send your requests to our address at İkitelli Osb Mah. Atatürk Bulvarı No:104/A Başakşehir Istanbul via mail, or through other methods determined by the Personal Data Protection Board.
Thank you for reading this Information Notice.
Eşbah Yapı Yatırım A.Ş.
