Corporate General Privacy Notice

As Üntel Kabloları Sanayi ve Ticaret A.Ş. (“Üntel Kablo”), we have prepared this Privacy Notice in order to inform our Visitors, Online Visitors, Customers, Prospective Customers, Supplier Employees, and Supplier Representatives regarding the processing, storage, and transfer of their personal data within the scope of our activities carried out in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”), as well as the applicable legislation and legal regulations.

What Categories of Personal Data Do We Process and for What Purposes?

Your personal data may be processed by Üntel Kabloları Sanayi ve Ticaret A.Ş. in accordance with the principles set forth under Article 4.2 of the KVKK:

(i) Processing in compliance with the law and the principles of good faith,

(ii) Ensuring that personal data is accurate and, where necessary, kept up to date,

(iii) Processing for specific, explicit, and legitimate purposes,

(iv) Processing in a manner that is relevant, limited, and proportionate to the purposes for which it is processed,

(v) Retaining personal data for the period stipulated by the applicable legislation or required for the purpose for which it is processed,

in line with these principles, your personal data may be processed for the purposes specified below within the scope of our existing and ongoing business relationships with our business partners (it is possible for an individual to fall within more than one category).

A. Our Visitors

The identity information (e.g. name, surname) and physical premises security information (e.g. CCTV recordings) of our Visitors shall be processed for the following purposes:

creation and monitoring of visitor records,
ensuring the security of physical premises.

B. Our Online Visitors

The transaction security information (e.g. your IP address) of our Online Visitors using our website, and (where you voluntarily provide such information to us*)

shall be processed for the following purposes:

ensuring compliance with applicable legislation,
carrying out information security processes,
providing information to authorized persons, public institutions, and organizations,
enabling your access to our website via the internet.

C. Our Customers

The identity information, contact information, customer transaction information (e.g. order information), physical premises security information, financial information (e.g. balance sheet information), legal transaction information, and marketing information (e.g. purchase history) of our individual customers or the authorized representatives and/or employees of our corporate customers shall be processed for the following purposes:

ensuring compliance with applicable legislation,
carrying out finance and accounting activities,
conducting and auditing business activities,
carrying out logistics operations,
providing after-sales support services,
carrying out goods/services sales processes,
conducting marketing analysis activities,
carrying out contract processes,
providing information to authorized persons, public institutions, and organizations,
ensuring the security of physical premises,
resolving legal disputes,
carrying out storage and archiving activities,
carrying out risk management processes,
carrying out activities aimed at enhancing loyalty to the company/products/services,
carrying out communication activities.

D. Our Prospective Customers

The identity information, contact information, customer transaction information, physical premises security information, and marketing information of our individual prospective customers or the authorized representatives and/or employees of our corporate prospective customers shall be processed for the following purposes:

managing goods/services sales processes,
carrying out contract processes,
ensuring the security of physical premises,
conducting marketing analysis activities.

E. Our Supplier Employees

The identity information, contact information, and physical premises security information of our Supplier Employees shall be processed for the following purposes:

carrying out communication activities,
conducting and auditing business activities,
ensuring the security of physical premises,
carrying out supply chain management processes,
carrying out logistics operations,
ensuring compliance with applicable legislation,
carrying out occupational health and safety activities.

F. Our Supplier Representatives

The identity information, contact information, physical premises security information, customer transaction information, financial information, marketing information, and legal transaction information of our individual suppliers or the authorized representatives of our corporate suppliers shall be processed for the following purposes:

conducting and auditing business activities,
carrying out goods/services procurement processes,
carrying out finance and accounting activities,
carrying out contract processes,
carrying out investment processes,
ensuring the security of physical premises,
monitoring and carrying out legal affairs.

1) How Do We Collect Your Personal Data?

Your personal data specified under the categories above are collected through automated or non-automated means via physical methods such as order forms, contracts, and visitor forms; information systems and electronic devices (e.g. telecommunication infrastructure, computers, and telephones); third parties (e.g. KKB and Findeks); our website; and other documents submitted by the relevant data subject.

2) What Is the Legal Basis for Collecting Your Personal Data?

Your personal data are processed by Üntel Kabloları Sanayi ve Ticaret A.Ş. based on the legal grounds specified under Article 5 of the KVKK for the purposes explained above:

(i) Where it is expressly provided for by law,

(ii) Where it is necessary to process the personal data of the parties to a contract, provided that such processing is directly related to the establishment or performance of the contract,

(iii) Where it is necessary for the data controller to fulfill its legal obligations,

(iv) Where processing is necessary for the establishment, exercise, or protection of a legal right,

(v) Where processing is necessary for the legitimate interests of the data controller, provided that it does not violate the fundamental rights and freedoms of the data subject.

3) Do We Transfer Your Personal Data to Third Parties?

a) The personal data of our Visitors may be shared with law enforcement authorities and judicial authorities for the purpose of resolving legal disputes and where required under the applicable legislation.

b) The personal data of our Online Visitors may be shared with judicial authorities and authorized public institutions and organizations for the purpose of resolving legal disputes and where required under the applicable legislation.

c) The personal data of our Customers are transferred to authorized public institutions and organizations within the scope prescribed by the applicable legislation for the purposes of ensuring compliance with legal obligations, monitoring and conducting legal affairs, and providing information to authorized persons, institutions, and organizations. They are also transferred to our IT service provider, suppliers, cargo companies, insurance companies, banks, and financial advisor for the purposes of conducting and auditing business activities and carrying out risk management processes. Furthermore, such personal data may be transferred to the law firm from which we receive legal services and to judicial authorities in order to be used as evidence in the event of future legal disputes.

d) The personal data of our Prospective Customers may be transferred to the law firm from which we receive legal services and to judicial authorities in order to be used as evidence in the event of future legal disputes.

e) The personal data of our Supplier Employees are transferred to authorized public institutions and organizations within the scope prescribed by the applicable legislation for the purposes of ensuring compliance with legal obligations, monitoring and conducting legal affairs, providing information to authorized persons, institutions, and organizations, and conducting and auditing business activities. To the extent necessary for the proper performance of the services, such personal data are also transferred to our group companies, IT service provider, suppliers, cargo companies, banks, and financial advisor. Furthermore, such personal data may be transferred to the law firm from which we receive legal services and to judicial authorities in order to be used as evidence in the event of future legal disputes.

f) The personal data of our Supplier Representatives are transferred to authorized public institutions and organizations within the scope prescribed by the applicable legislation for the purposes of ensuring compliance with legal obligations, monitoring and conducting legal affairs, providing information to authorized persons, institutions, and organizations, and conducting and auditing business activities. To the extent necessary for the proper performance of the services, such personal data are also transferred to our group companies, IT service provider, suppliers, cargo companies, banks, and financial advisor. Furthermore, such personal data may be transferred to the law firm from which we receive legal services and to judicial authorities in order to be used as evidence in the event of future legal disputes.

4) Do We Transfer Your Personal Data Abroad?

Your personal data, including your identity and contact information, are transferred abroad due to the fact that the servers used to ensure the continuity of our business processes are located outside Türkiye. Such transfers are carried out based on our legitimate interests through the execution of standard contractual clauses and by implementing the necessary measures to ensure the security of your personal data.

5) How Can You Exercise Your Rights Regarding Your Personal Data?

You may submit your requests within the scope of Article 11 of the KVKK, which regulates the rights of data subjects, by using the Application Form to the Data Controller prepared for your convenience in accordance with the Communiqué on the Principles and Procedures for Applications to the Data Controller, available on Üntel Kablo’s website at https://www.untel.com.tr/.

Data Controller: Üntel Kabloları Sanayi ve Ticaret A.Ş.

Address: Demirciler Köyü Makine OSB, 6th Street No:4, Dilovası / İstanbul, Türkiye

E-mail: info@untel.com.tr