Privacy Policy

Privacy Policy

GRAFİT MADENCİLİK SAN.VE TİC. A.Ş.
“Personal Data Protection Law” Information Notice

Definitions

In this information notice, the following terms shall have the meanings set forth below:

• Personal Data Protection Law (“KVKK”): Refers to Law No. 6698 on the Protection of Personal Data, which entered into force after being published in the Official Gazette on April 7, 2016.
• Personal Data: Refers to any information relating to an identified or identifiable natural person.
• Data Controller: Refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data record system. (Hereinafter referred to as the “Company” for Grafit Madencilik San.Ve Tic. A.Ş.)
• Data Processor: Refers to the natural or legal person who processes personal data on behalf of the Data Controller based on the authority given.
• Contact Person: The person responsible for facilitating communication between the Data Controller and either the relevant individual or the Personal Data Protection Authority.

The target audience of this notice comprises all natural persons whose personal data are processed by our Company, excluding the employees of our Company or those candidates who have applied for employment with our Company.

PURPOSE OF PROCESSING PERSONAL DATA

The purposes and legal grounds for processing personal data are as follows:

The personal data you share—whether through automated or non-automated means—will be processed for the following purposes:

• To enable you and/or the institutions or organizations you represent to benefit from the products and services provided by our Company.
• To conduct administrative operations related to communications managed by our Company.
• To ensure the physical security and supervision of the locations used by our Company.
• To establish business partner/customer/supplier (authorized persons or their employees) relationships.
• To fulfill contractual requirements and financial reconciliations related to products and services offered jointly with our business partners, suppliers, or other third parties.
• To implement our Company’s human resources policies.
• To facilitate participation in events organized by our Company.

In accordance with Articles 4, 5, and 6 of the KVKK, your personal data will be processed in connection with the activities of our Company as detailed below, ensuring that:

• They are processed in compliance with the law and principles of honesty,
• They are accurate and, when necessary, kept up to date,
• They are collected for specific, explicit, and legitimate purposes,
• They are limited and proportional to the purposes for which they are processed,
• They are stored in accordance with the prescribed retention periods stated in the relevant legislation or as required for the purpose for which they are processed.

METHODS OF COLLECTING AND STORING PERSONAL DATA

The personal data you share with our Company may be collected, processed, and transferred for the purposes described in this Information Notice, in accordance with the basic principles stipulated by the KVKK and within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK. This may occur via automated or non-automated methods, through offices, branches, websites, social media channels, mobile applications, cameras, audio recordings, and other verbal, written, or electronic channels, and based on different legal grounds necessary for our Company’s operations.

Your personal data will be stored in electronic and/or physical environments. In order to prevent unauthorized access, manipulation, loss, or damage to the environments where your personal data is stored, our Company implements necessary business process designs and technical security infrastructure enhancements.

Your personal data will be processed with all necessary information security measures in place and will not be used for purposes other than those communicated to you. It will be stored and processed for the duration of the legal retention period or, if no such period is provided, for the period required by the purpose of processing. Once this period expires, your personal data will be removed from our data flows through deletion, destruction, or anonymization methods.

TRANSFER OF PERSONAL DATA

In accordance with Articles 8 and 9 of the KVKK, your personal data may be transferred to third parties deemed necessary for the continuation of our Company’s activities, within the framework of the personal data processing conditions and purposes specified above. Such third parties may include business partners, cooperating institutions, suppliers, company executives/employees, legally authorized public institutions and organizations, and legally authorized private law persons. No transfers will be made abroad.

RIGHTS OF THE PERSONAL DATA OWNER

Pursuant to Article 11 of the KVKK, every individual has the right to request from the Data Controller, in writing, with their identity and address verification documents attached, within a period not exceeding 30 (thirty) days, free of charge, regarding the following concerning their personal data:

a) To learn whether their personal data has been processed,
b) If processed, to request information about it,
c) To learn the purpose of processing their personal data and whether it is used in accordance with that purpose,
d) To know the third parties to whom their personal data have been transferred domestically or abroad,
e) To request the correction of any incomplete or incorrect personal data,
f) To request the deletion or destruction of personal data in accordance with the conditions stipulated in Article 7 of the KVKK,
g) To request compensation for any damage incurred due to the unlawful processing of their personal data,
h) To request that information about the transfer of personal data to third parties, as per subparagraphs (d) and (e), be communicated to them,
i) To object to the production of an adverse result solely based on automated system analysis of the processed data,
j) To request compensation for any damage incurred due to the unlawful processing of personal data.

For requests related to the above rights, if you submit a written application to Grafit Madencilik San. ve Tic. A.Ş., your request will be responded to free of charge within 30 (thirty) days at the latest. The application must be submitted clearly and understandably, with your identity and address verification documents attached, either in person, by mail, or through a notary channel to the following address:

Grafit Madencilik
860 Sok. No:14 Pirinç Center B-16
Konak / İzmir

Contact Person: Belma Ulubay
Tel: 02522253030

Additionally, for requests related to subparagraphs (f) and (g) and for any claims of damage due to the unlawful processing of personal data, you have the right to apply in writing to Sabancı Vakfı. Your request will be responded to free of charge within 30 (thirty) days at the latest. The application must be submitted clearly and understandably, with your identity and address verification documents attached, either in person, by mail, or through a notary channel to the following address:

Sabancı Vakfı
Sabancı Center
34330 4. Levent, Beşiktaş
Istanbul, Turkey