Skip to content Skip to sidebar Skip to footer
Mail-bulk Phone-alt
Close

n accordance with the regulations made in accordance with the principles of the Law No. 6698 on the Protection of Personal Data and the principles of the implementation regulation, the protection of your personal data and/or special personal data is important to us, Bolton Industrial Property Services and Attorney Deniz Dinar Uğur (hereinafter referred to as BOLTON). We are sensitive about the storage of all personal data and/or special personal data sent to us. In this context, we have taken the necessary measures as BOLTON within the framework of the provisions of the Protection of Personal Data and the implementation regulation. Our Privacy Policy, which has been prepared and put into effect for the protection of your personal data, is as follows.

1. DEFINITIONS

“Data Controller” refers to BOLTON SINAİ MÜLKİYET HİZMETLERİ, which determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

“Data Owner” refers to the real person whose personal data is processed. “Company” refers to BOLTON INDUSTRIAL MÜLKİYET HİZMETLERİ in accordance with this policy.

“Law” means the Personal Data Protection Law No. 6698.

“Personal Data” means any information relating to a natural person whose identity is determined or identifiable.

is being done.

“Special Personal Data” refers to data regarding individuals’ race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, appearance and dress, membership in associations, foundations or unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.

“Board” refers to the Personal Data Protection Board.

“Policy” means this “Privacy Policy”.

“Processing of Personal Data” means any operation performed on personal data, such as obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, either fully or partially by automatic means or, provided that it is part of any data recording system, by non-automatic means.

“Explicit Consent” refers to consent regarding a specific subject, based on information and expressed with free will.

“Destruction” means making personal data inaccessible, irretrievable and reusable by anyone.

“Deletion” means making personal data inaccessible and non-reusable for the relevant users in any way.

“Anonymization” refers to making personal data incapable of being associated with an identified or identifiable natural person in any way, even when matched with other data.

“Destruction” means deletion, destruction or anonymization of personal data.

“Data” refers to personal data and special personal data together.

  1. PURPOSE OF PRIVACY POLICY

Protection of personal data and compliance with the law are our basic principles. As BOLTON, in all our work, the personal data and/or special personal data we receive from you have been kept confidential and not shared with third parties. In this context, our company has always shown the necessary sensitivity regarding the protection of personal data and/or special personal data. Again, in accordance with the Law on the Protection of Personal Data No. 6698 (hereinafter referred to as the “Law” or “KVKK”), our in-company arrangements have been re-established; technical and administrative measures have been taken. As BOLTON, we accept, declare and undertake to comply with all obligations imposed by the law in the ongoing process.

 

  1. SCOPE OF PRIVACY POLICY

This Privacy Policy has been prepared in accordance with the Personal Data Protection Law No. 6698. Your personal data and/or special personal data are processed with your consent or in accordance with the law. Your data in question;

✓ Ensuring company security,

✓ To provide you with complete service,

✓ To be able to carry out our commercial activities,

✓ Your problems can be resolved quickly,

✓ It is used to increase our quality.

Some personal data and/or special personal data received from you are depersonalized and anonymized in the procedures stipulated by the Law. Data used for statistical purposes are not currently included in the regulation of the Law and the scope of our policy. As BOLTON, we have the right to change this policy in order to protect personal data within the scope of compliance with the Law. The privacy policy aims to protect the data obtained by any means of real and legal persons, customers, employees and all other persons with whom BOLTON is a solution partner. In this context, it contains various regulations in order to achieve the intended goal.

  1. BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA AND/OR SPECIAL NATURE PERSONAL DATA

Our basic principles regarding the processing of personal data and/or special personal data are as follows. In this context, these principles will apply to the data processed by BOLTON based on explicit consent or in compliance with the Law.

Being in Compliance with Law: BOLTON questions the source and legality of personal data and/or special personal data that it collects from real and legal persons through various means. In this context, it is important for BOLTON to obtain data in accordance with the law.

Compliance with the Rules of Integrity: BOLTON questions the source of personal data and/or special personal data that it collects from real and legal persons through various means. In this context, it is important for BOLTON to obtain data within the framework of the rules of integrity.

Limited, Proportionate and Related to the Purpose of Processing: BOLTON uses personal data and/or special personal data obtained through various means in accordance with the purpose of processing, limited and proportionate to the purpose of processing and to the extent required for the performance of the service.

Accuracy of Personal Data and/or Special Personal Data: BOLTON attaches importance to the accuracy and correctness of personal data and/or special personal data received from real and legal persons and collected through various means. However, BOLTON is not obliged to investigate the accuracy of personal data and/or special personal data declared by its customers or real and legal persons with whom it is in contact. Because this is not possible legally and in line with our working principles.

BOLTON attaches importance to notifying the company of any changes in the personal data and/or special categories of personal data it has obtained in various ways and updating the data if such changes are made.

Processing for Specified and Legitimate Purposes: BOLTON processes personal data and/or special personal data without obtaining the explicit consent of the data owner or within the framework of the exceptions provided by law. The purpose of processing each data is specific and no personal data processing activity is carried out for any illegitimate purpose.

Preservation for the Period Stipulated by Law and/or Necessary for the Purpose of Processing: BOLTON stores the personal data and/or special personal data it obtains for the period stipulated by the relevant laws and/or necessary for the purpose of processing. When the said purposes are terminated, the data is anonymized, destroyed or deleted.

 

  1. DELETION, DESTRUCTION AND ANONYMIZATION OF PERSONAL DATA

Your personal data and/or special personal data will be deleted, destroyed or anonymized upon the expiration of the statute of limitations and retention periods stipulated in the Law, completion of judicial processes or other requirements suitable for the purpose. Deletion, destruction and anonymization processes are carried out upon the request of the relevant data owner or by BOLTON ex officio (self-administration).

 

  1. PRINCIPLE OF PARTISM

The parsimony principle is also known as the maximum savings principle. Personal data and/or special personal data received through various means are transferred to our company’s system. According to the principle in question, data is processed into the system as much as necessary. The data to be collected by BOLTON is determined and varies in accordance with the purpose. In this context, data is collected in accordance with the purpose and data that is not parallel to the purpose is not collected. Excess data other than its purpose is not recorded in the company system, it is deleted, destroyed or made anonymous. However, the data in question can be used for statistical purposes.

 

  1. PRIVACY AND SECURITY OF DATA

As BOLTON, we attach importance to the confidentiality of your personal data and/or special personal data. In this context, your personal data and/or special personal data reaching our Company through any means are confidential. BOLTON complies with the confidentiality of the data in question at every stage of its commercial activities. In this context, full compliance with this company privacy policy is ensured. Necessary technical and administrative measures are taken to prevent personal data and/or special personal data collected through various means from falling into the hands of unauthorized persons, to prevent the rights of the data owner from being harmed or victimized, and to protect the data. In addition, data protection is requested from third parties with whom we share personal data and/or special personal data within the framework of legal compliance, when necessary. Again, our software programs are updated and continuously renewed. In order to provide high-level protection, technological requirements are met and compliance with the standards is ensured.

 

  1. DATA CURRENTNESS

The principle of up-to-dateness is essential within BOLTON. Because personal data and/or special personal data obtained in various ways can be updated when necessary or upon request. Necessary measures regarding updating are also taken by BOLTON.

 

  1. ACCURACY OF DATA

The principle of accuracy of declared personal data and/or special personal data has been adopted by BOLTON. BOLTON is not obliged to investigate the accuracy of personal data and/or special personal data declared by its customers or real and legal persons with whom it is in contact. Because this is not possible legally and in line with our working principles. In this context, transactions are carried out on the basis that the declared data is accurate.

  1. PURPOSES OF PROCESSING PERSONAL DATA AND/OR SPECIAL NATURE PERSONAL DATA

The processing of personal data and/or special personal data is carried out in line with the purposes in the Information Texts of BOLTON. The Information Texts in question may vary depending on the personal data and/or special personal data processed. In parallel with the differences in the Information Texts, the purposes of processing personal data and/or special personal data may also vary.

 

  1. COLLECTION AND PROCESSING OF PERSONAL DATA AND/OR SPECIAL NATURE PERSONAL DATA WITHIN A CONTRACTUAL RELATIONSHIP

If a contractual relationship is established with customers or potential customers, personal data collected pursuant to the contract may be processed by BOLTON without obtaining explicit consent. In cases where special personal data is processed, data may be processed based on explicit consent or legal grounds within the scope of Article 6 of the Law. The data in question is used within the framework of the performance of goods and/or services, execution of the contract, and conduct of commercial activities. These data may be updated at any time by contacting customers.

 

  1. PERSONAL DATA AND/OR SPECIAL NATURE PERSONAL DATA PROCESSED THROUGH AUTOMATIC SYSTEMS

Data obtained from information obtained through automatic systems without the explicit consent of individuals cannot be used against individuals. BOLTON acts in accordance with the relevant legislation in personal data and/or special personal data processed through automatic systems.

 

  1. PERSONAL DATA AND/OR SPECIAL NATURED PERSONAL DATA OF BOLTON EMPLOYEES

PROCESSING WITHIN THE FRAMEWORK OF LEGAL OBLIGATIONS:

Personal data of employees may be processed by BOLTON without their explicit consent, unless there is an explicit provision in the relevant Law regarding the processing of data or in order to fulfill the legal obligations of the data controller.

PROCESSING OF PERSONAL DATA IN ACCORDANCE WITH THE EMPLOYMENT CONTRACT AND BUSINESS RELATIONSHIP:

Personal data of employees may be processed without the explicit consent of employees, within the framework of proportionality, as necessary to ensure the business relationship between the company and employees. BOLTON undertakes to protect and maintain confidentiality of employee data under all circumstances and to take the necessary measures in this regard.

PROCESSING OF SPECIAL NATURED PERSONAL DATA OF EMPLOYEES:

In accordance with the Law on the Protection of Personal Data No. 6698, the processing of special personal data requires the explicit consent of the person whose data will be processed and, in addition, the necessary measures prescribed by the Board. BOLTON takes both the explicit consent of the person concerned and the necessary measures determined by the Board when processing special personal data in accordance with Law No. 6698 and the principles of the Board, when necessary. However, special personal data may be processed without the explicit consent of the person concerned, in exceptional cases stipulated in the Law, provided that it is limited and proportionate.

PERSONAL DATA PROCESSED THROUGH AUTOMATIC SYSTEMS:

Some personal data of employees may be processed in automated systems. The data in question is used in the performance evaluation of employees, the keeping of statistical data, promotions and scoring within the company. Employees have the right to object to adverse results that arise regarding them. The objection must be made in accordance with the internal company rules and procedures. The objection in question is subject to evaluation within the company.

PROCESSING OF PERSONAL DATA FOR THE BENEFIT OF EMPLOYEES:

Personal data of employees may be processed by BOLTON without obtaining explicit consent within the framework of the relationship provided by the employment contract for transactions related to the employee’s benefit. Again, in disputes regarding the employment relationship with BOLTON, the Company may process personal data of employees.

INTERNAL TELECOMMUNICATIONS, INTERNET AND COMMUNICATIONS:

In order to facilitate the performance of the work, BOLTON may allocate computers, phones, cars, applications, software and e-mail to employees within the company. BOLTON may control and audit personal data on the vehicles it allocates within the scope of its disclosure obligations. The employee may not use the vehicles allocated to him/her for his/her private purposes. He/she must use them only for the purpose of performing the work. Again, the employee accepts, declares and undertakes that he/she will not keep any data or information other than the work and its necessity in the vehicles allocated from the moment the working relationship with BOLTON begins.

  1. DOMESTIC AND INTERNATIONAL TRANSFER OF PERSONAL DATA AND/OR SPECIAL NATURE PERSONAL DATA

BOLTON may transfer data domestically and internationally in accordance with the conditions stipulated in the Personal Data Protection Law and within the framework of the principles determined by the Board, in cases of compliance with the law or with the explicit consent of the relevant person. BOLTON acts in accordance with Articles 8 and 9 of Law No. 6698 when transferring personal data and/or special personal data.

  1. AUDIT AND TRANSACTION SECURITY

Necessary technical and administrative measures are taken to prevent unauthorized persons from obtaining personal data and/or special personal data collected through various means, to prevent the data owner from being harmed or victimized, and to protect the data. In addition, data protection is requested from companies with whom we share personal data and/or special personal data within the framework of legal compliance, when necessary. Again, our software programs are updated, continuously renewed and developed. All technological requirements are met and compliance with standards is ensured to ensure high-level protection. In parallel with all these, BOLTON conducts all internal and external audits required to protect personal data and/or special personal data.

  1. NOTIFICATION OF DATA BREACHES

In case of any breach of data, BOLTON immediately takes action to eliminate the breaches reported to it. It takes the necessary measures to minimize the damage to the relevant party. You can apply for the notification of breaches according to the procedures specified on our company’s website. In addition, if personal data and/or special personal data are obtained by unauthorized third parties, the company directly reports the matter to the Personal Data Protection Board.

  1. RIGHTS OF THE DATA OWNER RELATED PERSON REQUESTING INFORMATION

The rights of the data owner are regulated in Article 11 of the Personal Data Protection Law No. 6698. BOLTON accepts that the relevant person is informed before data processing and his/her explicit consent is obtained when necessary, and that the relevant person has the right to request information about his/her data after the data is processed, to update, delete, destroy and anonymize it. The relevant persons have the following rights through the “Information Request Form According to the Personal Data Protection Law No. 6698” from the relevant link on the web address https://dispatent.com.tr/;

  1. a) Learning whether personal data is being processed,
  2. b) Requesting information regarding the processing of personal data,
  3. c) To learn the purpose of processing personal data and whether they are used in accordance with their purpose,

d) To know the third parties to whom personal data is transferred, either domestically or abroad,

  1. d) Request correction of personal data in case it is processed incompletely or incorrectly,
  2. e) Request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the law titled “Deletion, destruction or anonymization of personal data”,
  3. f) Request that third parties to whom personal data has been transferred be informed that incomplete or incorrectly processed data has been corrected or that the data has been deleted or destroyed upon the request of the relevant person,
  4. g) To object to the emergence of a result to the detriment of the person himself/herself, by means of analysis of the processed data exclusively through automatic systems,
  5. h) To request compensation in case of damages due to unlawful processing of personal data.

The company will not respond to any requests for information made on behalf of someone else. If BOLTON detects that an application was made on behalf of someone else, BOLTON reserves all rights to sue and demand. The request will be responded to as soon as possible and no later than thirty days from the date the relevant person reaches BOLTON. If deemed necessary, BOLTON may request other information and documents from the relevant person who made the application.

BOLTON INDUSTRIAL PROPERTY SERVICES LIMITED