UTB Trade & Trader
DATA PROCESSING AND RETENTION POLICY

1. PURPOSE

As UTB Export-Import Software and Promotion Services (M. Bilgehan CANITEZ); Personal data of real persons, including our members, customers, visitors, suppliers and employees, are subject to the relevant legislation, especially the Constitution of the Republic of Turkey, the International Conventions on human rights to which our country is a party, and the Law on the Protection of Personal Data No. 6698 ("KVKK"). It is our priority to ensure that the rights of the data subject are processed effectively and that the data is processed.


Therefore, but not limited to those listed; Transactions regarding the processing, storage and transfer of data of our employees, suppliers, customers, visitors, members, users visiting our stores, website and mobile applications, in short, all personal data we obtain during our activities UTB Export-İthalat Yazılım and We perform  according to the Promotion Services (M. Bilgehan CANITEZ) Personal Data Protection and Processing Policy ("Policy").

For the purpose of protecting personal data, we take all administrative and technical protection measures required by the nature of the data in accordance with the legislation and up-to-date technology. This Policy covers the processing, storage, transfer, deletion or anonymization of personal data shared during our commercial, promotion- marketing or social responsibility and similar activities within the framework of the principles mentioned in the KVKK. explains the methods we follow.

With UTB Export-Import Software and Promotion Services (M. Bilgehan CANITEZ); Personal data of real persons, including our members, customers, visitors, suppliers and employees, are subject to the relevant legislation, especially the Constitution of the Republic of Turkey, the International Conventions on human rights to which our country is a party, and the Law on the Protection of Personal Data No. 6698 ("KVKK"). It is one of our fundamental responsibilities to ensure that the rights of the persons whose data are processed are used effectively by processing them in an appropriate manner.

2. SCOPE

All personal data processed by the Company, including our visitors, business contacts, business partners, employees, suppliers, members, and third parties, are within the scope of this Policy. This Policy prepared by our Company , has been prepared in accordance with the scope defined in the Personal Data Protection Law no. 6698 ("KVKK").

3. DEFINITIONS

Explicit Consent : It expresses the consent that is based on being informed and expressed freely on a particular subject.

Personal Data : Represents all kinds of information (name-surname, TR, e-mail address, date of birth, credit card number, etc.) relating to an identified or identifiable natural person.

Processing of Personal Data : Obtaining, recording, storing, keeping, changing, rearranging, disclosing, transferring personal data completely or partially automatically or non-automatically provided that it is a part of any data recording system,  means all kinds of operations carried out on the data such as taking over, making it available, classifying or preventing its use.

Personal Data Owner/Relevant Person : The real person whose personal data is processed refers to persons (customers, suppliers, employees, visitors, etc.).

Private Personal Data : The race, ethnic origin, political opinion, philosophical belief, Biometric and genetic data are personal data of special nature, including sect or other beliefs, clothing, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures.

Data Processor: Refers to the natural or legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller. For example, suppliers companies to which the employee candidates have sent their information.

Data Controller : It refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. is doing. Our company is considered as the data controller in this context.


KVK Board: Personal Data Protection Board.

KVKK : The Law on the Protection of Personal Data published in the Official Gazette dated 7 April 2016 and numbered 29677.

Policy : UTB Export-Ithal Software and Promotion Services (M. Bilgehan CANITEZ) Policy on Protection and Processing of Personal Data.

4. CLASSIFICATION OF PERSONAL DATA

Personal data: Personal data; Any information relating to an identified or identifiable natural person. The protection of personal data is only related to real persons, and information belonging to legal entities that do not contain information about a natural person is excluded from personal data protection. Therefore, this Policy does not apply to data belonging to legal entities. 


Private personal data : People's race, ethnicity, political Biometric and genetic data are personal data of special nature, with data related to thought, philosophical belief, religion, sect or other beliefs, disguise, membership to associations, foundations or trade unions, health, sexual life, criminal convictions, and security measures.

5. PURPOSE OF PROCESSING PERSONAL DATA

Many regulations in the legislation require personal data to be kept for a certain period of time. For this reason, we keep the personal data we process for as long as required by the relevant legislation or for the purposes of processing the personal data. In the event that the storage period stipulated in the legislation expires or the purpose of processing disappears, we delete, destroy or anonymize personal data. Our principles and procedures regarding retention periods are detailed in the "Data Retention and Disposal Policy".

• Planning, auditing and execution of information security processes

• Creating and managing information technologies infrastructure

• Executing our Commercial Activities,

• Contributing to Marketing Planning,

• Ensuring to take place in the International Competition Market,

• Providing information about the Target Market and the sector in the International Competition Market,

• To enable importers and exporters to meet through our e-commerce site and call center

• To save time and costs,

• Within the scope of the contract and to provide support services within the framework of service standards

• To identify the preferences and needs of our members/visitors and to shape and update our services within this scope

•  UTB Trader and Exporter To ensure communication between companies,

• To ensure cooperation between UTB Trader and Exporter Companies,

• To ensure that our legal obligations fulfill our legal obligations as required or mandated by legal regulations

• Compensation management

•  Planning and execution of production and/or operation processes

• Market research for sales and marketing of products and services planning and execution of activities

• Planning and execution of marketing processes of products and/or services

• Planning and execution of sales processes of products and/or services

• Ensuring that the data is accurate and up-to-date

• Evaluating job applications

• Contacting people who have a business relationship with the company

• Marketing

• Supporting the training, development and career processes of our employees

• Seller / supplier management

• Making legal reporting

• Billing

• Executing the Membership System

• Providing corporate communication

•  SMS, Electronic mail to send a newsletter, to engage in marketing activities or to make notifications.

6. GENERAL RULES REGARDING THE PROCESSING OF PERSONAL DATA

a) Compliance with the law and the rules of honesty: Our company, except for the exceptions defined in Article 5 part 2 of the KVKK, by obtaining the explicit consent of the individuals. works. It questions the source of the data it collects or comes to it from other companies and attaches importance to obtaining them in accordance with the law and within the framework of the rules of good faith.

b) Being accurate and up-to-date when necessary: Our company, institution It attaches importance to the fact that all data within its body are correct and not contain false information, and finally, if there is a change in personal data, it is important to update them if they are forwarded to it. The  information declared by the person concerned is considered correct.

c) Processing for specific, clear and legitimate purposes: Our company is only limited to the purposes it provides and for which it has been approved by the persons during the service. processes data. It does not process, use and make use of data other than for business purposes.

d) Being connected, limited and measured for the purpose for which they are processed: Our company only uses the data for the purposes for which they are processed and to the extent required by the service. .

e) Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed: Our company keeps the contractual data as long as the conflict periods of the Law, and the requirements of commercial and tax law. retains it. On the other hand, when these purposes disappear, it deletes  or anonymizes the data.

g) In case of collection, processing and use of personal data on our company's websites, mobile applications and other systems or applications, the relevant persons are subject to confidentiality. notification and  if necessary, about cookies.

7.  CONDITIONS OF THE PROCESSING OF PERSONAL DATA WITHOUT THE EXPRESS CONSENT OF THE RELATED PERSON

According to article 5 part 2 of the KVKK, in the presence of one of the following conditions, it is possible to process personal data without the explicit consent of the data subject:

a) It is clearly stipulated in the laws.

b) The life of the person himself or someone else, who is unable to express his consent due to actual impossibility or whose consent is not given legal validity or it is mandatory for the  protection of bodily integrity.

c) It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract.

ç) It is mandatory for the data controller to fulfill its legal obligation.

d) The data subject has been made public by himself.

e) Data processing is mandatory for the establishment, exercise or protection of a right.

f) Provided that it does not harm the fundamental rights and freedoms of the person concerned, Data processing is mandatory for the legitimate interests of the data controller

8. TRANSFER OF PERSONAL DATA

Transfer of personal data to the country :

As a company, it is determined in the KVKK about the transfer of personal data and by the KVK Board

We act in line with the decisions and regulations taken. Exceptions in the legislation are reserved

On the condition that personal data and special quality data can be used without the express consent of the Relevant Person.

It is not transferred to individuals or legal entities by us. KVKK and other legislation exceptional

In cases without the express consent of the Relevant Person, the data is bound in the manner and within the limits set forth in the legislation

It can be transferred to the administrative or judicial institution or organization authorized as

.In addition,

with exceptional circumstances;

•  In cases explained in the Policy

•  Öin the cases listed in the Policy regarding personal data of special nature

•  The KVK Board and the relevant legislation With the taking of the measures, the Relevant Person's

Health and personal data of special nature can only be used for the protection of public health, protective

the execution of medicine, medical diagnosis, treatment and care services, with health services

obligation to keep confidential for the purpose of planning and managing its financing; under

It can be transferred to individuals or authorized institutions and organizations without seeking explicit consent.


Transfer of personal data abroad :

As a rule, personal data is not transferred abroad without the explicit consent of the Relevant Person. However, this

In cases where one of the exceptional cases of the policy exists, the third party abroad; people

but:

•  Existence in countries where there is sufficient protection declared by the KVK Board

•  In Turkey and the foreigner in question if it is located in countries where there is no adequate protection

The data controllers in the country must undertake adequate protection in writing and KVK

Personal data may be transferred abroad without express consent, provided that the Board has permission.

Institutions and organizations to which personal data is transferred:

•  YTB Trader membership package holders,

•  Export Company membership package holders,

•  Supplyçforward

•  To our business partners and business contacts

•  To technical services

•  To transport companies

•  To cargo companies

•  To legally authorized public institutions and organizations

•  Can be transferred to legally authorized private legal persons in accordance with the principles and rules explained above.



9. LIGHTING RESPONSIBILITY AS DATA RESPONSIBLE

Our company provides the following information to the relevant persons during the acquisition of personal data.

a. Our company identity,

b. The purpose for which personal data will be processed,

c. To whom and for what purpose the processed personal data can be transferred,

d. Method and legal reason for collecting personal data,

e. Other rights listed in article 11



10. RIGHTS OF THE RELATED PERSON STATED IN KVKK Art. 11

According to article.11 of the KVK Law, you have the rights listed below. This facilitates your rights

An application form has also been prepared by our Company for you and is on your website

It is presented to you.

Persons whose personal data are processed, by applying to the person who is announced on our website by our Company

regarding its own data;

1. öLearning whether personal data is processed,

2. If personal data has been processed, requesting information about it,

3. ölearning the purpose of processing personal data and whether they are used in accordance with its purpose,

4. Third, where personal data is transferred at home or abroad; know people,

5. Requesting correction of personal data in case of incomplete or incorrect processing and this

Third of the process carried out within the scope of the transfer of personal data; requesting people to be notified,

6. Within the framework of the conditions set forth in Article 7 of the KVK Law, KVK and other relevant legal provisions

Although it has been processed appropriately, in case the reasons requiring its processing disappear

to request the deletion or destruction of personal data and to


Third where data is transferred; requesting people to be notified,

7. The person himself

by analyzing the processed data exclusively through automated systems

to object to the emergence of a result against her,

8. In case of loss due to unlawful processing of personal data,

has the right to demand its removal.



11. RELATED PERSON INFORMATION REQUEST METHOD

The person concerned can apply to our Company regarding the above-mentioned rights;

Fill the application form, which can be obtained from the official website of the company, and with a wet signature

after signing

a. By personally delivering to our company address

b. Committed to return by mail to our company address by letter,

c. By mail to our company address through a notary public.

Our company fulfills the requests in the application at the latest according to the nature of the request; within thirty days

concludes for free in a short time. However, the process in question requires an additional cost

In this case, the fee in the tariff determined by the KVK Board may be charged. The company may accept the request

can refuse by explaining the reason such as; gives its answer in writing or electronically.



12. RIGHT OF COMPLAINTS TO THE INSTITUTIONAL PERSON

Rejection of the application, insufficient response or response to the application within the time limit

in cases where it is not given; the data owner, thirty years from the date he learns the answer and in any case, the application

has the right to lodge a complaint with the KVK Board within sixty days from the date of.

You can apply according to the procedures specified on our corporate website with the notification of violations.

Click here for the KVK Application and Information Request Form.

Our company will adopt this Policy as soon as possible and annually in the changes in the Personal Data Protection Law.

It is reviewed at least once and makes the relevant adjustments.

Our company, by publishing this Policy on its website, informs the said Personal Data Owners

Informs about the law.

CLARIFICATION TEXT

UTB Export-Import Software and Promotion Services (M. Bilgehan CANITEZ). (the "Company") will be recorded, classified, preserved,   will be updated, will be subject to the relevant processes in accordance with the processing conditions described in the Law, and will be transferred to third parties and institutions in cases and to the extent permitted by the legislation. This  Clarification Text in question is in compliance with the applicable legislation, especially the Law, and published by the Board

It has been arranged in accordance with the rules shown in the regulations, communiqués, decisions and guides.

1. RELATED PERSON

Relevant persons within the scope of this Clarification Text are all real and legal persons with the qualification of "YTB Trader" defined on the Company website.

2. DATA SPEAKER

Your personal data will be collected and processed within the scope described below by UTB Export-Import Software and Promotion Services (M. Bilgehan CANITEZ) as the data controller. For your questions regarding transactions involving your personal data, you can contact the said Company via the e-mail address [email protected].

3. PERSONAL DATA

Any information relating to an identified or identifiable natural person. In this context, anonymous information, anonymized information and other data that cannot be associated with a specific person are not considered as personal data

. (KVKK art 3/I (ç))

A real person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, and clothing, association, foundation or union Membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data are considered special personal data. (KVKK art. 6)

4. GENERAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA

Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, obtaining personal data in whole or in part by automated or non-automatic means, provided that it is a part of any data recording system. Any operation that can be carried out on personal data, such as bringing, classifying or preventing its use, means "processing of personal data". (KVKK art. 3/I

(d))

As a company, we process personal data in accordance with the principles listed below and within the framework of the purposes set forth under the heading "Purposes of Processing Personal Data" in this information and clarification text:

(i) To comply with the law and the rules of honesty,

(ii) To be accurate and up-to-date when necessary,

(iii) To be processed for specific, clear and legitimate purposes,

(iv) Being connected, limited and restrained with the purpose for which they are processed

(v) Being kept for the period required by the relevant legislation or for the purpose for which they are processed

3. PURPOSE, COLLECTION METHODS AND LEGAL REASONS FOR THE PROCESSING OF PERSONAL DATA

Our company clearly reveals the purposes of processing personal data and processes personal data within the scope of purposes related to these activities in line with its communication activities. Your personal data collected through the channels and methods specified in this Illumination Text are processed and stored by the Company for the following purposes:


Personal Data Processed

•  Name and surname,

•  Languages he knows,

•  Phone number, e-mail address

•  Message content, message subject

•  Photos, information and all kinds of documents you have submitted

Purposes of Personal Data Processing

• Execution of the membership registration process,

• Establishment of communication channel between members.

• Performing the necessary verifications in case of conflicts that may arise,

• Ensuring the security for the activities related to the data controller,

• Ensuring and executing the relevant information security,

• Security and execution of access authorizations,

• Relevant archive and preservation studies,

• Implementation and management of related service and contract processes,

• Transferring information to institutions, organizations and persons authorized within the scope of the law,

• Transferring information about companies that are exporters and/or manufacturers that are paid members within the scope of the working purposes of this digital platform and database,

• Announcement of objectionable and suspicious situations,

• Fulfillment of savings such as taking, suspending or canceling registrations,

• Performing identity confirmation procedures,

• UTB Sharing the data processed as a trader with the relevant businesses,

• The processes of sharing and identifying and removing requests that do not comply with the purposes of use of the digital platform,

• Studies on the execution, control and sustainability of the business activities of the relevant digital platform

• Execution of related events, training activities and organizations,

• Execution of requests and complaints and possible legal proceedings,

Legal Reasons for the Processing of Personal Data
Your personal data, in line with the realization of the above-mentioned purposes by the Company, is subject to 5/2-c of the Law No. 6698. It is processed in line with the legal reason that "it is necessary to process the personal data of the parties of the contract, provided that it is directly related to the establishment or performance of a contract".
Personal Data Collection Methods
Your personal data mentioned above is collected through the contact forms on the website and any means you have contacted.



4. TRANSFERRING PERSONAL DATA

The Company is responsible for the disclosure of your personal data, which you have transmitted for the purposes described and listed above, without the requirement of express consent; To the administrative and official authorities that need to be transferred legally, to the relevant persons and institutions in order to fulfill the legal obligation and to the legal obligations, to independent audit companies, tax consultants and other external professional consultants, lawyers, insurance companies, due to legal obligations and within the framework of legal restrictions, partners, domestic and foreign third parties from which services are received or will be received, our shareholders, our business partners, member businesses registered on this digital platform, legally authorized public institutions and private persons, as well as those specified in Articles 8 and 9 of the KVK Law. Personal data can be transferred within the framework of the terms and purposes of processing  as well as other legal regulations.

5. YOUR LEGAL RIGHTS

In the Communiqué on the Procedures and Principles of Application to the Data Controller, regarding the requests regarding the rights of the owners of the data in the capacity of UTB Trader; name-surname, signed application letter, for citizens of the Republic of Turkey T.R. identification number, nationality for foreigners, passport  number or identity number if any, place of residence for notification, if available, electronic  mail address, telephone and fax number, subject of request in writing or registered e-mail (KEP) address, secure Identity can be confirmed by using electronic signature, mobile signature or the e-mail address previously notified to the Company by the relevant person and registered in the Company's system. .................................................................. If it is sent to ..................... address or [email protected] e-mail the necessary action will be taken regarding the relevant request within 30 days at the latest. However, The claimant is responsible for the financial expenses that may arise during the execution of the relevant transaction. In this  frame, the relevant persons are; to learn whether personal data is processed, to request information about it if personal data has been processed, to learn the purpose of processing personal data and whether they are used in accordance with its purpose, to know the third parties in the country or abroad to whom personal data is transferred, in case of incomplete or incorrect processing of personal data requesting the correction of these and requesting the notification of the transaction made in this context to the third parties to whom the personal data has been transferred, requesting the deletion or destruction of the personal data in the event that the reasons requiring processing disappear despite the fact that it has been processed in accordance with the provisions of the law and other relevant laws, and requesting the personal data to be deleted or destroyed within this scope They have the right to request the notification of the third parties to whom the data has been transferred, to object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems, and to demand the compensation of the damage in case of damage due to the unlawful processing of personal data.< br/>

The Company undertakes to implement the legal provisions in the context of possible changes in the relevant legislation regarding the Clarification Text on the Protection of Personal Data.

HOW TO CONTACT US

The application channels, methods and procedures are explained in detail in the content of the "KVKK Related Person Application Form" on our website. It is possible for you to provide the necessary information and documents through the aforementioned tab.


Data Controller : UTB Export-Ithal Software and Promotion Services (M. Bilgehan CANITEZ)

Address : ................................ .........Konya

Phone : +90 332 ......

DATA RETENTION AND DESTRUCTION POLICY

I. INTRODUCTION

1. PURPOSE

The purpose of this policy; Pursuant to the "Law on the Protection of Personal Data" and the regulations and communiqués in force, the data processing activities by UTB Export-Import Software and Promotion Services (M. Bilgehan CANITEZ) in accordance with the law are essential, especially the privacy of the data owners. The purpose of this Policy is to determine the principles of the destruction process and other obligations regarding the protection of the rights and freedoms and the storage of the personal data obtained and deletion, destruction and anonymization when necessary.

2. SCOPE

Any information relating to an identified or identifiable natural person is used as personal data by the Company as data controller fully or partially automatically or by non-automatic means provided that it is a part of any data recording system. Based on the fact that all kinds of transactions such as obtaining, recording, storing, preserving, changing, rearranging, explaining, transferring, taking over, making available, classifying or preventing its use are considered as data processing activities by the Company. Establishing the procedures and principles of the destruction process for the deletion, destruction and anonymization of personal data, when necessary, following the data processing activity carried out, determines the scope of this Policy.

3. DEFINITIONS

Explicit consent : Anonymization of  consent on a specific subject, based on information and free will,

Anonymous: Making personal data not be associated with an identified or identifiable natural person under any circumstances, even by matching with other data,

Relevant person : Real person whose personal data is processed,

Relevant user : Except for the person or unit responsible for the technical storage, protection and backup of the data, the real person processing personal data within the organization of the data controller or in line with the authorization and instruction received from the data controller. or legal persons,

Destruction : Deletion, destruction or anonymization of personal data,

Law :Law on the Protection of Personal Data No. 6698 dated 24/3/2016,

Blackout such as scratching, painting and icing all of the personal data so that it cannot be associated with an identified or identifiable natural person. operations,

Recording medium : Any  media in which personal data is processed wholly or partially automatically or non-automatically, provided that it is a part of any data recording system,

Personal data : All kinds of information relating to an identified or identifiable natural person,

Processing of personal data : Wholly or partially automatic personal data or by non-automatic means provided that it is a part of any data recording system, such as recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing its use. any  processes carried out on the data,

Personal data retention and destruction policy: Data controllers determine the maximum period required for the purpose for which personal data is processed, and delete, destroy and the policy on which they are based on the process of anonymization,

Board : Personal Data Protection Board,

Authority : Personal Data Protection Authority,

Periodic destruction : In the event that all the conditions for the processing of personal data in the law are eliminated, the deletion will be carried out ex officio at repetitive intervals as specified in the personal data storage and destruction policy, no

Data registration system : The registration system in which personal data is structured and processed according to certain criteria,

Data controller : The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system,

Regulation : Deletion, Destruction or Deletion of Personal Data No. 30224 Refers to the Regulation on Anonymization.

4. IMPLEMENTATION OF THE POLICY AND RELATED LEGISLATION

This Policy is in line with the relevant legislation in force and in particular the Law on the Protection of Personal Data No. 6698, the Regulation on the Data Controllers Registry No. 30286 and the Deletion of Personal Data No. 30224, None It has been prepared in accordance with the rules set forth in the regulations, communiqués, resolutions and guides published by the Board, especially the Regulation on the Anonymization and Anonymization. In the event that there is a change in the Law or other relevant legislation by the Company after the publication date of the Policy and the Policy becomes incompatible with the said change, the amended provisions and rules will find an area of application. All communiqués, decisions and guidelines published by the Board are followed by our Company, and the rules stipulated by the Policy are kept up to date.


II. PROCESSES REGARDING THE STORAGE AND DISPOSAL OF PERSONAL DATA

1.  REASONS REQUESTING THE STORAGE AND DISPOSAL OF PERSONAL DATA


Personal data processed in our company within the framework of our activities are kept for the period stipulated in the relevant legislation and are kept for the retention periods. To provide the company, service and product, to provide services to those concerned, to better understand the needs of those concerned, to develop relations of those concerned, to offer special offers via e-mail, telephone or mail, to market our products and services, to comply with applicable legal processes, and to exercise our legal rights. to follow; managing recruitment processes; Processes and stores personal data in order to   fulfill its obligations under the employment contract between the Company and the personnel. It is deleted, destroyed or anonymized ex officio or upon request:

 Changing the provisions of the relevant legislation which are the basis for the processing or storage of personal data,

 To prevent the processing or storage of personal data the disappearance of the purpose that requires it,

• The conditions that require the processing of personal data in Articles 5 and 6 of the Law are  extinct.

• In cases where the processing of personal data is only based on the condition of explicit consent,  revocation of the consent of the relevant person,

 The application of the person concerned regarding the deletion, destruction or anonymization of his/her personal data within the framework of the rights in subparagraphs (e) and (f) of Article 11 of the Law, Accepted by the Controller,

 The Data Controller rejects the application made to him by the data subject for the deletion, destruction or  anonymization of his/her personal data, or if the answer given is insufficient, or a response within the time stipulated in the Law. in case of   Complaining to the Board and approval of this request by the Board,

2. PERSONAL DATA RECORDING AND STORAGE ENVIRONMENTS

Personal data recording medium refers to any environment in which personal data is fully or partially automated or processed by non-automatic means, provided that it is a part of any data recording system.


Personal data regarding the data subject persons are secured by our Company in accordance with the relevant legislation and within the framework of international data security principles, especially the provisions of the KVKK No. 6098. somehow the following data is stored in the recording medium:

a) Technical recording media:

• Computer environment,

• Central servers,

• Optical discs(CD, DVD etc.),

• Removable memory(USB, Memory Card etc.),

• Information security devices and software,

• Fully or partially automatic data recording systems (servers of card readers, face recognition machines and tools.)

b) Non-technical data recording media:

• Papers,

• Manual data recording systems

• Written, printed and visual media,

• Cabinets of relevant departments.

3. STORAGE AND DISPOSAL PERIOD OF PERSONAL DATA

It should be kept for as long as  In this context, your personal data, which are processed in accordance with the principles and rules that must be observed in data processing activities and kept at our Company, are kept for the period necessary for the purpose for which they are processed; In the event that personal data is deleted, destroyed or anonymized, it is deleted, destroyed or anonymized within the first periodic destruction period following the date on which this obligation arises.



The periods of data storage and destruction processes by our company are included in the Annex-1 Personal Data Storage and Destruction Periods. Except for the periods specified in Annex-1 by our company, the period of time for periodic destruction is limited to a maximum of 6 months.


Our company is responsible for the deletion, destruction or acts in accordance with the general principles set forth in article 4 of the Law and the technical and administrative measures set forth in article 12.


Deletion of personal data by us, no All transactions regarding the storage and anonymization of data are recorded and kept for at least 3 years in accordance with the legal obligation.


Assigned by the Company regarding the storage and destruction of data Personal data specialist personnel is the person responsible for the execution and supervision of the personal data storage and destruction policy.

4. Deletion, Destruction and Anonymization of PERSONAL DATA AND TECHNIQUES

Personal data processed by the Company is subject to "Deletion, Destruction or Anonymization of Personal Data", pursuant to Article 7 of the Law. It is deleted, destroyed or anonymized ex officio or upon the request of the relevant data owner, in the event that the reasons that require it to be processed are eliminated in accordance with the provisions of the "Regulation on the Law".

a) Deletion of personal data

Deletion of personal data is the process of rendering personal data inaccessible and  usable again for the relevant users.

  Location on Servers Domain Personal Data: For the personal data on the servers whose  requires to be kept, the deletion process is performed by the system administrator by removing the  access authorization of the relevant users.

  Electronics /Personal Data in the Digital Environment: Personal data in the electronic environment, which require their storage, are rendered inaccessible and non-reusable for employees (relevant users) in any way.


 Personal Data in the Physical Environment: Other employees, except for the unit manager, responsible for the document archive for those whose period has expired, from the personal data kept in the physical environment It is rendered inaccessible and unusable again. In addition, the blackening process is also applied by drawing/painting/deleting  in a way that cannot be read.


b) Destruction of personal data

Destroying personal data is the process of making personal data inaccessible,  recoverable and unusable by anyone in any way.

  In the Physical Environment Personal Data Included: Among the personal data in the paper media, the ones that need to be kept  are irreversibly destroyed in the paper clipping machines.

  Electronic/ Personal Data in the Digital Environment: While the data processed by fully or partially automated means and stored in digital media are deleted;

  In no way accessible to the Relevant Users and Methods for deleting the data from the relevant software in a way that will be rendered unusable again are used.

c) Anonymization of personal data

Anonymization of personal data, personal data Even if it is matched with other data, it cannot be associated with an identified or identifiable natural person under any circumstances. 


All kinds of technical   ; and, although administrative measures are taken, it is made anonymous by applying methods in accordance with our personal data retention and destruction policy.

PROCESSSTORAGE PERIODDISTORAGE TIME
Human resources processesContract period + 10 yearsWithin the first periodic destruction period after the end of the retention period
Membership related records10 yearsWithin the first periodic destruction period after the end of the retention period
ContractualContract period + 10 yearsFirst periodic destruction after expiry of storage period  within the period
Member transaction information10 yearsWithin the first periodic destruction period after the end of the retention period
Personal data of members3 yearsWithin the first periodic destruction period following the expiry of the retention period
Visual and audio recordings1 month Within the first periodic destruction period after the end of the retention period
E-mail recordsContract period + 10 yearsWithin the first periodic destruction period after the expiry of the retention period
Customer information sheetsTerm of commercial activity + 5 yearsEnd of retention period  within the first period of periodic destruction
Personal information kept under the Labor Law10 years from the end of the employment relationshipWithin the first periodic destruction period after the end of the retention period
Occupational health and safety practicesContract period + 10 yearsEnd of storage period within the period of the first periodic destruction
Tax records informationTerm of commercial activity + 5 yearsWithin the first periodic destruction period after the end of the storage period
Financial recordsTerm of commercial activity + 5 yearsFirst following the expiry of the retention period  within the period of periodic destruction
Personal data of visitors2 years Within the first periodic destruction time following the end of the retention period
Cookie and Log Records6 monthsWithin the first periodic destruction period after the end of the retention period
COMMERCIAL ELECTRONIC TRANSMISSION CONFIRMATION
Law No. 6563 on the Regulation of Electronic Commerce and Commercial Communication and Commercial In accordance with the Regulation on Electronic Messages, telephone, call centers, fax, automatic dialing machines, smart voice recording systems, electronic mail, short message service. data, sound and image, which are carried out electronically and sent for commercial purposes, using Messages with content are considered as commercial electronic messages. In this context, this commercial Sending such messages is possible with prior approvals from the recipients.

By accepting the Consent Form here By accepting the Approval Form here, UTB Export-Import Software and Promotion Services (M. Bilgehan CANITEZ) By accepting the Approval Form here, informing with all kinds of commercial posts to be made by It is possible to communicate with e-mails and messages within the scope of its activities, You agree that the records can be shared with official institutions and organizations.

Even if you do not accept the Approval Form here, you can benefit from the services of our company. You will continue to benefit. At all times, even if you have given such consent You can revoke your consent by contacting us at [email protected]. you can. You will receive your cancellation request within 3 working days from the receipt of our company. The sending process of the messages to be sent will be stopped.
INTERESTED PERSON APPLICATION FORM

Relevant person in the Law on Protection of Personal Data No. 6698 ("KVK Law") to the personal data owners defined as  (hereinafter referred to as "Relevant Person"), Making certain requests regarding the processing of personal data in accordance with Article 11 of the KVK Law right has been granted. The aforementioned request rights;

a) Learning whether personal data is processed,

b) Personal data requesting information about it if it has been processed,

c) The purpose of processing personal data and whether they are used in accordance with their purpose

ç) To know the third parties to whom personal data is transferred in the country or abroad,

d) Requesting correction of personal data in case of incomplete or incorrect processing,

e) As stipulated in Article 7, to request the deletion or destruction of personal data within the framework of the conditions,

f) in accordance with paragraphs (d) and (e)

to notify the third parties to whom the personal data has been transferred,

g) The processed data shall be exclusively Objection to the emergence of a result against the person by analyzing it through automated systems

ğ) In case of loss due to unlawful processing of personal data, to remedy the damage

request.

In accordance with the first paragraph of Article 13 of the KVK Law; to our Company, which is the data controller

The applications to be made regarding these rights can be made in writing or by the Personal Data Protection Board ("Board")

Applications can be made by printing out the attached form

• With the application of the person concerned,

• Via a notary public or

• From the  electronic mail address that the Relevant Person has previously notified to our Company and registered in our Company's system.

Information regarding written application channels specific is given


Application Method
Application Address
Conditions to be Indicated in the Content of the Post
Personal Application (Personal Application of the Relevant Person to apply with a supporting document)
Company address will be specified
"Protection of Personal Data" on the envelope Information Request within the Scope of the Law" will be written.
Notification via notary
Company address will be specified
"Information Request Under the Law on Protection of Personal Data" will be written in the notification envelope.
To our company by e–mail to be sent from the e-mail address that he has previously notified and registered in our company's system
[email protected]
In the subject part of the e-mail, "Personal Data Protection Law Information Request"

Our company provides additional information to verify the identity of the Related Person in the applications to be made by the Related Person via e-mail. may take the necessary measures. In addition, after other methods to be determined by the Board are announced, this How the applications will be received will be announced by our Company. In accordance with the second paragraph of Article 13 of the KVK Law, from the date of receipt of your request according to the nature of the request. will be replied within thirty days from Our responses are in written form in accordance with the provisions of Article 13 of the relevant KVK Law. or electronically.

TEXT OF EXPLICIT CONSENT
The relevant personal data to be processed within the scope of the Clarification Text, the classes of these data, the processing purposes, persons to be transferred, collection approaches and legal reasons, data controller's rights and identity have been explained in a detailed and understandable manner, and this the information text has been read and understood.
5/2 of the Law on Protection of Personal Data No. 6698 a, c, ç, Explained in e, f subparagraphs "prescribed by law, establishment or performance of the contract, legal fulfillment of the obligation, establishment, establishment or performance of a right, exclusion of those processed pursuant to the exception provisions within the framework of "legitimate interest" provided that; Purpose in the clarification text of my personal data, except for the exception provisions, limited to subject, class, transfer, method and legal reason, to the places described, in the entirety of this statement, all relevant meaning and aware of the consequences, conscious of the possible consequences in the future, with my free will I approve.
I declare that the personal data I have shared with the company are correct and up-to-date I accept and declare that in case of any changes, I will notify the Company about these changes, In addition, including my personal data of special nature explained in the KVK Law, The processing of my personal data is limited to the purpose of being processed within the scope of the relevant process. It is open to be used, shared, stored within the required time, provided that that I have consented and that the necessary illumination has been provided to me in this regard; herein text, Company Personal Data Protection and Processing Regulation and Disclosure I accept that I have read and understood the text.

By clicking the above statement, commitment, acceptance and express consent button I'm doing it.
Cookie Policy
As UTB Export-Import Software and Promotion Services (M. Bilgehan CANITEZ) ("Company"), online Cookies, pixels, gifs to improve your experience during your visits to our channels. We make use of some technologies such as ("cookies"). The use of these technologies was initially numbered 6698. In accordance with the legislation we are subject to, including the Law on the Protection of Personal Data ("KVK Law") way is carried out. The purpose of this Cookie Illumination text is the www.ytbtrade.com/tr internet operated by us. by Site users/members/visitors ("Relevant Person") during the operation of the Site ("Site") Information to you regarding the processing of personal data obtained during the use of cookies is to give. In this text, which type of cookies we use for what purposes on our site and how to use these cookies. We would like to explain to you how you can control it. As a company, you can opt out of using the cookies we use on our site, choose their types or we may change its functions or add new cookies to our site. Therefore, this lighting We reserve the right to change the provisions of the text at any time.

1. PURPOSE OF USE OF COOKIES

The data we obtain through cookies from users visiting our website are as follows: We use it for the purposes: • To provide the basic functions necessary for the operation of the website, • To improve the services offered to you by increasing the functionality of the website, • To improve the existing website and to offer new features on the site and to provide the features offered. personalize it according to your preferences, • Reminding the preferences and choices made by our visitors on the website to personalize the use of the website, • To ensure the legal and commercial security of the website, you and our Company, • Integration and analysis of different servers on which the website works, to increase performance on the site, • Determining the number of visitors to the site and making performance adjustments accordingly, or making it easier for visitors to find what they are looking for, • Ensuring that users' login information is remembered, • Increasing functionality and providing ease of use.

2. TYPES OF COOKIES USED

Cookies to perform the basic functions necessary for the website to work, to analyze the website. and improving its performance, increasing the functionality of the website and its ease of use. to personalize the use of the website and to ensure the legal security of our Company. It can be used to provide control and supervision of visits. • Mandatory Cookies Compulsory cookies to cookies that must be minimum for a targeted function to work is called. For security purposes, to ensure the correct functioning of our website is used. These types of cookies are necessary for site performance and are approved by our visitors. not subject. • Performance and Analytics Cookies Our members, users, customers and customers by performing performance analysis in the use of our site. we are improving the services we offer to our potential customers. Our visitors, Determining the most viewed pages on our site, whether our site is working properly or not. It is done with performance and analysis cookies. • Functionality Cookies The site is reminded of the preferences and choices made by our visitors on our site. services are personalized. of cookies on our website The information is in the table below.

•Target and Advertising Cookies Cookies to promote products and services on our site or in channels other than our site. we are using. In addition, with some of our business partners, advertising and promotion within or outside of our site. We can cooperate to do it. For example, if you click on an ad you see on our site, that you did not click on the ad, if after the ad has caught your attention, the ad will be removed from the service on the site to which it is directed. Cookies can be used to track whether you benefit from it.

3. USE AND CONTROL OF COOKIES

You have the right to customize your preferences by changing the browser settings in which you view our website. you have. If the browser you use offers this opportunity, you can access cookies through your browser settings. It is possible to change the preferences. Thus, it differs according to the possibilities offered by the browser. However, data owners can prevent the use of cookies without using cookies. Possibility to choose to receive a warning first or to disable or delete only some cookies exists. Preferences on this subject vary according to the browser you use and are subject to the general explanation. You can reach it at https://www.aboutcookies.org/. Your preferences for cookies are posted on our website. It may need to be done separately for each device you access.

You have the opportunity to customize your preferences regarding cookies by changing the settings of your browser. Google Adwords https://support.google.com/ads/answer/2662922?hl=en Google Analytics https://tools.google.com/dlpage/gaoptout Google Chrome https://support.google.com/chrome/answer/95647?hl=en Internet Explorer https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies Mozilla Firefox https://support.mozilla.com/en-US/kb/Cookies Opera https://www.opera.com/computer Safari https://support.apple.com/kb/ph19214?locale=en_EN

4. YOUR LEGAL RIGHTS

Data for the rights of the owners of the data in the capacity of UTB Trader. Explained in the Communiqué on the Procedures and Principles of Application to the Responsible Person; name-surname, signed application letter, for the citizens of the Republic of Türkiye, T.C. ID number, nationality for foreigners, passport number or identification number, if any, the place of residence for notification, if available, the basis for notification e-mail address, telephone and fax number, the subject of the request in writing or registered electronic mail (KEP) address, secure electronic signature, mobile signature or by the relevant person to the Company previously. identity confirmation using the e-mail address notified and registered in the Company's system. in an acceptable way .................................................. to ......................................... or If it is sent to [email protected] e-mail address, within 30 days at the latest, Necessary action will be taken. However, the demand for financial expenses that may arise during the execution of the relevant transaction. owner is responsible. In this context, the relevant persons; learning whether personal data is processed, personal data If the data has been processed, requesting information about it, the purpose of processing the personal data and their purpose learning whether it is used appropriately, where personal data is transferred at home or abroad knowing third parties, in case of incomplete or incorrect processing of personal data, request rectification and the process carried out in this context to third parties to whom personal data is transferred. to be notified, to be processed in accordance with the provisions of the law and other relevant laws. deletion or deletion of personal data in the event that the reasons requiring its processing disappear, to request the destruction of the process and to third parties to whom personal data is transferred. requesting notification, analyzing the processed data exclusively through automated systems objecting to the emergence of a result against the person by means of have the right to demand the compensation of the damage in case of loss due to unlawful processing. they have.

In the relevant legislation regarding the Clarification Text on the Protection of Personal Data In the context of possible changes, the Company undertakes to implement the legal provisions.

HOW TO CONTACT US

In the content of the title "KVKK Related Person Application Form" on our site, application channels, methods and methods are explained in detail. You provide the necessary information and documents through the aforementioned tab. possible.
REFERENCES