Privacy Policy

ESAS ENTEGRE SANAYİ SİSTEMLERİ LTD.

PRIVACY NOTICE

Purpose This Privacy Notice has been prepared by ESAS ENTEGRE SANAYİ SİSTEMLERİ (hereinafter referred to as the "ESAS") as the data controller, in accordance with Article 10 of the Personal Data Protection Law No. 6698 and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Obligation to Inform. It aims to inform you, as a data subject, in the capacity of employee candidate, employee, executive, shareholder, supplier, customer, visitor, and/or other relevant persons, regarding the data processing activities carried out by the Company.

Explicit Consent: Consent that is related to a specific issue, based on information, and expressed with free will
Data Subject: The person whose personal data is processed
Personal Data: Any information relating to an identified or identifiable natural person
Processing of Personal Data: Any operation which is performed upon personal data, wholly or partly by automatic means, or by non-automatic means which form part of a data filing system, such as collection, recording, storage, retention, alteration, rearrangement, disclosure, transfer, acquisition, making available, classification, or prevention of use
KVKK: Personal Data Protection Law No. 6698
Special Categories of Personal Data: Data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data
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

3. Data Controller
As ESAS ENTEGRE SANAYİ SİSTEMLERİ, we hereby inform you that the personal data you have provided or will provide to our Company in your capacity as an employee candidate, employee, executive, shareholder, supplier, customer, visitor and/or other relevant person, is being processed by us as the data controller within the scope of the Law on the Protection of Personal Data (KVKK) and other applicable legislation.

4. Purposes of Personal Data Processing and Categories of Processed Personal Data

Purposes of Personal Data Processing
Your personal data is processed for the purpose of carrying out the Company’s operations, in compliance with the limitations set forth in the Law on the Protection of Personal Data (KVKK) and other applicable legislation. In this context, your personal data is processed for the following purposes:

• Execution and supervision of business operations
• Obtaining necessary contact information to conduct business operations
• Creating necessary records in software systems used within the Company for business operations
• Execution of contractual processes
• Fulfillment and follow-up of mutual contractual and legal obligations
• Fulfillment of obligations arising from employment contracts and legislation, including the Labor Law No. 4857, the Occupational Health and Safety Law No. 6331, and the Social Insurance and General Health Insurance Law No. 5510; management of employee benefits and related processes
• Execution of occupational health and safety activities
• Fulfillment and follow-up of obligations arising from legal regulations
• Monitoring and management of legal affairs
• Execution of finance and accounting operations
• Execution of human resources processes
• Provision of information and documents to authorized public institutions and judicial authorities in cases specified by law
• Execution of data storage and archiving activities
• Ensuring the physical security of company premises
• Creation and monitoring of visitor logs

Categories of Processed Personal Data
The categories of personal data to be processed and/or currently being processed by our Company may vary depending on the group of individuals concerned. However, in accordance with the KVKK and other relevant legislation, and for the purposes and legal grounds specified in this Clarification Text, the following personal data may be processed:

• Identity Data: Name, surname, Turkish ID number, mother’s name, father’s name, place and date of birth, signature, etc.
• Contact Data: Residential address, workplace address, landline number, mobile phone number, email address, registered email (KEP) address, fax number, etc.
• Customer Transaction Data: Call center records, order and request information, information on transaction receipts, invoice details, promissory notes, check information, etc.
• Legal Transaction Data: Information in correspondence with judicial authorities, information in case files, etc.
• Physical Security Data: CCTV footage recorded within the company premises and entry/exit log data
• Financial Data: Financial records and payment information regarding services received or provided by the Company, balance of receivables and payables, balance sheet details, financial performance data, credit and risk information, etc.
• Employee-Related Data: In addition to the above data categories, the following may also be processed for employee candidates and employees: personnel records, professional experience information, transaction security data, vehicle data, family and next-of-kin information, reference details, visual records, health data, and data regarding criminal convictions and security measures.

5. Method and Legal Basis for Collecting Personal Data
Your personal data will be collected, either through automated or non-automated methods, verbally, in writing, or electronically, in order to fulfill the purposes specified under section (4) of this text, using the following means:

• Verbal communication of personal data by the data subject or their representative to our Company
• Physical delivery of written documents to our Company
• Sending documents to our Company via our corporate email or registered email (KEP) address
• Submission of data to our Company by filling out forms in written or electronic format
• Sending documents via fax to our fax number

Your personal data will be processed for the purposes stated in this document based on the legal grounds specified in Article 5(2) of the Personal Data Protection Law (KVKK), namely:

• (a) It is expressly provided for by law
• (b) It is necessary for the performance or conclusion of a contract to which the data subject is a party
• (c) It is necessary for the data controller to fulfill its legal obligations
• (d) It is necessary for the establishment, exercise, or protection of a right
• (e) Provided that it does not harm the fundamental rights and freedoms of the data subject, it is necessary for the legitimate interests of the data controller

In cases where processing of special categories of personal data is required within the scope of our Company’s activities, such data may be processed after providing the necessary information to you, and if required, obtaining your explicit consent in accordance with Article 6(3)(a) of the KVKK.

6. Transfer of Processed Personal Data to Third Parties and Purpose of Transfer
Your personal data may be transferred, without seeking your explicit consent pursuant to Article 8(2)(a) of the Law on the Protection of Personal Data (KVKK), to the parties listed below and for the purposes outlined here and in section (4) of this text:

• For the execution of contractual processes and the fulfillment of mutual contractual and legal obligations, your data may be shared with notaries, enforcement offices, courts, and/or authorized public institutions and organizations if necessary.
• For the purpose of legal proceedings, your data may be shared with our attorneys to the extent necessary, within the scope of confidentiality obligations.
• For the execution of business activities, your data may be shared to the extent necessary and under confidentiality obligations with domestic suppliers/software license holders responsible for the maintenance and installation of software programs used within our Company.
• For financial and accounting purposes, your data may be shared with the banks we work with and our financial advisors if necessary.
• For the fulfillment of our legal obligations under relevant legislation, your data may be shared with auditing firms and relevant institutions and organizations, provided they are based in Turkey.
• For the execution of contractual, procurement, and sales processes, your data may be shared with our domestic logistics service providers/contracted courier companies.
• For the fulfillment of legal obligations and provision of information to authorized persons, institutions, and organizations, your data may be shared with authorized public authorities.

In cases where the transfer of special categories of personal data is required within the scope of our Company’s activities, such data may be transferred after providing necessary information and, if required, obtaining your explicit consent in accordance with Articles 6(3)(a) and 8(1) of the KVKK.

7. Your Rights as a Data Subject

Pursuant to Article 11 of the Law on the Protection of Personal Data (KVKK), you may submit a request to our Company in person, provided that you can verify your identity, to:

• Learn whether your personal data is being processed and, if so, request information regarding such processing,
• Learn the purpose of processing your personal data and whether they are used in accordance with the intended purpose,
• Learn whether your personal data is transferred domestically or abroad and to whom they are transferred,
• Request the correction of your personal data if they are incomplete or incorrectly processed and request that such corrections be notified to third parties to whom the data has been transferred,
• Request the deletion or destruction of your personal data within the scope of the conditions set forth in Article 7 of the KVKK and request that such operations be notified to third parties to whom the data has been transferred. However, the Company will determine the most appropriate method of disposal (deletion, destruction, or anonymization) based on the specific circumstances. You may also request information regarding the justification for the selected method,
• Object to any outcome that may arise to your detriment as a result of the exclusive analysis of your personal data through automated systems,
• Request compensation if you suffer damage due to the unlawful processing of your personal data.

Your application will be concluded free of charge within thirty (30) days at the latest, depending on the nature of your request. However, if the process requires additional costs for the Company, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board, as per the “Communiqué on the Principles and Procedures for the Request to Data Controller.”

To exercise your rights regarding the processing of your personal data, you may submit your request by filling out the “Data Subject Application Form” available at esastechnology.com, or in accordance with Article 11 and the first paragraph of Article 13 of the KVKK and the Communiqué mentioned above, via the following methods:

• By sending a written application via notary public or registered mail with return receipt, to verify your identity and prevent disclosure to unauthorized parties,
• By sending an e-mail to kvkk@esastechnology.com using a secure electronic signature, mobile signature, or your e-mail address previously registered in our systems,
• Or through other methods that may be determined by the Personal Data Protection Board in the future.

WEBSITE USAGE
TERMS AND CONDITIONS AND DISCLAIMER

1. PURPOSE

1.1. ESAS (hereinafter referred to as “ESAS”) provides this website (“Site”) for your information, education, and communication. Please feel free to browse the Site. You may download the materials displayed on the Site for personal use only, provided that you also retain all copyright and other proprietary notices contained in the materials. However, without the prior written permission of ESAS, you may not distribute, modify, transmit, reuse, repost, or use the content of the Site—including text, images, audio, and video—for public or commercial purposes.

1.2. Your access to and use of the Site is also subject to the following terms and conditions and to all applicable laws of the Republic of Turkey. By accessing and browsing the Site, you accept, without limitation or qualification, the terms set forth herein.

2. TERMS AND CONDITIONS & DISCLAIMER:

2.1. Unless otherwise stated, everything you see or read on the Site is protected by copyright, and the texts and/or materials on this Site may not be used except as provided herein without the prior written permission of ESAS. ESAS does not warrant or represent that your use of materials displayed on the Site will not infringe the rights of third parties not owned by or affiliated with ESAS.

2.2. Although ESAS makes reasonable efforts to include accurate and up-to-date information on the Site, it makes no warranties or representations (i) as to the accuracy, completeness, reliability, usability, or results of the use of the materials and other content on this Site; (ii) regarding the availability of copyrighted, trademarked, or proprietary materials belonging to third parties that may be featured on the Site; or (iii) that any materials or promotional content found on or accessible through the Site are free of viruses, worms, Trojan horses, or other harmful components. You acknowledge that any reliance on such materials and other content found on the Site is at your own risk.

2.3. ESAS reserves the right, at its sole discretion but without any obligation, to correct any errors or omissions in any part of the Site.

2.4. ESAS may make changes to the Site, the materials, or any promotional content featured on the Site at any time without prior notice.

2.5. Without limitation to the foregoing, all materials and other content on the Site are provided "as is" and "as available" without any express or implied warranties of any kind, including but not limited to implied warranties of ownership, non-infringement, merchantability, or fitness for a particular purpose.

2.6. While ESAS makes efforts to keep the Site accessible 24 hours a day, it shall not be held liable for any unavailability of the Site at any time or for any duration, regardless of the reason.

2.7. ESAS reserves the right to suspend access to the Site, temporarily or permanently, at any time and without notice. ESAS shall not be liable for any loss or damage arising from the unavailability or suspension of the Site, whether based on contract, tort, or any other legal theory.

2.8. Any data, questions, comments, suggestions, or similar communications and/or materials you transmit to the Site by e-mail or otherwise shall be treated as non-confidential and non-proprietary. Anything you transmit or post may be used by ESAS or its affiliates for any purpose without restriction, including but not limited to reproduction, disclosure, transmission, publication, and broadcasting. Furthermore, ESAS is free to use any ideas, concepts, know-how, or techniques contained in any communication and/or material you send to the Site for any purpose, including but not limited to developing, manufacturing, and marketing products using such information.

2.9. The ESAS products, materials, and technologies displayed on the Site may be protected by foreign patents and may fall within the scope of such patents. Lists of specific product names and patent numbers may be provided at ESAS’s discretion upon request.

2.10. ESAS has not reviewed all the sites linked to the Site and is not responsible for the content of any off-site page or any other site linked to the Site. Your linking to any off-site pages or other sites is at your own risk.

2.11. ESAS controls the Site from its headquarters in Ankara, Turkey. No content from the Site may be used or exported in violation of Turkish laws and regulations.

3. APPLICABLE LAW AND JURISDICTION

3.1. The Site can be accessed from all provinces of Turkey and from other countries around the world. However, Turkish Law shall apply to any disputes arising from or related to the Site and the provisions herein. The Central Courts and Central Enforcement Offices of Ankara, Republic of Turkey, shall have exclusive jurisdiction.

4. UPDATES AND REVISIONS

4.1. ESAS may revise this text at any time by updating it. Such updates and revisions shall be binding on you, and it is your responsibility to periodically visit and review this text.

4.2. The accuracy and truthfulness of the information provided on the Site are not guaranteed by ESAS, and the information on the Site may be changed without prior notice to any user of the Site.

4.3. ESAS shall not be liable or responsible for any failure to provide information to any user of the Site.

Website Privacy and Cookie Policy Disclosure Statement

The purpose of this Cookie Policy is to inform you about the types and purposes of cookies obtained during the visits of users/visitors (“Data Subjects”) to the website operated by us at www.esastechnology.com (“Site”). By using the website, this Disclosure Statement shall be deemed to have been communicated to you.

ESAS may update and amend the provisions of this Disclosure Statement at any time by publishing them in various locations. Any such updates and amendments made by ESAS shall become effective as of the date of their publication.

1. DEFINITIONS AND ABBREVIATIONS
In this Disclosure Statement, the following terms shall have the meanings ascribed to them below:

ESAS: The legal entity that is considered the data controller within the scope of the Law on the Protection of Personal Data No. 6698, responsible for determining the purposes and means of processing personal data, and for establishing and managing the data recording system.

Personal Data: Any information relating to an identified or identifiable natural person.

Processing of Personal Data: Any operation performed on personal data, whether fully or partially by automated means or by non-automated means provided that it is part of a data recording system, such as collection, recording, storage, retention, alteration, reorganization, disclosure, transfer, acquisition, making available, classification, or prevention of use.

Data Subject (Personal Data Owner): The natural person whose personal data is processed.

KVKK: The Law on the Protection of Personal Data No. 6698, which came into force upon its publication in the Official Gazette on April 7, 2016.

Cookie: Small text files stored on your device or network server through browsers by the websites you visit, enabling the identification of the respective device.

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.

2. PERSONAL DATA PROCESSED THROUGH COOKIES
Through cookies, your usage and visit habits on the Site, session information, past transactions, and browsing data are processed.

3. PURPOSE OF PROCESSING PERSONAL DATA IN THE INTERNET
Your personal data processed through cookies are handled in compliance with the Data Protection Legislation and limited to the purposes stated below:

• Your browsing data on the Site are processed and securely stored to provide better service to our visitors.
• Your past transactions are stored to create a summary of your preferences.
• Your browsing data and/or usage history on the Site may be monitored to improve the Site’s content according to your preferences and/or to determine your preferences.
• Functional and analytical cookies are used to analyze how the Site is used and to improve your user experience.
• Data are processed to manage information security processes and access authorizations.

4. METHOD AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
Your personal data processed through cookies are obtained by ESAS during your visit to our website through channels such as:

• Website contact forms,
• Website visits,
• Log files, clear GIF files, and/or third-party sources.

Your personal data processed through cookies are collected electronically via cookies in accordance with the fundamental principles set forth in the Law on the Protection of Personal Data (KVKK) and processed based on the legal ground set out in Article 5(2)(f) of the KVKK:
“Processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”

ESAS may match information collected through different online and offline methods or at different times on the Site and may use such information together with data obtained from other sources, such as third parties.

5. WHO HAS ACCESS TO THE INFORMATION OBTAINED THROUGH THE PROCESSING OF DATA IN THE INTERNET AND TO WHOM THIS INFORMATION IS TRANSFERRED
The records stored and maintained in the digital environment are accessible by authorized personnel of ESAS Individuals with access to the records declare that they will maintain the confidentiality of the data they access through a confidentiality agreement.
The information stored and maintained in the digital environment may be shared with judicial authorities and legally authorized public institutions and organizations in accordance with the procedures and principles specified in the laws.
ESAS will not disclose the personal data it obtains to third parties in a manner contrary to this disclosure statement, and will not use it for purposes other than processing.

TYPES OF COOKIES

Below you can find the different types and classifications of cookies we use on our website:

6.1. FIRST-PARTY COOKIES:
First-party cookies are sent only to the relevant site each time you request a page from the site on your computer.
The website can recognize you both during your visit and on subsequent visits. For this reason, it is practically impossible to make full use of the internet with first-party cookies disabled in a browser.

6.2. THIRD-PARTY COOKIES:
Third-party cookies are cookies sent to another website while you are viewing a website.
Third-party cookies are used for digital marketing purposes and can be utilized by ad servers to use your behavior data from one site for ads displayed on another site, as well as in website analytics.

6.3. COOKIES BASED ON STORAGE DURATION:

PERSISTENT COOKIES: Persistent cookies are used to enhance the functionality of the website and provide visitors with a faster and better service. These cookies are used to remember your preferences and are stored on your device via browsers. Some types of persistent cookies can be used to provide personalized suggestions based on factors such as your purpose of visiting the site.

SESSION COOKIES: These cookies are used to separate the user's visit into sessions and do not collect data from the user. The cookie is deleted when the user closes the webpage or remains inactive for a certain period. The main purpose of using session cookies is to ensure that the website functions correctly during your visit.

 

6.4. COOKIES BASED ON USAGE:

Cookie Type	What's It Used For?	Do these cookies collect my personal information / can they identify me?
Necessary Cookies	Necessary cookies are essential for the proper functioning of the website. They are required for you to perform activities on the site and take advantage of the features offered by the site. An example of the use of necessary cookies is remembering previous actions when returning to a page within the same session. Necessary cookies do not have the ability to collect your personal information.	If the use of necessary cookies is not accepted, you may experience issues with using significant parts of the site and its performance.
Performance Cookies	Performance cookies help in analyzing the interaction of visitors with our site by providing information in areas such as visited areas, time spent on the site, and any encountered issues.	The use of performance cookies is necessary for improving the performance of the site. Performance cookies do not have access to personal identification information. All data obtained by performance cookies is collected in an anonymized manner.
Functionality Cookies	Functionality cookies are used to remember your site usage preferences such as "username, language you use, page layout settings" for a personalized online experience.	Functionality cookies may have access to personal data containing identifiers such as profile pictures and usernames if you are a registered member of the site. If the use of functionality cookies is not allowed, the performance of the website may be affected, and access to certain content may be restricted.
Targeting / Advertising Cookies	Targeting and advertising cookies are used to present content that is relevant to the interests of visitors. They can be used to remember the websites you visit, serve targeted ads, or limit the number of times ads outside the visitor's interest are displayed, as well as measure the effectiveness of advertising campaigns.	Targeting and advertising cookies are a type of "Third-Party Cookies" and many of these cookies can track visitors by their IP addresses and collect personally identifiable information. The collected information is accessible for marketing and advertising purposes by third parties that advertise on the site.

7. CONTROL AND BLOCKING OF COOKIE USAGE

Data owners have the right to personalize their cookie preferences by changing their browser settings. Depending on the browser used, users can change their cookie preferences through browser settings. Within the options provided by the browser, data owners have the ability to block the use of cookies, receive a warning before cookies are used, disable cookies, or delete them.
It is not mandatory to use cookies to access our site; you have the opportunity to personalize your cookie preferences by changing your browser settings.

Since changing and personalizing cookie settings may vary depending on the device used, it may be necessary to make separate cookie policy changes for each device accessed. Additionally, by clicking on the "Cookie Preferences" link on the Site, you can personalize your preferences for cookies, excluding Essential (Basic) Cookies.

To prevent the use of cookies, you will need to disable the "cookie usage feature" in your browser and delete any cookies associated with this website.

It is important to note that restricting the use of cookies will also restrict certain actions on our site. In particular, restricting the use of cookies known as "First-Party Cookies" will limit your access to certain sections of our site. The actions to restrict or block cookies can be performed by visitors at any time they desire.

 

8. SECURITY OF YOUR PERSONAL DATA

ESAS takes appropriate measures, consistent with relevant privacy and data security laws and regulations, to protect your personal data. Depending on the state of technology, implementation costs, and the nature of the data to be protected, technical and organizational measures are implemented to prevent risks such as destruction, loss, alteration, unauthorized disclosure, or unauthorized access to your data.
The personal data subject to this disclosure statement is stored within ESAS and is only accessible to a limited number of individuals. After the processing period, this personal data will be deleted, destroyed, or anonymized in accordance with ESAS's Personal Data Processing, Storage, and Destruction Policy.