Personal Data Protection Law (KVKK)

Through this policy notification, Aluform Pekintaş Aluminum Industry and Trade Inc. (“Aluform Pekintaş”) aims to clearly and transparently inform you about which personal data we collect, how and where we use it, and how we process it, within the scope of our existing or future products, goods, and services, in full compliance with all provisions of Law No. 6698 on the Protection of Personal Data (KVKK), especially Article 10, and other relevant legislation. This applies across the central office, regional directorates, factories, and group companies within the Aluform Pekintaş commercial organization.

We hereby declare that Aluform Pekintaş, together with its organizational units and other group companies, is committed to the fundamental principles of personal data protection, which include: processing personal data lawfully and fairly; keeping personal data accurate and up-to-date when necessary; processing personal data for specific, clear, and legitimate purposes; limiting the processing of personal data to what is relevant, proportional, and connected to the purpose of collection; retaining personal data only as long as required by applicable legislation or for the purpose for which it was collected; informing and notifying data subjects; establishing the necessary system for data subjects to exercise their rights; taking necessary measures to safeguard personal data; transferring personal data to third parties in accordance with relevant legislation and the regulations of the Personal Data Protection Board; and handling the processing and protection of special categories of personal data with the necessary sensitivity

1. What is a Data Controller? What is a Data Representative?

Within the scope of Law No. 6698 on the Protection of Personal Data (KVKK), Aluform Pekintaş acts as the data controller. In other words, in accordance with the regulations based on this law, a data controller is defined as the legal entity that determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

Aluform Pekintaş, including its central office, regional directorates, factories, and, if necessary, its group companies, may contact you using various communication tools such as email, SMS, phone calls, written or visual messages regarding our existing or products, goods, and services. This includes the promotion and detailing of our services and products, their personalization based on your requests, preferences, usage, and choices, conducting market feasibility studies, organizing and executing marketing and sales activities planned by the company, and planning and implementing actions to maintain and increase trust and loyalty in our products and services. Additionally, it includes monitoring, responding to, and concluding requests, suggestions, and complaints from customers through authorized units within the organizational structure.

For these purposes, within the Aluform Pekintaş commercial organization—including the central office, regional directorates, factories, and if necessary, group companies—personal data you provide (such as name, address, phone number, email address, IP address, bank account information, invoice details, and other similar information) may be collected, processed, recorded, stored, classified, and updated in full compliance with all provisions of Law No. 6698, especially Article 10, and other relevant legislation. This processing will also adhere to the principles of good faith and honesty as outlined in Article 2 of the Civil Code and commonly accepted practices.

Where legally permissible or limited to the purpose of processing, your personal data may be shared with third parties, departments directly or indirectly involved within Aluform Pekintaş’s central office, regional directorates, factories, or, if necessary, group companies, Aluform Pekintaş employees, and external solution partners affiliated with the group.

Aluform Pekintaş ensures that all the operations and actions described above are carried out in full compliance with the fundamental principles set forth in Law No. 6698 on the Protection of Personal Data and Article 10 of the same law, as well as relevant regulations.

2.For What Purposes Can Your Personal Data Be Processed?

Aluform Pekintaş’s primary aim is to provide you with better services while ensuring that your personal data is processed fully in compliance with all provisions of Law No. 6698 on the Protection of Personal Data (KVKK). In accordance with Article 10 of the same law and other relevant regulations, your existing personal data may be processed to contact you using tools such as email, SMS, phone calls, or other written and visual methods regarding our current or planned products, goods, and services; to promote and provide detailed information about these products and services; to personalize and present them according to your requests, preferences, usage, and choices; and to conduct market feasibility studies.

Additionally, your personal data may be used for organizing and executing marketing and sales activities planned by the company, planning and implementing actions to maintain and enhance trust and loyalty in our products and services, and monitoring, responding to, and concluding requests, suggestions, and complaints from customers through authorized units within the organizational structure.

Within the Aluform Pekintaş commercial organization—including the central office, factories, and if necessary, group companies—or via Aluform Pekintaş distributors, personal data provided in connection with product and service requests is processed for the purposes of directing, activating, recording, completing, and auditing these requests. Your personal data is processed and securely stored in physical or electronic environments for the duration necessary for the processing purpose, in line with the principles of protection and security. Aluform Pekintaş fully complies with all obligations stipulated in Law No. 6698 and other directly or indirectly relevant legal regulations regarding the protection of personal data.

3.Under What Conditions Can Your Personal Data Be Transferred

Your personal data, processed by Aluform Pekintaş or through the central office, factories, and, if necessary, group companies within the Aluform Pekintaş commercial organization, may be transferred in accordance with the procedures set out in Law No. 6698 on the Protection of Personal Data (KVKK) and the fundamental regulations established by the Personal Data Protection Authority. Such transfers will fully comply with the principles outlined in the law and with the rules specified in Article 8 for domestic transfers and Article 9 for international transfers, and will be carried out in a manner consistent with the purposes and conditions of personal data processing.

In connection with current or future products, goods, and services offered by Aluform Pekintaş or within its commercial organization, your personal data may be used to contact you via email, SMS, phone calls, or other written, verbal, or visual communication tools, to promote and provide detailed information about our products and services, to personalize and present them according to your requests, preferences, usage, and choices, to conduct market feasibility studies, to organize and execute marketing and sales activities planned by the company, to plan and implement actions aimed at maintaining and enhancing trust and loyalty in our products and services, and to monitor, respond to, and conclude requests, suggestions, and complaints from customers through authorized units within the organizational structure.

Within the scope of management and business workflow procedures, personal data related to product and service requests submitted to Aluform Pekintaş may be processed for directing, activating, tracking, completing, auditing, and enhancing these requests. Such data may be transferred to domestic or international partners, group companies, customers served in the course of business, Aluform Pekintaş distributors, employees under the Aluform Pekintaş organization either temporarily or permanently, relevant departments within the organization, public authorities and security units when required for public safety, service providers, legal entities, audit firms, banks, insurance companies, logistics, advertising and promotional agencies, software providers acting jointly as relevant users when necessary, and lawyers providing legal support. Data may also be stored, processed, and maintained in our databases or any future platform or system that may replace them, within the limits permitted by KVKK and in accordance with the principles of data protection.

4. Regarding the Transfer of Data Abroad

Your personal data, processed by Aluform Pekintaş or through the central office, factories, and, if necessary, group companies within the Aluform Pekintaş commercial organization, may be transferred abroad in accordance with Article 4(2) of Law No. 6698 on the Protection of Personal Data (KVKK), which requires that data processing be lawful and in accordance with the rules of honesty, accurate and updated when necessary, processed for specific, clear, and legitimate purposes, limited and proportionate to the purpose for which they are processed, and retained for the period stipulated by relevant legislation or as necessary for the purpose of processing. Such transfers may occur with your explicit consent or, where the conditions set forth in Article 5(2) and the provisions of Article 6(3) of KVKK are met, without explicit consent.

Provided that explicit consent is obtained, and in compliance with Article 9 of the same law and the required safeguards outlined therein, personal data may be transferred only to individuals and organizations in foreign countries recognized by the Personal Data Protection Board as providing adequate protection.

For countries determined not to provide sufficient protection, transfers may only occur if the data controllers in Turkey and in the relevant foreign country provide a written commitment to ensure adequate protection and if the transfer is authorized by the Board.

5. Acquisition, Management, and Legal Basis of Your Personal Data

Your personal data is collected by Aluform Pekintaş or through the central office, regional directorates, factories, and, if necessary, group companies within the Aluform Pekintaş commercial organization for purposes related to existing or planned products, goods, and services. 

This may include reaching out to you via email, SMS, phone calls, or other verbal, written, and visual communication tools to introduce and provide details about our services and products, tailor them according to your requests, preferences, usage, and choices, conduct market feasibility studies, organize and execute marketing and sales activities, ensure continuity and enhancement of trust in our products and services, and monitor, respond to, and conclude requests, demands, suggestions, or complaints from customers through the relevant authorized units within our organizational structure.

Within the framework of company management and operational procedures, your personal data may also be collected to facilitate the processing, tracking, fulfillment, conclusion, and auditing of product, service, and order requests submitted to Aluform Pekintaş through the company, its commercial organization, group companies, or authorized dealers, using communication tools such as email, SMS, phone, and other verbal, written, or visual methods when necessary.

The personal data collected for these purposes may be processed and transferred in accordance with the principles outlined in Article 4(2) of Law No. 6698 on the Protection of Personal Data (KVKK), either based on your explicit consent or, when the specific conditions set forth in Articles 5(2) and 6(3) are met, without obtaining explicit consent, ensuring that your rights under Article 6 are fully respected.

6.Rights of Data Subjects under Article 11 of Law No. 6698 (KVKK) and the Procedure for Their Enforcement

We would like to inform you that Aluform Pekintaş is obliged, in accordance with Law No. 6698 on the Protection of Personal Data (KVKK) and related legislation, to retain personal data belonging to all Aluform Pekintaş customers and related individuals for a certain period even after the termination of the commercial relationship. Any real person acting on behalf of a legal entity that conducts transactions with our company (e.g., a representative authorized by a company power of attorney, lawyer, company executive, individual agent, employee, etc.) may submit a written application along with documents proving their identity and rights.

Through this process, you can exercise the rights specified in Article 11 of KVKK regarding your personal data, including the right to: find out whether your personal data has been processed; request information if your personal data has been processed; learn the purpose of processing and whether your personal data is being used in accordance with that purpose; know the third parties to whom your personal data has been transferred domestically or abroad; request correction of your personal data if it has been processed incompletely or incorrectly.

Applications can be submitted in writing, either in person or via registered mail with return receipt, to the address: Büyükdere Cad. No:32 Pekintaş Plaza 34388 Mecidiyeköy / ISTANBUL. Requests will be evaluated by ALUFORM PEKİNTAŞ and concluded within a maximum of 30 (thirty) days in accordance with the provisions of KVKK. No fee will be charged for such requests; however, under the conditions specified in Article 13/2 of KVKK, Aluform Pekintaş reserves the right to request a fee in accordance with the tariff determined by the Personal Data Protection Board.

Except for the cases outlined under Article 28 (“Exceptions”) of KVKK, your rights under Article 11 of KVKK include, within the framework of Article 7: requesting the deletion or destruction of your personal data; requesting notification of actions taken in accordance with the above-mentioned clauses (d) and (e) to third parties to whom your personal data has been transferred; objecting to any result arising against you solely due to the analysis of your personal data through automated systems; and requesting compensation for damages in case of unlawful processing of your personal data. We hereby inform you that these rights are protected under the provisions of Law No. 6698 (KVKK).

7-Audio and Visual Monitoring Activities at Aluform Pekintaş and Its Affiliates

Aluform Pekintaş may carry out audio and visual monitoring activities, primarily through cameras, at its own or its affiliates’ business areas, factories, sales sites, and during transportation activities on land, air, and sea vehicles, whether partially or fully operated on its behalf. These activities will be conducted in accordance with the personal data processing conditions specified in Law No. 6698, for precautionary purposes and to ensure general security, and with a focus on the stated objectives.

Data subjects are informed about the visual and audio monitoring activities carried out by Aluform Pekintaş in accordance with Article 10 of Law No. 6698. These records are not shared with any institution or organization outside the official procedures, except for authorized Turkish government institutions, and are accessed only by the relevant user groups within the affiliate network according to official procedures.

8. Deletion and Destruction of Your Personal Data

In accordance with Law No. 6698 on the Protection of Personal Data (KVKK) and other relevant legislation, your personal data that has been processed will be deleted or destroyed when the reasons requiring its processing no longer exist. The deletion of personal data refers to rendering personal data completely inaccessible and unusable for the relevant users.

The destruction of personal data refers to ensuring that the data cannot be accessed, retrieved, or used by anyone under any circumstances. As the data controller, our company is obliged to take all necessary technical and administrative measures regarding the destruction of personal data.

Upon your request, Aluform Pekintaş or its commercial organization, including headquarters, regional offices, factories, and, if necessary, group companies, will fulfill the legal obligations related to the deletion and destruction of your existing personal data.