PRIVACY

PRIVACY NOTICE

We, Hergüner Danışmanlık A.Ş. (“Hergüner Danışmanlık”), have prepared this Privacy Notice for the purpose of providing information to individuals regarding their personal data that may be processed in relation to the products and services provided to or by Hergüner Danışmanlık or within the scope of its commercial activities. This Privacy Notice also describes the purposes of processing, the methods and legal grounds for collection, the categories of recipients to whom the personal data may be transferred, and the rights of the individuals whose data is collected under the Law on the Protection of Personal Data numbered 6698 (“LPPD”). This Privacy Notice applies to the personal data of individuals and shall not apply in cases where Hergüner acts as the “data controller” or where Hergüner Danışmanlık acts as the “data processor” at the instruction of its customers.

We attribute great importance to protecting the personal data that we process in the capacity of the “data controller” and prioritize transparency and accountability within our relevant processes. We process your personal data in accordance with the relevant legislation, only for the purposes and limitations defined below, and take the utmost care to implement the necessary and appropriate technical and organizational measures.

Our relevant business processes and data processing processes are carried out in accordance with the pre-determined corporate policies and procedures that have been prepared in conformity with the legislation and are operated on our ISO 27001:2013 Information Security Management System, ISO 22301 Business Continuity Management System, and ISO 9001:2015 Quality Management System certified infrastructure. Our personal data processing processes are carried out as explained under this Privacy Notice in conformity with our policies and procedures regarding the processing, retention and disposal of personal data and the relevant legislation.

Your personal data may be collected through the information and documents that are produced or shared with us prior to, during, or after purchasing products/services from Hergüner Danışmanlık or selling products/services to Hergüner Danışmanlık or other similar relations; transactions, stakeholders, publicly available resources and platforms (such as media records, the trade registry, and the chamber of commerce); communications, research, meetings, interviews, and correspondences made with Hergüner Danışmanlık and through other channels, including our website and social media, via oral, written, and electronic platforms, and are processed through automatic (electronic systems and programs that we use) and non-automatic (physical files and keeping physical records) means for the purposes explained in this Privacy Notice.

Your personal data will be retained within Turkey for the legal retention periods, if any, and/or for the period necessary for the purposes of processing. Your personal data will be erased, destroyed, or anonymized at the end of the retention period necessary for the purposes of processing.

Processing of Personal Data in our Main Activities

Legal Grounds for Processing Personal Data

Your personal data may be processed within the scope of the services we provide to our customers as well as the administration, management, and financial operations of Hergüner Danışmanlık, for the purposes described below to the extent that it is necessary, on the legal grounds that processing personal data is necessary for the enactment or fulfilment of the contract as indicated under Article 5(2)(c) of the LPPD or is mandatory for the legitimate interests of Hergüner Danışmanlık as per Article 5(2)(f) of the LPPD. Your personal data may also be processed for the purposes of pursuing or defending against legal proceedings on the legal grounds that processing is mandatory for the establishment, exercise, or protection of rights as indicated under Article 5(2)(e) of the LPPD or for the purposes of fulfilling our legal liabilities and complying with the information and documentation requests of the competent authorities on the legal grounds that processing is necessary for compliance with our legal obligations as per Article 5/(2)(ç) of the LPPD.

1.Consulting Services

1.1.Your Personal Data

We may process the personal data of our customers to whom we provide services, their suppliers, business partners, project partners, other third parties, and their representatives and employees.

1.2. Purposes of Processing

Your personal data is processed for the below purposes:

  • Providing services to our customers such as consulting, business assistance, office management, human resources, accounting, procurement and property management, IT services, organization management, customer management and communications, translation services, and the performance of our other contractual obligations to our customers.
  • Carrying out invoicing, payment, accounting, and settlement processes with you, your company or our customers).
  • Maintaining the security of our assets and information.
  • Managing and administering our corporate structure, carrying out internal reporting, auditing, and business development processes, managing contracts, carrying out legal and accounting processes, and performing Hergüner Danışmanlık’s internal rules and procedures.
  • Providing information and documentation requested by legal, criminal, and administrative authorities, execution offices, or law enforcement officers
  • Performing Hergüner Danışmanlık’s legal obligations

 1.3. Transfer of Personal Data

Your personal data may be shared with third parties for the above-mentioned purposes, and in compliance with the legislation, to the extent that it is necessary and relevant for the purposes in question. The majority of cases where your personal data may be shared with third parties within the scope of the existing processes of Hergüner Danışmanlık are as follows:

Your personal data may be shared predominantly with suppliers who provide us services, our customers and third parties, such as related institutions and organizations, if necessary for us to provide services to our customers, and the competent authorities in accordance with requests made by authorities that are authorized to request your information as per the relevant legislation or in case of a dispute.

2. Goods/Services Supplier Processes and Relations with other Third Parties

2.1. Your Personal Data

We may process personal data regarding suppliers who provide us consulting/assistance or whom we conduct business with in the course of procuring goods/services for our or our customers’ needs and personal data regarding other third parties that have a relationship with Hergüner Danışmanlık, as well as the representatives and employees of such.

2.2. Purposes of Processing

Your personal data is processed for the below purposes:

  • Carrying out the supply of goods/service and procurement processes that are necessary for our or our customers’ needs and for the performance of our other contractual obligations to you, or your company, or to our suppliers, customers, and other relevant parties.
  • Carrying out invoicing, payment, accounting, and settlement processes with you, your company and/or our customers.
  • Maintaining the security of our assets and information.
  • Managing and administering our corporate structure, carrying out internal reporting, auditing, and business development processes, managing contracts, carrying out legal and accounting processes, and performing Hergüner Danışmanlık’s internal rules and procedures.
  • Providing information and documentation requested by legal, criminal and administrative authorities, execution offices or law enforcement officers
  • Performing Hergüner Danışmanlık’s legal obligations

2.3. Transfer of Personal Data

Your personal data may be shared with third parties for the above-mentioned purposes and in compliance with the legislation to the extent that it is necessary and relevant for the purposes in question. Your personal data may be shared predominantly with the relevant banks to execute payments arising from the supply of goods and services or any other relationship with Hergüner Danışmanlık; our other suppliers to the extent necessary; our customers and third parties, such as related institutions and organizations, if necessary to provide our services to customers; and the competent authorities in accordance with requests made by authorities that are authorized to request your information as per the relevant legislation or in case of a dispute.

3. Visiting our Offices

If you visit Hergüner Danışmanlık’s office, your identity, contact information, company, vehicle information, and information regarding your visit may be processed for the purposes of organizing the meeting/event that you will attend, keeping guest records, ensuring and monitoring the safety of our offices and the building, and for the purposes of mandatory legal disclosures with official authorities and pursuing legal proceedings, if any. CCTV cameras, managed and monitored by Hergüner, are in use in the common areas of our offices and at the entrances connecting to the common areas of the building.

Guest information may be mutually shared with the data processors providing services to Hergüner Danışmanlık and with the management of the building in which our offices are located for the purposes of ensuring the general security of the building, if necessary.

You may find more detailed information here.

Processing of Personal Data in our Other Activities

In the event that it is necessary to process your personal data for the purposes of an incidental process rather our fundamental activities indicated above, the relevant data processing processes will either rely on the below mentioned legal grounds or your consent, subject to Articles 5 and 6 of the LPPD:

a.Clear provision in the laws.

b. Processing is mandatory for the protection of the life or physical integrity of the person or any other person who is bodily incapable of giving their consent or whose consent is not deemed legally valid.

c. Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the enactment or fulfilment of that contract.

d. Processing is mandatory for Hergüner Danışmanlık to perform its legal obligations.

e. You have made the personal data available to the public.

f. Processing is mandatory for the establishment, exercise, or protection of any right.

g. Processing is mandatory for the legitimate interests of Hergüner Danışmanlık, provided that this processing does not violate your fundamental rights and freedoms.

Your Rights and Contact

We would like to remind you that individuals are granted the below rights under the LPPD:

a. The right to be informed whether their personal data has been processed or to request information about whether their personal data has been processed

b. The right to be informed of the purposes of the data processing and whether their personal data has been used for the intended purposes.

c. The right to be informed of the third parties to whom their personal data has been transferred either domestically or abroad.

d. The right to request the rectification of incomplete or inaccurate data, if any; request the erasure or destruction of their personal data under the conditions laid down in the LPPD legislation; or request a notification from the third parties to whom their personal data has been transferred regarding the operations carried out with respect to their aforementioned request.

e. The right to object to the processing of their personal data collected exclusively by automatic means that has led to an unfavorable consequence for them.

f. The right to request compensation for any damages arising from the unlawful processing of their personal data.

For your queries or requests in relation to your personal data, you may submit your written request to our address at “Büyükdere Caddesi 199 Levent 34394 Istanbul – Turkey” to the attention of Hergüner Danışmanlık A.Ş., through mail or by sending an e-mail to our e-mail address at info@herguner.av.tr (from the e-mail address that you previously informed us of and that can be found under our records). We will be able to provide a more satisfactory response to your request if your request is precise, explicit, and clear. Please note that your request should concern your own data, or if you are acting on behalf of another person, you must provide us with a special power of attorney covering the request. As per the regulations, your request should include your name, surname, Turkish ID number (for foreigners, nationality information and passport number), proof of identity, and the contact information for where our response to your request should be sent.