PRIVACY

PRIVACY NOTICE

We, Hergüner Bilgen Özeke Avukatlık Ortaklığı (“Hergüner”), have prepared this Privacy Notice to inform you regarding your personal data that may be processed by Hergüner and regarding the purposes of processing, methods and legal grounds for collection, categories of recipients to whom the personal data may be transferred, and your rights under the Law on the Protection of Personal Data numbered 6698 (“LPPD”). This Privacy Notice applies to personal data of individuals and shall not apply in cases where Hergüner acts as the “data processor”.

As one of the leading law firms in Turkey, we attribute great importance to protecting the personal data that we process in a “data controller” capacity within the framework of applicable legislation, including the LPPD, the Attorneyship Law numbered 1136, as well as to the confidentiality between attorneys and clients.  We prioritize transparency and accountability with respect to data processing activities and 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 applicable 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 you have produced or shared with us prior to, during, or after receiving services from Hergüner or selling goods/services to Hergüner or through 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 that Hergüner has made with you 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 physical record keeping activities) 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 in accordance with the legislation and relevant policies and procedures of Hergüner.

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 legal advisory/advocacy services we provide to our clients, our business development and procurement processes, as well as the administration, management, and financial operations of Hergüner, for the purposes described below and to the extent 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, you have made the personal data available to the public in accordance with Article 5(2)(d) of the LPPD, the data processing is mandatory for the establishment, exercise, or protection of any right under Article 5(2)(e) of the LPPD, or that processing personal data is mandatory for the legitimate interests of Hergüner in accordance with Article 5(2)(f) of the LPPD or upon your consent where necessary.

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 obligations under the applicable legislation, especially the Attorneyship Law, 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 or if processing personal data is mandatory for the legitimate interests of Hergüner as per Article 5/(2)(f) of the LPPD.

Your personal data may be processed in the course of providing you updates on legislative amendments or legal developments as well as our newsletters, publications and events to the extent necessary with respect to the legal advisory/advocacy relationship and on the legal grounds that the processing of personal data is mandatory for the legitimate interests of Hergüner as per Article 5/(2)(f) of the LPPD or upon the consent of the individuals who are interested in our services, publications and events.

1. Legal Advisory and Advocacy Services

As part of our legal advisory and advocacy services, we may process the personal data of clients, project stakeholders, suppliers that provide consultancy/support with respect to our main activities, experts who provide opinions, individuals that are the subject of or party to the relevant legal advisory or advocacy services or dispute, as well as their representatives and employees, and of third parties such as judges, public prosecutors, counter party attorneys, experts and notaries public.

1.1. Purposes of Processing

Your personal data is processed for the below purposes:

  • Providing legal advisory and advocacy services to our clients, the performance of our other contractual obligations, and reporting;
  • Communication with our clients, their stakeholders, and third party communication on behalf of our clients, within the context of the services provided to our clients;
  • Informing clients of legislative and other developments;
  • Obtaining expert and legal opinions by Hergüner, the procurement of third party goods/services with respect to the services provided to clients, and the management of such processes;
  • Carrying out invoicing, payment, accounting, and settlement processes;
  • Carrying out corporate communication processes and improving client relations and communication;
  • Organizing and announcing events hosted by Hergüner or that Hergüner participates in or otherwise involving Hergüner;
  • Carrying out internal processes such as finance, IT, HR, office administration, secretariat, correspondences, archive, etc.;
  • Maintaining the security of Hergüner’s 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’s internal rules and procedures;
  • Providing information and documentation requested under the relevant legislation by judicial or administrative authorities, including execution offices, law enforcement officers;
  • Performing Hergüner’s legal obligations under the legislation, especially under the Attorneyship Law numbered 1136.

1.2. Transfer of Personal Data

Your personal data may be shared with third parties for the abovementioned purposes, within the scope of the standard processes of Hergüner and in accordance with the legislation, to the extent necessary and relevant for the purposes in question. The principal circumstances where your personal data may be shared with third parties within the scope of Hergüner’s existing practices are as follows:

Your personal data may be shared with third parties such as clients, relevant project partners, experts and consultants that we have requested an opinion from, courts, notaries public, and relevant institutions and organizations in the course of our legal advisory and advocacy services; banks to execute payments; event organizers venues and similar parties with respect to event organizations; the suppliers and consultants we receive services from in fields such as IT, HR, finance, accounting, auditing, design, mailing, and bulk communications; and the competent authorities in accordance with our legal obligations or the requests made by authorities authorized to request your information as per the legislation or in case of a dispute.

2. Business Development and Newsletter Publications

Personal data may be processed regarding our clients that we provide legal advisory and advocacy services to, project partners, suppliers that we receive counselling/support from with respect to our main activities, experts that provide us opinions, together with their representatives and employees, as well as individuals that are interested in our services and publications.

2.1. Purposes of Processing

Your personal data is processed for the below purposes:

  • Providing legal advisory and advocacy services to clients and fulfilling our contractual obligations and reporting;
  • Carrying out business development activities and improving our services;
  • Carrying out corporate communication processes and improving client relations and communication;
  • Sharing our publications and works such as newsletters, client alerts, articles, legal developments etc. with existing and potential clients and other individuals that are interested in our publications and work through mail, e-mail or other communications means;
  • Organizing and announcing events and activities that Hergüner has organized or will participate/become a part of;
  • Carrying out internal processes such as finance, IT, HR, office administration, secretariat, correspondences, archive, etc.;
  • 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’s internal rules and procedures;
  • Providing information and documentation requested under the relevant legislation by judicial or administrative authorities, including execution offices or law enforcement officers;
  • Performing Hergüner’s legal obligations under the legislation, especially under the Attorneyship Law numbered 1136.

2.2. Transfer of Personal Data

Your personal data may be shared with third parties for the abovementioned purposes, within the scope of the standard processes of Hergüner and in accordance with the legislation, to the extent necessary and relevant for the purposes in question. The principal circumstances where your personal data may be shared with third parties within the scope of Hergüner’s existing practices are as follows:

Your personal data may be shared with event organizers and venues and similar parties with respect to event organizations; local and foreign platforms publishing professional experience upon consents of the client referees; the suppliers and consultants we receive services from in fields such as IT, HR, finance, accounting, auditing, design, mailing, and bulk communications; and the competent authorities, in accordance with the requests made by authorities that are authorized to request your information as per the relevant legislation, or in case of a dispute.

2.3. Newsletter Subscriptions

If you have requested to be included in the delivery list for our Newsletters and Client Alerts, your personal data may be processed for the purposes of performing the relevant delivery. If you no longer wish to receive e-mails from Hergüner with respect to the deliveries in question, you may click on the link indicating “Please click if you do not want to receive information e-mail” included in the e-mail that has been sent to you. If you do not want to receive printed newsletters sent via mail, please send your request to info@herguner.av.tr.

3. Goods/Services Procurement Processes Outside our Main Activities

Within our good/service supply processes that are outside of the scope of the main activities of Hergüner, the personal data of suppliers that we receive consultancy/support from, as well as third parties that we are in connection with such as lease, purchase, and other relations, and their representatives and employees may be processed.

3.1. Purposes of Processing

Your personal data is processed for the below purposes:

  • Carrying out good/service supply and purchase processes for fulfilling the needs of our office and performing our contractual obligations within the scope of good/service relations and making necessary communications;
  • Carrying out invoicing, payment, accounting, and agreement processes;
  • Carrying out internal processes such as finance, IT, HR, office management, secretariat, archive etc.;
  • 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’s internal rules and procedures;
  • Providing information and documentation requested under the relevant legislation by judicial or administrative authorities, including execution offices or law enforcement officers;
  • Performing Hergüner’s legal obligations under the legislation, especially under the Attorneyship Law numbered 1136.

3.2. Transfer of Personal Data

Your personal data may be shared with third parties for the abovementioned purposes, within the scope of the standard processes of Hergüner and in accordance with the legislation, to the extent necessary and relevant for the purposes in question. The principle circumstances where your personal data may be shared with third parties within the scope of Hergüner’s existing practices are as follows:

Your personal data may be shared with banks to execute payments with respect to procurement of goods or services or your relevant relation with Hergüner; our other suppliers to the extent necessary; our clients and third parties, such as related institutions and organizations, where necessary for our services provided to clients; and the competent authorities, in accordance with the requests made by authorities that are authorized to request your information as per the relevant legislation, or in case of a dispute.

4. Using our Website

We use necessary cookies on our website at https://www.herguner.av.tr, which are kept temporarily in order to enable the visitors to effectively use our website. The relevant cookies will be erased automatically upon the termination of the website session.

Your personal data may be shared with the suppliers that we receive services from and with the competent authorities within the scope of the requests received from the authorities that are entitled to request your information and in case of disputes.

The personal data that you have shared with us through contact forms on our website for your requests regarding our publications, such as registration for our Newsletter and Client Alert delivery lists, may be processed for the purposes explained under section 2 above “Business Development and Newsletter Publications” and shared with the groups of recipient indicated therein.

5. Visiting our Offices

If you visit Hergüner’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 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 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. Your consent;
b. Clear provision in the laws;
c. 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;
d. Processing of personal data of the parties to a contract is necessary, provided that it is directly related to entering into or fulfilment of that contract;
e. Processing is mandatory for Hergüner to perform its legal obligations;
f. You have made the personal data available to the public;
g. Processing is mandatory for the establishment, exercise, or protection of any right;
h. Processing is mandatory for the legitimate interests of Hergüner, provided that this processing does not violate your fundamental rights and freedoms.

Your Rights and Contact

We would like to remind that you 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” 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.


PRIVACY NOTICE

We, Hergüner Danışmanlık A.Ş. (“Hergüner Danışmanlık”), have prepared this Privacy Notice to inform you regarding your personal data that may be processed by Hergüner Danışmanlık, and regarding the purposes of processing, methods and legal grounds for collection, categories of recipients to whom the personal data may be transferred, and your rights under the Law on the Protection of Personal Data numbered 6698 (“LPPD”).  This Privacy Notice applies to personal data of individuals and shall not apply in cases where Hergüner Danışmanlık acts as the “data processor”.

We attribute great importance to protecting the personal data that we process in a “data controller” capacity within the framework of applicable legislation, and we prioritize transparency and accountability with respect to data processing activities and 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 applicable 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 you have produced produced or shared with us prior to, during, or after purchasing goods/services from Hergüner Danışmanlık or selling goods/services to Hergüner Danışmanlık or through 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 that Hergüner Danışmanlık has made with you 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 physical record keeping activities) 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 in accordance with the legislation and relevant policies and procedures of Hergüner Danışmanlık.

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 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 obligations 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

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.

1.1. 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;
  • Carrying out internal processes such as finance, IT, HR, office management, secretariat, archive etc.;
  • Maintaining the security of Hergüner Danışmanlık 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 judicial or administrative authorities, including execution offices, law enforcement officers;
  • Performing Hergüner Danışmanlık’s legal obligations.

1.2. Transfer of Personal Data

Your personal data may be shared with third parties for the abovementioned purposes, and in accordance with the legislation, to the extent necessary and relevant for the purposes in question. The principal circumstances where your personal data may be shared with third parties within the scope of Hergüner Danışmanlık are as follows:

Your personal data may be shared 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

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.

2.1. Purposes of Processing

Your personal data is processed for the below purposes:

  • Carrying out goods/service supply and procurement processes for fulfilling the needs of our office or our customers’ and performing 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;
  • Carrying out internal processes such as finance, IT, HR, office management, secretariat, archive etc.;
  • 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 judicial or administrative authorities, including execution offices, law enforcement officers;
  • Performing Hergüner Danışmanlık’s legal obligations.

2.2. Transfer of Personal Data

Your personal data may be shared with third parties for the abovementioned purposes and in accordance with the legislation, to the extent necessary and relevant for the purposes in question. Your personal data may be shared with the banks to execute payments with respect to procurement of goods or services or your relevant relations 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 the requests made by the 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 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. Your consent;
b. Clear provision in the laws;
c. 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;
d. Processing of personal data of the parties to a contract is necessary, provided that it is directly related to entering into or fulfilment of that contract;
e. Processing is mandatory for Hergüner Danışmanlık to perform its legal obligations;
f. You have made the personal data available to the public;
g. Processing is mandatory for the establishment, exercise, or protection of any right;
h. 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 that you 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.