PDPL

FROW AUTOMOTIVE SPARE PARTS MARKETING TRANSPORTATION AND FOREIGN TRADE INC
CLARIFICATION TEXT UNDER THE PERSONAL DATA PROTECTION LAW No. 6698

Identity of the Data Controller FROW AUTOMOTIVE SPARE PARTS MARKETING TRANSPORTATION AND FOREIGN TRADE INC uses all kinds of information in accordance with the Personal Data Protection Law No. 6698 (“PDPL”) and takes all legal measures in the processing of your personal data within the scope of its activities. Each person can access detailed information on the processing of their personal data, their transfer to third parties, legal reasons for collecting this personal data and their rights under KVKK from the information text below.

Mersis Number: 0388-0610-7410-0019
Website Address: www.frow.com.tr
Phone Number: +90 216 561 20 21
E-Mail Address: info@frow.com.tr
Address: Eyüp Sultan, Gülibrişim Sk., 34885 Sancaktepe/İstanbul

A. Processed Personal Data, Purpose of Data Processing, Collection Method and Legal Reason for Processing

As FROW AUTOMOTIVE SPARE PARTS MARKETING TRANSPORTATION AND FOREIGN TRADE INC , in its capacity as Data Controller, we are responsible for the Turkish Commercial Code no. 6102, the Personal Data Protection Law no. 6698, the Labor Law no. 4857, the Code of Obligations no. 6098, the Turkish Penal Code no. 5237. Within the framework of our legal obligations arising from the Law No. 5651 on the Regulation of Publications made on the internet and combating crimes committed through these publications and other relevant legislations and regulations, in order to benefit from our activities stated below, in case of sharing with us and accessing our website, based on your explicit consent or as stated above. In accordance with the relevant legislation, our Company; will be able to obtain personal data, record it, preserve it, update it in order to continue its services, rearrange it, transfer it to third parties in the country or abroad in cases and to the extent permitted by the legislation, and process it by taking the necessary administrative and technical measures in other ways approved by law.

FROW AUTOMOTIVE SPARE PARTS MARKETING TRANSPORTATION AND FOREIGN TRADE INC in accordance with PDPL; with the rule of honesty, commit to update the information accurately when necessary in line with specific, clear and legitimate purposes, in connection with the purpose for which they are processed, in a limited and proportionate manner.

Particular attention is paid to keep them for the period stipulated in the relevant legislation or for the period necessary for the purpose for which they are processed, and for this purpose, necessary inspections are carried out.

As FROW AUTOMOTIVE, we show utmost sensitivity regarding the security of your personal data and take all necessary technical, administrative and legal measures to protect your personal data. The legal reasons our company relies on during data processing are as follows:

Existence of explicit consent (“Art. 5/1, Art. 6”).
It is clearly stipulated in the law (“Art.5/2-a”).
It is necessary for the protection of the life or physical integrity of the person who is unable to express his/her consent due to actual impossibility or whose consent is not given legal validity (“Article 5/2-b”).
It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract (“Art. 5/2-c”).
It is mandatory for the data controller to fulfill its legal obligation (“Article 5/2-ç”).
It has been made public by the person concerned (“Art.5/2-d”).
Data processing is mandatory for the establishment, exercise or protection of a right (“Article 5/2-e”).
It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned (“Article 5/2-f”).

Purpose of Data Processing	Processed Personal Data	Data Processing Terms	Data Collection Methods
Ensuring security by recording our company’s business and working areas	Camera record	m. 5/2-f	Via camera systems (Automatic means)
Recording phone calls/Call center records	Voice recording	m. 5/2-f	Via call center (Automatic means)
Ensuring security checks at the entrances	Name and surname, visit day and time, license plate information	m. 5/2-f	From the person concerned (by non-automatic means)
Management of demand, suggestion, request, complaint and malfunction processes	Name and surname, e-mail, phone number, title, signature, request/complaint detail	m.5/2-e, m.5/2-f	By electronic means (Partly by automatic means)
Execution of goods/service supply and contract processes	Name, surname, TR ID number, signature circular, e-mail, telephone, TIN, tax office, bank account number, signature, address, reference information	m.5/2-c, m.5/2-d, m.5/2-e	By physical means, e-mail and telephone (Partly automatic and non-automatic means)
Execution of sales and contract processes	Name, surname, TR ID number, signature circular, e-mail, telephone, TIN, tax office, bank account number, signature, address	m.5/2-c, m.5/2-d, m.5/2-e	By physical means, e-mail and telephone (Partly automatic and non-automatic means)
Execution of invoice processes	Name and surname, TIN, TR ID number, e-mail, telephone, address	m.5/2-a, m.5/2-c, m.5/2-ç, m.5/2-e	By physical or digital means (by non-automatic or partially automatic means)
Preparation of audit documents	Name and surname, TR ID number, signature, e-signature	m. 5/2-c, m .5/2-f	Via relevant documents (by non-automatic means)
Preparation of general assembly meeting minutes and powers of attorney and recording the meeting	Name and surname, TR ID number, signature, title, visual and audio videos	m.5 /2-ç, m.5 /2-f	By physical means, e-mail and camera (Partly automatic and non-automatic means)
Follow-up of litigation, mediation and enforcement processes	Personal data subject to and/or contained in the file	m.5/1, m. 6/1, m. 5/2-a, m.5/2-d, m.5/2-e, m. 5/2-f	By physical means and e-mail (Partly automatic and non-automatic means)
Forwarding incoming and outgoing call records and mails to relevant places	Name and surname, telephone, e-mail, institution, title, address	m.5/2-f	By physical means, fax and e-mail (by non-automatic or partially automatic means)
Listing phone numbers to maintain communication	Name, surname, title, phone number	m.5/2-f	By e-mail, telephone, physical means (Partly automated means)
Conducting correspondence with public institutions and organizations	Name and surname, address, TR ID number, ID serial number, date of birth, mother and father’s name, title, photo, video, telephone, e-mail, signature	m. 5/2-a, m.5/2-c, m.5/2-ç	By physical means or e-mail (by non-automated or partially automatic means)

B. Transfer of Personal Data

Your personal data, which is stated to be processed in the title, in line with the data processing purposes under the same title, if necessary and limited to the realization of our company’s activities and business processes;

To audit firms, financial advisors, relevant public institutions and organizations, in accordance with the relevant legislation (execution of activities in accordance with the legislation, fulfillment of our legal obligations, management of contract processes),
To banks and financial institutions, (execution of contract processes, execution of finance and accounting affairs, follow-up and execution of legal affairs),
To our suppliers, business partners, direct/indirect/domestic/international subsidiaries involved in business processes for the realization of activities (Ensuring/supervising business continuity, Carrying out contract processes, Tracking requests and complaints, Tracking and carrying out legal affairs)
To the relevant supplier company from which our company provides services in its business processes, to our business partners (Ensuring/supervising business continuity, Execution of contract processes, Follow-up of requests and complaints, Follow-up and execution of legal affairs)
It is transferred to legally authorized public institutions and organizations (execution of activities in accordance with the legislation, monitoring and execution of legal affairs, fulfillment of our legal obligations in accordance with legal/administrative regulations) in line with the requests of the relevant public institutions and organizations and limited to the purposes of the request.

C. Rights of the Relevant Person

Everyone has the following rights in accordance with Article 11 of the PDPL;

Learning whether personal data has been processed or not, Requesting information if personal data has been processed,
Learning the purpose of processing personal data and whether they are used for their intended purpose,
Knowing the third parties to whom personal data is transferred at home or abroad,
Requesting correction of personal data in case personal data has been processed incompletely or incorrectly and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,
Requesting the deletion or destruction of personal data in case the reasons requiring processing no longer exist, even though it has been processed in accordance with the provisions of KVKK and other relevant laws, and requesting that the transaction carried out in this context be notified to third parties to whom personal data has been transferred,
Objecting to the emergence of a result that is unfavorable to the individual by analyzing the processed data exclusively through automatic systems,
Request compensation for damages in case of damage due to unlawful processing of personal data.
Anyone can submit their requests regarding these rights to our Company in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. Requests will be evaluated and decided free of charge as soon as possible and within thirty (30) days at the latest. If the evaluation and decision-making process requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be taken as basis.