Personal Data Protection Law

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AIM

With this policy Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. Making explanations about the personal data processing activities and the systems adopted by our company for the protection of personal data, in this context, ensuring transparency by informing the people whose personal data are processed by our company, especially our business partners, current and prospective employees, current and potential customers, company shareholders, visitors and third parties. is intended.

PRINCIPLES OF PROCESSING PERSONAL DATA

Selva Home Rose to ensure compliance with KVKK  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. Personal data will be processed in accordance with the general principles and provisions stipulated in the legislation. In this context, Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It acts in accordance with the principles listed below in the processing of personal data in accordance with international and national legislation regarding KVKK.

1. Engaging in Personal Data Processing Activities in Compliance with the Law and the Rule of Integrity

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It is obliged to act in accordance with the law and the rules of honesty within the scope of the processing of personal data. In this context, proportionality requirements will be taken into account and will not use personal data other than for the purpose of processing.

2. Ensuring Personal Data Are Accurate and Up-to-Date When Necessary

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It is responsible for ensuring that the personal data it processes are correct and up-to-date, taking into account the fundamental rights and legitimate interests of personal data owners, and to establish the necessary systems to take the necessary measures in this direction.

3. Processing for Specific, Explicit and Legitimate Purposes

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It is obliged to determine the purpose for which personal data will be processed and to inform the data owners about these purposes before the personal data is processed. Personal data will not be processed other than for the specified legitimate and lawful purposes.

4. Relating to the Purpose for which they are Processed, Limited and Proportionate

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It will process personal data in a way that is suitable for the realization of the determined purposes and will avoid the processing of personal data that is not relevant or needed for the realization of the purpose.

5. Preservation For The Time Required For The Purpose For Which They Are Processed Or Prescribed In The Relevant Legislation Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. In accordance with Article 138 of the Turkish Penal Code and Articles 4 and 7 of the KVK Law; will keep the personal data they process only for the period stipulated in the relevant legislation and laws or as required by the personal data processing purpose.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; First of all, it will determine whether a period is foreseen for the storage of personal data in the relevant legislation, if a period is determined, it will act in accordance with this period, and if a period is not determined, it will keep the personal data for the period required for the purpose for which they are processed. In the event that the period expires or the reasons for its processing disappear, personal data Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It will be deleted, destroyed or anonymized by

6. Execution of Personal Data Processing Activities in Compliance with All of the Basic Principles in Article 4 of the Law Based on One or More of the Personal Data Processing Conditions Specified in Article 5 of the Law

As a rule, personal data will be processed in accordance with one or more of the conditions specified in Article 5 of the KVK Law.  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It will be determined whether the personal data processing activities carried out by the Company business units are carried out based on one or more of these conditions, personal data processing activities that do not meet one or more of these conditions will not be included in the processes. In addition to ensuring that personal data processing activities are carried out based on one or more of the personal data processing conditions, in all personal data processing activities, as specified in Article 4 of the KVK Law and III of the Policy. It will be ensured that all principles specified in the sections are acted in accordance with and that they contain these principles. Personal data processing activities will be carried out, taking into account the special provisions stipulated in the KVK Law regarding the processing of personal data of a special nature and its transfer to third parties and abroad; In addition to the above-mentioned issues, in these cases, personal data processing activities will be carried out by fulfilling the special requirements required by the law.

PERSONAL DATA PROCESSING CONDITIONS

1. Detection and Processing of Personal Data

Pursuant to KVKK, personal data is defined as “any information relating to an identified or identifiable natural person”. The concept of personal data does not only consist of information that enables the identification and diagnosis of individuals such as name, surname, place of birth, date of birth, but also includes all physical, social, cultural, economic and psychological information of individuals. In addition to the person's identity information, citizenship number, tax number, passport number, social security number, driver's license number, vehicle license plate, home address, work address, e-mail address, phone number, fax number, resume, photo, video, genetics All information that makes the person specific or identifiable, such as blood type, criminal history and criminal record information, is personal data and falls within the scope of protection of personal data. According to this definition,

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. ; It will determine whether all the data it collects, including third parties, especially its business partners, employees and customers, is within the scope of personal data and will process this data in accordance with the rules of KVKK. Processing of personal data; performed on data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, making available, classifying or preventing its use by fully or partially automatic or non-automatic means provided that it is a part of any data recording system. It covers all kinds of transactions.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. ; Pursuant to KVKK, personal data will only be processed with the explicit consent of the persons concerned. expressly stipulated by law. Persons who are unable to express their consent due to actual impossibility or whose consent is not given legal validity are a necessary condition for the protection of life or physical integrity of themselves or someone else, Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the contracting parties, in cases where it is necessary for the responsible person to fulfill his legal obligation. Making personal data public by the person concerned, Data processing is mandatory for the establishment, exercise or protection of a right, Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

2. Processing of Private Personal Data

Within the scope of the law, some personal data has been evaluated within the scope of private data and Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It will not process such data without the express consent of the person concerned or without the exceptions set out in the third paragraph of Article 6 of the Law. express consent; It means obtaining a detailed consent after informing the person whose data will be collected for what purposes this data is collected.
KVKK; Data on the person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data counted as private data.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; In the processing of sensitive personal data, it will also take adequate measures determined by the Personal Data Protection Board.

3. Transfer of Personal Data

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It will be able to transfer personal data to third parties with the explicit consent of the data owner, by taking the necessary security measures in line with the purposes of personal data processing in accordance with the law. However, Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Data that can be processed without explicit consent, and data related to health and sexual life, may be transferred to third parties without explicit consent in accordance with the limitations set forth in the KVKK.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It will take the necessary administrative and technical measures in order to transfer the data it transfers without express consent in accordance with the limitations in the PDPL.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Personal data may be transferred to foreign countries declared to have adequate protection by the KVK Board or, in the absence of sufficient protection, to foreign countries where data controllers in Turkey and the relevant foreign country undertake an adequate protection in writing and where the permission of the KVK Board is granted.

4. Building Entrances and Personal Data Processing Activities Inside, Network and Website Users

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Selva Home Rose, in order to ensure security by  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; In its buildings and facilities, personal data processing activities are carried out for monitoring the entrance and exit of guests and monitoring with security cameras. Selva Home Rose by using security cameras and recording guest entries and exits  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Personal data processing activity is carried out by. In this context, Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It acts in accordance with the Constitution, the KVK Law and other relevant legislation.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Video recordings of our visitors are taken through the camera monitoring system at the building, facility entrances and inside the facility.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Ticaret A.Ş., within the scope of monitoring activity with security cameras; to increase the quality of the service offered, to ensure its reliability, Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It aims to ensure the safety of customers and third parties and to protect the interests of customers regarding the service they receive.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. ; Carrying out camera surveillance activities for security purposes is carried out in accordance with the regulations in the KVK Law, the Law on Private Security Services and the relevant legislation.

Only a limited number of Selva Home Roses are available for digitally recorded and preserved records.  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; The employee has access.
Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. ; In accordance with Article 12 of the KVK Law, necessary technical and administrative measures are taken to ensure the security of personal data obtained as a result of camera monitoring.

Apart from recording with the above mentioned camera Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; by; Selva Home Rose, to ensure security and for the purposes set out in this policy  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Personal data processing activities are carried out for the tracking of guest entries and exits in its buildings and facilities.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. ; Internet access is provided to visitors who request it during their stay in the building and facilities for the purposes specified in this policy and to ensure security. These records can only be requested by authorized public institutions and organizations or Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It is processed in order to fulfill the relevant legal obligations in the audit processes to be carried out within the scope of the audit. Only a limited number of employees have access to the log records obtained.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. ; on websites owned by him; to ensure that the visitors of these sites perform their visits on the sites in accordance with the purposes of their visit; Internet movements within the site are recorded by technical means in order to show them customized content and to engage in online advertising activities.

5. Deletion, Destruction, Anonymization of Personal Data
Although it has been processed in accordance with the provisions of the relevant law, as regulated in Article 138 of the Turkish Penal Code and Article 7 of the KVK Law, in the event that the reasons requiring it to be processed disappear, Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Personal data is deleted, destroyed or anonymized by the Company, on its own decision or upon the request of the personal data owner.

In this context, Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; takes the necessary technical and administrative measures to fulfill its related obligations, develops the necessary operating mechanisms in this regard, assigns training to the relevant business units to act in accordance with these obligations and raises their awareness.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Ticaret A.Ş., OBLIGATIONS

1. Obligation to Inform Personal Data Owner

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; During the acquisition of personal data, personal data owners will be enlightened on the following matters:
- Identity of the data controller and its representative, if any,
- The purpose for which personal data will be processed,
- To whom and for what purpose personal data can be transferred,
- Method and legal reasons for collecting personal data,
- KVKK art. its rights pursuant to 11.

In accordance with this obligation, Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; publishes the illumination text they have prepared on their websites and designs appropriate processes to enlighten the data owner during data collection activities.

2. Obligation to Respond to Applications of Personal Data Owners

Personal data owners, in writing in accordance with the KVKK or by other methods to be determined by the KVK Board, Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; The applicant can request information by applying with the attached application form or “………………………..” KEP address.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; In order to evaluate the rights of the personal data owners and to provide the necessary information to the personal data owners, the procedures regarding answering the applications and other administrative and technical regulations pursuant to Article 13 of the KVKK have been established and implemented.
Personal data owners;

- Learning whether your personal data is processed or not,
- If your personal data has been processed, requesting information about it,
- To learn the purpose of processing your personal data and whether they are used in accordance with the purpose,
- Knowing the third parties to whom your personal data is transferred, in the country or abroad,
- Requesting correction of your personal data if it is incomplete or incorrectly processed,
- To request the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
- Requesting notification of the transactions made on your personal data made in accordance with the relevant legislation, to the third parties to whom your personal data has been transferred,
- Objecting to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
- In case you suffer damage due to unlawful processing of your personal data, it has the right to demand the compensation of the damage.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It processes only requests sent to registered e-mail addresses, signed with a written or secure electronic signature. If the KVK Board determines other application methods, it will also accept applications through these methods.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. ; According to the nature of the request, the request will be answered as soon as possible and within 30 (thirty) days at the latest. Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It will accept the applications and take the necessary actions or reject the applications with justification.
The personal data owner may file a complaint to the KVK Board within 30 (thirty) days from the date of learning the answer and in any case within 60 (sixty) days from the date of application, in case his application is rejected, he finds the answer insufficient or the application is not answered.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; In order to prevent complaints, it will respond to personal data owners in a timely and justified manner as stipulated by KVKK.

3. Obligation to Ensure the Security of Personal Data

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It ensures that the personal data they are processing is prevented from being processed illegally and accessing the data unlawfully, and that necessary technical and administrative measures are taken to ensure the appropriate level of security in order to preserve the data. Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; In order to comply with the obligations within this scope, it will show the necessary care and ensure the security of personal data.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; In terms of technical and administrative measures to be taken, it carries out the necessary inspections regarding the operation of the measures and establishes the systems for having them done. These inspection results are Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It will be examined by the units in charge and necessary measures will be taken.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; In case the processed personal data is obtained by others illegally, it is obliged to notify the personal data owner as soon as possible and to the KVK Board if required by the legislation. In this context, Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Necessary mechanisms have been established within it.
Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; If situations posing a security risk are detected by the Company, it will immediately take measures to eliminate the risk.

3.1. Taking Technical and Administrative Measures for the Provision of Legal Data Processing

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It analyzes all processes related to personal data processing activities carried out by its business units; All the activities carried out by the business units from the collection to the deletion of the data are not audited for compliance with the law.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Personal data processing activities carried out within its body are controlled by established technical systems.
The technical measures taken are reported regularly, and when a deficiency or illegality is detected, the relevant person is notified and the deficiencies or illegalities are eliminated.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It informs and trains its employees on the law of protection of personal data and the processing of personal data in accordance with the law.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; and its business partners, employees and customers, it puts records in the contracts and documents that impose the obligation not to process, disclose and use personal data in violation of the regulations in the KVKK.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Access to personal data is limited to the relevant company employee only for the purpose of processing.

The procedures to ensure that the activities of each business unit comply with the personal data processing conditions specified in the KVKK are determined specifically for each business unit and the activity it carries out. Implementation rules are determined specific to business units, necessary administrative measures are taken and procedures are established to ensure the control of these rules and the continuity of the application, and trainings are provided.

3.2. Taking Technical and Administrative Measures to Prevent Unlawful Access to Personal Data

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It takes the necessary administrative and technical measures according to the nature of the data to be protected in order to prevent the illegal acquisition, disclosure, display and transfer of personal data to third parties.
Technical measures are taken in line with technological developments and the measures taken are periodically updated and renewed.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; designs and commissions access and authorization technical processes in accordance with legal compliance requirements. The technical measures taken are periodically reported to the relevant person and technological solutions are produced for issues with security risks.

Relevant software and systems are installed, including software and hardware, including virus protection systems and firewalls.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. ; employees are trained on the technical measures taken and personnel knowledgeable in technical matters are employed.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It undertakes that its employees will not disclose the personal data they have learned to others in violation of the provisions of the KVKK and will not use it for purposes other than processing. It is ensured that this commitment is also valid after the employees leave the job.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. Articles that will protect personal data are added to the agreements made with the persons to whom personal data is transferred.

3.3. Supervision of the Measures Taken for the Protection of Personal Data

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; In terms of technical and administrative measures to be taken, it carries out the necessary inspections regarding the operation of the measures and constructs the systems to have them done. These inspection results are Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; It is reported to the relevant department within the scope of its internal functioning and necessary activities are carried out to improve the measures taken.
3.3. Measures to be Taken in Case of Unauthorized Disclosure of Personal Data

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; In the event that the processed personal data is obtained by others through unlawful means, it is obliged to notify the relevant personal data owner and the KVK Board as soon as possible. In this context, the necessary internal structure is being created.

4. Obligation to Register in the Data Controllers Registry

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Before starting the data processing, it will be determined by the KVK Board and will create a record in the data controllers registry by submitting the application information and documents within the announcement period. The documents to be submitted are as follows:

- Selva Home Rose as data controller  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; Identity and address information of the Company and its representative, if any,
- The purpose for which personal data will be processed,
- Explanations about the data subject group and groups and the data categories of these people
- Recipient or recipient groups to whom personal data can be transferred,
- Personal data intended to be transferred to foreign countries,
- Measures taken regarding personal data security,
- The maximum period required for the purpose for which personal data is processed.

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Ticaret A.Ş., ORGANIZATIONAL STRUCTURE

Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc.; The “Personal Data Protection Committee” responsible for the fulfillment of the actions determined by the senior management for compliance, or the person who will be responsible for this matter, has been appointed to manage this policy and other policies related to this policy.

In this context, the following minimum actions are taken by the Committee or the person to be appointed:

- To determine the basic policies regarding the processing and protection of personal data and what needs to be done to comply with the legislation,
- Submitting the determined basic policy and action steps to the approval of the senior management; to monitor and coordinate its implementation,
- To decide how the policies regarding the processing and protection of personal data will be implemented and how the audit will be carried out, to make the necessary assignments after receiving the approval of the senior management,
- Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. To determine the risks that may occur in the personal data processing activities of the Company and to ensure that the necessary measures are taken; submitting improvement suggestions to the top management for approval,
- To ensure that employees are trained on the protection of personal data and company policies,
- To decide on the applications of personal data owners at the highest level,
- Selva Home Rose  It. Tourism. Real estate. Commitment. Transport. Food. Furniture. Insurance. Imports. Export. Industry. Trade Inc. To make necessary arrangements within the company in order for the Company to fulfill its obligations under KVKK,
- To follow the developments on the protection of personal data; To advise the senior management on what to do within the scope of these developments,
Managing relations with the Institution and the Board.

ANNEX-1 DEFINITIONS

Explicit Consent Consent on a specific subject, based on information and expressed with free will.

Anonymization It is the modification of personal data in such a way that it loses its quality as personal data and this situation cannot be undone. Ex: Masking, aggregation, data corruption etc. making personal data incapable of being associated with a natural person, by means of techniques.

Employee Candidate Natural persons who have applied for a job in our company by any means or have made their resume and related information available to our company for review Business Partners Employees in institutions (such as but not limited to suppliers) with which our company has any business relationship, including shareholders and officials of these institutions , natural persons Processing of Personal Data Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, of personal data wholly or partially automatically or non-automatically provided that it is a part of any data recording system. All kinds of operations performed on data such as bringing, classifying or preventing its use. Personal Data Owner The natural person whose personal data is processed. E.g; Customers and employees. Personal Data Any information relating to an identified or identifiable natural person. Therefore, the processing of information regarding legal persons is not within the scope of the Law. E.g; name-surname, TCKN, e-mail, address, date of birth, credit card number, bank account number, etc. Real persons who use or have used the products and services offered by our Company, regardless of whether they have any contractual relationship with our Customer Company.

Special Quality Personal Data, data related to ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and bi-metric and genetic data are special data. Potential Customer Real persons who have requested or interested in using our products and services, or who have been evaluated in accordance with the rules of commercial practice and honesty that they may have. Shareholder of the Company.