Data Protection Information

 

GENERAL WEBSITE NOTICE ON

PROTECTION AND PROCESSING OF PERSONAL DATA

 

As BIRINCI OTOMOTIV SANAYI ve TICARET ANONIM SIRKETI (“BIRINCI OTOMOTIV” or “COMPANY”), we display maximum sensitivity to the security of your personal data. With this conscious, we set a premium on processing and storage of personal data belonging to the real persons, with whom the Company interacts, in compliance with Law No. 6698 on Protection of Personal Data (“Law”), secondary regulations (legislation, communiqué, circular) that have been and will be enacted under the Law and the binding decrees that have been and will be taken by the Personal Data Protection Board. With the full understanding of this responsibility, we process your personal data in the capacity of “Data Controller” per the Law, in the manner explained below and within the limits stipulated by the regulation.

 

  1. Information on Data Controller

Under the law, Birinci Otomotiv Sanayi ve Ticaret Anonim Sirketi registered by Gebze Registry of Commerce with the registration number 21963 and MERSIS number 0178001005900012 and having its registered address at “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Çayırova/KOCAELI” is the Data Controller.

 

  1. Purposes for Processing of Personal Data

Your personal data can be processed by the Company to fulfill the commercial activities carried out by the Company in accordance with the regulation and Company policies, carry out the necessary works by the business units of the Company and conduct activities in this direction, determine, plan and implement the commercial policies in the short, medium and long term, establish its corporate identity and ensure its operation, manage customer relations and corporate communication processes, plan, audit and execute information security processes, carry out marketing activities, conduct sales of goods/services and ensure the commercial and legal safety of real and legal persons, with whom the Company has a business relationship, within the limits specified in the law in accordance with the rules of honesty, and always relevant, limited and proportionate to the purposes for which they are processed.

 

  1. Transfer of Personal Data

Within the scope of the above-mentioned purposes and in accordance with the conditions specified in Articles 8 and 9 of the Law, your personal data are transferred primarily to legally authorized public institutions, judicial and administrative authorities, private law legal and real persons allowed in miscellaneous legislation, institutions and organizations authorized to audit the Company, contracted payment institutions to fulfill the payments and financial liabilities, the business associates from whom services are received or with which collaboration is made for the execution and development of the Company’s activities, and to the Company’s suppliers when necessary, by taking the data security measures specified in the Law.

 

  1. Method and Legal Reason for Collection of Personal Data

Your personal data is collected by the authorized units and employees of the Company through automatic and non-automatic methods, verbally, in writing, or electronically. Within this scope, personal data categorized as identity, contact, location, personnel, legal action, physical space security, transaction security, risk management, finance, professional experience, audio-visual records, marketing, and customer transaction are processed with the explicit consent, when necessary, per the Article 5/1 of the Law and based on the legal reasons mentioned in the second paragraph of the Article 5/2 of the Law that it is mandatory to process the personal data of the parties to the contract when it is directly related to the conclusion or performance of a contract, to fulfill the legal obligation of the data controller and for the establishment, exercise or protection of a right and the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the data subject and when they have been anonymized by the data subject himself/herself.

 

  1. Rights of Data Subjects Under the Law

By applying to the Company at any time, you can exercise your rights given below:

  • to learn whether your personal data are processed or not,
  • to demand information regarding this if your personal data have been processed,
  • to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
  • to know the third parties to whom your personal data are transferred in the country or abroad,
  • to request the rectification of the incomplete or inaccurate data, if any,
  • to request the erasure or destruction of your personal data within the framework of the conditions stipulated by Article 7 of the Law,
  • to request the notification of the procedure made under the sub-clause (d) and (e) of Article 11 of the Law to the third parties,
  • to raise objections to the processing, exclusively by automatic means, of your data, which leads to an unfavorable consequence against you,
  • to claim compensation for the damage arising from the unlawful processing of your personal data.

You can submit your requests concerning your rights and enforcement of the Law by filling out the application form that you can access at http://www.birinci.com or you can obtain from the workplace, with your wet signature to the address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Çayırova/KOCAELI” through notary public, return receipt mail or personally or by filling out the application form in the electronic environment after signing it with your electronic signature, to our KEP address or info@birinci.com from your e-mail address registered to the data registration system of the Company. If such requests within this scope are responded to in writing, BIRINCI OTOMOTIV responds to such requests at no charge up to ten pages, but it charges 1 Turkish Lira for each page above ten pages. If the response to the application is given in a recording medium such as a CD or flash memory, the charge that may be requested by the Company will not exceed the cost of the recording medium.

 

NOTICE TO BE PUT AT THE ENTRANCE OF OFFICES THAT RECEIVE VISITOR

Dear Visitor,

BIRINCI OTOMOTIV SANAYI ve TICARET ANONIM SIRKETI (“BIRINCI OTOMOTIV”) having its registered address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Cayırova/KOCAELI” uses your name, surname, and credentials that you have shared with it, limited to the following purposes;

  • to keep records of the visits to the offices of BIRINCI OTOMOTIV,
  • to ensure the security of BIRINCI OTOMOTIV offices,

Your abovementioned personal data is processed by the security company personnel that we have contracted with and authorized as a data processor by BIRINCI OTOMOTIV, through non-automatic means without being transferred to third-party recipient groups.

Your personal data is collected non-automatically through your identity statement made personally by means of processing your personal data in the visit book based on the legitimate interest of BIRINCI OTOMOTIV for keeping the visitor records provided not to harm the fundamental rights and freedoms of the data subject specified in subparagraph (f) of the 2nd paragraph of Article 5 of the Law on the Protection of Personal Data.

By applying to BIRINCI OTOMOTIV, the data subject can exercise his/her rights given below:

  • to learn whether his/her personal data are processed or not and to demand information as to if his/her personal data have been processed,
  • to learn the purpose of the processing of his/her personal data and whether these personal data are used in compliance with the purpose,
  • to know the third parties to whom his/her personal data are transferred in the country or abroad,
  • to request the rectification of the incomplete or inaccurate data, if any,
  • to request the erasure or destruction of his/her personal data if the conditions for processing are no longer available and to request notification of third parties about these operations if they have been transferred to any third party,
  • to claim compensation for the damage arising from the unlawful processing of his/her personal data.

Requests regarding the rights of the data subjects and enforcement of the Law can be submitted in writing to the address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Çayırova/KOCAELI”. If such requests within this scope are responded to in writing, BIRINCI OTOMOTIV responds to such requests at no charge up to ten pages, but it charges 1 Turkish Lira for each page above ten pages. If the response to the application is given in a recording medium such as a CD or flash memory, the charge that may be requested by the Personal Data Protection Authority will not exceed the cost of the recording medium.

THIS WORKPLACE IS MONITORED BY THE CAMERA RECORDING

 SYSTEM FOR SECURITY MEASURES.

This Notice has been issued by BIRINCI OTOMOTIV SANAYI ve TICARET ANONIM SIRKETI (BIRINCI OTOMOTIV), which acts as a data controller according to Law No. 6698 on Protection of Personal Data (“Law”) to make explanations and give information to the employees of Birinci Otomotiv and visitors to the Company’s headquarters and facilities about the processing of visual personal data in compliance with the Law. Your personal data of visual nature collected by Birinci Otomotiv will be processed based on the legal reason that data processing is mandatory for the legitimate interests of the data controller, provided not to harm your fundamental rights and freedoms specified in Article 5/2-f of the Law. Your visual personal data may be processed and collected automatically by the camera recording system in the areas where the relevant warning letter is put in the headquarters of Birinci Otomotiv. Your personal data of visual nature collected within the body of Birinci Otomotiv to take workplace security measures may be processed by the relevant units of Birinci Otomotiv, specifically the Information Processing Department. Camera images may only be transferred to relevant institutions under paragraph 8/2 of the Law, within the scope of requests of public institutions and organizations and judicial or administrative authorities to fulfill possible legal obligations. As the personal data subject, you can submit the following requests specified in Article 11 of the Law:

 

  • to learn whether your personal data are processed or not,
  • to demand information as to if your personal data have been processed,
  • to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
  • to know the third parties to whom his personal data are transferred in the country or abroad,
  • to request the rectification of the incomplete or inaccurate data, if any,

 

by filling out the application form that you can access at the website of Birinci Otomotiv to the address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Çayırova/KOCAELI” through notary public or by delivering it personally. If you submit your requests to Birinci Otomotiv, your request will be concluded in 30 days at the latest at no charge. If such requests within this scope are responded to in writing, we will respond to such requests at no charge up to ten pages, but charge 1 Turkish Lira for each page above ten pages per the Communique on the Procedures and Principles of Application to Data Controller. If the response to the application is given in a recording medium such as a CD or flash memory, the cost of the recording medium will be charged to you.

 

NOTICE ON PROCESSING AND PROTECTION OF PERSONAL DATA OF

TRAINEE EMPLOYEE

 

BIRINCI OTOMOTIV SANAYI ve TICARET ANONIM SIRKETI (“Birinci Otomotiv” or the “Company”) having its registered address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Cayırova/KOCAELI” processes your personal data such as CV, student certificate, internship contract, passport photo, residence information, family identity records, criminal records, documents demonstrating military service status, photocopies of identity cards, insurance service records, education documents, bank account information limited to the purposes given below:

 

  • to carry out Employee Candidate/Trainee/Student Selection and Placement Processes,
  • to contact your parents if you are under the age of 18 legally,
  • to fulfil the obligations arising from the Vocational Education Law No. 3308,
  • to determine and maintain human resources strategies,

 

Your personal data mentioned above will be transferred to the supervisors and employees of the human resources department of BIRINCI OTOMOTIV, to the supervisors of the relevant department where you will do your internship, and to the Company managers if deemed necessary. For the above-mentioned purposes and in accordance with Article 5/1 and 5/2-d-e-f of the Law No. 6698 on the Protection of Personal Data (“Law”), your personal data are collected on the basis of legal reasons that they have been anonymized by the data subject himself/herself, data processing is mandatory for the legitimate interests of the Company and for the establishment, exercise or protection of a right provided not to harm the fundamental rights and freedoms of the data subject.

 

By applying to BIRINCI OTOMOTIV at any time, you can exercise your rights given below:

  • to learn whether your personal data are processed or not,
  • to demand for information as to if your personal data have been processed,
  • to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
  • to know the third parties to whom your personal data are transferred in country or abroad,
  • to request the rectification of the incomplete or inaccurate data, if any,
  • to request the erasure or destruction of your personal data within the framework of the conditions stipulated by Article 7 of the Law,
  • to request the notification of the procedure made under the sub-clause (d) and (e) of Article 11 of the Law to the third parties,
  • to raise objections the processing, exclusively by automatic means, of your data, which leads to an unfavorable consequence against you,
  • to claim compensation for the damage arising from the unlawful processing of your personal data.

You can submit your requests concerning your rights and enforcement of the Law by filling out the application form that you can access at http://www.birinci.com with wet signature to the address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Çayırova/KOCAELI” through notary public, return receipt mail or personally or by filling out the application form in electronic environment after signing it with your electronic signature to our KEP address or info@birinci.com from your e-mail address registered to the data registration system of the Company. If such requests within this scope are responded in writing, BIRINCI OTOMOTIV responds to such requests at no charge up to ten pages, but it charges 1 Turkish Lira for each page above ten pages. If the response to the application is given in a recording medium such as CD or flash memory, the charge that may be requested by the Company will not exceed the cost of the recording medium.

 

NOTICE ON PROCESSING OF PERSONAL DATA

OF SUB-CONTRACTOR WORKERS

To whom it may concern,

BIRINCI OTOMOTIV SANAYI ve TICARET ANONIM SIRKETI (“BIRINCI OTOMOTIV”) having its registered address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Cayırova/KOCAELI” processes your personal data such as your name, surname, e-mail address and credentials limited to the following purposes:

  • to execute business and human resources processes,
  • to follow up on food, service, security, and cleaning services processes, which are taken on a turnkey basis,
  • to fulfill its obligations arising from the contractual relations entered into with the subcontractors of BIRINCI OTOMOTIV,
  • to fulfill the obligations arising from Labor Law No. 4857,
  • to fulfill the obligations arising from the Occupational Health and Safety Law No. 6331,

Your personal data is processed automatically and non-automatically for the aforesaid purposes based on the legal reasons clearly stipulated by Article 5/2-a-c-ç-f of Law No. 6698 on the Protection of Personal Data (“Law”) that it is mandatory to process the personal data of the contracting parties for the performance of the contract, to fulfill its legal obligations of the data controller and for the legitimate interests of the data controller, provided not to harm the fundamental rights and freedoms of the data subject.

By applying to BIRINCI OTOMOTIV, you can exercise your rights given below at any time:

  • to learn whether your personal data are processed or not and to demand information as to if your personal data have been processed,
  • to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
  • to know the third parties to whom your personal data are transferred in the country or abroad,
  • to request the rectification of the incomplete or inaccurate data, if any,
  • to request the erasure or destruction of your personal data if the conditions for processing are no longer available and to request notification of third parties about these operations if they have been transferred to any third party,
  • to claim compensation for the damage arising from the unlawful processing of your personal data.

You can submit your requests concerning your rights and enforcement of the Law by filling out the application form that you can access at http://www.birinci.com with a wet signature to the addressTOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Çayırova/KOCAELI” through notary public or personally. If such requests within this scope are responded to in writing, BIRINCI OTOMOTIV responds to such requests at no charge up to ten pages, but it charges 1 Turkish Lira for each page above ten pages. If the response to the application is given in a recording medium such as a CD or flash memory, the charge that may be requested by BIRINCI OTOMOTIV will not exceed the cost of the recording medium.

NOTICE ON PERSONAL DATA PROCESSED IN THE SUPPLY PROCESSES

To whom it may concern,

BIRINCI OTOMOTIV SANAYI ve TICARET ANONIM SIRKETI (“BIRINCI OTOMOTIV”) having its registered address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Cayırova/KOCAELI” processes your personal data such as your name, surname, e-mail address, and phone number as a result of the commercial relationship that you or the company you are affiliated with have entered with BIRINCI OTOMOTIV, limited to the following purposes;

  • to maintain the commercial relations that you or the company you are affiliated with BIRINCI OTOMOTIV,
  • to fulfill mutual obligations,
  • to meet your demands.

 

Your personal data are acquired through automatic and non-automatic means for the abovementioned purposes based on legal reasons that processing of personal data belonging to parties of the contract is mandatory for the conclusion or enforcement of a contract and legitimate interests of the data controller provided not to damage fundamental rights and freedoms of the data subject according to specified in subparagraph (f) of the Article 5/2-c of the Law on the Protection of Personal Data No. 6698. Your personal data listed above will not be transferred to third parties and will only be processed by the authorized units within BIRINCI OTOMOTIV.

By applying to BIRINCI OTOMOTIV, you can exercise your rights given below at any time:

  • to learn whether your personal data are processed or not and to demand information as to if your personal data have been processed,
  • to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
  • to know the third parties to whom your personal data are transferred in the country or abroad,
  • to request the rectification of the incomplete or inaccurate data, if any,
  • to request the erasure or destruction of your personal data if the conditions for processing are no longer available and to request notification of third parties about these operations if they have been transferred to any third party,
  • to claim compensation for the damage arising from the unlawful processing of your personal data.

You can submit your requests concerning your rights and enforcement of the Law by filling out the application form that you can access at http://www.birinci.com with your wet signature to the address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 Çayırova/KOCAELI” through notary public or personally. If such requests within this scope are responded to in writing, BIRINCI OTOMOTIV responds to such requests at no charge up to ten pages, but it charges 1 Turkish Lira for each page above ten pages. If the response to the application is given in a recording medium such as a CD or flash memory, the charge that may be requested by BIRINCI OTOMOTIV will not exceed the cost of the recording medium.

NOTICE ON THE PERSONAL DATA

TO BE PROCESSED WITHIN THE SCOPE OF PROMOTIONAL, ADVERTISEMENT, MARKETING, AND MOTIVATION-INCREASING ACTIVITIES

 

 

Dear Employee,

BIRINCI OTOMOTIV SANAYI ve TICARET ANONIM SIRKETI (“BIRINCI OTOMOTIV”) having its registered address “TOSB Automotive Sub-Industry Specialized Organized Industrial Zone, 2nd Street, No: 1 41420 Şekerpınar Çayırova/KOCAELI” processes your personal data of visual nature such as your name, surname, date of marriage, date of birth, occupation, photo, camera image, clothing automatically and non-automatically limited to the following purposes in compliance with the Law No. 6698 on Protection of Personal Data (“Law”):

  • to carry out the company’s promotion, advertising, and marketing activities of BIRINCI OTOMOTIV,
  • to ensure the update of information,
  • to enhance the sense of belonging and awareness,
  • to use them visually in the training to be given in the future at BIRINCI OTOMOTIV,
  • to use them visually in the materials covering design such as banners, posters, brochures, etc. to be used within the scope of training and events,

 

for photographing and camera recording by human resources department employees and managers of BIRINCI OTOMOTIV and video recording and production teams that BIRINCI OTOMOTIV has contracted with and publishing them on the official website and social media accounts of BIRINCI OTOMOTIV as well as boards within the body of BIRINCI OTOMOTIV.

 

Your general and private personal data to be processed within this scope will be processed with your explicit consent under Articles 5/1 and 6/2 of Law No. 6698 on the Protection of Personal Data (“Law”), limited to the purposes mentioned above, and will be transferred to social media channels of BIRINCI OTOMOTIV on the website/intranet of BIRINCI OTOMOTIV in compliance with the Article 8/1 of the Law. Personal data processed within the scope of these promotional or advertising activities will be stored for 5 years from the date of the event and will be deleted, destructed, or anonymized in the first periodic destruction term following the end of the 5 years. By applying to BIRINCI OTOMOTIV, you can exercise your rights given below at any time:

  • to learn whether your personal data are processed or not and to demand information as to if your personal data have been processed,
  • to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
  • to know the third parties to whom your personal data are transferred in the country or abroad,
  • to request the rectification of the incomplete or inaccurate data, if any,
  • to request the erasure or destruction of your personal data if the conditions for processing are no longer available and to request notification of third parties about these operations if they have been transferred to any third party,
  • to claim compensation for the damage arising from the unlawful processing of your personal data.

 

If your application made for these purposes requires an additional cost, you will have to pay the charge determined by the Communiqué on Procedures and Principles of Application to the Data Controller issued by the Personal Data Protection Board. In case a written response is given to your application, no fee will be charged for the first 10 (ten) pages, and a processing fee of TL 1 will be charged for each page above 10 (ten) pages. If the response to your application is given in a recording medium such as a CD or flash memory, the cost of the recording medium will be charged to you. Your requests in your application will be concluded as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. To exercise your rights under the law, you can submit your applications in written form in Turkish to BIRINCI OTOMOTIV, and for detailed information, you can visit the website of BIRINCI OTOMOTIV at http://www.birinci.com. You can make your application by one of the following methods;

 

  1. Sending a wet-signed copy, clearly stating your requests, by hand or via a notary public, to the address “TAYSAD Industrial Zone, 2nd Street No:1 41420 Şekerpınar Çayırova/Kocaeli”,
  2. By using your KEP (Registered Electronic Mail) address, secure electronic signature, mobile signature, or your e-mail address previously notified to BIRINCI OTOMOTIV and registered in BIRINCI OTOMOTIV’s system, to the [**] KEP address of BIRINCI OTOMOTIV.

 

In the application covering your explanations concerning the right that you have as the personal data subject and you will make and request to exercise the above-mentioned rights, your request must be explicit, understandable, and about you, and if you are acting on behalf of someone else, you have to submit your special power of attorney certified by a notary public. In your applications, name-surname, signature, T.R. ID number, residence or workplace address, e-mail address, telephone and fax number, the elements of the request are mandatory under the “Communiqué on the Procedures and Principles of Application to the Data Controller”. Applications that do not contain the aforementioned aspects will be rejected by BIRINCI OTOMOTIV.

 

 

Birinci Otomotiv Sanayi Ve Ticaret A.S.