Personal Data Processing Clarification Text
As Origin FGL Lojistik A.Ş. (hereinafter referred to as “Origin FGL”), we have prepared this Clarification Text on the Processing of Personal Data (“Clarification Text”) to inform the data owners in relation to the processing, storage, and transfer of their personal data within the scope of our activities arising from the Personal Data Protection Law No. 6698 (“PDPL”) and the relevant legislation and legal regulations.
This Clarification Text shall be effective as of the date of its publication by Origin FGL. Origin FGL reserves the right to amend the Clarification Text whenever necessary.
Relevant Data Subjects: Supplier Representative / Employee
Data Category | Processed Personal Data | Purposes of Data Processing | Legal Grounds for Processing | Data Collection Methods |
01- Identity Data | Name-Surname, Signature, Turkish ID Number, Place of Birth, Marital Status, Information on ID Copy (Place and Date of Birth, Gender, Serial Number, Nationality, Expiry Date, Parents’ Names and Information) | Emergency Management Processes, Fulfillment of Employment and Legal Obligations for Employees, Execution of Finance and Accounting Operations, Compliance with Legal Requirements, Execution of Contractual Processes, Ensuring Physical Space Security, Evaluation of Requests, Informing Authorized Persons, Institutions and Organizations, Management and Reporting Activities, Legal Affairs Management, Organization and Event Management, Execution of Goods/Services Procurement Processes, Execution of Business Activities, Human Resources Process Planning, Access Management, Execution of Occupational Health and Safety Activities, Execution of Training Activities, Execution of Communication Activities | Turkish Commercial Code No. 6102, Labour Law No. 4857, Occupational Health and Safety Law No. 6331, Tax Procedure Law No. 213, PDPL No. 6698, | Collected via e-mail, phone, contracts, and submitted documents. |
02 – Contact Data | Address, E-mail, Phone Number | Compliance with Legal Requirements, Finance and Accounting Operations, Execution of Contractual Processes, Evaluation of Requests, Execution of Communication Activities, Informing Authorized Persons, Institutions and Organizations, Execution of Management Activities, Legal Affairs Management, Organization and Event Management | Labour Law No. 4857, Social Insurance and General Health Insurance Law No. 5510, Turkish Code of Obligations No. 6098, Occupational Health and Safety Law No. 6331, PDPL No. 6698, | Collected via e-mail or phone from you or your company, contracts, and submitted documents. |
04 – Employment Data | Position/Title, Social Security Information, Military Status, Employment Dates and Times, Seniority/Notice and Annual Leave Details | Compliance with Legal Requirements, Legal Affairs Management, Execution/Supervision of Business Activities, Execution of Contractual Processes, Informing Authorized Persons, Institutions and Organizations | Labour Law No. 4857, Social Insurance and General Health Insurance Law No. 5510, Turkish Code of Obligations No. 6098, Occupational Health and Safety Law No. 6331, PDPL No. 6698, Art. 5/2(c), 5/2(ç), 5/2(e) as above. | Collected via e-mail or phone from you or your company, contracts, and submitted documents. |
05 – Legal Transaction Data | Contracts, Signature Circulars, Power of Attorney, Notices | Compliance with Legal Requirements, Execution of Finance and Accounting Operations, Goods/Services Sales Processes, Execution of Contractual Processes, Legal Affairs Management | Enforcement and Bankruptcy Law No. 2004, Labour Law No. 4857, Social Insurance and General Health Insurance Law No. 5510, Turkish Code of Obligations No. 6098, Occupational Health and Safety Law No. 6331, PDPL No. 6698, Art. 5/2(c), 5/2(ç), 5/2(e) as above. | Collected via e-mail, contracts, notifications, and submitted documents. |
06 – Customer Transaction Data | Invoice, Cheque-Note | Compliance with Legal Requirements, Execution of Finance and Accounting Operations, Goods/Services Sales Processes, Execution of Contractual Processes | Tax Procedure Law No. 213 (Art. 230), PDPL No. 6698, Art. 5/2(e) as above. | Collected via invoices and cheque-note information. |
07 – Physical Space Security | CCTV Footage | Ensuring Physical Space Security | PDPL No. 6698 Art. 5/2(f): Processing is necessary for the legitimate interests of the data controller, provided that it does not violate the fundamental rights of the data subject. | Collected automatically via camera systems upon entry to company premises. |
08 – Transaction Security | Log Records, Passwords | Compliance with Legal Requirements, Execution of Information Security Processes, Execution of Communication Activities | Law No. 5651 and related regulations, PDPL No. 6698 Art. 5/2(e), 5/2(f) as above. | Automatically processed when using passwords or internet access. |
10 – Financial Data | Bank Account Details, IBAN | Execution of Finance and Accounting Operations, Business Activities Management/Supervision, Contractual Process Management, Compliance with Legal Requirements, Informing Authorized Persons, Institutions and Organizations | Turkish Commercial Code No. 6102, PDPL No. 6698, Art. 5/2(c), 5/2(e) as above. | Collected via e-mail, phone, or direct provision by your company representatives. |
11 – Professional Experience | Role, Certificates and Professional Qualifications, Previous Employers | Compliance with Legal Requirements, Fulfillment of Employment and Legal Obligations | Labour Law No. 4857, Occupational Health and Safety Law No. 6331, PDPL No. 6698, Art. 5/2(f) as above. | Collected via e-mail or phone from you/r company, contracts, and submitted documents. |
Health Data | Health Reports (Audiometry, Lung Function Test, Chest X-ray, Hemogram, Kidney Function Test, Blood Type, Illness Information, Medical Test/Imaging, Disability Information, Accident Report) | Compliance with Legal Requirements, Informing Authorized Institutions, Fulfillment of Employment and Legal Obligations, Execution of Occupational Health and Safety Processes | Labour Law No. 4857, Occupational Health and Safety Law No. 6331, PDPL No. 6698 Art. 6/3 | Collected via e-mail, phone, and submitted documents. |
Transfer of Processed Personal Data: To Whom and for What Purpose?
Personal data collected by Origin FGL is transferred in accordance with Articles 8 and 9 of the KVKK.
Data Category | Personal Data | Purpose of Transfer | To Whom It Is Transferred | Method of Transfer | International Data Transfer |
01 – Identity Data | Name-Surname, Signature, Turkish ID Number, Place of Birth, Marital Status, Information on ID Copy (Place and Date of Birth, Gender, Serial Number, Nationality, Expiry Date, Parents’ Names and Information) | Financial/accounting/logistics operations, legal proceedings, handling requests/complaints, regulatory compliance | Private/legal persons, suppliers, public authorities, customers | Email, Post | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
02 – Contact Data | Address, Email, Phone Number | Financial/accounting/logistics operations, sales, and contract processes | Private/legal persons, suppliers, public authorities | Email, Post | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
04 – Employment Data | Position/Title, Social Security Information, Military Status, Employment Dates and Times, Seniority/Notice and Annual Leave Details | Contract processes, Informing Authorized Persons, Institutions and Organizations | Private/legal persons, suppliers, public authorities | Email, Post, CD or USB | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
05 – Legal Data | Power of attorney, Signature circular, Contracts | Financial/accounting operations, regulatory compliance, Informing Authorized Persons, Institutions and Organizations | Private/legal persons, public authorities | Email, Post | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
06 – Customer Transactions | Invoices, Cheque/Bill Info | Financial/accounting operations, Informing Authorized Persons, Institutions and Organizations | Private/legal persons, public authorities | Email, Post | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
07 – Physical Security | CCTV Footage | Informing Authorized Persons, Institutions and Organizations | Public authorities | CD or USB | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
08 – Transaction Security | Log Records, Passwords | Compliance with Legal Requirements, Execution of Information Security Processes, Execution of Communication Activities | Public authorities | CD or USB | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
10 – Financial Data | Bank Account Details, IBAN | Execution of Finance and Accounting Operations, Business Activities Management/Supervision, Contractual Process Management, Compliance with Legal Requirements, Informing Authorized Persons, Institutions and Organizations | Private/legal persons, public authorities | Email, Invoice, Receipt | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
11 – Professional Experience | Role, Certificates and Professional Qualifications, Previous Employers | Compliance with Legal Requirements, Fulfillment of Employment and Legal Obligations | Public authorities | Email, Post | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
Health Data | Health Reports (Audiometry, Lung Function Test, Chest X-ray, Hemogram, Kidney Function Test, Blood Type, Illness Information, Medical Test/Imaging, Disability Information, Accident Report) | Compliance with Legal Requirements, Informing Authorized Institutions, Fulfillment of Employment and Legal Obligations, Execution of Occupational Health and Safety Processes | Public authorities | Email, CD or USB | Transferred abroad due to foreign-based systems used (Microsoft 365, Outlook, cloud systems like Barracuda Backup) |
YOUR RIGHTS UNDER ARTICLE 11 OF THE KVKK
As the data subject, under Article 11 of the KVKK, you have the following rights:
- To learn whether personal data is processed,
- To request information if your data is processed,
- To learn the purpose of data processing and whether it is used accordingly,
- To know third parties to whom data is transferred domestically or abroad,
- To request correction if your data is incomplete or incorrect and that such correction is shared with third parties,
- To request deletion or destruction of your data if the reasons requiring processing cease to exist, and to request that this be shared with third parties,
- To object to any result against you arising from analysis by automated systems,
- To request compensation if you incur damage due to unlawful processing of your data
You can submit your requests regarding the rights listed above by filling out the Data Owner Application Form available at www.originfgl.com, and delivering the signed form together with identification documents in person to the address “Oruçreis Mah. Vadi Cad. No: 108 İstanbul Ticaret Sarayı Kat: 3 Giyimkent Sitesi, Esenler/İstanbul” , via notary, or by sending it to kvkk@originfgl.com
Origin FGL will conclude your request free of charge within 30 days at the latest, depending on the nature of the request. However, if the process incurs a cost, the fee determined by the Personal Data Protection Board may be charged.
Applications must be made in Turkish. The application must include your name, surname, signature (if hand written), Turkish ID number (for Turkish citizens), passport/ID number (for foreigners), residential or workplace address for notification, email (if available), phone/fax number, and subject of the request.
In the application to be made by the personal data subject in order to exercise the above-mentioned rights, and which includes explanations regarding the right they request to exercise, the requested matter must be clear and understandable, the subject of the request must be related to the applicant personally, or if acting on behalf of someone else, the applicant must be specifically authorized in this regard and must document such authorization; the application must include identity and address information, and documents verifying the applicant’s identity must be attached.
This notification is made in the capacity of “Data Controller” under the KVKK.
Origin FGL Lojistik A.Ş. | ||
Address | : | Oruçreis Mah. Vadi Cad. No:108 İstanbul Ticaret Sarayı K:3 Giyimkent Sitesi Esenler/İSTANBUL |
: | ||
Web | : | |
