SOLARIS IMAGING CENTER TRADE A.Sh.

PROTECTION AND PROCESSING OF PERSONAL DATA POLICY

entry 

Purpose
Scope
Abbreviations and Definitions 
ISSUES RELATED TO THE PROCESSING OF PERSONAL DATA

Processing of Personal Data in Accordance with the Legislation
Processing Conditions
Informing And Informing the Relevant People
Processing of Personal Data of a Special Nature
CATEGORIES OF PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

Categories of Personal Data Processed
Purposes of Personal Data Processing
ISSUES RELATED TO THE PROTECTION OF PERSONAL DATA

Technical Measures
Administrative Measures
Issues Related to the Protection of Personal Data of a Special Nature
Providing Training and Supervision to Employees on the Protection and Processing of Personal Data 
ISSUES RELATED TO THE TRANSFER OF PERSONAL DATA

Transfer of Personal Data of a Special Nature
Scope and Purposes of Data Transfer
THE RIGHTS OF THE PERSONAL DATA OWNERS AND THE EXERCISE OF THESE RIGHTS 
DESTRUCTION OF PERSONAL DATA (CONDITIONS FOR DELETION, DESTRUCTION AND ANONYMIZATION
SPECIAL CIRCUMSTANCES IN WHICH PERSONAL DATA IS PROCESSED
THE RELATIONSHIP OF THE PERSONAL DATA PROTECTION AND PROCESSING POLICY WITH OTHER POLICIES
10.UPDATE PERIOD OF THE POLICY 
11.ENTRY INTO FORCE AND REPEAL OF THE POLICY  

1.entry 

1.1 Purpose 

 Personal Data Protection and Processing Policy, Established in Turkey, Headquarters; Ataköy 8-8-9-10 Section Mah. Çobançeşme E5 Side Road No:16/1 A Inner Door No: 20 Located at Ataköy-Bakırköy-Istanbul, 0773073379200001 mersis no, Bakırköy Tax Office, taxpayer Solaris Imaging Center Trade A no: 7730733792 .Sh. It has been prepared by (the “COMPANY”) in order to ensure compliance with the obligations imposed on data controllers within the scope of the Personal Data Protection Law No. 6698 (“KVKK”) and to determine the procedures and principles regarding the work and transactions related to data processing and protection activities that are being carried out. 

THE COMPANY; With its sensitive approach to the protection of personal data, T of the personal data belonging to COMPANY employees, employee candidates, customers, suppliers, visitors and other third parties.C. The Constitution, international conventions, the Law on the Protection of Personal Data numbered 6698 and other relevant legislation in accordance with the processing and ensuring the effective use of the rights of the persons concerned has determined as a priority. The works and transactions related to the processing and protection of personal data are carried out in accordance with the Policy prepared by the COMPANY in this direction.

1.2 Scope 

 All personal data of our customers, employees, employee candidates, visitors, suppliers, service providers, customers whose personal data has been collected, employees of the institutions with which we cooperate and third parties processed automatically or by non-automatic means, provided that they are part of any data recording system, are covered by this Policy and this Policy is applied to all recording environments and personal data processing activities owned or managed by the COMPANY in which personal data is processed. The Company reserves the right to make changes in accordance with the amendments to be made to the KVKK and the relevant regulation.

1.3 Abbreviations and Definitions 

 Explicit Consent : Consent related to a specific topic, based on information and explained by free will. 

Anonymization : Making personal data that cannot be associated with an identified or identifiable real person under any circumstances, even by matching it with other data. 

Employee : Solaris Imaging Center Trade A.Sh.  the staff. 

Contact Person : The real person whose personal data is processed. 

Related User: Persons who process personal data within the data controller organization or in accordance with the authority and instructions received from the data controller, except for the person or unit responsible for the technical storage, protection and backup of data. 

Destruction : Deletion, destruction or anonymization of personal data. 

Law : Law No. 6698 on the Protection of Personal Data. 

Recording Environment: Any environment in which personal data is processed by non-automatic means, provided that it is fully or partially automatic or part of any data recording system. 

Personal Data : Any kind of information related to an identified or identifiable real person. 

Personal Data Processing Inventory: An inventory in which data controllers detail the personal data processing activities they perform depending on their business processes, the purposes of processing personal data and the legal reason, the data category, the recipient group transferred and the contact group of the data subject, explaining the maximum retention period required for the purposes for which personal data are processed, the personal data envisaged for transfer to foreign countries and the measures taken for data security. 

Processing of Personal Data: All kinds of operations performed on data such as obtaining, recording, storing, storing, changing, rearranging, disclosing, transferring, inheriting, making available, classifying or preventing the use of personal data by means that are fully or partially automatic or non-automatic provided that they are part of any data recording system. 

Special Categories of Personal Data: Race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs of persons, clothing and clothing, association, foundation or trade union membership, health, sexual life, criminal conviction and security measures related data, as well as biometric and genetic data. 

Policy : The Policy of Protection and Processing of Personal Data.

Company: Solaris Imaging Center Trade A.Sh. 

Data Processor: A natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller. 

Data Recording System: A recording system in which personal data is processed by being structured according to certain criteria. 

Data Controller: The natural or legal person responsible for the establishment and management of the data recording system, who determines the purposes and means of processing personal data. 

2. ISSUES RELATED TO THE PROCESSING OF PERSONAL DATA

 2.1. Processing of Personal Data in Accordance with the Legislation

 The following principles have been adopted by the Company for the collection, processing and analysis of personal data.

Processing of personal data in accordance with the law and the rules of honesty; The Company acts in accordance with the principles established by legal regulations and the general rule of trust and honesty in the processing of personal data.
Keeping the personal data accurate and updated when necessary; The Company takes the necessary measures to keep the personal data accurate and up-to-date during the processing period and establishes the necessary mechanisms to ensure the accuracy and timeliness of the personal data for certain periods of time.
Processing of personal data for specific, clear and legitimate purposes; The Company clearly and precisely determines the purpose of processing personal data, which is legitimate and in accordance with the law. The Company processes as much personal data as is necessary for and in connection with the commercial activity it is carrying out.
Limited and metered processing of personal data related to the purposes for which they are processed; The Company collects personal data only in the nature and extent required by business activities and processes them limited to the specified purposes
Retention of personal data for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed; The Company retains personal data for the period required for the purpose for which they are processed and for the minimum period stipulated in the legal legislation to which the relevant activity is subject. Within this scope, our Company firstly determines whether a period of time is stipulated for the storage of personal data in the relevant legislation and acts in accordance with this period if a period of time is determined. If there is no legal period, the personal data are stored for the period necessary for the purpose for which they are processed. Personal data are destroyed at the end of the specified storage periods in accordance with the periodic destruction periods or the application of the data owner and with the determined destruction methods (deletion and/ or destruction and/ or anonymization).
Informing and informing the relevant persons; Data owners should be informed in detail before the collection and processing of their personal data.
Taking the necessary measures for the protection of personal data;
To act in accordance with the relevant legislation and KVK Board regulations in determining and implementing the purposes of processing personal data, transferring it to third parties,
Special regulation of the processing and protection of personal data of a special nature.

2.2. Processing Conditions

 Personal data may be collected and processed by the Company directly from the relevant person, electronically or in physical environments, within the framework of the commercial, legal, contractual or otherwise established relationship between the Company and the Relevant Person, except for the express consent of the relevant person, within the framework of the purposes detailed below and in accordance with the legislation. Dec.1. Personal data may be collected and processed by the Company directly from the relevant person, electronically or in physical environments. 

 These issues are stated in the lighting texts prepared separately for each data subject and presented to the data subjects (Employee and employee candidates lighting text, website privacy and cookie texts, supplier lighting text, visitor lighting text, etc.).

If the processed data is personal data of a special nature, the conditions contained in the “Personal Data Protection Policy of a Special Nature” will be applied.

Apart from explicit consent, personal data may also be processed in the event of the existence of one of the conditions specified in the law. The basis of the personal data processing activity may be only one of the following conditions, as well as more than one conditions may be the basis of the same personal data processing activity.

Having the explicit consent of the personal data owner,
Failure to obtain the explicit consent of the person concerned due to actual impossibility,
Clearly stipulated in the laws,
The processing is mandatory in order for the Company to fulfill its legal obligations,