Turunç processes your personal data with respect to the personal data processing conditions and purposes set forth by the PDPL, and subject to the following:
– in accordance with applicable law and the principle of good faith;
– by keeping the shared personal data accurate and up-to-date;
– for particular, explicit and lawful purposes;
– in accordance with the purpose of the processing, and in limited and proportionate manner; and
– within terms and conditions determined by applicable law or as necessary for the purposes of processing.
I. Collection of Personal Data
1. Through the Website
Personal data belonging to you is collected through your visit to the website www.turunc.av.tr (“Website”) and directly from you. Your data is stored in the Turunç user database.
2. Through Camera Footage
The entrance and accounting department of our workplace are recorded by camera to ensure security of the workplace, monitoring entry and exit to the workplace, and monitoring workflow, in each case to protect the legitimate interests of Turunç. Notifications are posted in the relevant units and areas. No voice recordings are made.
II. Purposes and Legal Basis for Processing Personal Data
1. Processing Based on Explicit Consent
Newsletter Subscription. An option to share your e-mail address to subscribe to our newsletters is provided on the Website. Sharing this information is entirely up to your discretion. Not sharing this information has no effect on using the Website.
We request this information to create a record in our user database. The user database records are used to manage our business relations.
When subscribing to our newsletters, by providing the relevant personal data and checking the consent box on the Website, you give your explicit consent to Turunç to process such data for these purposes. In this case, your personal data mentioned in this paragraph will be processed by Turunç based on your explicit consent within the scope of PDPL Article 5/1.
2. Processing Based on Lawfulness
E-mail Communications. E-mails to corporate Turunç e-mail addresses, which operate on the software developed by Microsoft Corporation, are stored along with any attachments on Microsoft Corporation’s servers located outside of Turkey. If you include personal data belonging to yourself or third parties while conducting correspondence via e-mail, such data will be transferred abroad. By sending e-mails to Turunç’s corporate accounts, you give your consent for such e-mails and their attachments to be stored by Microsoft Corporation’s servers located abroad. If you do not consent to your e-mails and attachments to be stored by Microsoft Corporation’s servers located abroad, please do not send your personal data via e-mail.
III. Automatic Data Processing
Your personal data is processed automatically for statistical purposes.
IV. Transferring Personal Data to Third Parties
1. Transfer of Personal Data based on PDPL Article 8/2(a)
Turunç may transfer and disclose your personal data without your consent in order to fulfill its statutory obligations and/or to perform its obligations under contract agreement, to comply with its legal duties and/or establish, use or protect its rights, to the following persons:
(a) solely for the purpose of fulfilling its obligations, and limited and proportionate to the service obtained, in particular to technical support units within Turunç and Turunç’s e-mail service providers, and to relevant departments, banks, audit firms, attorneys, law firms, financial consultants, as well as to third party suppliers necessary for its business and/or service providers such as third parties who host or organize events or seminars; and
(b) law enforcement, judicial authorities, relevant ministries and directorates, and other public institutions authorized by law.
Even if rarely, we may be required to disclose your data in order to comply with statutory or regulatory requirements. Please be assured that necessary efforts will be made to inform before such disclosure unless we are restricted from doing so.
Data transfers within Turkey are limited to PDPL Article 5/2, paragraph (a) (by operation of law per PDPL Article 8/2 (a), paragraph (c) (entry into and/or performance of a contract), paragraph (ç) (compliance with a legal obligation) and paragraph (e) (establishment, use or protection of a right).
Information concerning third parties to whom your data is disclosed and/or third party categories within Turkey is always available for your review.
2. Personal Data Access From Abroad
Your personal data is transferred to the following entities located outside of Turkey: (a) Microsoft Corporation, with its headquarters in the United States of America, from which communication services are obtained via servers, cloud services and corporate e-mail addresses and (b) MailerLite Limited, with its headquarters in Ireland and MailerLite, Inc., with its headquarters in the United States of America, from which communication services for sending newsletters is obtained.
Such storage is based on your explicit consent obtained from you via the Website. The legal basis for your explicit consent is the Article 9/1 of the PDPL. You can always withdraw your explicit consent to the transfer of your personal data to outside of Turkey. Your withdrawal of consent will not affect the lawfulness of the processing based on your consent prior to such withdrawal.
Turunç also uses social media applications such as LinkedIn, Facebook and Twitter. If you use these applications, you should review the privacy policies of such applications for more information about how they process your personal information.
V. Protection, Storage Period and Destruction of Personal Data
Turunç is obliged to take, and takes to the maximum extent, all kinds of physical, technical and administrative measures to ensure an adequate level of security in order to prevent the unlawful processing of your personal data and unlawful access to your personal data, and to ensure the protection of your personal data.
The processing of your personal data for the purpose of newsletter subscription will be undertaken for the duration of the provision of the relevant service so long as you do not withdraw your explicit consent to the provision of the relevant services.
If you withdraw your explicit consent, your personal data will be deleted, destroyed or anonymized during the first destruction period.
Turunç has prepared separate and tailored privacy notices for its clients, employees, job applicants, suppliers and managers. These privacy notices have been delivered or made available to each relevant group.
VII. Your Rights
As the data subject, you have the following rights under applicable law: (a) to learn whether and how your personal data is processed (Art. 11/a and b), (b) to learn the purpose of the processing and whether the data is used in accordance with its purpose (Art. 11/c), (c) to know the third parties to whom data is transferred (Art. 11/ç), (d) to request rectification (Art. 11/d), (e) to request the deletion of your personal data in case the reasons requiring processing have ceased to exists (Art. 7, Art. 11/e), (f) to request that third parties to whom your personal data has been transferred be notified of any relevant operations regarding rectification and deletion (Art. 11/f), (g) to object to the results obtained as a result of analysis (Art. 11/g), (h) to request the restriction of processing (Art. 7) and (i) to request the compensation in case of damage caused due to unlawful processing (Art. 11/ğ).
Your rights mentioned above are limited by law and will likely only be granted by us under certain conditions. (Please examine in particular Articles 10 and 13 of the PDPL.) You can forward the requests listed above to the [email protected] e-mail address. Turunç will conclude your request as soon as possible and no later than thirty (30) days after receipt of the request and the necessary documents.
Please be informed that even after you withdraw your explicit consent, especially for the personal data we may process without your explicit consent, we may continue to process your personal data to use and protect our own legal rights or to be able to perform our legal obligations, as required or permitted by applicable law.
Turunç Law Firm
Teşvikiye Caddesi 19/11, Teşvikiye, Istanbul, Turkey
Please contact the administrative unit via e-mail.
Upon your request, Turunç can always update your personal data.
Right to Complain to the Personal Data Protection Board
You can use the following contact information to exercise your right to file a complaint with the Board pursuant to Articles 13, 14 and 15 of the PDPL:
Board: Personal Data Protection Board
Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4, Balgat, Çankaya, Ankara 06520, Turkey
Phone: +90 312 216 5000
Last Updated: November 17, 2022