TRIMline Interiors

ENLIGHTENMENT TEXT FOR PROTECTION OF PERSONAL DATA LAW

PURPOSE

We, as Tirim İnşaat Mimarlık Taahhüt San. Ve Tic. A.Ş., respect the confidentiality of your personal data, attach great importance to the data security and put this issue among our prioritises. We adopt the principles of collection, processing and protection of the personal data belong to our customers, potential customers, website users, employees, employee candidates, Trimline’s former employees, interns, company shareholders, company officials, business partners, employees of the group companies, visitors according to the regulations that are set forth in the Personal Data Protection Law No. 6698 for the purpose of processing and protecting these personal data.

Therefore, we recommend you to read this text carefully that explains how we process your personal data, with whom we share it and how you can exercise your rights.

All personal data that belong to all persons associated with Trimline, including those who benefit from our services, may be recorded, stored, updated and processed and shared with third parties within the framework permitted by the legislation as long as your relationship with our company continues for specific, explicit and legitimate purposes and in accordance with the Personal Data Protection Law No. 6698, provided that they comply with the law and good faith.

As defined in the Personal Data Protection Law, we, as Trimline, have been determining the information that we have obtained from you in the capacity of “Data Controller” within our relationship with you.

DEFINITIONS

The terms herein shall refer to;

Personal Data: all the information relating to an identified or identifiable natural person,
Processing of Personal Data: any operation performed upon personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or provided that the process is a part of any data registry system, through non-automatic means,
Personal Data Protection Law No. 6698 “KVKK”: the Personal Data Protection Law No. 6698 that was enacted by being published in the Official Gazette on April 7, 2016,
Authority: the Personal Data Protection Authority,
Board: the Personal Data Protection Board,
Data Processor: the natural or legal person who processes personal data on behalf of the controller upon his authorization,
Data Controller: the natural or legal person who determines the purpose and means of processing personal data and is responsible for establishing and managing the data registry system,
Data Subject: the natural person, whose personal data is processed,
Contact Person: the natural person is solely liable for the management of communication between the Authority and the Data Controller, and not authorized to represent the Data Controller regarding the obligations set out under the Law and receives the notifications given by the Authority (Contact person is not authorized to evaluate the questions and requests from the Data Subject rather is only establishes the communication),
Trimline: Tirim İnşaat Mimarlık Taahhüt San. Ve Tic. A.Ş.

DATA CONTROLLER

Data Controller : Tirim İnşaat Mimarlık Taahhüt San. Ve Tic. A.Ş.

Esentepe Mah. Kelebek Sok. Marmarakule A Blok No:2 K:13 D:105

Kartal/Istanbul – Turkey

Contact Person : Derya Dinç

Telephone :

E-mail : ik@trimline.com.tr

IMPLEMENTATION

We, as Tirim İnşaat Mimarlık Taahhüt San. Ve Tic. A.Ş., attach great importance to securing, collecting, processing, transferring and destructing of the personal data belong to our customers, potential customers, website users, employees, employee candidates, Trimline’s former employees, interns, company shareholders, company officials, business partners, employees of the group companies, visitors and related to the third person that we have under the Constitution of Turkey, the international conventions to which our country is a party and the relevant legislation, primarily the Protection of Personal Data Law No. 6698.

With this regard, your personal data that you share with us can be processed, transferred to domestic and foreign third parties, stored, used for profiling and classified only if relevant with, limited to and proportionate to our activities and objectives for which they are processed and in accordance with the Law.

Purpose of Processing Your Personal Data

Your personal data may be processed with explicit consent and without seeking the explicit consent of the data subject only in cases where one of the following conditions are met;

if it is clearly stipulated in the laws,
if it is mandatory for us to be able to perform our legal obligations related to the establishment or conclusion of the contract,
if it is mandatory for the establishment, exercise or protection of any right,
if it is mandatory for our legitimate interests,
if it is made available to the public by you (relevant data subjects),

Also, the following principles shall comply within the processing of personal data:

Lawfulness and conformity with rules of bona fides.
Accuracy and being up to date, where necessary.
Being processed for specific, explicit and legitimate purposes.
Being relevant to, limited to and proportionate to the purposes for which they are processed.
Being retained for the period of time stipulated by relevant legislation or the purpose for which they are processed.

Your personal data may be processed by our company for the following purposes without compromising our quality;

Carrying out occupational health and safety activities,
Planning and following up the work carried out with business partners, vendors or suppliers,
Creating and managing the customer records,
Maintaining customer relations and tracking corporate governance activities,
Managing and following the customer demands and complaints,
Ensuring Business Continuity,
Following the contract processes,
Following and executing the legal processes and communication processes with official institutions,
Ensuring the legal and commercial security,
Developing and improving the services offered by our company,
Identifying and implementing the commercial and business strategies,
Doing market research,
Planning and organizing activities to ensure and/or increase dependence on products and services,
Maintaining the business and operations,
Managing the sales and purchasing processes,
Fulfilling the guarantee obligations,
Establishing contractual processes such as sales and after-sales support with you as our customers, concluding and following all necessary transactions, managing contract processes and planning and concluding the operational processes related to sales,
Creating and updating profit reports by obtaining information about customer-based developments,
Planning and organizing activities to ensure and/or increase dependence on products and services,
Managing company activities and procedures,
Realizing the financial and accounting transactions,
Performing financial, accounting and financial transactions, including billing activities related to sales, managing risks,
Conducting internal audit processes,
Fulfilling the notification obligation to the relevant/authorized public institutions,
Managing job and internship application and evaluation processes,
Creating personnel files and managing on-the-job processes,
Managing Human Resources processes,
Fulfilling the obligations arising from the employment contract and legislation for the employees,
Conducting Training Activities,
Managing the physical security processes,
Planning information security processes, building and managing the infrastructure for information technologies,
Managing risks.

The method and legal reason for the collection of personal data

Your personal data may be collected, fully or partially, orally, in writing or electronically through automatic means or provided that the process is a part of any data registry system, through non-automatic means for the foregoing purposes and scope.

Under the management of commercial processes; contact forms, fair organizations, business cards, supplier information request forms, other commercial documents, payment information and papers, negotiable instruments, application forms for employee and intern candidates, resumes, electronic mails, websites, various contracts, mobile applications, consumer complaint forms are being collected orally, in writing or electronically and through various methods that can be obtained also out of our company, including our customers, suppliers, other 3^rd persons.

Transfer of your personal data

Your personal data may be transferred to authorized public institutions and organizations as per the obligations and requirements from legal legislation, the intermediary financial institutions for the assessment of financial risks, the independent audit firms for the management of audit processes, the organizations providing intermediary / agency service during business travel and organization, fairs, to our business partners, suppliers, shareholders and local / international organizations that we get support in our business processes, the subsidiaries, domestic / foreign service providers and cooperating organizations under the related agreements to carry out direct / indirect domestic / international operations as Trimline and to other 3^rd persons as being responsible with Trimline by taking data security measures to retain data, to avoid unauthorized access and prevent them from being processed illegally and in accordance with the PPDL and applicable legislation for the purposes listed above.

Retention and Erasure of Data

The relevant personal data must be retained for a certain period of time as per the legislation. Therefore, the retention of personal data in accordance with the legislation and for the required period is under the responsibility of our company. These retention periods are defined in detail on the data base in the personal data inventory prepared. The personal data are retained for the period of time stipulated by relevant legislation or the purpose for which they are processed. The data are retained in physical or electronic media. Our company has taken the necessary security measures and ensure a safe environment for the retention and protection of data. The personal data whose retention period has expired is destructed every 6 months (being erased/destroyed/anonymised)

Your Rights as A Data Subject

Under the 11^th article of PDPL No. 6698,

You have the right to apply to the controller and

to learn whether your personal data are processed or not,
to request information if your personal data are processed,
to learn the purpose of your data processing and whether your data is used for intended purposes,
to know the third parties to whom your personal data is transferred at home or abroad,
to request the rectification of the incomplete or inaccurate data, if any,
to request the erasure or destruction of your personal data under the conditions laid down in PPDL,
to request notification of the operations to third parties to whom your personal data has been transferred, when you request any rectification of the incomplete or inaccurate data and any erasure or destruction of your personal data
to object to the processing, exclusively by automatic means, of your personal data, which leads to an unfavourable consequence for the data subject,
to request compensation for the damage arising from the unlawful processing of your personal data.

You can file your application thought a petition, including your request to exercise these rights, or by filling out the Information Request Form at www.trimline.com.tr. Your application should have the following requirements;

It shall contain the applicant’s identity and address, (Documents proving your identity must be attached),
The subject you request shall be relevant to you,
If you are acting on behalf of someone else, you should be specifically authorized and certified,
The subject you request shall be clear and apprehensible.

Application Method	Application Address	Information to Be Displayed in The Application
Application in Person		“Information Request as per the PPDL” shall be written on the envelope/notice.
Application through Notary Public		“Information Request as per PPDL” shall be written on the envelope/notice.
Through secure electronic means	trim@hs01.kep.tr	“Information Request as per PPDL” shall be written in the subject section of the e-mail.
Through your registered e-mail address	ik@trimline.com.tr	“Information Request as per PPDL” shall be written in the subject section of the e-mail.

Within the scope of the foregoing article, our company will conclude your application according to the nature of your request free of charge or according to the tariff to be set by the PDP Board as soon as possible (not more than 30 days).

In case your application is refused, the answer is found to be insufficient or your application is not responded within its time, you, as the Data Subject, can file a complaint to the Board as per the 14^th Article of Personal Data Protection Law No. 6698 within the thirty days from the date you were responded or in any case within sixty days from the date of application with the consent of the person.

As per the article 28/2 of PDPL No. 6698; in the following cases, the data subjects shall not claim their other foregoing rights, except for the right to claim damages;

Where personal data processing is required for the prevention of a crime or criminal investigation.
Where personal data processing is carried out on the data which is made public by the data subject himself.
Where personal data processing is required for inspection or regulatory duties and disciplinary investigation and prosecution to be carried out by the public institutions and organizations and by professional associations having the status of a public institution, assigned and authorized for such actions, in accordance with the power conferred on them by the law,
Where personal data processing is required for the protection of State’s economic and financial interests with regard to budgetary, tax-related and financial issues.

OTHER PROVISIONS

In the processes under this Enlightenment Text for the Protection and Processing of Personal Data, the relevant applicable legal regulations on the protection and processing of personal data shall primarily apply.

The Enlightenment Text is available for the relevant people by being published on the web site, www.trimline.com.tr. The Enlightenment Text may be changed and updated to comply with the changing conditions and legislation and made available for the relevant people through the above-written web site.

-------------------------
Application Form
-------------------------

TİRİM İNŞAAT MİMARLIK TAAHHÜT SAN. VE TİC. A.Ş.