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Privacy Statement On The Processing Of Personal Data Kyc Processes

Communication Process Clarification Text
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Information Text Regarding The Electronic Commercial Message (“ECM”) Process of Sanipak Sağlıklı Yaşam Ürünleri San. ve Tic. A.Ş
Privacy Statement On The Processing Of Personal Data Kyc Processes

PRIVACY STATEMENT ON THE PROCESSING OF PERSONAL DATA KYC PROCESSES

A. Data Controller

As SANİPAK SAĞLIKLI YAŞAM ÜRÜNLERİ SAN. VE TİC. A.Ş. (“Company”), we process your personal data as the data controller in accordance with the relevant legislation. With this statement, it is aimed to inform you about your personal data processed within the scope of Third Party (customer, business partner, dealer, supplier, etc.) Know Your Customer (KYC) Process Management, within the framework of our obligation to inform under the LPPD , GDPR and applicable laws (“Data Protection Regulations”).

B. Processed Personal Data, Purposes of Processing Your Personal Data, and Legal Grounds

Your personal data will be processed for the following purposes and legal grounds:

Data Processing Purposes Legal Grounds of the Processing Processed Personal Data
  • Conducting business partner risk assessment and KYC processes to prevent illegal and unlawful practices and for the safety of Company’s operations,
  • Conducting compliance examinations to prevent fraud, money laundering, and financing of terrorism, screening sanctions lists and ensuring compliance with sanctions regimes in this context,
  • Conducting our operations in accordance with applicable legislation,
  • Contacting you within the scope of the risk assessment process,
  • Protecting and exercising our rights in case of a possible dispute and conducting legal processes.
Processing is necessary for the legitimate interests of the controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject. (article 5/2-f of the LPPD, article 6/1-f of the GDPR)
  • Identity (name, surname, ID/passport photocopy)
  • Contact (phone number, e-mail address, postal address)
  • Professional Experience (company worked for, position, and title information)
  • Risk Management (shareholding information, shareholders of the company and share rates, company’s relationship withSANİPAK SAĞLIKLI YAŞAM ÜRÜNLERİ SAN. VE TİC. A.Ş., information processed within the scope of detecting and assessing financial and operational risks)

1Law on the Protection of Personal Data numbered 6698
2General Data Protection Regulation (Regulation (EU) 2016/679 Of The European Parliament and of the Council of 27 April 2016).

 

Data Processing Purposes Legal Grounds of the Processing Processed Personal Data
  • Fulfillment of our legal obligations in cases where authorized institutions or organizations request from SANİPAK SAĞLIKLI YAŞAM ÜRÜNLERİ SAN. VE TİC. A.Ş. or where it is foreseen that we will notify these institutions.
Processing is necessary to fulfill legal obligations (article 5/2-ç of the LPPD, article 6/1-c of the GDPR)
  • Identity (name, surname, ID/passport photocopy)
  • Contact (phone number, e-mail address, postal address)
  • Professional Experience (company worked for, position, and title information)
  • Risk Management (shareholding information, shareholders of the company and share rates, company’s relationship withSANİPAK SAĞLIKLI YAŞAM ÜRÜNLERİ SAN. VE TİC. A.Ş. , information processed within the scope of detecting and assessing financial and operational risks)
  • Legal Transaction Information (information on correspondence with judicial/administrative authorities, dispute information)

C. Third Parties To Whom Personal Data Shall Be Transferred and The Purposes of Transfer

Your personal data is transferred to third parties in accordance with Data Protection Regulations for the purposes specified below:

Purpose of Personal Data Transfer Parties to Whom Personal Data is Transferred
  • To fulfill our legal obligations in cases where authorized institutions or organizations request information from our Company or where it is required that we notify such institutions or organizations.
Authorized institutions and organizations
  • To obtain product/service support from suppliers and business partners within the scope of the purposes specified under the heading “B) Processed Personal Data, Purposes of Processing Your Personal Data, and Legal Grounds”.
Suppliers and business partners located in Turkey and abroad
  • To ensure coordination in business processes, compliance with group policies, and the execution of review and audit procedures.
Eczacıbaşı Group Companies located in Turkey and abroad3

Personal data of data subjects to whom GDPR applies may be processed in countries outside the European Economic Area. When sharing your personal data, we comply with all the rules set out in the relevant legislation and take necessary technical and organizational measures to ensure the security of your data. If there is no data protection standard in the country where your data is transferred, data protection is adequately guaranteed by other measures. In this context, SANİPAK SAĞLIKLI YAŞAM ÜRÜNLERİ SAN. VE TİC. A.Ş. implements the Standard Contractual Clauses approved by the European Commission or similar contractual clauses in other jurisdictions when necessary.

The personal data of data subjects to whom the LPPD applies are transferred abroad in accordance with the Regulation on the Procedures and Principles Regarding the Transfer of Personal Data Abroad, published in the Official Gazette dated July 10, 2024 and numbered 32598, and the relevant legislation, by providing appropriate safeguards. Necessary technical and administrative measures are taken to ensure the secure transfer of personal data abroad.

D. Method of Personal Data Collection

Your personal data is collected by automatic or partially automatic methods through the paper form or digital information request form, communications via telephone and e-mail channels, and electronic media. In case the information/documents are provided physically, they are collected by non-automatic methods, provided that they are part of a data recording system.

E. Duration of Personal Data Storage

Compliance with Data Protection Regulations is ensured in the storage of personal data. If a legal period is specified for the storage of your data, this period is complied with. These legal periods are primarily evaluated when deciding how long to store personal data. If no legal period is stipulated for the storage of your personal data, your personal data is stored within the framework of the principle of "retention for the reasonable period of time needed". When the data is no longer needed, the personal data is completely deleted, destroyed, or anonymized.

F. Rights Relating to Personal Data

Regarding the processing of your personal data, you have a number of rights.

As the data subject, we hereby inform you that you have the following rights under Article 11 of the LPPD:

•    To learn whether or not your personal data have been processed,
•    If your personal data have been processed, to request information about it,
•    To learn the purpose of processing your personal data, and whether or not they have been used for the intended purposes,
•    To know which third parties within Turkey or abroad your personal data have been transferred to,
•    To request rectification if your personal data are processed incompletely or inaccurately, and to ask that the third parties to whom your data were transferred be notified of the amendments,
•    To request deletion or destruction of your personal data in the case that the reasons for processing the data have disappeared even though they were duly processed according to the Law, and ask that the third parties to whom your data were transferred be notified of this change, 
•    To object to the processing, exclusively by automatic means, of your personal data, which leads to an unfavorable consequences for you,
•    To request compensation for any damages you incurred because of an unlawful processing according to the LPPD of your personal data.

In addition to the above, your additional rights under GDPR are as follows:

•    The right to have the processing of your personal data blocked or restricted.
•    The right to move, copy or transfer personal data securely, in a commonly used and machine-readable format, from one data controller to another.
•    The right to object to the processing of your data in certain circumstances. You also have the right to object to the use of your personal data in direct marketing efforts.

You also have the right to complain to a Data Protection Authority regarding our processing of your personal data. For more information, please contact the relevant Data Protection Authority in your country.

Please contact us via the following channels to exercise your rights recognized by the LPPD, GDPR or applicable laws:

Data Controller :   SANİPAK SAĞLIKLI YAŞAM ÜRÜNLERİ SAN. VE TİC. A.Ş.
E-mail :  sanipak-kvkk@eczacibasi.com.tr
Registered Mail Address (KEP) :  sanipak@hs02.kep.tr
Address :  Rüzgarlıbahçe Mah. Çam Pınarı Sk. Eczacıbaşı Blok No:3 İç Kapı No:1 Beykoz, 34805, İstanbul

In order to exercise your rights under LPPD, you can also choose any of the methods specified in the Communiqué on Application Principles and Procedures for The Request to Data Controller. Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and within thirty days at the latest. If the transaction also requires a cost, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Authority.

The main supervisory Data Protection Authority of the Company is the Turkish Personal Data Protection Authority.

Communication Process Clarification Text
Cookie Clarification Text
Information Security Policy
Interested Person Application Form
Information Text Regarding The Electronic Commercial Message (“ECM”) Process of Sanipak Sağlıklı Yaşam Ürünleri San. ve Tic. A.Ş
Privacy Statement On The Processing Of Personal Data Kyc Processes
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