Legal texts
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 |
|---|---|---|
|
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) |
|
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 |
|---|---|---|
|
Processing is necessary to fulfill legal obligations (article 5/2-ç of the LPPD, article 6/1-c of the GDPR) |
|
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 |
|---|---|
|
Authorized institutions and organizations |
|
Suppliers and business partners located in Turkey and abroad |
|
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.