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CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA IN ACCORDANCE WITH THE THE PROTECTION OF PERSONAL DATA (ACT NO. 6698)

This Clarification Text on the Processing of Personal Data (“Clarification Text”) is prepared by Calinos Holding Inc. (“The Company”) as the data controller in order to fulfill the obligation to disclose the processing of your personal data, thereunder the Article 10 of the Act no. 6698 on the Protection of Personal Data (“Law”, “PPDL”)) and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Clarification Obligation.

This Clarification Text is intended for the persons specified in the titles. For other persons such as employee candidates, employees, suppliers and their officials/employees, additional disclosure texts have been prepared specifically for the relevant person groups and are appropriately disclosed to the relevant persons.

Data Controller

Your Personal Data may be processed by Calinos Holding Inc (“Calinos”) as the data controller, in accordance with the Law and relevant legislation, within the framework of the purposes set out below and in connection with these purposes, in a limited and measured manner, within the scope described below.

I.Purposes and Legal Reasons for Processing Personal Data Processed Through Website Visit

We would like to inform you about our data processing activities defined in the PPDL, including but not limited to the collection, storage and transfer of your personal data obtained in connection with your use of our website www.calinos.com or our mobile application. The information below relates to the personal data processing activities carried out when you visit our aforementioned website or contact us with devices that can connect to the internet such as computers, smartphones, tablets or by phone.

1. Non-member visitor to our website

When you do not register on our website or otherwise do not transmit personal data to us, but only visit our website and its related sub-pages, only your personal data that your browser automatically transfers to our server is collected and the following information is collected and stored in ‘server log files’ until it is automatically deleted:

Data Purpose of Processing Personal Data Legal Reasons/ PPDL Art.
Transaction Security Data

- IP address
- Date and time
- Time zone difference with respect to GMT
- Content of the request (pop-up pages)
- Access status / HTTP status code
- Amount of data transferred
- The website from which the request came
- Browser
- Operating system and interface
- Language and version of the scanner software

- Conducting Activities in Compliance with the Legislation
- Execution of Information Security Processes

- 5/2 (a): expressly stipulated in laws
- 5/2 (ç): In order for the data controller to fulfill its legal obligation,
- 5/2 (ç): The ability of the data controller to fulfill its legal obligations

2. Visitor who communicates with us by e-mail

If you contact us via e-mail or using the contact form, your personal data that you share with us will be collected and processed.

Data Purpose of Processing Personal Data Legal Reasons/ PPDL Art.
Identity Data

- Name and Last Name
- Address

- Execution of Communication Activities
- Follow-up of Requests / Complaints

- 5/2 (ç): The ability of the data controller to fulfill its legal obligations
- 5/2 (f): For the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedom of the data subject.

Communication Data

- E-mail address
- Telefone

- Execution of Communication Activities
- Follow-up of Requests / Complaints

- 5/2 (ç): The ability of the data controller to fulfill its legal obligations
- 5/2 (f): For the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedom of the data subject.

Other Data
- Any content you send to us for a job application
- Managing job application processes
- 5/2 (c): Being directly related to the establishment or performance of the contract

Transfer of Personal Data

You may transfer your personal data to public institutions and organizations authorized to request this data, natural or private legal entities such as our business partners and suppliers, as well as to the provider who makes the web server available as required by the system, limited to the above-mentioned purposes and legal reasons and in accordance with legal obligations or obligations, if any. The data you send to us via the contact form may be shared domestically in accordance with Articles 8 and 9 of the law.

3. For detailed information about the use of cookies, you can reach our “Cookie Policy” from the link on the side : Cookie Policy

II. Persons who visit our workplaces / Visitor Data

The Company obtains your personal data as a result of processing the identity information provided by you to the visitor records to enter the businesses.

Data Purpose of Processing Personal Data Legal Reasons PPDL Art.
Identity Data

- Name / Last Name
- TR Identity
- Passport Document No
- Weapon License Document No
- ID Serial No

- Ensuring the Security of Movable Property and Resources
- Creating and Tracking Visitor Records
- Ensuring Physical Space Security

- 5/2 (f): For the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedom of the data subject.
Communication Data
- Company Data

- Ensuring the Security of Movable Property and Resources
- Creating and Tracking Visitor Records
- Ensuring Physical Space Security

- 5/2 (f): For the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedom of the data subject.

Visual Data

- Ensuring the Security of Movable Property and Resources
- Creating and Tracking Visitor Records
- Ensuring Physical Space Security

- 5/2 (f): For the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedom of the data subject.

Surveillance Camera Data

- Ensuring the Security of Movable Property and Resources
- Creating and Tracking Visitor Records
- Ensuring Physical Space Security

- 5/2 (f): For the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedom of the data subject.

Transfer of Personal Data

Your data arising from your visit may be shared with legally authorized public institutions, if requested within the scope of the above-mentioned purposes and reasons.

In addition, during your physical visit to our workplaces, in case you want to access it over the company network, the personal data obtained due to our access is given below.

Data Purpose of Processing Personal Data Legal Reasons PPDL Art.
Transaction Security Data

- IP address
- MAC Address
- Access logs

- Conducting Activities in Compliance with the Legislation
- Execution of Information Security Processes
- Execution of Access Authorizations

- 5/2 (ç): The ability of the data controller to fulfill its legal obligations
- 5/2 (f): For the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedom of the data subject.

Transfer of Personal Data

Your personal data may be shared with legally authorized public institutions, domestic and/or foreign supplier companies that provide internet access services and Information Technology Services, and the Company’s partners and affiliates, in accordance with the 8. and 9. articles of the law, if requested in line with the above-mentioned purposes and legal reasons.

Collection Method of Personal Data

Your personal data, the technical communication files you transmit via e-mail or automatically transmitted by the computer when you visit, the data transmitted through our office and the channels we provide similar services, the physical forms, the information you convey to us during the contractual relationship process collected and processed, updated when necessary, during the period of your use of our products and services through cooperating institutions and organizations, official institutions, banks and other third parties or similar means, orally, in writing or electronically; fully or partially automated or by non-automatic means as part of any data recording system.

Your Rights Regarding Your Personal Data

You have the rights to;

  • Learning whether your personal data is processed or not,
  • If your personal data has been processed, requesting information about it,
  • To learn the purpose of processing your personal data and whether they are used in accordance with the purpose,
  • Finding out/ knowing the third parties to whom personal data is transferred in the country or abroad,
  • In case of incomplete or incorrect processing of personal data, to request their correction and to notify the third parties to whom the personal data has been transferred,
  • Requesting the deletion or destruction of personal data and requesting the notification of the transaction made within this scope to third parties to whom the personal data has been transferred,
  • Objecting to the emergence of a result against the person themselves by analyzing the processed data exclusively through automated systems,
  • Demanding the compensation of the damage in case of loss due to unlawful processing of personal data .


By applying to Calinos

Your requests regarding your rights listed above will be concluded free of charge as soon as possible and within 30 days at the latest, depending on the nature of your request., from the arrival of your application which shall be in accordance with the procedures stipulated in the Communiqué on the Procedures and Principles of Application, providing your identity and include your clear request to Calinos (as data controller) via either notary, mail to the address of “Kavacık Mah. Ekinciler Cad. Elbistan Çıkmazı Sok. No:6 Beykoz, İstanbul” written and signed by hand, KEP address of calinosholding@hs03.kep.tr or e-mail (kvkk@calinos.com). However, if the process requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board may be requested.