AVC BASIM PACKAGING INDUSTRY PERSONAL DATA PROTECTION AND PROCESSING POLICY

The personal data protection and processing policy ("Policy") has been prepared by AVC Basım in order to comply with the Personal Data Protection Law No. 6698 ("KVKK") regarding the protection and processing of personal data. In this context, the aim is to continue to carry out its activities in accordance with the principles of legality, honesty and transparency that have been adopted by AVC Printing since its establishment.

PRINCIPLES ON THE PROCESSING OF PERSONAL DATA

One of the most important issues for AVC BASIM is to comply with the general principles stipulated in the legislation in the processing of personal data. In this context, AVC BASIM undertakes to act in accordance with the principles listed below in the processing of personal data in accordance with all legal regulations and especially KVKK.

1. Engaging in Personal Data Processing Activities in Compliance with the Law and the Rules of Honesty

AVC BASIM, in accordance with Article 4 of KVKK, regarding the processing of personal data; In accordance with the law and the rules of honesty; accurate and up to date when necessary; Pursuing specific, clear and legitimate purposes; will engage in personal data processing in a limited and measured manner in connection with the purpose.

In this context, AVC BASIM will take into account the proportionality requirements in the processing of personal data and will not use personal data other than what is required for the purpose.

2. Ensuring Personal Data is Accurate and Up-to-Date Where Necessary

AVC BASIM ensures that the personal data it processes are accurate and up-to-date, taking into account the fundamental rights of personal data owners and their own legitimate interests; will take the necessary measures in this regard.

3. Processing for Specific, Clear and Legitimate Purposes

AVC BASIM will process personal data for legitimate and lawful reasons. AVC BASIM undertakes to process personal data in connection with the activities it carries out and to the extent necessary. The purpose for which personal data will be processed by AVC BASIM will be determined before the personal data processing activity begins.

4. Being Related to the Purpose for Processing, Being Limited and Proportionate

AVC BASIM will process personal data in a manner suitable for achieving the specified purposes and will avoid processing personal data that is not relevant or needed to achieve the purpose.

5. Preservation for the Period Envisaged in the Relevant Legislation or Necessary for the Purpose for which they are Processed

AVC BASIM, in accordance with Article 138 of the Turkish Penal Code and Articles 4 and 7 of the KVKK; It will retain the personal data it processes only for the period stipulated in the relevant legislation and laws or as required by the purpose of processing personal data.

In this context, AVC BASIM will first determine whether a certain period of time is foreseen for the storage of personal data in the relevant legislation, if any period is determined, it will act in accordance with this period, and if no period is determined, it will keep the personal data for the period necessary to achieve the purpose of processing. If the period expires or the reasons requiring processing disappear, personal data will be deleted or destroyed by AVC Basım. Personal data will not be stored by AVC BASIM with the possibility of use in the future.

6. Conducting Personal Data Processing Activities in Compliance with KVKK Principles

6.1 Personal data must be processed in accordance with one or more of the conditions specified in Article 5 of the KVKK. It will be determined whether the personal data processing activities carried out by AVC Basım are carried out based on one or more of these conditions, and personal data processing activities that do not meet one or more of these conditions will not be included in the processes.

6.2 In addition to ensuring that personal data processing activities are carried out based on one or more of the personal data processing conditions, it will be ensured that all personal data processing activities comply with the principles specified in Article 4 of the KVKK and include the said principles.

6.3 AVC BASIM will carry out personal data processing activities, taking into account the special provisions stipulated in the KVKK regarding the processing of special personal data and their transfer to third parties and abroad; In addition to the above-mentioned issues, personal data processing activities will be carried out by fulfilling the special requirements required by the law in these cases.

In this context, AVC BASIM will create the necessary processes to comply with the regulations in the KVK Law.

7. Things to be followed when transferring personal data

AVC BASIM must comply with the rules set out below in terms of transferring personal data, including sensitive personal data.

7.1. Transfer of Personal Data Domestically

AVC BASIM will transfer the data owner's personal data to third parties in accordance with the personal data processing purposes and by taking the necessary security measures. In this direction, AVC BASIM will put into operation the necessary structures to act in accordance with the conditions stipulated in Article 8 of the KVKK.

7.2. Transfer of Personal Data Abroad

Although AVC BASIM does not transfer personal data and special categories of personal data abroad as a basic principle, it takes the necessary security measures in line with the processing purposes when transferring personal data and special categories of personal data abroad.

Personal data by AVC BASIM is only subject to adequate protection by the KVK Board.

It can be transferred to foreign countries that have been declared to have adequate protection or, in the absence of adequate protection, to foreign countries where the data controllers in Turkey and the relevant foreign country have committed in writing to adequate protection and have the permission of the KVK Board.

In this regard, AVC BASIM will design the necessary processes to comply with the regulations stipulated in Article 9 of the KVKK.