Personal Data Protection Policy
1. DEFINITIONS ABBREVIATIONS| ABBREVIATIONS | |
|---|---|
| The PDPL | The PDPL Law on Protection of Personal Data No. 6698 published in the Official Gazette dated 7 April 2016 and numbered 29677 |
| GDPR | EU (European Union) General Data Protection Regulation The Constitution of the Republic of Turkey, dated 7 November 1982 and numbered 2709, published in the Official Gazette dated 9 November 1982 and numbered 17863 |
| Anayasa | 9 Kasım 1982 tarihli ve 17863 sayılı Resmi Gazete ‘de yayımlanan 7 Kasım 1982 tarihli ve 2709 sayılı Türkiye Cumhuriyeti Anayasası |
| TENZİL MEDYA | Tenzil Medya Tercüme Film Tanıtım Organizasyon Matbaacılık Yayıncılık Tekstil Dağıtım Tic. Ltd. Şti. |
| Data processor | Except for the person or unit responsible for technical storage, protection and backup of data, the person who processes personal data within the organization of the data controller or in line with the authorization and instruction received from the data controller |
| Data Owner / Relevant Person / Relevant | Persons express TENZİL MEDYA TERCÜME FILM LTD. ŞTİ.'s employees, member company officials, employees, employee candidates, interns, service providers, suppliers, employees of the institutions it cooperates with, visitors, and other third parties, including but not limited to those listed here, natural persons processed by TENZİL MEDYA TERCÜME FİLM LTD. STI. |
| Data Controller | The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. |
| Explicit Consent | Freely expressed consent, based on notification for the processing of personal data on a specific subject. |
| Personal Data | Any information relating to an identified or identifiable natural person. |
Tenzil Medya Tercüme Film Tanıtım Organizasyon Matbaacılık Yayıncılık Tekstil Dağıtım Tic. Ltd. Şti.
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.
Adres: EHLİBEYT MAH. CEYHUN ATUF KANSU CAD. BAŞKENT PLAZA No:106 Kapı No:42 Çankaya/ Ankara
Tel: 0312 284 12 11
Web Sitesi: www.tenzil.tv
E-Posta: muhasebe@tenzil.tv
Vergi Dairesi: BAŞKENT VERGİ DAİRESİ MÜDÜRLÜĞÜ
VKN: 8390554140
Ticaret Sicil No: 380045
3.PURPOSE AND SCOPE 3.1 PURPOSEAs TENZİL MEDIA TRANSLATION FILM LTD. ŞTİ, we attach importance to the security and privacy of your personal data. We take the necessary administrative and technical measures to collect, record, process, share, protect and, when necessary, delete or anonymize your personal data securely and in accordance with the law.
The purpose of this policy is to set forth the basic principles and methods to be followed to obtain, process, share, protect and when necessary, delete or anonymize personal data of TENZIL MEDYA TERCÜME FILM LTD. ŞTI, in accordance with the rules of the universal law, the Constitution and the Personal Data Protection Law No. 6698.
This policy is issued in TENZIL MEYA TERCUME FILM LTD. STI’s website (http://www.tenzil.tv).
3.2 SCOPEThis policy is implemented by TENZİL MEDYA TERCÜME FİLM LTD. ŞTI, for all kinds of activities related to the receipt, processing, and protection of personal data, for all natural persons whose data is processed by TENZİL MEDYA TERCÜME FİLM LTD. ŞTI. This includes personal data belonging to natural person officials and employees of legal entities.
This policy relates to all employees and officials of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ, authorities and employees of customer companies, officials, and employees of all institutions they are in cooperation with, and other natural persons whose data are processed by TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.
4. ISSUES REGARDING THE PROTECTION OF PERSONAL DATATENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. takes all necessary measures for the protection of personal data in accordance with its budget.
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. Takes all technical and administrative measures within the scope of the Information Security Management System. These measures are taken not only for the data recorded in the electronic environment, but also for all documents in written, printed, and oral media.
4.1 TECHNICAL MEASURES TAKEN TO PROTECT PERSONAL DATATENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. takes the following technical and administrative measures regarding the protection of personal data.
All electronic systems, computers, mobile devices and software running on these devices used by TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. are upgraded on time and are ensured to be made by the personnel.
All electronic systems, computers, mobile devices and software running on these devices used by TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. are upgraded on time and are ensured to be made by the personnel.
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ takes necessary measures in accordance with technological developments and periodically updates the measures taken.
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ carries out user account management for systems used by employees.
Necessary precautions regarding wireless access points are taken and log records are kept.
VIf needed, appropriate software for preventing data loss is used.
Appropriate systems for intrusion detection and prevention are used and necessary consultancy and support are received.
Data is backed up periodically, and these backups can be turned around if desired.
The use of strong passwords is provided by automatic systems with redirects.
Software and hardware containing anti-virus programs, firewalls are used, and these security systems are kept up-to-date.
Technical solutions for necessary access and authorization are used to ensure that only the relevant units and personnel have access to the data.
If deemed necessary, log records of access to personal data and files containing personal data are kept.
Staff who is informed about technical matters are employed.
In line with TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.’s needs, the necessary trainings are provided for technical personnel to increase knowledge and skills in related fields. The works that the employees want to carry out in order to improve their technical abilities are encouraged and an appropriate budget is allocated for this.
Necessary security and penetration tests are performed periodically, and necessary precautions are taken to detect security vulnerabilities, identify risks and eliminate these risks.
The Personal Data Processing Inventory has been prepared and the data is kept recorded for the period specified in this inventory. Then, personal data is anonymized, deleted or destroyed within the framework of the procedures and principles determined by the PDP Institution.
KThe Personal Data Processing Inventory is constantly kept up to date.
4.2 ADMINISTRATIVE MEASURES FOR THE PROTECTION OF PERSONAL DATATENZİL MEDIA TRANSLATION FILM LTD. STI. takes the following administrative measures regarding the protection of personal data.
Personal Data Processing Inventory is prepared and this inventory is kept up-to-date.
Institutional policies are prepared within the scope of PDPL and these policies are updated when necessary.
Contracts in which personal data must be shared with third parties are prepared in accordance with the Personal Data Protection Law and in line with the recommendations and directives of the Personal Data Protection Authority.
The employment contract is signed by TENZİL MEDYA TERCÜME FİLM LTD. STI. and contains provisions in accordance with the Employee Disclosure Notice and the Personal Data Protection Policy.
Employees are provided with periodic trainings on the protection of personal data. Newly recruited personnel are informed about the subject and are provided with training as soon as possible.
The technical specifications and contracts of the services and systems technologically purchased by TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. are prepared in a way that is compatible with TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.’s Personal Data Protection Policy and includes the necessary technical security measures.
Decisions taken by the Personal Data Protection Board are reviewed, and depending on these decisions, the necessary precautions are taken by TENZİL MEDYA TERCÜME FİLM LTD. STI.
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. prepares the necessary confidentiality commitments in accordance with the works performed.
TENZİL MEDIA TRANSLATION FILM LTD. STI. Carries out the necessary risk analyzes periodically.
TENZİL MEDIA TRANSLATION FILM LTD. STI. conducts regular and random inspections within the institution.
In case of data leakage, plans made for crisis management, informing the board and the relevant person, and reputation management are put into use, and regular consultancy services are used on this issue.
5. ISSUES REGARDING THE PROCESSING OF PERSONAL DATA
5.1 BASIC PRINCIPLES OF PROCESSING PERSONAL DATAIn the processing of personal data, TENZİL MEDYA TERCÜME FİLM LTD. STI. complies with the following basic principles.
Compliance with Law and Integrity RulesTENZİL MEDIA TRANSLATION FILM LTD. STI. acts in accordance with the principles brought by legal regulations and general honesty and trust rules in the processing of personal data. In this context, TENZİL MEDYA TERCÜME FILM LTD. STI. receives personal data by indicating to the data owner for what purpose and in what way it will be processed and processes the data only for these stated purposes and in the specified manner.
Being Accurate and Up to Date When Necessary
To fulfill the duties assigned to it by law in the best way possible and by observing the rights of personal data owners, TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. does the necessary work to ensure that the personal data is accurate and up to date when necessary.Processing for Certain Explicit and Legitimate Purposes
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. only carries out legitimate and lawful data processing activities. TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. clearly and precisely determines the purpose for each Data Processing activity and processes personal data only for this purpose.TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. only carries out legitimate and lawful data processing activities. TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. clearly and precisely determines the purpose for each Data Processing activity and processes personal data only for this purpose.
Being Connected to the Purposes for which they are Processed, Limited and ResponsibleTENZİL MEDYA TERCÜME FİLM LTD. ŞTİ processes personal data only for the stated purposes. It avoids the processing of personal data that is not related to the realization of the purpose or that is not needed.
Protection of Limited Time for the Purpose of Processing or Foreseen in the Relevant Legislation
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ retains personal data only for the period stipulated in the legislation or for the purpose for which they are processed. In this context, TENZİL MEDYA TERCÜME FILM LTD. STI. evaluates whether there is a period stipulated in the relevant legislation. In cases other than this, it gets the opinion of the relevant institutions, the Ministry and, if necessary, the PDP Institution for the works related to its duties and sets a time accordingly. In cases other than this situation, it determines a suitable period for the purpose for which they are processed and retains the personal data for that period. Transparency
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ gives great importance to transparency in the processing of personal data. It informs the relevant institutions and, if requested, the owners of personal data regarding the purpose and legal basis of processing personal data.
Data ReductionTENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. receives, saves and uses personal data suitable with its purpose and only with this purpose, in a limited manner.
5.2 TERMS OF PROCESSING PERSONAL DATATENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. processes personal data if at least one of the following conditions in Article 5 of the Law No. 669
Explicit Consent: Personal data may be processed in the presence of explicit consent, based on information and free will.
Explicitly Stipulated in Laws:
In cases where it is clearly stipulated in the laws, TENZİL MEDYA TERCÜME FİLM LTD. STI. Processes this personal data within the scope of legal obligation.
Actual Impossibility: The personal data of the person concerned may be processed if it is necessary for the protection of vital or bodily integrity of the person or another person, who is unable to express his or her consent due to Actual Impossibility or whose consent is not legally valid.
Establishment or Execution of the Contract: Provided that it is directly related to the establishment or execution of a contract, it is possible to process the personal data of the persons concerned, limited to this purpose, in the event that the processing of the personal data of the parties to the contract is mandatory. For example, acquiring the account number of the creditor for the payment of money pursuant to a contract or acquiring the payroll, deed records and document stating that the person has no enforcement debt during carrying out a loan agreement with a bank. In addition, in accordance with the contract, the seller recording the address of the buyer to fulfill the mail delivery debt or the employer keeping the bank information of the employees to pay the salary may be considered within this scope.
Legal Responsibility of the Data Controller: The personal data of the data subject may be processed, in cases where data processing is necessary for the data controller to fulfill their legal obligations.
Related Person Made Public by Themself: Personal data made public by the related person, in other words, personal data that is disclosed to the public in any way, can be processed. An example of this is when a person publicly announces their contact information to be contacted in certain circumstances. Publicizing can also be mentioned on corporate websites if the workplace telephone numbers and corporate e-mail addresses of the employees are shared openly for the access of third parties.
A Right being Obligatory for the Establishment, Use or Protection of a Right: It is possible to process the personal data of the person concerned if it is mandatory for the establishment, exercise, or protection of a right. For instance, a company's use of some data for proof in a lawsuit filed by its own employee, or the guardian or trustee keeping the financial information of the restricted person to protect the rights of a restricted person. Additionally, after the contract is terminated, keeping documents such as invoices, contracts, bail bonds for these purposes until the end of the statute of limitations against possible legal proceedings will be considered within this scope.
Legitimate Interest of the Data Controller:
Provided that it does not harm the fundamental rights and freedoms of the data subject, it is possible to process personal data if it is necessary for the legitimate interests of the data controller.
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. does not process personal data in any way other than the conditions written above. 5.3 CONDITIONS FOR PROCESSING SENSITIVE PERSONAL DATATENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. acts in accordance with the Personal Data Protection Law regarding sensitive personal data.
In the case of explicit consent of the person concerned, sensitive personal data, data other than the health and sexual life of the data owner in cases stipulated by the law, personal data related to the health and sexual life of the data owner can only be used for the protection of public health, in order to carry out preventive medicine, medical diagnosis, treatment and care services, the planning and management of health services and their financing. The data can be processed by persons or authorized institutions and organizations which are under the obligation of secrecy, with the conditions stated above.
5.4 PERSONAL DATA PROCESSING PURPOSESTENZİL MEDYA TERCÜME FİLM LTD. ŞTİ may process your personal data for the following purposes.
Continuing in accordance with the legislation,
Execution of emergency management processes,
Managing Information Security processes,
Managing the Candidate/Trainee selection and placement processes,
The Execution of the application processes of employee candidates
Ensuring employee satisfaction and loyalty,
A contract for Employees and fulfilling obligations arising from legislation,
Providing fringe benefits and other benefits for employees,
Carrying out audit activities,
Conducting educational activities,
Managing access authorizations,
Executing finance and accounting works,
Executing assignment processes,
The Follow-up and execution of legal affairs,
Carrying out internal audit activities,
Conducting communication activities,
Carrying out occupational health / safety activities,
Ensuring business continuity,
Executing the goods/service procurement processes,
Carrying out organizations and events,
Conducting the contract processes of social responsibility and civil society activities,
Carrying out sponsorship activities,
Carrying out strategic planning activities,
The Follow-up of requests and complaints,
Executing the Wage Policy,
Carrying out talent/career development activities,
Providing information to authorized persons, institutions, and organizations,
Creating and tracking visitor records,
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. maintaining a quality and effective human resources policy,
Implementation of personnel procurement processes in the best way possible,
The planning and Execution of talent career development activities,
Fulfilling the responsibilities arising from the employment contract and legislation for the personnel,
Planning, controlling and executing information security processes, creating and managing the information technology infrastructure,
Measuring the knowledge, ability, and performance of the personnel,
Effectively maintaining the services and supports provided for customer companies,
Maintaining financial and accounting transactions,
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.'s efforts to open up to new markets,
Executing marketing activities,
Ensuring effective participation in international fairs,
Providing health, education, etc. for TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. employees,
Providing trainings to improve the knowledge and skills of employees and/or member company employees of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.
Ensuring the security of fixtures and/or other resources belonging to TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.
Creating and tracking visitor records,
Taking necessary security measures inside the building,
Giving information to authorized persons or organizations based on legislation,
6. TRANSFER OF PERSONAL DATAIn sharing data with third parties, TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. acts in accordance with the limits set by the law and the principles in accordance with data privacy. In line with these obligations, data is shared with third parties based on the principles set below to share data quickly and securely.
6.1 TRANSFER OF PERSONAL DATA TO DOMESTIC THIRD PARTIESTo transfer personal data domestically, at least one of the following conditions must be met in accordance with Article 8 of the Law No. 6698:
When it is clearly stipulated in the law,
Being mandatory for the protection of vital or bodily integrity of the person or another person, who is unable to express consent due to Actual Impossibility or whose consent is not legally valid,
It is necessary to process the personal data of the parties to the contract, if it is directly related to the establishment or performance of a contract,
Being mandatory for the data controller to fulfill its legal obligation, the data subject making public themselves,
Data processing being mandatory for the establishment, use or protection of a right,
Data processing being mandatory for the legitimate interests of the data controller, obtaining the explicit consent of the data subject, provided that it does not harm the fundamental rights and freedoms of the related person,
Except for the cases stated here, TENZİL MEDYA TERCÜME FİLM LTD. ŞTI. does not, in any way share your personal data with third parties.
6.2 TRANSFER OF PERSONAL DATA TO THIRD PARTIES ABROADTTENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. carries out data sharing by obtaining written contracts that adequate protection will be provided within the scope of Law No. 6698 and by meeting the conditions stated below.
If it is necessary within the scope of the fulfillment of a contract, due to reasons arising from the law or an international agreement,
In case of Actual Impossibility,
TDue to legal responsibility of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ, the establishment, protection or use of a right, within the scope of an essential legitimate interest of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ, transferring data abroad and having the explicit consent of the interested person according to Article 9. Of the law,
In data transfer to countries where there is sufficient protection (counties deemed safe by the Board), the existence of the conditions specified in the Law (conditions specified in the 2nd paragraph of Article 5, and paragraph 3 of Article 6 of the Law), in the case of data transfer to countries where there is no adequate protection, situations specified in the Law (conditions specified in paragraph 2 of Article 5 and 3rd paragraph of Article 6 of the Law), adequate protection committed in writing and the Board getting permission can be carried out. Data is not transferred to third parties abroad without the permission of the Board.
If TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. transfers data to third parties who are abroad and who are in the position of data controller, it submits a commitment signed by both parties to the Personal Data Protection Institution regarding the situation where both parties are data controllers, the minimum conditions of which are determined by the Personal Data Protection Authority. The data transfer is made with the approval of the Personal Data Protection Authority. Without this approval, TENZİL MEDYA TERCÜME FILM LTD. ŞTI. does not transfer data to such third parties.
6.3 THE TRANSER OF SENSITIVE PERSONAL DATA
The data on people's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing manner, membership in associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are considered sensitive personal data.
Sensitive personal data can be processed with the explicit consent of the person. Apart from this, personal data other than health and sexual life may be processed without seeking the explicit consent of the person concerned, in cases stipulated by the laws. Personal data related to health and sexual life can only be processed for the purpose of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, by persons or authorized institutions and organizations that are under the obligation of secrecy without seeking the explicit consent of the person concerned.
TENZİL MEDIA TRANSLATION FILM LTD. STI. may transfer the mentioned sensitive personal data in the case of the above-mentioned conditions and in the event that the measures recommended by the PPD Institution are taken by the data recipient.
In the case of transferring sensitive data abroad, a written contract recommended by the PPD Institution is taken from the third party, which is the data controller or data processor, and additional measures may be requested when necessary.
7. RECEIVING PERSONAL DATA FROM THIRD PARTIESIn case of receiving personal data from third parties, TENZİL MEDYA TERCÜME FILM LTD. ŞTI. obtains the necessary commitments from the third party, from which it receives data, that the data is received in accordance with the law and that the conditions for the transfer are met. TENZİL MEDYA TERCÜME FILM LTD. ŞTI. takes all necessary technical and administrative measures regarding the data it receives. In case of any data leakage regarding this data, it immediately informs the third party from which the data is obtained, the PPD Institution and, if they have knowledge about the issue, the relevant persons.
8. PERSONAL DATA CATEGORIESThe personal data of the following data owner groups are recorded by TENZİL MEDYA TERCÜME FİLM LTD. ŞTI.
Data Owner Categories| Data Owner | Disclosure |
|---|---|
| TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ employee | TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ officials and employees |
| Employee Candidate | Persons applying for a job at TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ |
| Interns | Data of people who do internships at TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. |
| Supplier Employee | Employees of the supplier company or natural person |
| Supplier Official | Managers and partners of the supplier company |
| Person who received Goods/Services | People from whom TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. purchases goods or services |
| Customer Company | Employee/Officer Employees and officials of our customer companies |
| Visitor | Persons visiting the headquarters and/or branches of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. |
| Website Visitor | People visiting TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. websites |
| Social Media User | Social media users interacting with TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.’s social media accounts. |
| Identity Data | Name and surname, TR Identity Number, copy of identity card, driver's license, passport information, passport copy etc. |
| Communication Data | Employees' email addresses, phone numbers, mobile phone numbers, addresses, etc. |
| Financial Data | Employee bank account numbers, payrolls, Information on the expenditures made within the scope of the duties given by TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ., etc. |
| Health Data | Employees' health reports, health permit reports, health care applicants, blood group data, etc. for job applications. |
| Training Data | The schools from which the employees graduated, the certificates of the training they received and the certificates of participation, etc. |
| Audio and Visual Data | Audio and video recordings made within the scope of organized events. |
| Personality and Talent Data | The results of the tests carried out to determine the personality traits and abilities of the employee |
| Performance Data | Data on the Employee's Job performance. |
| Family and Relatives Data | Data on the employee's family and dependents. |
| Personnel Data | CV information, performance data, disciplinary investigation information, payroll information, property declaration information, etc. |
| Physical Security Data | Card Access System data, security cameras, license plate recognition systems, etc. Data held in relation to building safety. |
| Location Data | Received data on the places where the Employee is within the scope of the work. |
| Biometric Data | Fingerprint data used in door access systems. |
| Request/Complaint Data | Content data of requests and complaints made. |
| Signature Data | Wet signature data of the person. |
| Criminal Record Data | A document showing the criminal record of persons, issued by the General Directorate of Criminal Records. |
Apart from the physical security, there are security cameras in the building in order to ensure the security of the building. TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.’s visitors and vehicles are registered.
TENZİL MEDYA TERCÜME FİLM LTD. ŞTI. adheres to the following principles within the scope of measures related to building security.
9.1.1 Legal Basis, Purpose of Camera RecordingCamera recording carried out by TENZİL MEDYA TERCÜME FİLM LTD. ŞTI. is done in accordance with the Law on Private Security Services and the relevant legislation. This security service is considered within the scope of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.'s legitimate interests. There is an informative message on the subject at the entrance of the building.
9.1.2 Securing Camera Image DataRegarding the protection of camera images, TENZİL MEDYA TERCÜME FİLM LTD. ŞTI. takes all kinds of technical and administrative measures, and receives a commitment that the companies from which it receives security services will take all kinds of technical and administrative measures. To ensure that these technical and administrative measures are taken into account, the company that provides security services and the personnel of these companies or companies are inspected.
9.1.3 Accessing and Sharing Camera ImagesIn the case of an event, the security personnel can examine the records on the same day, but cannot copy or transfer them to another place. A record is kept of the log records of this access and the reason for the examination.
Access to footage history is done only by a limited number of personnel authorized to review this data. The approval of the Assistant General Manager is required to review said data. Camera recordings are shared with third parties only if it is legally necessary to examine the data. If requested by the judicial authorities, the camera recordings are shared with the judicial units with the decision of the judge or the court or in case of emergency, with the prosecutor's letter.
9.1.4. Storage Period of Camera ImagesCamera recordings are kept for the period determined by the decision of the Board of Directors, not exceeding 2 months. At the end of this period, the video recordings in question are deleted irreversibly.
9.2 Visitor RecordsVisitor records are kept in order to track the entrances and exits of the visitors at the entrance to the TENZİL MEDYA TERCÜME FİLM LTD. ŞTI building. Data regarding guest entry and exit are only recorded and processed for this purpose.
This data is accessed with the written request of the relevant unit and the written approval of the Assistant General Manager.
9.3 Vehicle EntriesEntry and exit times and license plate information of the vehicles belonging to the personnel and visitors of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. are recorded.
9.4 Internet Access Records for VisitorsWithin the scope of the law numbered 5651, TENZİL MEDYA TERCÜME FİLM LTD. ŞTI. is a collective use provider in terms of the internet service it provides for visitors. The data of people who use internet access as visitors are recorded, in line with the obligations of the collective use provider specified in the law and the relevant regulation.
9.5 Personnel Tracking SystemsThe entrance and exit of the personnel are tracked within the scope of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.'s legitimate interests. This tracking is done in two ways.
9.5.1. Card entry systemPermanent smart cards are given to TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. employees and temporary smart cards to the visitors. Entries made with these cards are recorded.
9.5.2. Face recognition systemFacial recognition data of the personnel are optionally used in the transition systems to determine the entry and exit times of the personnel, to ensure building security effectively, to regulate the performance of the personnel and their access to the physical spaces within the building. In this context, first the face of the employee is introduced directly to the camera system. Afterwards, the identity of the person passing through is determined this way.
The facial recognition data of the personnel is under no circumstances shared with any third party, including the company that established it.
Facial recognition information of the personnel who leave the company is destroyed within one week with the methods available in this policy. However, the log records of the person's entry and exit are kept for two years.
9.5.3. Fingerprint Access SystemFingerprint data of the personnel are optionally used in the access systems in order to determine the entry and exit times of the personnel, to ensure building security effectively, to regulate the performance of the personnel and their access to the physical spaces within the building.
Fingerprint data of the personnel are not shared with third parties in any way, including the company that installed the fingerprint system. The fingerprint data of the personnel who leaves the company is irreversibly deleted and their access permissions are revoked. However, past log records are kept for two years.
Fingerprint biometric data are irreversibly destroyed within 1 week after the relevant person leaves.
10. WEBSITESFor the websites that belong to TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. the IP information required to be kept within the scope of the law numbered 5651 are kept. Apart from this IP information, cookies can be used to make effective website designs, to make website designs and contents better, and to make the most effective use of the website for users who access the website.
Necessary notifications are made while receiving this personal data.
In cases where personal data is obtained through websites, the purpose of obtaining personal data, the legal reason for obtaining personal data and the recording period of personal data are notified to the person concerned.
In cases where explicit consent is obtained, the consent is obtained by making the necessary clarification notification and explicit consent records are kept.
Human Resources Data - Job Application
The application is held for evaluation. The reasonable period for this is two years.
2 years
Human Resources Data - Personnel File The data kept in the personnel files of the employees are kept in accordance with the provisions of the Labor Law No. 4857 and the Law of Obligations No. 6098.
10 years
Although personal data is processed in accordance with the provisions of the relevant law, pursuant to Article 138 of the Turkish Penal Code and Article 7 of the Personal Data Protection Law No. 6698, in the case that data processing reasons cease to exist, with the decision of the Board of Directors of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. or in the case of a request by the personal data owner, the data is irreversibly erased, destroyed or anonymized in a way that cannot be restored. Data retention periods are determined according to the relevant legislation and needs of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.
For the deletion, destruction or anonymization processes, the decisions, and suggestions of the Personal Data Protection Authority regarding these issues are taken into consideration. The most suitable solution allowed by technology, İS applied while taking into consideration the needs and means of TENZİL MEDYA TERCÜME FILM LTD. ŞTİ.
12.1. ANONYMIZATIONThe anonymization of personal data means that personal data cannot be associated with an identified or identifiable natural person under any circumstances, even if it is matched with other data. For personal data to be anonymized, personal data must be rendered unrelated to an identified or identifiable natural person, even by using appropriate techniques for the recording medium and the relevant field of activity, such as returning the personal data by the data controller or recipient groups and/or matching the data with other data.
TENZİL MEDYA TERCÜME FILM LTD. ŞTİ takes all necessary technical and administrative measures to anonymize personal data. The anonymization of personal data is done in accordance with the principles specified in the Regulation on Deletion, Destruction or Anonymization of Personal Data and the methods in the guide published by the PPD Institution on the subject.
12.2. DELETING PERSONAL DATAThe deletion of personal data is the process of making personal data inaccessible and non-reusable for relevant users.
TENZİL MEDYA TERCÜME FILM LTD. ŞTİ. takes all necessary technical and administrative measures to ensure that the deleted personal data cannot be accessed and reused for the relevant users.
The following methods are used for deletion of data.
12.2.1. Application Type Cloud Solutions as a ServiceIn the cloud system, data should be deleted by issuing a delete command. It should be noted that the relevant user does not have the authority to restore the deleted data on the cloud system while performing the aforementioned operation.
12.2.2. Personal Data on PaperPersonal data on paper should be deleted using the blackening method. The blackening process is done by cutting the personal data on the relevant document when possible, and in cases where it is not possible, making it invisible to the relevant users by using fixed ink, which cannot be read with technological solutions.
12.2.3. Office Files on the Central ServerThe file must be deleted with the delete command in the operating system or the access rights of the relevant user on the file or the directory where the file is located must be removed. While performing this operation, it should be noted that the relevant user is not also a system administrator.
12.2.4. Personal Data in Portable MediaNo confidential data is kept on portable media. Personal data in portable media should be deleted with software suitable for the hardware in question.
12.2.5. DatabasesRelevant lines containing personal data must be deleted with database commands (DELETE etc.). While performing the aforementioned operation, the relevant user must not be a database administrator.
12.3. DISPOSAL OF PERSONAL DATADestruction of personal data is the process of making personal data inaccessible, unrecoverable, and unusable by anyone in any way. TENZİL MEDIA TRANSLATION FILM LTD. ŞTİ. takes all necessary technical and administrative measures regarding the destruction of personal data.
12.3.1. LOCAL SYSTEMSOne or more of the following methods can be used to destroy the data on the said systems.
De-magnetization: It is the process of corrupting the data on it in an unreadable manner by exposing the magnetic media to a very high magnetic field by passing it through a special device.
Physical Destruction: The physical destruction of optical media and magnetic media, such as melting, incinerating or pulverizing. Data is rendered inaccessible by processes such as melting, incinerating, pulverizing, or passing through a metal grinder to optical or magnetic media. For solid disks, if the overwriting or demagnetization is not successful, this media must also be physically destroyed.
Overwriting: It is the process of preventing the recovery of old data by writing random data consisting of 0s and 1s at least seven times on magnetic media and rewritable optical media. This process is done using special software.
12.3.2. ENVIRONMENTAL SYSTEMSDepending on the media type, the disposal methods available are as follows:
Network devices (switches, routers, etc.): The storage media in these devices are fixed. Products often have a delete command but no destroy feature. It must be destroyed using one or more of the appropriate methods specified in (a).
Flash-based environments: Flash-based hard disks with ATA (SATA, PATA, etc.), SCSI (SCSI Express, etc.) interfaces, must be destroyed using the command if supported, if not, by using the manufacturer's recommended destruction method, or one of the appropriate methods specified in (a).
Magnetic tape: It is the media that stores the data with the help of micro magnet pieces on the flexible tape. It must be destroyed by exposing it to very strong magnetic environments and demagnetizing it or by physical destruction methods such as burning and melting.
Units such as magnetic disks: They are media that store data with the help of micro magnet pieces on flexible (plate) or fixed media. It must be destroyed by exposing it to very strong magnetic environments and demagnetizing it or by physical destruction methods such as burning and melting.
Mobile phones (Sim card and fixed memory areas): There is a delete command in fixed memory areas in portable smartphones, but most do not have a destroy command. It must be destroyed using one or more of the appropriate methods specified in (a).
Optical discs: They are data storage media such as CDs and DVDs. It must be destroyed by physical destruction methods such as burning, breaking into small pieces, melting.
Peripheral units such as printers, fingerprint door access systems with removable data recording media: The removal or destroy of all data recording media are verified by using one or more of the appropriate methods specified in 12.4.1, depending on their characteristics.
Peripheral units such as printers with fixed data recording medium, fingerprint door access systems: Most of these systems have a delete command, but no destroy command. It must be destroyed by using one or more of the appropriate methods specified in 12.4.1.
12.3.3. PAPER and MICROFICHE MEDIASince the personal data in the said media is permanently and physically written on the media, the main media must be destroyed. While performing this process, it is necessary to divide the media into small pieces of incomprehensible size, horizontally and vertically, if possible, in such a way that they cannot be reassembled with paper shredders or clipping machines. Personal data transferred from original paper format to electronic media by scanning should be destroyed by using one or more of the above-mentioned appropriate methods, depending on the electronic environment in which they are located.
12.3.4. CLOUD SYSTEMSDuring the storage and use of personal data in the aforementioned systems, encryption with cryptographic methods and, where possible, separate encryption keys should be used for personal data, especially for each cloud solution serviced. When the cloud computing service relationship ends; All copies of encryption keys required to make personal data usable must be destroyed.
13. RIGHTS OF THE PERSONAL DATA OWNER AND THE USE OF THESE RIGHTSWithin the framework of Article 2 of the Law, the person concerned may appeal to TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. and has the following rights regarding themselves:
Learning whether personal data is processed or not,
If personal data has been processed, requesting information about it,
Learning the purpose of processing personal data and whether they are used in accordance with the purpose,
Knowing the third parties to whom personal data is transferred in the country or abroad,
Requesting correction of personal data in case of incomplete or incorrect processing,
Requesting the deletion or destruction of personal data,
Requesting notification of the transactions regarding the correction, deletion or destruction of personal data to the third parties to whom the personal data has been transferred,
Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
Requesting compensation of the damage in case of damages due to unlawful processing of personal data.
To exercise the rights listed above, personal data owners fill out the form on the internet address of www.tenzil.tv/kvkk with the information and documents through which their identities can be determined, and after filling out the form (KEP, Application with Wet Signature, Application with Wet Signature Mail, E-mail containing wet signature) they can transmit their request to TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.
Pursuant to Article 28 of the PDPL, personal data owners cannot claim the above-mentioned rights in the following cases.
Processing of personal data for purposes such as research, planning and statistics by anonymizing them with official statistics.
Processing personal data for art, history, literature or scientific purposes or within the scope of freedom of expression, provided that it does not violate national defense, national security, public security, public order, economic security, privacy or personal rights or constitute a crime.
Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to ensure national defense, national security, public security, public order, or economic security.
Processing of personal data by judicial authorities or execution authorities in relation to investigation, prosecution, trial or execution proceedings.
Pursuant to paragraph 2 of Article 28 of the PDPL, data owners cannot claim their above-mentioned rights except for the elimination of damage.
The processing of personal data is necessary for the prevention of crime or for criminal investigation.
Processing of personal data made public by the person concerned.
Personal data processing is necessary for the execution of supervisory or regulation duties and for disciplinary investigation or prosecution by official and authorized public institutions, organizations, and professional organizations in public institution, based on the authority given by the law.
The processing of personal data is necessary for the protection of the economic and financial interests of the State regarding budgetary, tax and financial matters.
TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. responds to requests made by data owners within 30 days. TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. may reject the request while explaining its legal justification.
14. DATA CONTROLLER CONTACT PERSON, DATA PROTECTION OFFICERTENZİL MEDYA TERCÜME FİLM LTD. ŞTİ assigns a sufficient number of personnel to establish contact with the PPD Institution and to coordinate the protection of personal data within the institution. The person or persons appointed as the "contact PERSON" within the scope of Article 11 of the Regulation on the Data Controllers Registry are responsible for ensuring the communication between the data controller (TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.) and the person concerned or the Personal Data Protection Authority.
Responsibility for obligations and sanctions within the scope of Law No. 6698 is not on the contact person, but on the body authorized to commit and represent this legal person. In accordance with the provisions of the Law, the appointment as a contact person does not remove the responsibility of the data controller (TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.).
The duties of the personnel appointed as Data Protection Officers are as follows:
To advise the Data Controller about their obligations regarding PDP.
Monitoring PDPL compliance of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. and subsidiaries.
To contact the Personal Data Protection Authority and its foreign counterparts, if necessary.
To act as the contact point of the institution for the data subjects who are the owners of personal data, to process, evaluate and respond to the requests of the data owner regarding the data Processing activities of the Data Controller.
The Data Protection Officer may request consultancy and support to fulfill these duties.
There is at least one personnel assigned to contact Data Protection Officers within the scope of ensuring the necessary coordination and protection of personal data in each of the branches and units of TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ.
15. MEASURES TO BE TAKEN IN CASE OF DATA LEAKIn case the processed personal data is obtained by others illegally, TENZİL MEDYA TERCÜME FİLM LTD. ŞTI. informs the relevant person and the Board of this situation as soon as possible. If necessary, the Board may announce this situation on its own website or by any other method it deems appropriate.
16. TRAININGRegular trainings will be organized to raise awareness of all personnel and managers on the protection of personal data and ensure that TENZİL MEDYA TERCÜME FİLM LTD. ŞTİ. institutionally carries out activities in accordance with the relevant laws and regulations.