At Karadeniz Holding A.Ş. and its group companies ("Karadeniz Holding"), our primary principles include the protection of fundamental rights and freedoms, privacy related to private life, information security, and respect for ethical values. As the Data Controller under the Law on the Protection of Personal Data No. 6698 ("KVKK"), we are obliged to fulfill the disclosure obligation arising from Article 10 of KVKK. Below, we provide details on the processing and protection of your personal data and sensitive personal data. The term "personal data" used in this document includes sensitive personal data as defined in Article 3 of the KVKK. Your personal data will be processed by our company for the following purposes within the conditions and objectives of personal data processing stated in Articles 5 and 6 of KVKK.
A. Purpose of Processing and Transferring Personal Data
Personal data such as your name, surname, email address, and other related personal data shared in the context of making a report or asking a question through the Ethics Hotline are processed for the following purposes. Reports can also be made anonymously without sharing any personal data.
This hotline aims to communicate notifications of violations and questions within the scope of the Karadeniz Holding Ethics Principles Policy ("Policy") to the Karadeniz Holding Compliance Officers.
Employees and Business Partners are expected to report immediately to the Ethics Hotline any action or issue they believe to be contrary to this Policy.
Only Karadeniz Holding Employees and Business Partners can report to the Ethics Hotline.
Reports can be made either with or without names (anonymously). The identity of the reporters and the information provided are kept confidential and are never disclosed.
Employees can inquire through the Ethics Hotline whether a transaction or action they are uncertain about complies with the Policy.
Only Karadeniz Holding Employees can ask questions through the Ethics Hotline.
To provide appropriate responses to the questions asked through the Ethics Hotline, it is necessary for the Employee to provide their name and contact information.
B. Method of Collecting Personal Data and Legal Basis
Personal data are collected by our company in a clear and understandable manner through written information to personal data owners, and where necessary, with their explicit consent, according to the law and principles of honesty, explicitly stated legitimate purposes, and in a limited and proportionate manner. Your personal data are processed and shared with the above-mentioned individuals and institutions primarily for the requirements of Labor Law and Occupational Health and Safety legislation, and in accordance with Article 5/2/a of the KVKK. Furthermore, your personal data are processed and shared with the above-mentioned individuals and institutions within the legal reasons stated under Article 5/2 of the KVKK:
- Necessary to protect the life or physical integrity of the person who is physically incapable of giving consent or whose consent is not legally recognized.
- Necessary for the performance or fulfillment of a contract.
- Necessary for the data controller to fulfill a legal obligation.
- The data subject has made the data publicly available.
- Necessary for the establishment, exercise, or defense of legal claims.
- Necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
C. Data Subject Rights Under Article 11 of KVKK and Our Contact Information
As the Data Subject, you can exercise the following rights by applying to Karadeniz Holding as per Article 11 of KVKK:
1. To learn whether your personal data has been processed.
2. If your personal data has been processed, to request information regarding this.
3. To learn the purpose of processing your personal data and whether they are used in accordance with their purpose.
4. To know the third parties in the country or abroad to whom personal data has been transferred.
5. To request correction of personal data processed incompletely or inaccurately and to request notification of the operations made to third parties to whom personal data have been transferred.
6. To request deletion or destruction of personal data if the reasons necessitating their processing cease to exist despite being processed in accordance with the provisions of the law and other relevant laws, and to request notification of the operations made to third parties to whom personal data have been transferred.
7. To object to adverse consequences arising from the analysis of processed data solely through automated systems.
8. To request compensation for the damages in case of loss due to unlawful processing of personal data.
You can submit your request related to exercising your above-mentioned rights in Turkish, including identity verification documents, relevant information and documents, in writing to registered electronic mail (KEP) address or by filling out the form available at and sending it signed with a physical signature to Karadeniz Holding A.Ş., Merkez Mahallesi, Develi Caddesi, No:14, Kağıthane/Istanbul in person or through a notary.
In your application, you must include:
1. Your name, surname, and signature if the application is written.
2. Your Turkish Republic ID number if you are a citizen of Turkey, your nationality, passport number, or if applicable, your ID number if you are a foreigner.
3. Your residence or business address for notification purposes.
4. If applicable, your email address, phone, and fax number for notification purposes.
5. The subject of your request, along with any relevant information and documents related to the issue if available.