GDPR & Clarification Text

“DMS DEFENSE INDUSTRY AND AUTOMOTIVE TRADE INC.”

“DMS DEFENSE”

Customer Information Notice Regarding Personal Data

A) DATA CONTROLLER

DMS DEFENSE INDUSTRY AND AUTOMOTIVE TRADE INC.   (hereinafter referred to as DMS Defense) is the data controller.

As a company, we exercise the utmost care and sensitivity in protecting your personal data and attach importance to processing and storing all personal data belonging to our customers in compliance with the Personal Data Protection Law No. 6698. 

Necessary security measures have been defined in order to prevent unlawful processing and access to your personal data, and required administrative and technical measures such as authorization limitations and confidentiality agreements have been implemented to ensure that employees with access to this data do not disclose it unlawfully to third parties or use it outside the scope of processing.

B) METHOD AND LEGAL BASIS OF COLLECTING YOUR PERSONAL DATA

DMS Defense collects your personal data because it is related to the establishment and execution of a contract. Data collection activities are carried out through the provision of your data by you, our customers, to DMS Defense.

Collected personal data includes;

  • Identity Information: Turkish ID Number, Passport Number, name-surname, signature, photograph, gender, date of birth
  • Contact Information: E-mail address, home and workplace phone number, mobile phone number
  • Physical Space Security Information: Entry-exit records, camera recordings
  • Visual and Audio Records Information: Photographs, camera recordings and footage obtained.
  • Financial Information: Balance sheet information, financial performance data, IBAN details, payment amount, credit card and bank card information, refund amount, debt information.

C) PURPOSES OF PROCESSING PERSONAL DATA

DMS DEFENSE processes your above-mentioned personal data for the following purposes;

  • Execution of Emergency Management Processes: Ensuring communication between units and institutions during possible emergencies;
  • Compliance with Legal Regulations: Compliance with legal regulations such as Labor Law, Occupational Health and Safety Law, Law No. 5651, Law No. 6698 and other related legislation;
  • Execution of Finance and Accounting Processes: Payment of expenses, submission of monthly and annual legal declarations, payment of employee salaries, all accounting inputs and outputs;
  • Ensuring Physical Security of Premises: Monitoring the entry and exit of customers, visitors, employees and candidate employees (only in common areas);
  • Monitoring and Conducting Legal Affairs: Enabling individuals and the company to protect themselves in possible legal disputes;
  • Execution of Communication Activities: Sending e-mails, contacting by phone, sending SMS notifications;
  • Providing Information to Authorized Persons, Institutions and Organizations: Responding to official requests and court correspondence;
  • Storage and Archive Activities: Conducting storage and archiving processes for data that the company is legally obliged to retain for legally required periods;
  • Execution of Contract Processes: Creating supplier and sales contracts, collecting fees from real persons receiving service;
  • Execution of Management Activities: Using data in company management processes, planning meetings, managing supply and sales processes.
  • For Fulfilling Tax Obligations

These data are processed based on the legal grounds of contract performance and the legitimate interest of the data controller.

Your personal data will be stored with high security measures together with our technical and administrative safeguards for legally required periods in accordance with KVKK and the Regulation on Deletion, Destruction or Anonymization of Personal Data, and will be destroyed accordingly.

If the purpose of processing personal data ceases and legal retention periods expire, personal data will only be stored for possible legal disputes, establishing or defending legal rights, statute of limitations, and submission upon request by authorized authorities. All administrative and technical measures, storage and destruction methods are specified in the DMS DEFENSE Privacy Policy accessible via info@dmsgroup.com.tr.

  • Cases Where Personal Data May Be Processed Without Explicit Consent Under KVKK:

Pursuant to Article 5 of KVKK and Article 7 of the Regulation, your personal data may be processed without explicit consent in the following cases:

• In cases explicitly stipulated by law,

• If you are unable to provide consent due to actual impossibility or if your consent is not legally valid, and processing is necessary to protect your life or physical integrity or that of another person,

• If processing is directly related to the establishment or performance of a contract,

• If processing is necessary for fulfilling a legal obligation,

• If your personal data has been made public by yourself,

• If processing is necessary for the establishment, exercise or protection of a right,

• If processing is necessary for the legitimate interests of DMS Defense, provided that it does not harm your fundamental rights and freedoms,

  • Personal data obtained by our company is generally not shared abroad. However, if you send data through communication channels whose servers are located abroad (such as Gmail, WhatsApp, etc.) or request your personal information through such virtual environments, the transfer is carried out automatically and limited to the fact that the communication channel server is located abroad, based on the legitimate interest of the data controller.

There is a decision of the Personal Data Protection Board dated 31.05.2019 and numbered 2019/157 stating: “Since using the Gmail e-mail infrastructure of Google means that sent and received e-mails may be stored in data centers located in various parts of the world, in such cases personal data shall be considered transferred abroad and data controllers must comply with Article 9 of Law No. 6698 regarding transfer of personal data abroad.”

“Storage services obtained from data controllers/data processors whose servers are located abroad must also comply with Article 9 of the Law.” Such decision exists.

Since this transfer does not occur as a result of the data controller’s own preference, our company bears no legal responsibility regarding storage obligations of foreign-based companies.

Ç) TO WHOM PROCESSED PERSONAL DATA MAY BE TRANSFERRED

DMS DEFENSE may transfer your aforementioned personal data as follows;

In accordance with Articles 8 and 9 of KVKK and within the purposes stated in the DMS DEFENSE Privacy Policy, provided that necessary security measures are taken, personal data may be transferred domestically and internationally to third parties and may be processed and stored on servers or electronic environments located domestically or abroad. The third parties to whom personal data may be transferred may vary depending on the nature of the relationship between the data owner and DMS DEFENSE (customer-company etc.), but generally include the following:

  1. DMS DEFENSE INDUSTRY AND AUTOMOTIVE TRADE INC.
  2. Domestic and international storage providers, platform owners, data publishing institutions, infrastructure providers, business partners, suppliers and subcontractors working with DMS DEFENSE
  3. Banks and/or institutions authorized for collection purposes, domestic/international organizations and relevant third parties for carrying out such activities
  4. Certified Public Accountant (for invoicing payments received in return for provided services and sales)
  5. Legal consultants/lawyers (for establishing or exercising company rights in potential or existing legal disputes)
  6. Social Security Institution and/or Private Insurance Companies (employee identity information may be shared with insurance companies or SSI)
  7. Authorized institutions and organizations to whom data transfer is necessary in order to fulfill employer obligations under Labor Law No. 4857
  8. All official authorities and institutions within the legitimate interest of the company

D) OTHER RIGHTS OF THE DATA SUBJECT LISTED UNDER ARTICLE 11

Regarding the processing of your personal data by DMS DEFENSE, you have the right to;

• Learn whether your personal data is being processed

• Request information if your personal data has been processed

• Learn the purpose of processing and whether it is used appropriately

• Learn third parties to whom data is transferred domestically and abroad

• Request correction if personal data has been processed inaccurately

• Request deletion or destruction of personal data when reasons requiring processing cease and legal retention periods expire, provided this does not prejudice company rights

• Request compensation if you suffer damages due to unlawful processing of personal data

In order to exercise these rights, by filling out the Personal Data Information Request Form;

  • You may submit it in writing to our Human Resources Department,
  • Send it to our address via registered mail or notary,
  • Or send it via e-mail to info@dmsgroup.com.tr using your registered electronic mail address signed with secure electronic signature.

 

Your requests regarding personal data will be answered as soon as possible and in any case within 30 days. If the requested information response is less than 10 pages, no fee will be charged; if it exceeds 10 pages, a fee of 5 TL per additional page will be charged. In order for third parties to make requests on behalf of personal data owners, a special power of attorney issued through a notary must be available.

Personal data held within this scope;

The customer must write “I have read and understood” by hand in the explanation section below.

EXPLANATION AREA:

DATE :

NAME SURNAME :

SIGNATURE :