YB // YALÇIN BORU Personal Data Protection and Privacy Policy

Website Privacy Policy
During your visit on this website and benefiting from the services we offer through this website, the manner of use and protection of the information we receive about you and the services you request are subject to the terms set forth in this "Privacy Policy". By visiting this website and requesting to benefit from the services we offer through this website, you accept the terms set forth in this "Privacy Policy".

I. Purpose of the policy of protection and processing of personal data
Due to the sensitivity of the works we have been dealing up to date as YB YALÇIN BORU, the data from received from our customers or prospective customers have always been kept confidential and never been shared with third parties. Protection of personal data is the basic policy of our company. Nonetheless before any legal regulation, our company and our subsidiaries have considered the confidentiality of personal data of great importance, adopted it as a working principle, and given its working instructions in line with this principle. As YB YALÇIN BORU, we undertake to comply with all responsibilities stipulated by the Personal Data Protection Law. Our company's principles regarding the protection of personal data also include our subsidiaries.

II. Scope and amendment of the policy of protection and processing of personal data
This Policy issued by our Company has been prepared in accordance with the Protection of Personal Data Law (KVKK) No. 6698. The law has entered into force with all its provisions as of today. The data obtained from you as per your consent or other requirements for the compliance with laws prescribed in the Law shall be processed in order to improve the quality of our services offered to you, and to enhance the services and our quality policy. Likewise, some of the data that we obtained are excluded from being personal and anonymised. These data are data used for statistical purposes and are not subject to the enforcement of Law and our Policy. Personal Data Protection and Processing Policy of YB YALÇIN BORU aims to protect the data of our customers, prospective customers, employees and the data automatically obtained from the customers and employees of other companies working in partnership with us, or other persons, and it contains the regulations related to these.
Our company is entitled to amend our policy and Regulation provided that the amendment is in compliance with the Law and it ensures better protection of personal data.

III. Basic Rules for the processing of personal data
a) Compliance with the law and rules of good faith: YB YALÇIN BORU questions the source of the data it collects or receives from other companies, and considers it important to obtaining them in accordance with the law and within the framework of the rules of good faith. In this context, YB YALÇIN BORU gives the necessary warning and notifications to the third parties (and other intermediaries) selling the services it offers, for protection of personal data.
b) Being accurate and up-to-date when necessary: YB YALÇIN BORU considers it important to update all data contained within the organisation to be accurate, not to contain incorrect information and finally to update them if there is any change in the personal data.
c) Processing for certain, clear and legitimate purposes: YB YALÇIN BORU only processes the data in a limited manner, for the purposes it provides and receives the approval of which during the service. It does not process, use or make use of the data other than for business purposes.
d) Being relevant, limited and expedient with the purpose of processing: YB YALÇIN BORU uses the data only limited to the purpose for which it is processed and as the service requires.
e) Being retained for the time required for the purpose anticipated in the relevant legislation or for the purpose it is processed for: YB YALÇIN BORU retains the data originating from the agreements to the periods of disputes arising as specified in the Law, and as required by the provisions of the trade and tax law. However, it deletes or anonymises the data when such purposes disappear.

It is important to note that these rules are nonetheless effective whether YB YALÇIN BORU collects and processes data whether in accordance with the data subject's consent or as per the Law.

In accordance with Article 11 of the Personal Data Protection Law, you have the following rights: In order to facilitate the exercising of these rights, an application form has been prepared by YB YALÇIN BORU.

Regarding the personal data, by referring to the contact person announced by YB YALÇIN BORU on our website, the data subject has the following rights:
a) Learning whether the personal data is processed,
b) If the personal data has been processed, requesting information regarding this,
c) Learning the purpose of the data processing and whether it is used in accordance with the intended purposes,
ç) Knowing the identities of the third parties to whom the personal data is transferred in the country or abroad,
d) Requesting the correction of personal data in the case that it has been incompletely or inaccurately processed,
e) Requesting the deletion or destruction of personal data within the provisions stipulated by the Law,
f) Requesting the notification of the transactions carried out pursuant to sub-paragraphs (d) and (e) to the third parties to whom personal data has been transferred to,
g) Objecting against an unfavourable consequence for the data subject due to the data processed being exclusively analysed by automatic systems,
ğ) Claiming compensation in case of suffering loss due to illegal processing of the personal data.
As YB YALÇIN BORU, we respect these rights.

Principle of Maximum Saving / Parsimony (Azami Tasarruf İlkesi/Cimrilik İlkesi)
According to this principle named as the principle of maximum saving or the principle of parsimony, the data received by YB YALÇIN BORU is processed to the system only to the extent that is necessary. Therefore, we determine which data to collect based on the purpose. The unnecessary data shall not be collected. Other data transferred to our company are likewise transmitted to the company information systems. Redundant information is not saved in the system, but deleted or anonymised. These data may be used for statistical purposes. From the data of special nature, health data is processed only so as to provide better service to customers and to protect their health, and it is retained in the system with care.

Deletion of personal data (Kişisel verilerin silinmesi)
When the deadlines to respect as stipulated by the Law, the necessity of the completion of the judicial proceedings or other requirements disappear, the personal data shall be erased, destroyed or anonymised by the company, ex officio or upon the request of the data subject.

Accuracy and actuality of data (Doğruluk ve veri güncelliği)
As a rule, the data retained within YB YALÇIN BORU is processed upon the declaration of the data subjects and in a way that they declare. YB YALÇIN BORU is not obliged to search for the accuracy of the data declared by the customers getting in contact with the company, and such work is further not conducted due to legal requirements and our working principles. The information declared is considered accurate. The principle of accuracy and actuality of personal data is adopted by YB YALÇIN BORU as well. Our company updates the personal data it has received from official documents or it has processed upon the request of the data subject. It takes necessary measures for this.

Confidentiality and data security (Gizlilik ve veri güvenliği)
Personal data is confidential and YB YALÇIN BORU respects this confidentiality. Personal data can be accessed only by authorised persons within the body of the company. All necessary technical and administrative measures are taken in order to protect the personal data collected by YB YALÇIN BORU and to prevent unauthorised persons from accessing the personal data, and to prevent our customers and prospects from being harmed by such consequences. In this framework, we ensure that our software complies with the standards, and the third parties are selected carefully, and adhere to the data protection policy within the company.

IV. Purposes of data processing
YB YALÇIN BORU shall collect and process personal data for the purposes specified in the disclosure text. Data is collected and processed for the purpose of establishing an agreement and providing better service to customers.

V. Data related to customers, prospective customers and business and solution partners

Collection and processing of data for contractual relationship (Sözleşme ilişkisi için verinin toplanması ve işlenmesi)
If a contractual relationship is established with our customers and prospective customers, the personal data collected may be used without the consent of the customer. However, such use is effectuated in line with the purpose of the contract. The data is used for better performance of the contract and to the extent of the service requirements, and is updated by contacting customers when necessary. Nonetheless, the data that our prospective customers have communicated to us is processed in order to provide them with easier and high quality service. This data is erased in case of their request if it does not turn into a contractual relationship.

Data related to Business and Solution Partners (İş ve Çözüm Ortakları Verileri)
In sharing data with both Business and Solution Partners, YB YALÇIN BORU adopts it as principle to act in accordance with the law. We share data with our business and solution partners in compliance with data privacy commitment and only to the extent that the sharing is required by the service, and this necessarily enforces the parties to take measures to ensure data security.

Data processing for advertising purposes (Reklam amaçlı veri işleme)
Regarding the Regulation of E-Trade Regarding Commercial Communication and Commercial Electronic Messages In accordance with the regulation, an electronic message can be sent to persons who have previously approved. Explicit consent of the person to whom the advertisement will be sent is required. YB YALÇIN BORU complies with the details of the "approval" likewise determined pursuant to the same legislation.

Data processing due to the legal obligation of the company or as explicitly prescribed by the Law (Şirketin hukuki yükümlülüğü veya kanunda açıkça öngörülmesi sebebiyle yapılan veri işlemleri)
Personal data may be processed without getting further approval due to the fact that processing is explicitly stipulated by the relevant legislation or for fulfilment of a legal obligation determined by the legislation. The type and scope of data processing must be required for the legally permitted data processing activity, and must comply with the relevant legal provisions.

Data processing by the company (Şirketin veri işlemesi)
Personal data can be processed in accordance with the service provided by the company and the legitimate purposes of the company. Still, data may in no way be used for illegal services.

Processing personal data of special nature (Özel nitelikli verilerin işlenmesi)
According to the Law, the personal data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, clothing, membership to associations, foundations or trade-unions, health, sexual life, convictions and security measures, as well as the biometric and genetic data of individuals who have the capacity of personal data of special nature. In processing of personal data of special nature, YB YALÇIN BORU also takes adequate measures determined by the Board.
YB YALÇIN BORU may only process personal data of special nature with the approval of the data subjects for the purpose for which they are collected in order to provide better services.

Data obtained through subscription procedures (Üyelik işlemleri yolu ile elde edilen veriler)
If you subscribe to YB YALÇIN transaction, your personal data that you shared with us for subscription procedures will be processed in our systems. If you subscribe to our system via Facebook, Google or other social media platforms, your data such as your name, surname, profile picture and e-mail address provided by the relevant social media platforms with their partners can be accessed and such data is transferred to the systems of YB YALÇIN BORU.

Data processed by means of automated systems (Otomatik sistemlerle işlenen veriler)
YB YALÇIN BORU acts in accordance with the Law on the data processed by means of automated systems. The information obtained from such data may not be used against the data subjects without their explicit consent. However, YB YALÇIN BORU may make decisions about the data subjects by using the data in its system.

Cookie Policy (Çerez Politikası)
As with many websites, YB YALÇIN BORU uses technologies such as cookies to improve the browsing experience of its website users and improve its service quality. YB YALÇIN BORU Cookie Policy is designed to inform the website users about cookies and the types of cookies used and how to manage the cookie preferences.

If you do not confirm the use of cookies, please do not continue with the website or change your cookie preferences as described in this Policy. Please note that some features of the website may lose functionality if cookies are not allowed.

What is Cookies? (Çerez Nedir?)
Cookies are small text files that are stored on your computer or on your mobile device when you visit a website. In these files, the data such as your IP address, your login information, pages you access, etc. are stored. By means of cookies, your website preferences can be recalled, your session can be kept open, or you can be presented with the content of your interests. For detailed information about cookies, you can visit www.aboutcookies.org and www.allaboutcookies.org.

Types of Cookies (Çerez Türleri)
Cookies are categorised into different types according to criteria such as their storage period on mobile devices and by whom they are placed. The basic distinction within the scope of these criteria is as follows:

Session Cookies: Session cookies are temporary cookies and are deleted from the device after closing the browser. The main function of these cookies is to ensure that the website functions properly.

Persistent Cookies: Persistent cookies remain on the device after closing the browser until they are deleted by the user or until they expire.

First Party Cookies: First party cookies are cookies placed on the device by the operator of the website visited.

Third Party Cookies: Third party cookies are cookies placed on the device and controlled by persons other than the operator of the website visited.

In the case that personal data is collected, processed and used in the websites, other systems or applications of YB YALÇIN BORU, the data subjects are informed with a privacy statement and about cookies if necessary. Data subjects are informed about our applications on web pages. Personal data shall be processed in accordance with the law.

When you visit our website, we provide the following information to your attention regarding the cookies we use/will use on our page.

	Purpose of Use of Cookies	Cookie Policy
Google(analytics, double-click)	Computation Advertising In-site optimisation	Functional and analytical cookies Advertising cookies
Facebook	Advertising	Advertising cookies
Adjust	Computation Advertising In-site optimisation	Functional and Analytical Cookies Advertising cookies
Hotjar	Computation In-site optimisation	Functional and analytical cookies Advertising cookies
3rd party companies (criteo, rtbhouse)	Advertising	Functional and analytical cookies Advertising cookies

Cookies used in the Website of YB YALÇIN BORU
YB YALÇIN BORU uses various types of cookies in accordance with its Privacy Policy.

Obligatory Cookies: These are the technical cookies that enable the website to function properly and allow you to use its features. They are in the category of session cookies. If these cookies are blocked, it will result in the inability to use the website features. Your consent is not required for the use of obligatory cookies.

Analytical Cookies: Analytical cookies are used to improve your website experience. Analytical cookies allow us to understand how you use the website (e.g. which pages you visit, duration of visit etc.). In this way, we can improve the content we offer or change the website design.

Functionality Cookies: When you visit the website again, your language preferences, region selection, etc. allow it to be recalled.

Targeting/Advertising Cookies: YB YALÇIN BORU uses different first-party and third-party cookies for targeting and advertising purposes on its website. It is possible to block these cookies by changing your browser settings or by changing your cookie preferences as shown in this Policy.

How Can You Change Your Cookie Preferences?

It is possible to customise or completely block the cookies by changing the settings of the browser you use. You can find detailed information on the steps to be followed for different browsers from the links below:

Browser

Google Chrome

Internet Explorer

Mozilla Firefox

Yandex

Safari

In order to manage cookie preferences in other browsers, you can review the help or support page of the relevant browser.

Transfer of Personal Data in the Country and Abroad

Your personal data is shared by YB Yalçın Borutur.com with the contracted hotels in the country and abroad for your accommodation. Your personal data may also be shared with hotels which are not contracted with YB Yalçın Borutur.com, through other electronic platforms in the country and abroad for you to do searching, booking and accommodation.

Your Rights related to your Personal Data

By applying to YB YALÇIN BORU, you will have the following rights:

• To learn whether your personal data is processed,
• To request information if your personal data is processed,
• To learn the purpose of the data processing and whether it is used in accordance with the intended purposes,
• To know the identities of the third parties to whom the personal data is transferred in the country or abroad,
• To request correction of the personal data in the case that it is processed defectively or wrong, and to request the transaction performed within this scope to be informed to the third parties to whom the personal data is transferred,
• To request the personal data to be deleted or demolished in case that the reasons justifying the processing of the personal data are ceased despite being processed in accordance with the provisions of the Law No. 6698 and other relevant laws, and to request the transaction performed within this scope to be informed to the third parties to whom the personal data is transferred,
• To object to an unfavourable consequence for the data subject due to the data processed being exclusively analysed by automatic systems,
• To claim compensation in case of suffering a loss due to processing of the personal data in violation of the Law.

If you submit your requests regarding the above-mentioned rights to our Company in accordance with the other application procedures prescribed in the Communiqué on the Procedures and Principles of Application to the Data Controller, your request will be concluded by YB Yalçın Boru as soon as possible and within 30 (thirty) days at the latest, depending on the nature of your request. However, if the process requires an additional cost, YB YALÇIN BORU may charge you with the tariff determined by the Personal Data Protection Board

Functional and Analytical
Cookies include such purposes as data about recalling your preferences, effective use of the website, optimising the website to meet user requests, and how visitors use the website. By their nature, such cookies may contain personal data such as user name, etc.

Third Party Cookies
YB Yalçın Boru websites/mobile applications/mobile websites cooperate with trusted and well-known third party advertisement providers. Third-party service providers place their own cookies in order to serve you with specific advertisements. Cookies placed by third parties collect the surfing information of visitors on their websites, process them and analyse how they use them.

Advertising cookies
These cookies are used for increasing your user experience by offering a more advanced, customised portfolio of advertisements and presenting you a similar product/content that you desire based on your interests and preferences. The storage period of the above-mentioned session, persistent, functional, analytical and advertising cookies is about 2 (two) months, and the user can do the necessary adjustments on the period via the internet browser settings. The process of removing these settings may vary based on the internet browser.

How can I delete cookies?
Many internet browsers are set up to automatically accept and use cookies from the initial installation to your computer. By using the help or settings menus of your internet browser, you can block cookies or have your browser alert when a cookie is transferred to your device. You can use your browser's instructions or help options menu to get to know the different ways to manage cookies and get detailed information about how to change the settings of the browser.

VI. Data related to your employees
Processing of data for business relations
The personal data of our employees may be processed without approval as far as they are necessary in terms of business relations and health insurance. However, YB YALÇIN BORU ensures the confidentiality and protection of its employees' data.

Processing due to Legal Obligations
YB YALÇIN BORU may process the personal data of its employees without further approval of its employees due to the fact that processing is explicitly stipulated by the relevant legislation or for fulfilment of a legal obligation determined by the legislation. This matter is limited to the obligations arising from the law.

Processing for the Favour of the Employees
YB YALÇIN BORU may process personal data without approval for transactions in line with the interests of the company employees, in such cases as private health insurance. YB YALÇIN BORU may process the data of the employees for the disputes arising from the business relations.

Processing personal data of special nature
According to the Law, the personal data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, clothing, membership to associations, foundations or trade-unions, health, sexual life, convictions and security measures, as well as the biometric and genetic data of individuals who have the capacity of personal data of special nature. In processing of personal data of special nature, YB YALÇIN BORU also takes adequate measures determined by the Board as well as receiving the approval of the data subject. Without the consent of the individual, personal data of special nature may only be processed in a limited manner and in the circumstances permitted by the Law. Personal data of special nature obtained from our employees in order for them to benefit from insurance and health services are only used for the relevant purposes.

Data processed by means of automated systems
Data processed on automated systems related to the employees may be used in internal promotions and performance evaluations. Our employees have the right to object to the results, and they can do such objection by following the internal procedures of the Company. The objections of employees are likewise finalised within the company.

Telecommunication and internet
The computer, telephone, e-mail and other applications allocated to employees within the Company are allocated to the employees for business purposes only. Employees may not use any of these means allocated by the company for personal purposes and personal communication. The company may check and inspect all data on these means. Employees undertake not to hold any data or information other than the business related data or information on the computer, telephone or other means allocated to them from the moment their employment starts.

VII. Transfer of personal data in the country and abroad
Personal data may be shared with the business and solution partners and the affiliates of YB YALÇIN BORU in order to ensure the service provided by YB YALÇIN BORU.

YB YALÇIN BORU will be able to transfer personal data to the following individuals and institutions for certain purposes:
» As limited to ensure the fulfilment of the purposes of establishment of the business partnership, to the business partners of YB YALÇIN BORU,
» As limited to the purpose of providing the services outsourced from a supplier and required to fulfil the commercial activities of our Company, to the suppliers of YB YALÇIN BORU,
» As limited to ensure that our company's commercial activities that require the participation of the affiliates of our Company are carried out, to the solution partners of YB YALÇIN BORU,
» To the affiliates of YB YALÇIN BORU.

YB YALÇIN BORU is authorised to transfer personal data in accordance with the other requirements in the Law and in accordance with the approval of the person in the country and abroad within the framework of the conditions determined by the Board.

VIII. The rights of the relevant person
YB YALÇIN BORU acknowledges that the relevant person is entitled to have his/her approval taken before the data is processed, and to self-determination after the processing of the data.

Regarding the personal data, by referring to the contact person announced by YB YALÇIN BORU on our website, the data subject has the following rights:
a) Learning whether his/her personal data is processed,
b) If the personal data has been processed, requesting information regarding this,
c) Learning the purpose of the data processing and whether it is used in accordance with the intended purposes,
ç) Knowing the identities of the third parties to whom the personal data is transferred in the country or abroad,
d) Requesting the correction of personal data in the case that it has been incompletely or inaccurately processed,
e) Requesting the deletion or destruction of personal data within the provisions stipulated by Article 7,
f) Requesting the notification of the transactions carried out pursuant to sub-paragraphs (d) and (e) to the third parties to whom personal data has been transferred to,
g) Objecting against an unfavourable consequence for the data subject due to the data processed being exclusively analysed by automatic systems,
ğ) Claiming compensation in case of suffering loss due to illegal processing of the personal data.
Nonetheless, the individuals do not have any rights with regard to the data anonymised in the Company. YB YALÇIN BORU may share personal data with the relevant institutions and organisations for the purpose of exercising a judicial duty or the statutory powers of the state authority in accordance with the business and contractual relationship.

The subjects of personal data may exercise their rights mentioned above by properly completing the application form in the company's official website address at www.YB Yalçın Borutur.com.tr, originally signing the form, and sending it by registered letter with return receipt along with their photocopies of identity (for ID cards, only a copy of the front page) to the address Merdivenköy Mh. Nur Sk. 1I/11 C Blok Kadıköy / İstanbul. Your applications shall be concluded as soon as possible depending on the nature of the requests, or within 30 days at the latest after it reaches our company. You must submit your applications by registered letter with return receipt. In addition, only the respective part of your application shall be answered, and an application about your spouse, relative or friend shall not be accepted. YB YALÇIN BORU may request further information and documents from applicants.

IX. Principle of Confidentiality
The data of both employees and other persons in YB YALÇIN BORU is confidential. No one may use, copy, reproduce, transfer such data to others or use it for any purpose other than business purposes in compliance with the agreement and law.

X. Transaction security
All necessary technical and administrative measures are taken in order to protect the personal data collected by YB YALÇIN BORU and to prevent unauthorised persons from accessing the personal data, and to prevent our customers and prospects from being harmed by such consequences. In this framework, we ensure that our software complies with the standards, and the third parties are selected carefully, and adhere to the data protection policy within the company. Security measures are constantly being renewed and improved.

XI. Inspection
YB YALÇIN BORU procures the necessary internal and external inspections on personal data protection.

XII. Notification of Violations
When YB YALÇIN BORU is notified of any violation of personal data, it takes immediate action to remedy such violation. It minimizes the damage of the data subject and compensates the damage. When personal data is obtained by unauthorised persons from outside, it immediately notifies the Personal Data Protection Board of the situation.

Application regarding the notification of violations can also be made in accordance with the procedures specified at the address http://YB Yalçın Boru ……………..com.

Contact
For your questions and requests regarding the confidentiality agreement, you can send a registered letter with return receipt to the address below along with the form below, after printing it out and filling it in.

YALÇIN BORU JEO. İML. İNŞ. TURZ. SAN. TİC. LTD. ŞTİ.

Address:

Polatlı / ANKARA
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