Clarification Text Regarding the Processing of Personal Data


Last update: 22/12/2024


SAM Güvenlik ve Koruma Hizmetleri A.Ş. takes all possible security measures to ensure that your personal data is collected, stored, and shared in compliance with the law, and to protect your privacy.

Our goal is to inform you in the most transparent way possible, in accordance with Article 10 of the Personal Data Protection Law No. 6698 and in line with your satisfaction, about how your personal data is collected, the purposes for which it is processed, the recipients to whom it is shared, the legal grounds, and your rights.

a) Data Controller

In accordance with the Personal Data Protection Law No. 6698 ("Law No. 6698"), your personal data may be collected and processed by SAM Güvenlik ve Koruma Hizmetleri A.Ş. ("COMPANY") as the data controller, within the scope explained below.

b) Purpose of Processing Personal Data

The COMPANY may collect personal data from parties such as its customers, employees, potential customers, job applicants, business partners, and suppliers, in categories including identity information, contact information, customer information, customer transaction data, transaction security information, legal transaction and compliance data, as well as marketing and sales information.

The personal data collected may be processed for the following purposes:

  • To ensure the provision of COMPANY products and services to you, fulfill our obligations towards you, organize records and documents, and comply with local and international legal regulations regarding information retention, reporting, notification, tax, and other obligations.

  • To offer personalized advertisements, campaigns, advantages, and other benefits for sales and marketing activities aimed at improving the quality of services and products.

  • To manage and monitor infrastructure and commercial activities, including compliance with internal policies and procedures related to auditing, finance, accounting, invoicing, collections, information systems, data and website hosting, business continuity, records, document, and printing management.

  • To communicate with you regarding information technology requirements, system structure, the necessity of IT support services, and to provide you with necessary information related to these services and products.

  • To carry out traffic measurement, statistical analysis, segmentation/profiling, and CRM activities for sales and marketing purposes.

  • To measure and enhance customer satisfaction, manage complaints, gather opinions and suggestions about new services and products, receive issue and error reports, and provide you with information regarding products, services, complaints, and requests.

  • To take your orders, process your payments, cooperate with third parties for logistics, ensure product delivery, suggest products and services you may be interested in, conduct online behavioral advertising and marketing, manage customer portfolios, measure and improve service quality, communication, optimization, audit, risk management, control, promotions, analysis, identify interests, scoring, profiling, marketing, sales, advertising, and communication.

  • To provide comparative product and/or service offers, modeling, current or new product development, and improvements, using your personal data in compliance with the laws and relevant regulations that govern the activities stated in the COMPANY’s articles of incorporation.

  • To comply with information retention, reporting, and notification obligations imposed by official authorities, fulfill the requirements of contracts, and carry out the legal obligations that the COMPANY is subject to regarding the use of these services.

  • To determine and implement the COMPANY’s commercial and business strategies; manage financial operations, communications, market research, social responsibility activities, procurement operations (demand, offer, evaluation, order, budgeting, contract), internal system and application management operations, and legal operations.

  • To comply with applicable laws and regulatory obligations (including those outside your country of residence), including anti-money laundering and counter-terrorism laws, follow legal processes, and review, evaluate, and respond to requests from official and government authorities (including those outside your country of residence), within the conditions and purposes specified in Articles 5 and 6 of the Law No. 6698.

c) Who Your Personal Data May Be Transferred to and for What Purposes

Your collected personal data may be transferred for the purposes outlined above, and to the following parties:

  • The COMPANY’s business partners, suppliers, shareholders, and affiliates of Yıldız Holding.

  • Persons or organizations authorized under the Tax Procedural Law, Social Security Institution regulations, the Court of Accounts, the Law on the Prevention of Laundering Proceeds of Crime, the Anti-Money Laundering Law, the Turkish Commercial Code, the Code of Obligations, and other relevant laws and regulations.

  • Public authorities, administrative bodies, and legal authorities authorized by law.

  • Foreign companies and affiliates.

  • Persons or legal entities with whom we cooperate, or service providers involved in product/service comparison, analysis, evaluation, advertising, or performing the purposes stated above, program partner institutions and organizations, and institutions we work with for sending messages to our customers, as well as courier companies that deliver your orders, in accordance with the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law No. 6698.

ç) Method and Legal Grounds for Collecting Personal Data

Your personal data is collected by the COMPANY through various channels, such as the COMPANY’s headquarters, applications made via partner websites, institutions with which we provide or receive support services, natural and/or legal persons involved in legal regulations or contracts, our website, mobile applications, call centers, social media accounts, and other channels that may be established in the future, either verbally, in writing, or electronically.

The COMPANY collects your personal data for the purposes mentioned above, including the fulfillment of contracts, in accordance with applicable legal regulations.

d) Rights of the Data Subject Under Article 11 of the Law No. 6698

As personal data owners, if you submit your requests related to your rights using the methods outlined below, the COMPANY will respond to your request as soon as possible and no later than thirty days, depending on the nature of the request. No fee will be charged for responses up to ten pages. For each page exceeding ten pages, a fee of 1 Turkish Lira will be charged. If the response to the application is provided on a recording medium such as a CD or flash drive, the fee that may be requested by our company will not exceed the cost of the recording medium.

In this context, personal data owners have the following rights:

  • Learn whether personal data is being processed,
  • Request information if personal data has been processed,
  • Learn the purpose of processing personal data and whether they are being used in accordance with that purpose,
  • Know the third parties to whom personal data has been transferred, both domestically and abroad,
  • Request correction if personal data has been processed inaccurately or incompletely, and request that the correction be communicated to third parties to whom personal data has been transferred,
  • Request deletion or destruction of personal data if the reasons for processing no longer exist, even if the data has been processed in accordance with the Law No. 6698 and other relevant laws, and request that this process be communicated to third parties to whom personal data has been transferred,
  • Object to the processing of data exclusively by automated systems if this results in an adverse outcome for the individual,
  • Request compensation for damages caused by the unlawful processing of personal data.

To exercise the above rights, you may submit your request in writing or via the electronic mail address previously provided to the COMPANY and recorded in our system, in accordance with Article 13 of the Law No. 6698 and the Communiqué on Application Procedures and Principles to the Data Controller (No. 30356, dated 10.03.2018). Only information regarding the applicant will be provided in the application, and information about family members or third parties will not be disclosed. The COMPANY reserves the right to verify your identity before responding.

In your application, you must include the following:

a) Your name, surname, and if the application is written, your signature,

b) For Turkish citizens, your Turkish ID number; for foreigners, your nationality, passport number, or if available, your identity number,

c) Your address for notification (residence or workplace address),

ç) If available, your electronic mail address, phone, and fax number for notification,

d) The subject of your request.

If applicable, any information and documents related to the subject must be attached to your application.

For written applications, you can submit them along with the necessary documents to our company as the data controller at the following address: Yenibosna Merkez Mahallesi Ladin SK. Kuyumcukent Blok No: 4M/1B030 Bahçelievler / Istanbul / Turkey.

For email applications, you can send them to info@samguvenlik.com.tr.

Depending on the nature of your request, it is necessary to provide the required information and documents in complete and accurate form for identity verification. If the requested information and documents are not provided properly, there may be delays or issues in conducting a thorough investigation of your request. In this case, the COMPANY reserves its legal rights. Therefore, it is important that your application is submitted with all the necessary and requested information and documents based on the nature of your request.

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