Privacy Policy

SUN-KA SUNGURLU KAĞITÇILIK SANAYİ VE TİCARET ANONİM ŞİRKETİ CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

Data Controller

In the capacity of data controller, your personal data may be processed by Sun-Ka Sungurlu Kağıtçılık Sanayi Ve Ticaret Anonim Şirketi (“Sun-Ka”), residing at the address of Hacettepe Mah. 11111 Sk. Sunka Kağıt Fb. Blok No: 1 Sungurlu/ÇORUM, in accordance with the Law, within the framework of the purposes listed below and in a connected, limited, and proportionate manner with these purposes, maintaining the accuracy and up-to-date nature of the personal data as received by us, within the scope described below.

Purposes of Collection and Processing of Personal Data

Sun-Ka may obtain personal data directly from the data subjects themselves, as well as indirectly from third parties and from data made public by the data subjects themselves. Your collected personal data may be processed by Sun-Ka in accordance with the fundamental principles stipulated in the Law and within the personal data processing conditions specified in Articles 5 and 6 of the Law; primarily for the fulfillment of duties and obligations listed in the Turkish Commercial Code No. 6102, ensuring the legal, technical, commercial, and occupational safety of Sun-Ka and relevant persons in a business relationship with Sun-Ka during the management processes of data subjects' personal data, and for the execution of operations. In this context, personal data may be collected verbally, physically, or electronically, and subjected to processing activities within the scope of Sun-Ka’s operations.

IDENTITY DATA
Data Belonging to the Identity Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
·Name and surname ·Gender ·Nationality ·Date of birth ·Place of birth ·Signature ·T.R. Identity Number ·Marital Status ·Social Security (SGK) Number	·Employee ·Candidate Employee ·Shareholder/Partner ·Supplier employee ·Supplier authorized representative ·Visitor ·Business partner ·Customer ·Customer employee/representative ·Potential business partner employee/representative ·Potential supplier employee/representative ·Potential customer employee/representative ·Potential business partner ·Subcontractor employee/representative					Obtained directly from the individuals during job applications, business partnerships, commercial relations, internship applications, procurement of supply services, information requests, receipt of requests or complaints, goods/services sales and shipment processes, training, and similar activities.		· Fulfillment of obligations stipulated in the Labor Law No. 4857 · Execution of candidate employee/intern/student selection and placement processes · Execution of application processes of candidate employees · Execution of employee satisfaction and loyalty processes · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of fringe benefits and interests processes for employees · Execution of audit/ethics activities · Execution of training activities · Execution of finance and accounting affairs · Execution of activities in compliance with legislation · Arrangement of visa, customs, etc. procedures within the scope of export activities · Execution of goods/services procurement processes · Execution of goods/services production and operation processes · Execution of activities regarding customer satisfaction · Planning of customer relationship management · Execution of goods/services sales processes · Reporting of business activities · Execution of contract processes · Execution of marketing processes of products/services · Execution of communication activities · Follow-up of requests/complaints · Providing information to authorized persons, institutions, and organizations · Execution of procurement activities · Creation and follow-up of visitor records
Legal Grounds
Law No. 6698 Article 5/2 (a): Explicitly provided for by law. Law No. 6698 Article 5/2 (c): Necessity of processing personal data belonging to the parties of a contract, provided that it is directly related to the establishment or performance of the contract. Law No. 6698 Article 5/2 (ç): Fulfillment of legal obligations. Law No. 6698 Article 5/2 (e): Necessity of data processing for the establishment, exercise, or protection of a right. Law No. 6698 Article 5/2 (f): Necessity of processing data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
CONTACT DATA
Data Belonging to the Contact Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
·Address ·E-mail address ·Residence ·Contact address ·Phone Number	·Employee ·Candidate Employee ·Shareholder/Partner ·Supplier employee ·Supplier representative ·Visitor ·Business partner ·Customer ·Customer employee/representative ·Potential business partner employee/representative ·Potential supplier employee/representative ·Potential customer employee/representative ·Potential business partner ·Subcontractor employee/representative					Obtained directly from the individuals during job applications, business partnerships, membership, internship applications, procurement of supply services, customer relationship management, information requests, receipt of requests or complaints, surveys, newsletters, training, and similar activities.		· Fulfillment of obligations stipulated in the Labor Law No. 4857 · Execution of candidate employee application processes · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of audit/ethics activities · Execution of training activities · Execution of finance and accounting affairs · Execution of activities in compliance with legislation · Arrangement of visa, customs, etc. procedures within the scope of export activities · Execution of goods/services procurement processes · Execution of goods/services sales processes · Execution of goods/services production and operation processes · Execution of activities regarding customer satisfaction · Execution of contract processes · Execution of marketing processes of products/services · Completion of product sample and testing procedures · Execution of communication activities · Follow-up of requests/complaints · Providing information to authorized persons, institutions, and organizations · Execution of procurement activities
Legal Grounds
Law No. 6698 Article 5/2 (a): Explicitly provided for by law. Law No. 6698 Article 5/2 (c): Necessity of processing personal data belonging to the parties of a contract, provided that it is directly related to the establishment or performance of the contract. Law No. 6698 Article 5/2 (ç): Fulfillment of legal obligations. Law No. 6698 Article 5/2 (e): Necessity of data processing for the establishment, exercise, or protection of a right. Law No. 6698 Article 5/2 (f): Necessity of processing data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
PHYSICAL SPACE SECURITY DATA
Data Belonging to the Physical Space Security Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
·Entry and exit records ·Security camera recordings located at Sun-Ka facilities	·Employee ·Candidate Employee ·Shareholder/Partner ·Supplier employee ·Supplier representative ·Potential supplier employee/representative ·Visitor ·Customer ·Customer representative/employee ·Potential business partner employee/representative ·Potential customer employee/representative ·Potential business partner ·Subcontractor employee/representative ·Business Partner					Obtained via security cameras starting from the entrance upon visiting Sun-Ka facilities.		· Fulfillment of obligations in the Labor Law No. 4857 and relevant legislation · Execution of audit and ethics activities · Ensuring physical space security · Execution of activities aimed at ensuring business continuity · Execution of goods/services procurement processes · Providing information to authorized persons, institutions, and organizations · Creation and follow-up of visitor records
Legal Grounds
Law No. 6698 Article 5/2 (e): Necessity of data processing for the establishment, exercise, or protection of a right. Law No. 6698 Article 5/2 (f): Necessity of processing data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
TRANSACTION SECURITY DATA
Data Belonging to the Transaction Security Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
·Cookie Records ·IP address information ·IP Address Tracking ·Internet Access Log Records ·Website log-in and log-out information ·System and Application User Account Information (Usernames, email accounts, last login dates, IP data, etc.) ·Password and credential information, etc.	·Employee ·Visitor					Obtained through visiting websites belonging to Sun-Ka, connecting to the internet via the Sun-Ka network, receiving services via the call center, or communicating with Sun-Ka via the call center or email address.		· Fulfillment of obligations under the Law No. 5651 on Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications and relevant legislation · Execution of information security processes · Management of access authorizations · Execution of activities in compliance with legislation · Ensuring physical space security · Execution of communication activities · Execution / auditing of Sun-Ka activities · Follow-up of requests / complaints · Ensuring the security of data controller operations · Providing information to authorized persons, institutions, and organizations · Creation and follow-up of visitor records
Legal Grounds
Law No. 6698 Article 5/2 (ç): Fulfillment of legal obligations. Law No. 6698 Article 5/2 (a): Explicitly provided for by law.
VISUAL AND AUDIO DATA
Data Belonging to the Visual and Audio Records Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
·Photograph ·Camera Recordings	·Employee ·Candidate Employee ·Visitor					Obtained through photographs submitted during job applications to Sun-Ka and closed-circuit television (CCTV) security cameras.		· Fulfillment of obligations in the Law No. 4857 and relevant legislation · Execution of human resources processes · Ensuring physical space security · Execution of activities in compliance with legislation · Execution of communication activities · Execution / auditing of Sun-Ka activities · Ensuring the security of movable property and resources · Ensuring the security of data controller operations · Providing information to authorized persons, institutions, and organizations · Creation and follow-up of visitor records
Legal Grounds
Law No. 6698 Article 5/2 (ç): Fulfillment of legal obligations. Law No. 6698 Article 5/2 (a): Explicitly provided for by law. Law No. 6698 Article 5/2 (f): Necessity of processing data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
CUSTOMER TRANSACTION
Data Belonging to the Customer Transaction Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
·Invoice ·Promissory Note ·Check ·Order information ·Request information	·Customer					Obtained directly from the relevant individuals or their authorized representatives/employees for the purpose of planning and executing goods and/or services procurement and sales processes.		· Fulfillment of obligations within the framework of the Tax Procedure Law No. 213 and related secondary legislation · Execution of finance and accounting affairs · Execution of goods/services procurement processes · Execution of goods/services sales processes · Execution of goods/services production and operation processes · Planning of goods/services sales processes · Execution of marketing processes of products/services
Legal Grounds
Law No. 6698 Article 5/2 (c): Establishment or performance of a contract. Law No. 6698 Article 5/2 (ç): Fulfillment of legal obligations.
FINANCE
Data Belonging to the Finance Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
·Bank details ·Account details ·Card details	·Employee ·Customer ·Supplier					Obtained directly from the individuals or their authorized representatives/employees for the execution of goods and/or services purchasing and sales processes, fulfilling obligations arising from sales contracts, and performing commitments under employment contracts.		· Fulfillment of obligations arising from the Labor Law No. 4857 · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of finance and accounting affairs · Execution of goods/services procurement processes · Execution of goods/services sales processes · Management of wage policy · Execution of investment processes
Legal Grounds
Law No. 6698 Article 5/2 (c): Establishment or performance of a contract. Law No. 6698 Article 5/2 (ç): Fulfillment of legal obligations.
MARKETING
Data Belonging to the Marketing Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
·Shopping history data	·Customer					Obtained within the scope of goods and/or services purchasing and sales processes.		· Execution of processes regarding loyalty to Sun-Ka products and services · Execution of customer relationship management processes · Execution of activities oriented towards customer satisfaction · Planning and execution of marketing analysis studies · Execution of advertising/campaign/promotional processes
Legal Grounds
Law No. 6698 Article 5/2 (c): Establishment or performance of a contract. Law No. 6698 Article 5/2 (f): Necessity of processing data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
PROFESSIONAL EXPERIENCE
Data Belonging to the Professional Experience Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
·Diploma information, ·Courses attended, ·In-service training details, ·Certificates, ·Transcript records	·Employee ·Candidate employee					Obtained through job applications submitted for employee recruitment, applications for intern recruitment, and the sharing of personnel files for supplier employees to provide services.		· Fulfillment of obligations in the Law No. 4857 and relevant legislation · Execution of job application processes · Execution of human resources processes · Execution of communication activities · Execution / auditing of Sun-Ka activities · Providing information to authorized persons, institutions, and organizations
Legal Grounds
Law No. 6698 Article 5/2 (c): Establishment or performance of a contract. Law No. 6698 Article 5/2 (ç): Fulfillment of legal obligations.
LEGAL ACTION
Data Belonging to the Legal Action Category	Data Subject Group				Method of Data Collection		Purpose of Processing Personal Data
· Contracts, information security and confidentiality undertakings, · Legal document records received from authorized institutions, enforcement file information, lawsuit file information, records in correspondence with judicial authorities, information security undertakings, · Execution wage garnishment and alimony records, court minutes, contracts, police reports, legal follow-up information, records in court files	·Employee ·Business Partner ·Supplier				Obtained from courts regarding parties to legal disputes, party information in contracts, enforcement offices for employee wage garnishments, and directly from the individual.		· Fulfillment of obligations arising from employment contracts and legislation for employees, · Execution of fringe benefits and interests processes for employees, · Execution of activities in compliance with legislation, · Execution of finance and accounting affairs, · Follow-up and execution of legal affairs, · Execution of human resources processes, · Fulfillment of legal obligations arising from legislation, · Creation of employee personnel files, · Providing information to authorized persons, institutions, and organizations
Legal Grounds
Law No. 6698 Article 5/2 (a): Explicitly provided for by law. Law No. 6698 Article 5/2 (ç): Fulfillment of legal obligations. Law No. 6698 Article 5/2 (c): Establishment and performance of a contract.
LOCATION
Data Belonging to the Location Category	Data Subject Group					Method of Data Collection		Purpose of Processing Personal Data
· GPS Data	· Employee					Obtained automatically directly from the individual via the tracking systems installed in vehicles belonging to Sun-Ka.		· Execution of emergency management processes · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of fringe benefits and interests processes for employees · Execution of audit / ethics activities · Execution / auditing of business operations · Ensuring the security of movable property and resources
Legal Grounds
Law No. 6698 Article 5/2 (c): Establishment or performance of a contract.
HEALTH INFORMATION
Data Belonging to the Health Information Category	Data Subject Group			Method of Data Collection					Purpose of Processing Personal Data
· Personal Health Information · Blood Type Information	· Employee			Obtained through the sharing of personnel file records in order for employees to perform their services.					· Fulfillment of obligations under the Labor Law No. 4857 · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of audit/ethics activities · Execution of job application processes · Execution of human resources processes · Providing information to authorized persons, institutions, and organizations
Legal Grounds
Law No. 6698 Article 6/2: Explicit Consent
CRIMINAL CONVICTION AND SECURITY MEASURES DATA
Data Belonging to the Criminal Conviction Category		Data Subject Group	Method of Data Collection							Purposes of Processing Special Categories of Personal Data
· Criminal Record		· Employee	Obtained through the sharing of personnel file records in order for employees to perform their services.							· Fulfillment of obligations under the Labor Law No. 4857 · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of audit/ethics activities · Execution of activities in compliance with legislation · Execution of human resources processes · Providing information to authorized persons, institutions, and organizations
Legal Grounds
Law No. 6698 Article 6/2: Explicit Consent

Parties to Whom Your Personal Data is Transferred and Purposes of Transfer

Your collected personal data may be transferred by Sun-Ka, in accordance with the fundamental principles stipulated in the Law and within the personal data processing conditions specified in Articles 8 and 9 of the Law, within the scope of the purposes listed above, to our business partners, suppliers, customers, legally authorized public/private institutions and organizations, and, in the presence of your explicit consent, abroad, provided that it is limited and necessary.

IDENTITY DATA

Transferred Parties

Purpose of Transferring Personal Data

·Real persons or private legal entities ·Publicly accessible ·Authorized public institutions and organizations ·Business Partners ·Suppliers

· Execution of application processes of candidate employees · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of fringe benefits and interests processes for employees · Execution of audit/ethics activities · Execution of training activities · Execution of finance and accounting affairs · Execution of activities in compliance with legislation · Arrangement of visa, customs, etc. procedures within the scope of export activities · Execution of goods/services procurement processes · Execution of goods/services production and operation processes · Execution of activities regarding customer satisfaction · Planning of customer relationship management · Execution of goods/services sales processes · Execution of contract processes · Execution of marketing processes of products/services · Completion of product sample and testing procedures · Execution of communication activities · Follow-up of requests / complaints · Providing information to authorized persons, institutions, and organizations · Execution of procurement activities

CONTACT DATA

Transferred Parties

Purpose of Transferring Personal Data

·Real persons or private legal entities ·Authorized public institutions and organizations ·Business Partners ·Suppliers

· Execution of application processes of candidate employees · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of audit/ethics activities · Execution of training activities · Execution of finance and accounting affairs · Execution of activities in compliance with legislation · Arrangement of visa, customs, etc. procedures within the scope of export activities · Execution of goods/services procurement and sales processes · Execution of goods/services production and operation processes · Execution of activities regarding customer satisfaction · Execution of contract processes · Execution of marketing processes of products/services · Execution of communication activities · Follow-up of requests / complaints · Providing information to authorized persons, institutions, and organizations · Execution of procurement activities

PHYSICAL SPACE SECURITY DATA

Transferred Parties

Purpose of Transferring Personal Data

·Authorized public institutions and organizations

· Fulfillment of obligations in the Labor Law No. 4857 and relevant legislation · Execution of audit and ethics activities · Ensuring physical space security · Execution of activities aimed at ensuring business continuity · Execution of goods/services procurement and sales processes · Providing information to authorized persons, institutions, and organizations · Creation and follow-up of visitor records

TRANSACTION SECURITY DATA

Transferred Parties

Purpose of Transferring Personal Data

·Authorized public institutions and organizations

· Fulfillment of obligations under the Law No. 5651 on Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications and relevant legislation · Execution of information security processes · Execution of activities in compliance with legislation · Ensuring physical space security · Execution / auditing of Sun-Ka activities · Follow-up of requests / complaints · Ensuring the security of data controller operations · Providing information to authorized persons, institutions, and organizations

VISUAL AND AUDIO DATA

Transferred Parties	Purpose of Transferring Personal Data
·Authorized public institutions and organizations	· Fulfillment of obligations under the Law No. 4857 and relevant legislation · Ensuring physical space security · Execution of human resources processes · Execution / auditing of Sun-Ka activities · Ensuring the security of movable property and resources · Ensuring the security of data controller operations · Providing information to authorized persons, institutions, and organizations · Creation and follow-up of visitor records
CUSTOMER TRANSACTION
Transferred Parties	Purpose of Transferring Personal Data
·Real persons or private legal entities ·Authorized public institutions and organizations ·Business Partners	· Fulfillment of obligations within the framework of the Tax Procedure Law No. 213 and related secondary legislation · Execution of audit/ethics activities · Execution of finance and accounting affairs · Execution of goods/services procurement and sales processes · Execution of goods/services production and operation processes · Execution of marketing processes of products/services
FINANCE
Transferred Parties	Purpose of Transferring Personal Data
·Real persons or private legal entities ·Authorized public institutions and organizations	· Fulfillment of obligations arising from the Labor Law No. 4857 · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of finance and accounting affairs · Execution of goods/services procurement and sales processes · Management of wage policy · Execution of investment processes
MARKETING
Transferred Parties	Purpose of Transferring Personal Data
·Real persons or private legal entities ·Authorized public institutions and organizations	· Execution of processes regarding loyalty to Sun-Ka products and services · Execution of customer relationship management processes · Execution of activities oriented towards customer satisfaction · Planning and execution of marketing analysis studies · Execution of advertising/campaign/promotional processes

PROFESSIONAL EXPERIENCE

Transferred Parties		Purpose of Transferring Personal Data
·Real persons or private legal entities ·Authorized public institutions and organizations ·Business Partners		· Fulfillment of obligations under the Law No. 4857 and relevant legislation · Execution of job application processes · Execution of human resources processes · Execution of communication activities · Execution / auditing of Sun-Ka activities · Providing information to authorized persons, institutions, and organizations
LEGAL ACTION
Transferred Parties	Purpose of Transferring Personal Data
· Authorized Public Institutions and Organizations · Business Partners	· Fulfillment of Obligations Arising from Employment Contracts and Legislation for Employees · Execution of Activities in Compliance with Legislation · Execution of Finance and Accounting Affairs · Follow-up and Execution of Legal Affairs · Execution / Auditing of Business Operations · Execution of Goods / Services Procurement Processes · Execution of Goods / Services Sales Processes · Follow-up of Requests / Complaints · Providing Information to Authorized Persons, Institutions, and Organizations
LOCATION
Transferred Parties		Purpose of Transferring Personal Data
·Authorized public institutions and organizations ·Business Partners		· Execution of emergency management processes · Fulfillment of obligations arising from employment contracts and legislation for employees · Execution of audit / ethics activities · Execution / auditing of business operations · Ensuring the security of movable property and resources
HEALTH INFORMATION
Transferred Parties			Purpose of Transferring Personal Data
· Authorized Public Institutions and Organizations			· Execution of Emergency Management Processes · Fulfillment of Obligations Arising from Employment Contracts and Legislation for Employees · Execution of Fringe Benefits and Interests Processes for Employees · Execution of Assignment Processes · Follow-up and Execution of Legal Affairs · Planning of Human Resources Processes · Execution / Auditing of Business Operations · Execution of Occupational Health / Safety Activities · Execution of Contract Processes · Providing Information to Authorized Persons, Institutions, and Organizations

Method and Legal Grounds for the Collection of Your Personal Data

Your personal data may be collected by Sun-Ka electronically via email, mobile applications, website, public internet sources, social media, telephone, SMS, and call center channels, as well as physically by hand delivery or postal services. Furthermore, your personal data will be collected based on the legal grounds specified in Articles 5 and 6 of the Law: the establishment and/or performance of a contract, the establishment, exercise, and/or protection of a right, fulfillment of a legal obligation, and other legal grounds described above, as well as your explicit consent where necessary.

Your Rights Listed in Article 11 of the Law as the Data Subject

Pursuant to Article 11 of the Law, we hereby inform you that as data subjects, 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 your personal data and whether they are used in accordance with their purpose,
Know the third parties to whom your personal data is transferred domestically or abroad,
Request the rectification of your personal data if it is incomplete or incorrectly processed, and request that the action taken in this context be notified to third parties to whom your personal data has been transferred,
Request the erasure or destruction of personal data in the event that the reasons requiring its processing cease to exist, even though it has been processed in accordance with the Law and other relevant legal provisions, and request that the action taken in this context be notified to third parties to whom your personal data has been transferred,
Object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems,
Demand compensation for damages in case you incur damages due to the unlawful processing of your personal data.

Regarding your requests concerning the rights listed above, you may submit your application containing the minimum conditions specified in the Communiqué on the Principles and Procedures for the Request to Data Controller in writing with a wet-ink signature in person to the Company headquarters at Hacettepe Mah. 11111 Sk. Sunka Kağıt Fb. Blok No: 1 Sungurlu/ÇORUM, send it via a notary public, transmit it with a secure electronic signature to our Company’s Registered Electronic Mail (KEP) address at sunkakagitcilik@hs01.kep.tr, or send it to our Company via the email address kvkk@larton.com.tr if your email address is already registered in our Company’s systems.