Personal Data Protection Law Information
The way in which the information we obtain about you and the services you request during your visit to this website and your use of the services we offer through this site will be used and protected is subject to the terms set forth in this “Privacy Policy”. By visiting this website and requesting to use the services we offer through this site, you agree to the terms set forth in this “Privacy Policy”.
I. Purpose of the personal data protection and processing policy
Due to the sensitive nature of the work we have undertaken as “DEVECİ ABEY AŞ” to date, data received from our customers or prospective customers has been kept confidential and has never been shared with third parties. The protection of personal data is a fundamental policy of our company. Even before any legal regulations were in place, our company and its subsidiaries placed great importance on the confidentiality of personal data, adopted it as a working principle, and instructed our employees to work in accordance with this principle. As “DEVECİ ABEY AŞ”, we also undertake to comply with all the responsibilities imposed by the Law on the Protection of Personal Data. Our companies’ principles regarding the protection of personal data also apply to our subsidiaries.
II. Scope and amendment of the personal data protection and processing policy.
This Policy, prepared by our company, is in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”). The Law has entered into force with all its provisions as of today. Data obtained from you with your consent or due to other legal grounds listed in the Law will be used to improve the quality of the services we provide, to enhance the services offered to you, and to improve our quality policy. Furthermore, some of the data we hold is anonymized and no longer considered personal. This data is used for statistical purposes and is not subject to the Law or our Policy. The “DEVECİ ABEY AŞ” Personal Data Protection and Processing Policy aims to protect the automatically obtained data of our customers, prospective customers, employees, and the customers and employees of companies with whom we have a partnership, or other individuals, and includes regulations regarding this.
Our company reserves the right to amend our policies and regulations – provided that this complies with the law and ensures better protection of personal data.
III. Basic rules regarding the processing of personal data
a) Compliance with the law and principles of honesty: DEVECİ ABEY AŞ questions the source of the data it collects or receives from other companies and attaches importance to ensuring that this data is obtained in accordance with the law and principles of honesty. In this context, DEVECİ ABEY AŞ provides the necessary warnings and notifications to third parties (including agents and other intermediaries) selling the services it offers, in order to protect personal data.
b) Accuracy and timeliness: DEVECİ ABEY AŞ attaches importance to ensuring that all data within the company is accurate, does not contain false information, and updates personal data if it is notified of any changes.
c) Processing for specific, explicit and legitimate purposes: DEVECİ ABEY AŞ processes data only for the purposes it provides and for which it has obtained consent from individuals during the provision of its services. It does not process, use, or allow the use of data for purposes other than its business purpose.
d) Being relevant, limited, and proportionate to the purpose for which they are processed: DEVECİ ABEY AŞ uses the data only to the extent necessary for the purpose for which it is processed and required by the service.
e) Retention for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed: DEVECİ ABEY AŞ retains data originating from contracts for the periods stipulated by law for dispute resolution, and for the requirements of commercial and tax law. However, when these purposes cease to exist, the data is deleted or anonymized.
It is important to note that these principles listed above apply regardless of whether DEVECİ ABEY AŞ collected or processed data with consent or in accordance with the law.
According to Article 11 of the Personal Data Protection Law, you have the following rights. To facilitate the exercise of these rights, DEVECİ ABEY AŞ has also prepared an application form for you.
Individuals whose personal data is processed may contact DEVECİ ABEY AŞ through the contact information provided on our website to request information regarding their data.
You have the right to: a) learn whether your personal data is being processed; b) request information regarding the processing of your personal data if it has been processed; c) learn the purpose of the processing of your personal data and whether it is being used in accordance with its purpose; d) know the third parties to whom your personal data has been transferred, domestically or internationally; e) request the correction of your personal data if it is incomplete or inaccurate; f) request the deletion or destruction of your personal data within the framework of the conditions stipulated in the law; g) request that the actions taken pursuant to clauses (d) and (e) be notified to the third parties to whom your personal data has been transferred; h) object to a result that is detrimental to you arising from the analysis of your processed data exclusively through automated systems; i) demand compensation for damages if you have suffered harm due to the unlawful processing of your personal data. As DEVECİ ABEY AŞ, we respect these rights.
The Principle of Maximum Economy/The Principle of Frugality
According to our principle of maximum economy, also known as the principle of frugality, data received by DEVECİ ABEY AŞ is only processed into the system to the extent necessary. Therefore, the data we collect is determined according to the purpose. Unnecessary data is not collected. Other data received by our company is similarly transferred to the company’s information systems. Redundant information is not recorded in the system; it is deleted or anonymized. This data may be used for statistical purposes. Regarding sensitive data, health data is collected only to provide better service to customers and protect their health, and is carefully maintained in the system.
Deletion of personal data
When legally required retention periods expire, judicial processes are completed, or other requirements cease to exist, our company will automatically delete, destroy, or anonymize personal data, or this data will be deleted or anonymized upon the request of the data subject.
Accuracy and data currency
Data within DEVECİ ABEY AŞ is, as a rule, processed based on the information provided by the data subjects. DEVECİ ABEY AŞ is not obligated to investigate the accuracy of the data provided by customers or individuals who contact DEVECİ ABEY AŞ, nor is this done due to legal reasons and our operating principles. The declared data is accepted as accurate. The principle of accuracy and timeliness of personal data is also adopted by DEVECİ ABEY AŞ. Our company updates the personal data it processes from official documents it receives or upon the request of the data subject. It takes the necessary measures for this.
Privacy and data security
Personal data is confidential, and DEVECİ ABEY AŞ respects this confidentiality. Only authorized personnel can access personal data within the company. DEVECİ ABEY AŞ takes all necessary technical and administrative measures to protect the personal data it collects, to prevent unauthorized access, and to ensure that our customers and prospective customers are not harmed. This includes ensuring that software complies with standards, carefully selecting third parties, and adhering to the data protection policy within the company.
IV. Data processing purposes
DEVECİ ABEY AŞ’s collection and processing of personal data will be carried out in accordance with the purposes stated in the privacy policy. Data is collected and processed for the purpose of establishing contracts and providing better service to customers.
V. Customer, potential customer and business and solution partner data
Collection and Processing of Data for Contractual Relationships: If a contractual relationship has been established with our customers and prospective customers, the collected personal data may be used without the customer’s consent. However, this use will be in accordance with the purpose of the contract. Data will be used to better execute the contract and meet the requirements of the service, and will be updated by contacting customers as needed. Conversely, data provided by prospective customers is processed to provide them with easier and higher-quality service in the future. This data will be deleted upon their request if it has not resulted in a contractual relationship.
Business and Solution Partner Data
DEVECİ ABEY AŞ adheres to the principle of acting in accordance with the law when sharing data with both business and solution partners. Data is shared with business and solution partners only to the extent necessary for the service, with a commitment to data confidentiality, and these parties are required to take measures to ensure data security.
Data processing for advertising purposes.
In accordance with the Law on the Regulation of E-Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages, advertising electronic messages may only be sent to individuals who have given their prior consent. The explicit consent of the recipient is a prerequisite. DEVECİ ABEY AŞ complies with the details of this “consent” as defined in the same legislation. The consent obtained must cover all commercial electronic messages sent to recipients’ email addresses for the purpose of promoting and marketing your company’s goods and services, promoting your business, or increasing brand awareness through content such as greetings and congratulations. This consent can be obtained in writing in a physical environment or through any electronic communication means. The important thing is that the recipient’s positive declaration of intent to receive commercial electronic messages, along with their name, surname, and email address, is included.
Data processing carried out due to the company’s legal obligation or explicitly provided for in the law: Personal data may be processed without further consent if the processing is explicitly stated in the relevant legislation or for the purpose of fulfilling a legal obligation determined by legislation. The type and scope of data processing must be necessary for the legally permitted data processing activity and must comply with the relevant legal provisions.
Company data processing
Personal data may be processed in accordance with the services offered by the company and its legitimate purposes. However, the data may not be used for any unlawful activities.
Processing of sensitive data
According to the law, personal data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, are considered special categories of personal data. DEVECİ ABEY AŞ also takes adequate measures, as determined by the Board, in the processing of special categories of personal data.
“DEVECİ ABEY AŞ” may process sensitive personal data with the consent of individuals only for the purpose for which it was collected, in order to provide better services.
Data processed by automated systems
DEVECİ ABEY AŞ complies with the law regarding data processed through automated systems. Information obtained from this data cannot be used against individuals without their explicit consent. However, DEVECİ ABEY AŞ may make decisions regarding individuals with whom it will conduct transactions using data in its own system.
User information and the internet
When personal data is collected, processed, and used on websites and other systems or applications belonging to DEVECİ ABEY AŞ, individuals are informed via a privacy notice and, if necessary, about cookies. Individuals are informed about our applications on the web pages. Personal data will be processed in accordance with the law. When you visit our website, we bring the following information to your attention regarding the cookies we use/will use on our page.
Data processed by automated systems
Data processed by automated systems regarding employees may be used in internal promotions and performance evaluations. Our employees have the right to appeal against unfavorable outcomes and will do so by following internal company procedures. Employee appeals will also be evaluated internally.
Google(analytics, doubleclick)
Purpose of Using Cookies: Measurement, Advertising, On-site improvement. Cookie Types: Functional and analytical cookies, Commercial cookies.
Functional and Analytical
Cookies remember your preferences, ensure the website is used effectively, optimize the site to respond to user requests, and contain data about how visitors use the site. By their nature, these types of cookies may contain personal information such as your username.
Third-Party Cookies: DEVECİ ABEY AŞ websites/mobile applications/mobile websites work with trusted, well-known third-party advertising providers. Third-party service providers place their own cookies to provide you with personalized advertisements. Cookies placed by third parties collect, process, and analyze visitors’ browsing information and how they use the websites.
Commercial cookies are used to enhance your user experience by presenting products/content similar to those you are interested in and have selected, and by providing a more advanced and personalized advertising portfolio. The session, persistent, functional, analytical, and commercial cookies mentioned above are stored in the background for approximately 2 (two) months, and the necessary adjustments can be made through the user’s internet browser settings. The process of removing these cookies may vary depending on the internet browser.
If your booking is interrupted due to system errors or disruptions during the reservation process, a call center representative will contact you.
How can I delete cookies?
Many internet browsers are set to automatically accept and use cookies from the moment they are first installed on your computer. You can block cookies or receive warnings when cookies are sent to your device using your internet browser’s help or settings menus. For detailed information on how to manage cookies and adjust your browser settings, you can refer to your browser’s instructions or help options screen.
Purposes of Collecting and Processing Security Data at Facilities
DEVECİ ABEY AŞ, acting as the data controller under Law No. 6698, collects your security camera footage during your visit to ensure the safety of both our company and you, and to enable our company to provide you with secure services. Your personal data is not used for purposes other than those stated above; it is processed based on the legitimate interest of the data controller as stipulated in Article 5/2 (f) of the KVKK (Personal Data Protection Law).
As a rule, your collected personal data will not be shared with any third party or institution. However, it may be shared to fulfill requests from legally authorized public institutions and organizations for the purpose of fulfilling legal obligations stipulated in Article 5/2(ç) of the law. Once the purpose of collection has ended, your data will be destroyed.
VI. Data belonging to our employees
Processing Data for Employment Relationships: Our employees’ personal data may be processed without consent to the extent necessary for employment relationships and health insurance purposes. However, DEVECİ ABEY AŞ ensures the confidentiality and protection of employee data.
Processing due to legal obligations
DEVECİ ABEY AŞ may process the personal data of its employees without obtaining further consent if the processing is explicitly stated in the relevant legislation or for the purpose of fulfilling a legal obligation determined by legislation. This is limited to obligations arising from the law.
Actions for the Benefit of Employees
“DEVECİ ABEY AŞ” may process personal data without obtaining consent for transactions that are in the best interest of company employees, such as private health insurance. “DEVECİ ABEY AŞ” may also process employee data for disputes arising from employment relationships.
Processing of sensitive data
According to the law, personal data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, are considered special categories of personal data. DEVECİ ABEY AŞ also takes adequate measures, as determined by the Board, in addition to obtaining the consent of the data subject when processing special categories of personal data. Special categories of personal data can only be processed without the consent of the data subject in cases permitted by law and in a limited manner. The special categories of personal data obtained from our employees to enable them to benefit from insurance and health services are used solely for the specific purpose.
Telecommunications and the internet
The computers, telephones, email addresses, and other applications allocated to employees within the company are provided solely for work purposes. Employees may not use any of these company-provided resources for personal purposes or communication. The company may control and monitor all data on these devices. From the moment they begin work, employees undertake not to store any data or information unrelated to work on the computer, telephones, or other devices allocated to them.
VII. Transfer of personal data within and outside the country
Personal data may be shared by DEVECİ ABEY AŞ with business and solution partners for the purpose of providing the service.
DEVECİ ABEY AŞ may transfer personal data to the following individuals and organizations for specific purposes:
“To a limited extent, in order to ensure the fulfillment of the purposes for which the business partnership was established, DEVECİ ABEY AŞ grants its business partners…”
“To a limited extent, and solely for the purpose of ensuring that our company procures services from suppliers through outsourcing and that these services are necessary for carrying out our company’s commercial activities, DEVECİ ABEY AŞ’s suppliers…”
“Limited to ensuring the conduct of our company’s commercial activities that require the participation of our subsidiaries.”
To the solution partners of DEVECİ ABEY AŞ,
DEVECİ ABEY AŞ has the authority to transfer personal data domestically and internationally, within the conditions determined by the Board in accordance with the law and other conditions in the law, and subject to the consent of the individual.
VIII. Rights of the relevant person
DEVECİ ABEY AŞ acknowledges that, under the law, the data subject has the right to obtain their consent before data processing and, after processing, the right to determine the fate of their data.
By contacting us through the announcement on our website by DEVECİ ABEY AŞ, you can inquire about your personal data;
a) To find out whether your personal data is being processed,
b) Requesting information regarding the processing of personal data,
c) To learn the purpose of processing personal data and whether it is being used appropriately for that purpose.
c) Knowing the third parties to whom personal data is transferred, whether domestically or internationally.
d) Requesting the correction of personal data if it has been processed incompletely or incorrectly.
e) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7,
f) Requesting that the actions taken pursuant to clauses (d) and (e) be notified to third parties to whom personal data has been transferred,
g) The right to object to a result that is detrimental to the individual, arising solely from the analysis of processed data by automated systems.
g) In the event of suffering damages due to the unlawful processing of personal data, the individual has the right to claim compensation for those damages.
However, individuals have no rights regarding anonymized data within the Company. DEVECİ ABEY AŞ may share personal data with relevant institutions and organizations for the purpose of fulfilling a judicial duty or enabling a state authority to exercise its legal powers, as required by business and contractual relationships.
Data subjects may submit their requests regarding the rights mentioned above by completing the application form available on the company’s official website www.stmax.com.tr, signing it with a wet signature, and sending it by registered mail with return receipt to the contact address below, along with photocopies of their identity documents (only the front side photocopy for national identity cards). Your applications will be answered as soon as possible, or within a maximum of 30 days after receipt by our company, depending on the content of your application. Applications must be submitted by registered mail with return receipt. Furthermore, only the part of your application that concerns you will be answered; applications made on behalf of your spouse, relative, or friend will not be accepted. DEVECİ ABEY AŞ may request additional relevant information and documents from applicants.
IX. Privacy Policy
All data held by employees and other individuals at “DEVECİ ABEY AŞ” is confidential. No one may use, copy, reproduce, transfer, or use this data for any purpose other than business purposes without a contract or legal basis.
X. Transaction security
“DEVECİ ABEY AŞ” takes all necessary technical and administrative measures to protect the personal data collected, to prevent it from falling into the hands of unauthorized persons, and to ensure that our customers and prospective customers are not harmed. In this context, we ensure that our software complies with standards, that third parties are carefully selected, and that our data protection policy is adhered to within the company. Security measures are continuously updated and improved.
XI. Audit
DEVECİ ABEY AŞ conducts the necessary internal and external audits regarding the protection of personal data.
XII. Reporting of Violations
DEVECİ ABEY AŞ will take immediate action to remedy any data breach when it is notified of such a breach. It will minimize and compensate for any damage suffered by the data subject. If personal data is accessed by unauthorized persons from outside the organization, it will immediately report the situation to the Personal Data Protection Board.
Applications regarding the reporting of violations can also be made according to the procedures specified on deveciabey.com.
Regarding requests made pursuant to the Personal Data Protection Law
All applications will be processed only if the form on the deveciabey.com website is completed, a photocopy of the ID card is attached, and the form is sent by registered mail to the address provided on the form, as also announced on the website.
Rights regarding personal data can only be exercised in relation to data belonging to the individual themselves. Requests concerning data of individuals other than the person filling out the form and attaching a photocopy of their ID will not be considered. Forms without an attached photocopy of an ID will not be considered. Please note that even when data deletion requests are fulfilled, we are obligated to share data with official authorities if requested by them.