CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

As Arven Pharmaceutical Industry and Trade Inc., Montero Gıda San. ve Tic. A.Ş., Verano Verano İlaç San. ve Tic. A.Ş., Verano Veteriner Ecza Deposu Tic. ve San. A.Ş., and Sanovel İlaç San. ve Tic. A.Ş., (hereinafter referred to as Toksöz Group), we attach great importance to the protection of personal data of all the people who contact us. In this context, we act in our capacity as the “data controller” in accordance with Personal Data Protection Law (“PDPL”) numbered 6698 and process your personal data in accordance with PDPL based on the objectives and limitations mentioned below. We show ultimate attention to taking the required administrative and technical measures accordingly.  Therefore, we would like to inform you about our personal data processing processes and your rights resulting from PDPL through the “Clarification Text on the Processing of Personal Data” (Statement). 

 

On what legal grounds do we collect your personal data?

Your personal data refer to any kind of information and document that you convey us when and/or after you contact us in written and/or orally, and/or in digital media, including your private data. These data are kept physically and digitally. Your personal data may be processed and transferred in Türkiye and abroad by the real persons and legal entities mentioned in this Statement in accordance with the data processing conditions and objectives stated in Articles 5 and 6 of PDPL and in line with the main principles envisaged by the same. 

 

Personal Data Protection and Processing Method

Toksöz Group may automatically or non-automatically collect and process your personal data by using the below-mentioned methods and tools to fulfil its legal responsibilities within the scope of the objectives mentioned in Article III of the Statement and to meet the requirements resulting from the issue for which you contact us.  

While processing your personal data, Toksöz Groups acts in accordance with the Constitution of Turkish Republic, the agreements to which our country is a party, and the data processing principles and responsibilities mentioned in PDPL and other relevant legislation.

 

Objectives of Personal Data Processing

Your personal data are processed within the scope of the objectives mentioned below:

to carry out the required operations resulting from the issue which you contact Toksöz Group for,

to respect the law and/or fulfil legal responsibilities in accordance with the relevant legislation,

to meet the demands of authorized institutions and corporations,

to inform you about the points, events and services about which you demand information,

to copy/back up data to prevent data loss,

to fulfil our legal responsibilities mentioned in the legal legislations and laws,

and for the other purposes mentioned in PDPL.

 

Transfer of personal data in Türkiye and abroad

Your personal data, collected in accordance with the PDPL and the Articles I and II mentioned above, can be transferred to the domestic/foreign companies/organizations and the affiliation companies in which the existing shareholders of Toksöz Group companies will have a share in future, the domestic/foreign companies/organizations associated with Toksöz Group, their business partners, service providers, real and/or legal entity shareholders and authorized public institutions and natural persons in accordance with the main principles in PDPL and personal data  processing objectives and conditions mentioned in Articles 8 and 9 of PDPL. Besides, Toksöz Group works with external companies to render services, such as  IT, cleaning, catering, security, transportation and dressing services. The related companies may sometimes access our company’s programs to offer their services and support our company. Therefore, they may access the personal data under the related programs. In addition, when required by legal responsibilities, your personal data may be transferred to judicial organs and administrative bodies, such as the Social Security Institution.  

 

Period of Personal data processing

Once the reason for us to process your personal data in accordance with Article 7/f.1 of PDPL is removed and/or the period of limitation we are legally given to process your data in line with the legislation, has expired, your data, which have been processed in accordance with PDPL and the objectives mentioned in this Statement, will be deleted, annihilated or anonymised and used accordingly.

The facilities of Toksöz Group, including their gates, corridors, common areas and facades, are viewed through security cameras for occupational health and security purposes. The security camera footage is accessible only by the Security Department of Toksöz Group and related departments. The security footage is protected for a limited period and destroyed in due course.

 

Your rights as data owners in line with PDPL

According to PDPL and the other legislation in force, you are entitled the rights to

learn whether your personal data are processed or not,

demand information about your personal data if processed,

learn why your personal data are processed and check if they are used in line with this objective,

know about the third parties to whom your personal data are transferred in Türkiye or abroad,

ask for correction if your personal data are processed incompletely or incorrectly,

request the deletion or annihilation your personal data within the framework of PDPL [1],

ask that the processes carried out in line with the articles e and f are communicated to the third parties,

object to any result what would turn out to be against you when your processed data are exclusively analysed by automatic systems, and

ask for compensation if you incur any loss because of unlawful data processing.

 

The conditions in which Toksöz Group can process your personal data without your consent in line with PDPL:

Toksöz Group can process your personal data, which it has lawfully collected, without your consent under the following conditions in line with Article 5 of PDPL:

 

When it is clearly prescribed by the laws,

If your consent cannot be taken due to factual impossibilities or if there is no legal validity for your consent or when it is required to process your personal data to protect your or another person’s life or bodily integrity,

When it is required to process the personal data that belong to the contracting parties to set or implement an agreement with the affiliate companies and national/international companies/corporations where the shareholders of the companies under Toksöz Group will have a share in future,

When Toksöz Group is required to fulfil a legal responsibility,

If you have already publicized your personal data,

When it is required to process data to establish, use or protect a right,

When it is required to process data to protect Toksöz Group’s legitimate interests unless your fundamental rights and freedoms are violated.

The ways to apply to Toksöz Group within the scope of your rights:

If you want to use the above-mentioned rights that you have in accordance with Article 11 of PDPL, you can contact Toksöz Group. To do this, please fill out the application form accessible through the link and submit it to us. You can bring the form to İstinye Mahallesi Balabandere Caddesi No:14 34460 Sarıyer/İSTANBUL in person or send it to us with certified mail via notary. Toksöz Group answers the demands at its earliest opportunity or within thirty (30) days at the latest based on the content of your demand. If the action we are to take requires additional costs, we will charge you in accordance with the tariff in PDPL. Apart from this, if there is any change and/or update in your personal data, you can contact us by sending us an e-mail (kisiselveri@toksozgrup.com.tr)  or personally coming to İstinye Mahallesi Balabandere Caddesi No:14 34460 Sarıyer/İSTANBUL.

For your kind attention.

[1] In order for us to meet this demand, it is necessary that the legal reason for processing your personal data is removed, the legal retention time is over or it is time barred. Your demand can be met only in due time.