CORPORATE GENERAL PRIVACY NOTICE | Libart International

As Libart Proje ve Uygulama Sanayi ve Ticaret Anonim Şirketi acting as the data controller, we have prepared this Corporate General Privacy Notice to inform our online visitors, website users, customers, and our suppliers' authorized representatives and employees about the processing, storage, and transfer of your personal data within the scope of our activities arising from Law No. 6698 on the Protection of Personal Data (Kişisel Verilerin Korunması Kanunu, "KVKK") and the relevant legislation and regulations.

What Are the Categories of Your Personal Data We Process and For What Purposes Do We Process Them?

Your personal information may be processed by Libart Proje ve Uygulama Sanayi ve Ticaret Anonim Şirketi in accordance with the principles set forth in Article 4.2 of KVKK:

Being in compliance with the law and the rules of good faith,
Being accurate and, where necessary, kept up to date,
Being processed for specified, explicit, and legitimate purposes,
Being relevant, limited, and proportionate to the purposes for which they are processed,
Being retained for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed,

within the scope of our established and ongoing business relationships with our business partners (a person may fall into more than one category), for the purposes specified below.

For Employees;

Data Categories	Examples of Data Types Processed in This Category
Identity Data	Your first name, last name, Turkish ID number, date of birth, place of birth, gender, marital status, copy of your identity card, signature etc.
Contact Data	Your phone number, full address, email address, contact information for the person you want us to reach in case of an emergency,
Location Data	Location records from tracking systems installed in company vehicles
Personnel Data	Your resume, military discharge certificate, financial and salary details, bank account information, insurance enrollment/retirement information etc.
Legal Transaction Data	Your information in correspondence with judicial authorities, Your information in the case file
Physical Location Security Data	Your security camera recordings,
Transaction Security Data	Your IP address information, website entry and exit information, etc.,
Professional Experience Data	Your educational background, diplomas, certificates, training received, skills, courses taken, copy of your driver's license etc.
Visual and Audio Recordings	Visual and audio recordings you share with our company
Health Data	Your detailed health information

your personal data may be processed for the following purposes.

Fulfillment of Employment Contract and Statutory Obligations for Employees
Implementation of Employee Benefits and Perks Processes
Implementation of Emergency Management Processes
Implementation of Communication Activities
Monitoring and Implementation of Legal Affairs
Implementation of Employee Benefits and Perks Processes
Implementation of Audit/Ethics Activities
Implementation of Training Activities
Implementation of Activities in Compliance with Legislation
Implementation of Finance and Accounting Affairs
Implementation of Assignment Processes
Planning of Human Resources Processes
Implementation/Audit of Business Activities
Implementation of Occupational Health and Safety Activities
Implementation of Performance Evaluation Processes
Ensuring the Security of Data Controller Operations
Implementation of Storage and Archiving Activities
Providing Information to Authorized Persons, Institutions, and Organizations
Ensuring customer satisfaction and transaction security,
Being able to carry out the necessary work by our relevant business units and execute the related business processes in order to carry out the commercial activities performed,
Being able to plan and implement commercial and/or business strategies, and carry out finance and accounting tasks,
Ensuring your physical and mental safety (e.g., ensuring occupational health and safety), the safety of our company, and taking the necessary administrative and technical measures in this regard,
Ensuring the legal, technical, and commercial security of individuals associated with companies with which we enter into any kind of business relationship,
Verifying your identity information and documents when necessary; taking necessary actions to prevent fraud, loss, and deception,
To be able to store your information that must be retained in accordance with relevant legislation; to be able to copy and back up your information to prevent information loss; to be able to ensure the consistency of your information; to be able to take the necessary technical and administrative measures for the security of your information,
To fulfill our legal obligations required or mandated by regulatory and supervisory authorities, to conduct legal proceedings and legal processes,

Employee candidate;

Data Categories	Examples of Data Types Processed in This Category
Identity Data	Your first name, last name, date of birth, place of birth, gender, marital status etc.
Contact Data	Your phone number, your full address, your email address etc.
Personnel Data	Your CV’s, military status information etc.
Legal Transaction Data	Your information in correspondence with judicial authorities, Your information in the case file.
Physical Location Security Data	Your security camera footage if you visit our company buildings
Transaction Security Data	Your IP address information, website entry and exit information, etc., will be collected when you visit our company building.
Professional Experience Data	Information about your work experience, educational background, diplomas, certificates, training received, skills, driver's license information etc.
Visual and Audio Recordings	Visual and audio recordings you share with our company
Health Data	Your chronic illness and disability status information

your personal data may be processed for the following purposes.

Conducting Employee Candidate / Intern / Student Selection and Placement Processes
Conducting the Application Process for Job Candidates
Conducting Communication Activities
Planning of Human Resources Processes
Monitoring and Execution of Legal Affairs
Conducting Activities in Compliance with Legislation
Ensuring Physical Location Security
Conducting Storage and Archiving Activities

Visitors;

Data Categories	Examples of Data Types Processed in This Category
Identity Data	Your name and surname
Contact Data	Your phone number and email address, if you share them with our company
Physical Location Security Data	Your security camera recordings if you visit our company addresses, Your vehicle's license plate information etc.

your personal data may be processed for the following purposes.

Management of Emergency Situations
Conducting Activities in Compliance with Legislation
Ensuring Physical Premises Security
Conducting Communication Activities
Conducting/Monitoring Business Activities
Conducting Storage and Archiving Activities
Ensuring the Security of Data Controller Operations
Providing Information to Authorized Persons, Institutions, and Organizations
Creating and Tracking Visitor Records

For Online Visitors;

Data Categories	Examples of Data Types Processed in This Category
Identity Data	Your name and surname if you submit a comment via the “Contact Us”, “Service Request” and “Request Form” button,
Contact Data	Your e-mail address shared via the “Contact Us”, “Service Request” and “Request Form” button if you submit a comment
Professional Experience Data	Your professional information shared via the “Request form”
Marketing Data	Purchase history information, surveys, cookie records, information obtained through campaign activities, etc.

your personal data may be processed for the following purposes.

Management of Emergency Situations
Conducting Activities in Compliance with Legislation
Management of Company/Product/Service Loyalty Processes
Conducting Communication Activities
Management of Customer Relationship Processes
Conducting Storage and Archiving Activities
Tracking Requests/Complaints
Ensuring the Security of Data Controller Operations
Providing Information to Authorized Persons, Institutions, and Organizations
Creating and Tracking Visitor Records

Customers;

The authorized representatives and/or employees of our individual customers or corporate customers;

Data Categories	Examples of Data Types Processed in This Category
Identity Data	Your name, surname, signatures
Contact Data	Your phone number, e-mail address, address,
Physical Location Security Data	Your security camera recordings if you visit our company addresses, Your vehicle's license plate information etc.
Legal Transaction Data	Your information in correspondence with judicial authorities, Your information in the case file.
Customer Transaction Data	Call center records, Invoice, promissory note, check information, Information on cashier receipts, Order information, Request information, etc.
Professional Experience Data	Information about your work experience, educational background, information etc. you share with our company
Marketing Data	Purchase history information, surveys, cookie records, information obtained through campaign activities, etc.
Visual and Audio Recordings	Visual and audio recordings you share with our company
Transaction Security Data	Your IP address information, website entry and exit information, etc., will be collected when you visit our company building.

Your personal data may be processed for the following purposes.

Ensuring activities are conducted in compliance with regulations,
Conducting finance and accounting operations,
Conducting/monitoring business activities,
Conducting logistics activities,
Conducting post-sales support services for goods/services,
Execution of goods/services sales processes,
Execution of marketing analysis studies,
Execution of contract processes,
Provision of information to authorized persons, institutions, and organizations,
Ensuring physical premises security,
Execution of the Remuneration Policy
Resolving legal disputes,
Carrying out storage and archiving activities,
Carrying out loyalty processes related to the company/product/service,
Carrying out communication activities.

For Our Supplier Representatives and Supplier Employees;

The personal data of our suppliers' authorized representatives and employees:

Data Categories	Examples of Data Types Processed in This Category
Identity Data	Your name, surname, Turkish ID Number
Contact Data	Your phone number, full address, e-mail address
Physical Location Security Data	Your security camera recordings if you visit our company addresses, Your vehicle's license plate information etc.
Legal Transaction Data	Information in correspondence with judicial authorities, information in case files, etc.
Professional Experience Data	Information about your work experience, educational status, diplomas, etc.
Visual and Audio Recordings	Visual and audio recordings you share with our company
Transaction Security Data	Your IP address information, website entry and exit information, etc., will be collected when you visit our company building.

Your personal data may be processed for the following purposes.

Conducting communication activities,
Conducting/monitoring business activities,
Ensuring physical space security,
Conducting supply chain management processes,
Conducting activities in compliance with legislation,
Conducting occupational health/safety activities
Conducting storage and archiving activities,
Conducting Contract Processes
Providing Information to Authorized Persons, Institutions, and Organizations
Creating and Tracking Visitor Records
Execution of goods/services procurement processes,
Execution of finance and accounting tasks,
Follow-up and execution of legal tasks,
Ensuring the security of our company and the physical security of our premises and providing administrative and technical measures related to these,
Performing necessary procedures to prevent fraud, loss, and deception,
Retaining your information as required by relevant legislation,
Performing copying and backup operations to prevent information loss,
To take the necessary technical and administrative measures for the security of your information,
To fulfill our legal obligations required or mandated by legal regulations to regulatory and supervisory authorities, and to conduct legal proceedings and legal processes, your information will be processed, recorded, stored, preserved, and classified.

What Are the Collection Methods for Your Personal Data?

Your personal data specified in the categories above;

Through physical means such as contracts,
Through information systems and electronic devices (e.g., telecommunications infrastructure, computers, and phones),
Servers,
Our website,
Through other documents declared by the data subject

are collected through automated or non-automated means.

What Is the Legal Basis for the Collection of Your Personal Data?

Your personal data is processed by Libart Proje ve Uygulama Sanayi ve Ticaret Anonim Şirketi based on the legal grounds listed below and stipulated in Article 5 of KVKK for the realization of the purposes explained above:

Being explicitly prescribed by law,
Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract,
It is mandatory for the data controller to fulfill its legal obligation,
Data processing is mandatory for the establishment, exercise, or protection of a right,
Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject

Do We Transfer Your Personal Data to Third Parties?

For Employees;

To natural persons or private law legal entities (to organizations from which we receive legal and financial advisory services),
To our subsidiaries and associated companies
To the banks, consulting firms, and insurance companies with which our company has agreements
To authorized public institutions and organizations
Customers
Our suppliers
To law enforcement and judicial authorities within the scope of the purposes specified above and upon request as required by the relevant legislation.

For Employee candidate

Your personal data may be transferred to judicial authorities or relevant law enforcement agencies in the event of legal disputes or upon request in accordance with applicable legislation.

For Visitors:

Your personal data may be transferred to judicial authorities or relevant law enforcement agencies in the event of legal disputes or upon request in accordance with applicable legislation.

For Online Visitors:

Your personal data may be transferred to judicial authorities or relevant law enforcement agencies in the event of legal disputes or upon request in accordance with applicable legislation.

For Customers:

To natural persons or private law legal entities (to organizations from which we receive legal and financial advisory services),
To our subsidiaries and associated companies
To authorized public institutions and organizations
Our suppliers
To law enforcement and judicial authorities within the scope of the purposes specified above and upon request as required by the relevant legislation.

For Our Supplier Representatives and Supplier Employees:

To natural persons or private law legal entities (to organizations from which we receive legal and financial advisory services),
To our subsidiaries and associated companies
To authorized public institutions and organizations
Customers
Our suppliers
To law enforcement and judicial authorities within the scope of the purposes specified above and upon request as required by the relevant legislation.

Do We Transfer Your Personal Data Abroad?

Libart Proje ve Uygulama Sanayi ve Ticaret Anonim Şirketi, provides backup services through a service provider whose servers are located abroad. Personal data processed by our company, including identity, communication, legal transactions, customer transactions, transaction security, professional experience, marketing, and visual and audio recordings, are also backed up by this service provider. While no special category personal data is transferred abroad, the relevant legislation is followed regarding the personal data transferred, and legal protocols are established with the service provider regarding the transfer and storage of personal data.

How Can You Exercise Your Rights Regarding Your Personal Data?

You may submit your requests within the scope of Article 11 of KVKK, which regulates the rights of the data subject, to us through the "Data Controller Application Form" prepared for your convenience in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller available on “https://www.libart.com/” belonging to Libart Proje ve Uygulama Sanayi ve Ticaret Anonim Şirketi

Data Controller: Libart Proje ve Uygulama Sanayi ve Ticaret Anonim Şirketi

Adress: Beylikdüzü OSB Mah. 2. Cad. No: 8/1 Beylikdüzü/İstanbul

E-mail: [email protected]

Kep adress: [email protected]

This document has been prepared within the scope of KVKK Compliance Consultancy