Data Protection (KVKK)

This Website and Business Communications Information Notice ("Notice") applies to personal data processed in connection with bonnaporcelain.com.tr, contact and quotation forms, Quote List functions, project files, email, telephone and related professional or commercial communications.

Data controller / Veri Sorumlusu:
Otelsan Otel Ekipmanları ve Mimarlık Hizmetleri Anonim Şirketi ("OTELSAN")

Address:
Üçevler Mahallesi, Coşkun Caddesi, İnci Plaza, Kat: 1, Ofis: 10, Nilüfer / Bursa, Türkiye

Telephone: +90 224 250 27 00
Commercial email: export@otelsan.com.tr
Privacy / KVKK: info@otelsan.com.tr
Tax registration: Çekirge Tax Office · Tax No. 6491061135

Personal data may be collected wholly or partly by automated means through website contact and quotation forms, Quote List functions, project-file uploads, cookies and similar technologies, consent-preference tools, server/security infrastructure, email systems and external resources used by bonnaporcelain.com.tr.

Data may also be processed by non-automated means where information obtained through telephone calls, correspondence, quotations, project documents, logistics processes or other business communications becomes part of a data-recording system.

Information is generally obtained directly from the data subject. Where relevant and lawful, it may also be received from the organisation or authorised representative on whose behalf the person communicates, commercial partners involved in a project or legitimate publicly available business sources.

The processing condition applicable to each activity is assessed according to its purpose and circumstances. OTELSAN does not treat explicit consent as a general or default basis for all processing.

OTELSAN does not ordinarily request special-category personal data through general website contact, Quote List or quotation forms.

Special categories under Article 6 of the KVKK include data concerning race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing and appearance, association, foundation or trade-union membership, health, sexual life, criminal convictions and security measures, biometric data and genetic data.

Visitors should not submit such information through ordinary website forms or project attachments unless OTELSAN has specifically requested the information for a lawful and necessary purpose.

If special-category personal data is exceptionally processed, OTELSAN must apply an appropriate processing condition under Article 6 and the additional administrative and technical measures required by applicable law.

Personal data may be transferred only to the extent necessary for an applicable purpose and lawful basis. Depending on the relevant activity, recipient groups may include:

Certain website and business activities may involve technical infrastructure or recipients located outside Türkiye.

In the current technical review of bonnaporcelain.com.tr, the tested homepage made a request to Google-hosted font infrastructure before an optional cookie preference was submitted. In addition, the Corporate export-network feature loads an externally hosted D3.js resource from d3js.org. These browser connections may transmit technical connection information, including IP address and browser/device information, to external infrastructure.

International transfers may also arise where an overseas supplier, distributor, logistics provider, project partner or other recipient must receive information in connection with a specific international business request or commercial transaction.

Transfers falling within Article 9 of the KVKK must be carried out only where a transfer mechanism permitted by the law is available. Depending on the circumstances, this may include an adequacy decision, an appropriate safeguard such as an applicable standard contract, another recognised safeguard, or a statutory exceptional transfer mechanism where its specific conditions are met.

Where explicit consent is legally relied upon for a specific transfer, that consent must be obtained separately and cannot be inferred merely from visiting bonnaporcelain.com.tr, acknowledging this Notice or submitting an unrelated website form.

Personal data is retained only for the period necessary for the relevant processing purpose and for any period required by applicable law.

When establishing an appropriate retention period, OTELSAN may consider the duration of an enquiry, quotation, project or customer relationship; applicable accounting, tax, commercial and customs obligations; warranty or claim periods; limitation periods; information-security requirements; and legal preservation obligations.

When the reasons requiring processing cease to exist, personal data is deleted, destroyed or anonymised in accordance with the KVKK, applicable secondary legislation and the relevant OTELSAN procedures.

Backup or archival copies, where used, should be handled through the applicable retention lifecycle and removed or overwritten in accordance with technical procedures unless continued preservation is legally required.

OTELSAN applies administrative and technical measures appropriate to the nature of the relevant processing activity and associated risk.

Depending on the applicable system, measures may include access restrictions, authentication, secure transmission, software and security updates, backups, service-provider controls, confidentiality obligations and incident handling.

Website forms, uploaded project files and technical logs may contain personal data. Such information should not be exposed through publicly accessible or unrestricted logs, and access should be limited to authorised persons or service providers that require it for the relevant operational, security or legal purpose.

The exact logging, storage and retention configuration of the website, hosting environment, mail systems and security tools must remain subject to periodic technical review.

Subject to the conditions of applicable law, data subjects may apply to OTELSAN in order to:

1. learn whether their personal data is being processed;
2. request information where their personal data has been processed;
3. learn the purpose of processing and whether data is used in accordance with that purpose;
4. learn the third parties in Türkiye or abroad to whom personal data has been transferred;
5. request correction of incomplete or inaccurate personal data;
6. request deletion or destruction of personal data where the conditions under Article 7 are met;
7. request notification of correction, deletion or destruction operations to relevant third parties;
8. object to a result arising against the individual through analysis of processed data exclusively by automated systems; and
9. claim compensation where damage has arisen from unlawful processing of personal data.

Applications concerning Article 11 rights should be made in Turkish and in accordance with the KVKK and the Communiqué on the Procedures and Principles of Application to the Data Controller.

Written application

A signed written application may be delivered personally or sent by post/courier to:

Otelsan Otel Ekipmanları ve Mimarlık Hizmetleri Anonim Şirketi
Üçevler Mahallesi, Coşkun Caddesi, İnci Plaza, Kat: 1, Ofis: 10, Nilüfer / Bursa, Türkiye

The envelope may be marked "KVKK İlgili Kişi Başvurusu" to facilitate appropriate routing.

Application by an email address already registered with OTELSAN

An application may be sent to info@otelsan.com.tr from an email address previously notified by the applicant to OTELSAN and already registered in OTELSAN's systems. The subject line may state "KVKK İlgili Kişi Başvurusu".

Other methods recognised by legislation

The applicant may also use KEP, secure electronic signature, mobile signature or another application method recognised under the applicable legislation where the necessary receiving infrastructure is available.

Information required in the application

The application should contain the information required by the applicable rules, including:

• name and surname;
• signature where the application is made in writing;
• Turkish identity number for Turkish citizens;
• nationality and passport number or, where applicable, foreign identity number for foreign applicants;
• address for notification;
• email address, telephone and fax number, where available;
• a clear description of the request; and
• supporting information and documents, where relevant.

OTELSAN will respond to a valid application according to the nature of the request as soon as possible and in any event within no more than thirty days.

Applications are generally handled free of charge. If fulfilment of a request generates an additional cost, a fee may be charged only where permitted under the tariff determined by the Personal Data Protection Board.

If an application to OTELSAN is rejected, the response is considered insufficient, or no response is provided within the statutory period, the data subject may lodge a complaint with the Personal Data Protection Board in accordance with Article 14 of the KVKK.

The complaint must generally be submitted within thirty days from the date on which the data subject learns of OTELSAN's response and, in all circumstances, within sixty days from the date of the original application to the data controller.

The application procedure to the data controller must be completed before a complaint is submitted to the Board, except where mandatory law provides otherwise.

This KVKK Notice is intended to inform data subjects about processing activities. Reading, receiving or acknowledging this Notice does not constitute explicit consent.

The current contact-form acknowledgement that refers to the Privacy Policy and KVKK Notice is treated as confirmation that the relevant information has been presented and read. It is not treated as blanket consent for unrelated marketing, optional cookies, profiling or international transfers.

Where OTELSAN requires explicit consent as the legal basis for a specific processing activity, the consent request must be presented separately, identify the specific processing concerned and allow the individual to make a freely given choice.

Refusing or withdrawing consent should not prevent unrelated website or business functions that can lawfully operate without that consent.

OTELSAN may revise this Notice where bonnaporcelain.com.tr, its forms, Quote List functions, service providers, processing activities, legal grounds, international-transfer arrangements or applicable legislation materially change.

The current version and revision date are shown at the top of this page.

A new or materially different processing activity should be reflected in the relevant information notice at or before the point at which personal data is collected.