PERSONAL DATA PROTECTION POLICY
This policy aims to explain the principles for the processing of personal data that should be known by natural persons, whose personal data we process, such as the suppliers, visitors, and users of websites (https://huqqa.com, https://themarketbosphorus.com, https://qurabiye.com) of HUQQA GIDA ISLETMELERI SAN. ve TIC. A.S. (hereinafter referred to as “HUQQA”).
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Definitions
Within the scope of this policy, the following terms have the following meanings:
HUQQA: refers to HUQQA GIDA ISLETMELERI SAN. ve TIC. A.S.,
Concerned person/natural person: refers to personal data subject,
Recording medium: refers to all kinds of medium where personal data processed fully or partially through automatic means or provided that the process is a part of any data registry system through non-automatic mean are kept,
Site: refers to the websites at the addresses https://huqqa.com, https://themarketbosphorus.com and/or https://qurabiye.com,
Data Processor: refers to the natural person or legal entity who processes the personal data on behalf of the data controller, with the authorization given by the data controller,
Data Controller: refers to the natural person or legal entity who/that determines the purpose and means of processing the personal data and is responsible for establishing and managing the data registry system.
Law No. 5651: refers to the Law on Regulation of Publications on the Internet and Suppression of Crimes Committed through Such Publication,
Law No. 6698/KVKK: refers to the Law on Personal Data Protection,
II. Obtaining and Processing of Your Personal Data
1. Processing of Personal Data of the Website Users (Online Visitor), WIFI Service Users, and Call Center Users
1.1. Processing of Personal Data of the Website Users (Online Visitor)
To make requests and suggestions, the users who use the website can fill out the form on the ‘’Contact’’ page at the links https://huqqa.com, https://themarketbosphorus.com and/or https://qurabiye.com and then, send the data such as name, surname, e-mail, phone, gender, date of birth, address, message, sector, and subject of the form.
The users accept that they share this data with the Site with their free will entirely and that this data is only requested to evaluate the requests and suggestions they send.
Furthermore, the traffic information of the users visiting the Website is processed per Law No. 5651.
1.2. Processing of Personal Data of the WIFI Service Users
To render this service and to comply with Law No. 5651 and the relevant Secondary legislation, it processes the mobile phone number and traffic information of the visitors who visit the premise of HUQQA physically and want to use the WIFI.
1.3. Processing of Personal Data of the Call Center Users
The personal data belonging to users, who call HUQQA, are collected and retained by it.
Personal data such as name, surname, phone, and e-mail address are collected from users who call HUQQA. These data are processed to conduct necessary works to benefit you from the products and services offered by our company and carry out the relevant business processes, to plan and execute activities necessary for suggesting and promoting the products and services offered by the company through customizing them according to your tastes, usage habits, and needs, to conduct necessary works by our relevant business units and relevant business processes to carry out commercial activities by the company, to plan and execute the commercial and/or business strategies of our company and to ensure legal, strategic and commercial job safety of our company and the concerned persons who have a business relationship with our company.
Your personal data that you have shared by calling HUQQA are collected and retained by our company to put your requests, suggestions, and complaints into the process, inform you about the result of the transaction and develop the services and products offered in this context.
2. Processing of Personal Data Within Procurement Processes:
HUQQA processes the personal data of the natural person suppliers, supplier employees and/or supplier officer and the natural persons, legal entity employees, and/or officers to whom product, service, or good is supplied by HUQQA, to follow up and execute the product, service or good procurement processes.
2.1. Personal data processed within procurement processes
HUQQA processes the following personal data within the scope of procurement processes:
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Identity information such as name, surname, T.R. identity number concerning natural person supplier and/or purchaser; financial information such as bank details; contact information such as an address, e-mail, mobile phone and personal data of special nature such as photos and signatures in documents such as the statements of signature, circulars, etc.
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Identity information such as name, surname, T.R. identity number concerning supplier and/or purchaser officer; personal data of special nature such as photos and signatures in documents such as the power of attorney/circulars, etc.; contact information such as an address, e-mail, mobile phone,
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Identity information such as name, surname, T.R. identity number concerning supplier and/or purchaser employee; personal information such as SSI payroll, OHS documents; personal data of special nature such as a medical report, criminal record; educational/professional experience and experience information such as educational background, certificates; financial information such as bank details; contact information such as an address, e-mail, mobile phone.
2.2. Purpose of Personal Data Processing Within Procurement Processes
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To fulfill the obligations arising from the legislation such as the Occupational Health and Safety Law, SSI, Labor Law, Turkish Code of Commerce, Tax Procedural Law,
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To follow up and execute the contract processes related to the procurement of goods, products, or services,
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To ensure compliance with corporate company rules.
2.3. Modes of Collection and Processing of Personal Data of the Supplier and/or Purchaser
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Supplier and/or purchaser officer, supplier and/or purchaser employee, or natural person supplier and/or purchaser itself,
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Documents such as Circular/Power of Attorney,
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Communication channels such as e-mail, phone, website,
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Contract,
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Reference Control Sheet.
3. Processing of Personal Data of Physical Visitors
3.1. Processed personal data of natural persons who visit HUQQA premise physically
HUQQA records images with cameras inside and outside the building to ensure the safety of its employees and visitors. The visitors are notified about the recording with the camera inside the building.
3.2. Personal Data of Natural Persons Who Visit Restaurants Physically
HUQQA processes the following personal data of special nature belonging to natural persons visiting restaurants;
HUQQA records images with cameras inside and outside the building to ensure the safety of its employees and visitors. The visitors are notified about the recording with the camera inside the building.
3.3. Purpose of Processing Personal Data of Visitors
HUQQA processes the personal data of people who visit the headquarters of HUQQA for the following purposes:
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To ensure the venue security
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To get identity information and documents per the applicable legislation,
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To give a visitor entrance card and create a visitor number,
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To keep records of visit entry and exit times,
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To create a gun delivery report for visitors who come with guns,
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To share the interior and exterior sketch of the building and necessary safety information with the visitor card.
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To plan and execute emergency management processes (terrorism, fire),
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To conduct security checks of people/products coming to the building,
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To inform the law enforcement in case of crime or illegality,
HUQQA processes the personal data of the people visiting the restaurants for the following purposes;
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To confirm and plan the reservations,
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To ensure the issuance of invoices,
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To ensure the security
3.3. Modes of Collection and Processing of Personal Data of Visitors
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Official identity documents of the visitor (such as T.R. ID, driving license, passport, lawyer identity card)
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Record images taken with CCTV,
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Reservation requests made via phone, QFB applications,
3.4. Providing the Security of Visitors’ Personal Data and Sharing Personal Data
Both the identity information of the visitors and the CCTV records are retained in systems only accessible by authorized persons. Upon request, these personal data can be shared with public institutions and organizations that are legally authorized to request such data.
4. Processing of Personal Data of Social Responsibility Project Participants and Training Participants
4.1. The personal data of project associates, project participants, and training participants (such as volunteer workers, parents, students) who/that take a role in the social responsibility projects and training organized by HUQQA are as follows:
4.2. Purpose of Processing of Personal Data of Project Associates, Project Participants, and Training Participants
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To raise the recognition of the company,
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To create social benefit and awareness,
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To plan and conduct corporate communication activities,
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Event management,
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To plan and carry out social responsibility and/or civil society activities,
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To plan and carry out sponsorship activities,
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To fulfill legal obligations of the company
4.3. Methods of Collection and Processing of Personal Data of Project Associates, Project Participants, and Training Participants
These personal data are obtained from the Project Associates and/or project participants and/or training participants themselves on a project and training basis.
III. Security and Transfer of Your Personal Data and Exercising Your Rights Related to Your Personal Data
All personal information that you have shared with us will be kept confidential in the database at HUQQA per the Art. 12 of Law No. 6698 on Protection of Personal Data and will not be shared with the third parties for commercial purposes.
HUQQA takes the following measures as a minimum to provide the security of the personal data it processes, to prevent unlawful access to them, and to prevent illegal data processing:
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It takes hash, encryption, transaction log, access management, and physical security measures to ensure that information systems storing personal data are protected against unauthorized access and illegal data processing.
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The website and all systems storing personal data are protected by a network firewall.
HUQQA stores personal data concerning online and physical visitors per the legislation and shares them with relevant public institutions and organizations upon request. The personal data concerning suppliers and/or purchasers can be shared with companies and affiliates within the body of HUQQA as well as the relevant public institutions regarding the goods, products, or services supplied. The personal data concerning participants and/or project associates of social responsibility projects organized by HUQQA can be shared in written, visual and social media with the explicit consent of the concerned person.
The rights that you have concerning your personal data you have shared within the scope of the purposes specified in this Personal Data Protection Policy and the modes of processing of the personal data per Art. 11 of Law No. 6698 are as follows:
a) to learn whether his/her personal data are processed or not,
b) to request information if his/her personal data are processed,
c) to learn the purpose of his/her data processing and whether this data is used for intended purposes,
ç) to know the third parties to whom his/her personal data is transferred at home or abroad,
d) to request the rectification of the incomplete or inaccurate data, if any,
e) to request the erasure or destruction of his/her personal data if the conditions requiring processing are no longer available although they have been processed per Law No. 6698 and other relevant provisions,
f) to request notification of the operations carried out in compliance with subparagraphs (d) and (e) to third parties to whom his/her personal data has been transferred,
g) to object to the processing, exclusively by automatic means, of his/her personal data, which leads to an unfavorable consequence for the data subject,
ğ) to request compensation for the damage arising from the unlawful processing of his/her personal data.
To exercise these rights, you can contact us using the ‘’Application Form’’ on our website through the methods specified in this form at any time.
IV. Retaining Your Personal Data Accurate and Up-to-Date
The relevant groups of the persons, whose personal data we process, accept and declare to be aware that accuracy and up-to-dateness of personal data they share through Website and/or they submit personally due to a contractual relationship are important to exercise the rights on their personal data under the KVKK and other relevant legislation and that they assume the entire responsibility of giving wrong information.
V. Personal Data Retention Period
The period for retaining the personal data of online visitors is 2 years per Law No. 5651. The period for retaining the CCTV records of physical visitors is 90 days. The personal data concerning identity information are retained within the framework of the periods stipulated in the relevant legislation. The personal data concerning suppliers and/or purchasers are retained for 10 years per the legislation following the termination of the legal relationship.
VI. Erasure, Destruction, or Anonymization of Your Personal Data
Your personal data processed for the purposes specified in this Personal Data Protection Policy will be anonymized and continued to be used by us when the purposes requiring processing are no longer available under Art. 7/f.1 of Law No. 6698, and the periods determined by the Law have expired per the Art. 17 of this Law and the Art. 138 of the Turkish Penal Code.
When the retention periods stipulated in the relevant legislation or required for processing have expired, HUQQA anonymizes the personal data it has processed by using one or several techniques specified in the Guide on the Erasure, Destruction or Anonymization of Personal Data published by the Personal Data Protection Board within 6-month period foreseen for the periodic destruction per its business processes and activities, and thus, continues to use these data in this way.
VII. Categorization of Personal Data
Concerned Person Groups
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Data Category
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Online visitors and WIFI Service Users, Call Center Users
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Identity Data, Communication Data, Legal Transaction Data
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Natural Person Supplier and/or Supplier, Supplier and/or Supplier Officer, Supplier and/or Supplier Employee
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Identity Data, Communication Data, Legal Transaction Data, Financial Data, Corporate Identity Data, Visual and Audio Data, Private Personal Data, Personnel Data
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Physical Visitor
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Identity Data, Visual and Audio Data
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Project Associate, Project Participant, Training Participant
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Identity Data, Communication Data, Audio-Visual Data, Financial Data, Education Data
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VIII. Amendments and Updates to the Policy
HUQQA may make amendments or updates to this Policy in line with the legal legislation and Company Policy. The concerned persons are notified about the new Policy text reflecting all these amendments and updates on the website.