Privacy Policy

DISCLOSURE TEXT WITHIN THE SCOPE OF THE PERSONAL DATA PROTECTION LAW NO. 6698

Dear Customer,

As Altium International Laboratuvar Cihazları A.Ş., we respect and value the privacy of personal life. Therefore, we would like to inform you about your rights regarding the use and protection of your personal data within the scope of the Personal Data Protection Law No. 6698 (hereinafter referred to as “PDPL”).

DEFINITIONS

Explicit Consent	Refers to the consent that is based on being informed about a specific subject and given freely with the individual’s free will.
Company	Refers to Altium International Laboratuvar Cihazları A.Ş., located at Barbaros Mahallesi Temmuz Sokak No:6 34746 Ataşehir / Istanbul.
Cookie	Small files stored on users’ computers or mobile devices that help save preferences and other information on the web pages they visit.
Relevant User	Individuals who process personal data within the data controller’s organization, under the authorization and instruction of the data controller, excluding those responsible for the technical storage, protection, and backup of the data.
Destruction	Refers to the deletion, destruction, or anonymization of personal data.
Contact Person	The natural person notified by the data controller at the time of registration with the Registry, responsible for communication with the Authority regarding the obligations under the Law and its secondary regulations, for legal entities based in Turkey or representatives of foreign data controllers. (The Contact Person is not authorized to represent the Data Controller. As the name implies, they are only responsible for facilitating communication between the data controller, data subjects, and the Authority.)
Law/KVKK	The Law on the Protection of Personal Data No. 6698, published in the Official Gazette dated April 7, 2016, and numbered 29677, enacted on March 24, 2016.
Recording Medium	Any environment where personal data is processed, whether partially or fully automatic or manually, as part of a data recording system.
Personal Data	Any information relating to an identified or identifiable natural person.
Processing of Personal Data	Any operation performed on personal data, whether fully or partially automated or non-automated, as part of a data recording system, such as collection, recording, storage, preservation, modification, rearrangement, disclosure, transfer, acquisition, making available, classification, or prevention of use.
Anonymization of Personal Data	Rendering personal data unidentifiable with an identified or identifiable natural person, even when matched with other data.
Deletion of Personal Data	Making personal data inaccessible and unusable by Relevant Users in any way.
Destruction of Personal Data	Making personal data inaccessible, unrecoverable, and unusable by anyone in any way.
Board	The Personal Data Protection Board.
Sensitive Personal Data	Data relating to race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dress, membership in associations, foundations, or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data.
Periodic Destruction	The act of deletion, destruction, or anonymization of personal data at recurring intervals, as specified in the data retention and destruction policy, when all processing conditions are no longer met.
Policy	The personal data protection policy established by the Company.
Data Processor	A natural or legal person who processes personal data on behalf of the data controller, based on the controller’s authorization.
Data Recording System	A recording system in which personal data is processed by being structured according to specific criteria.
Data Subject / Relevant Person	The natural person whose personal data is processed.
Data Controller	The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.
Source:	Law No. 6698 on the Protection of Personal Data Regulation on the Deletion, Destruction, or Anonymization of Personal Data Regulation on the Data Controllers’ Registry Communiqué on the Principles and Procedures to be Followed in Fulfillment of the Obligation to Inform Communiqué on the Principles and Procedures for Application to the Data Controller

a) Data Controller

As stated in this Clarification Text, the Company is the data controller within the scope of the Law on the Protection of Personal Data (KVKK).

Data Controller Information

Full Name: Altium International Laboratuvar Cihazları A.Ş.

Short Name: Company

Address: Barbaros Mahallesi Temmuz Sokak No:6 34746 Ataşehir / İstanbul

Website: https://altium.net/tr

b) Purposes and Legal Grounds for Processing Personal Data

Your collected personal data may be processed for the following purposes and based on the relevant legal grounds:

Carrying out the necessary activities by our business units to enable you to benefit from the products and services offered, and executing the related business processes;
Planning and execution of product and service sales processes;
Planning and execution of customer relationship management processes;
Carrying out activities aimed at ensuring customer satisfaction;
Following up contract processes and legal claims;
Execution of after-sales support services;
Collecting and evaluating complaints and suggestions, if any, to improve our service quality as a company, and carrying out related communication activities;
Ensuring that activities are carried out in accordance with the relevant legislation;
Execution of financial and accounting processes;
Execution of logistics operations;
Execution of emergency management processes;
Execution of information security processes;
Providing information to authorized persons, institutions, and organizations.

In accordance with Article 5(2) of the Law on the Protection of Personal Data (KVKK), personal data may be processed without the explicit consent of the data subject if one of the following conditions exists:

It is expressly provided for by law.
It is necessary for the protection of life or physical integrity of the person who is unable to give consent due to actual impossibility or whose consent is not legally valid.
It is necessary to process the personal data of the parties to a contract, provided that it is directly related to the establishment or performance of the contract.
It is necessary for the data controller to fulfill its legal obligation.
The data has been made public by the data subject.
It is necessary for the establishment, exercise, or protection of a right.
Provided that it does not harm the fundamental rights and freedoms of the data subject, it is necessary for the legitimate interests of the data controller.

Your personal data in the categories of identity, contact, professional experience, marketing, and location will be processed based on your explicit consent for the following purposes: measuring customer satisfaction; planning and execution of product and service marketing processes; conducting profiling and analysis activities; customizing and promoting the offered products and services according to your preferences, usage habits, and needs; and sending commercial electronic messages such as advertisements and promotions to the contact information you have shared with your consent. These data may also be shared with our suppliers and international business partners for these purposes.

Your personal data in the categories of identity, professional experience, and contact information will be shared with our international business partners based on your explicit consent for the purposes of executing and supervising business activities within the scope of the distributorship agreement, conducting customer satisfaction efforts, executing contract processes, and providing after-sales support services.

c) Method of Collecting Personal Data

Your personal data will be collected for the purposes stated in paragraph (b) of this text, based on the legal grounds specified in Articles 5(2) and 6 of the Law on the Protection of Personal Data (KVKK), through automatic or non-automatic means, directly from you or through our business partners, and in verbal, written, or electronic formats.

d) Recipients and Purposes of Personal Data Transfers

Your personal data may be transferred without your explicit consent in accordance with Article 8 of the Law on the Protection of Personal Data (KVKK) for the following purposes:

For the execution of financial and/or accounting processes related to the collection of payments for products and services, your data may be shared, if necessary, with notaries, enforcement offices, and/or courts.
In order to fulfill legal obligations as required by relevant legislation, your data may be shared with relevant public institutions, authorities, and competent bodies, if necessary or upon request.
For the purpose of legal proceedings, your data may be shared with our attorneys to the extent necessary and within the scope of confidentiality obligations.
During audit processes, your personal data may be shared with audit firms.

Due to the use of cloud computing applications whose servers are located abroad, it becomes necessary to transfer your personal data to our international business partners whose servers are based overseas, in order to provide you with services of international quality. This process is carried out in compliance with Article 9 of Law No. 6698 on the Protection of Personal Data.

e) Your Rights Under Article 11 of the Law on the Protection of Personal Data (KVKK)

As the data subject, we would like to inform you that you have the following rights under Article 11 of the KVKK:

To learn whether your personal data is being processed,
To request information if your personal data has been processed,
To learn the purpose of the processing of your personal data and whether they are used in accordance with that purpose,
To know the third parties to whom your personal data is transferred, domestically or abroad,
To request the correction of your personal data if it is incomplete or incorrectly processed,
To request the deletion or destruction of your personal data within the framework of the conditions set forth under the relevant legislation,
To request that the correction, deletion, or destruction operations carried out in accordance with the legislation be notified to third parties to whom your personal data has been transferred,
To object to any outcome against you that arises as a result of the analysis of your personal data exclusively through automated systems,
To request compensation if you suffer damage due to the unlawful processing of your personal data.

You can submit your requests related to your rights under Article 11 of the KVKK by completing all the information specified in the Data Subject Application Form, in accordance with Articles 11 and 13(1) of the KVKK and the Regulation on Procedures and Principles for Application to the Data Controller, by:

Visiting our Company’s office located at Barbaros Mah. Temmuz Sok. No:6 34746 Ataşehir/Istanbul in person,
Sending a written application via notary or by registered mail with return receipt to verify your identity and avoid disclosure of information to unauthorized persons,
Sending an email to [[email protected]] using a secure electronic signature, mobile signature, or (if available) the email address you have previously notified and that is registered in our systems,
Or by other methods that may be determined by the Board in the future.

In addition to the rights specified under Article 11 of the KVKK, you have the right to withdraw your explicit consent for the processing of your personal data at any time.

g) Changes and Updates

This disclosure text has been prepared within the scope of Law No. 6698 on the Protection of Personal Data and other relevant legislation. Necessary changes may be made to this disclosure text in line with changes in the applicable legal regulations and/or the Company’s personal data processing purposes and policies.