Personal Data Protection Privacy Notice
This Privacy Notice has been prepared pursuant to Article 10 of the Turkish Personal Data Protection Law No. 6698 to inform you, in line with our Company’s principles of high service quality and transparency, about the purposes for which your personal data will be processed, to whom and for what purposes processed personal data may be transferred, our methods and legal grounds for collecting personal data, and your rights as a data subject.
DATA CONTROLLER
Under the Turkish Personal Data Protection Law No. 6698 (the “Law”), your personal data are collected and processed for the purposes and by the methods described below by COSABELLA (the “Company”), affiliated with ALKOR ALÜMİNYUM İNŞAAT SANAYİ VE TİCARET ANONİM ŞİRKETİ, acting as data controller.
A) Purposes of Processing Personal Data
By the COMPANY:
Employees
1- Data in the category of criminal convictions and security measures:
a- Fulfilling obligations arising from employment contracts and legislation (explicit consent is obtained to process the relevant data).
2- Data in the category of philosophical beliefs, religion, denomination and other beliefs:
a- Fulfilling obligations arising from employment contracts and legislation (older identity card photocopies contain a religion field; if such data are identified, they will immediately be redacted and destroyed).
3- Data in the category of financial information:
a- Fulfilling obligations arising from employment contracts and legislation,
b- Carrying out finance and accounting operations,
c- Managing access authorizations,
d- Carrying out retention and archiving activities.
4- Data in the category of physical premises security:
a- Ensuring physical premises security,
b- Monitoring and conducting legal affairs,
c- Conducting and auditing business activities,
d- Carrying out occupational health and safety activities,
e- Providing information to authorized persons, institutions and organizations,
f- Creating and monitoring visitor records.
5- Data in the category of visual and audio recordings:
a- Carrying out occupational health and safety activities.
6- Data in the category of legal transactions:
a- Fulfilling obligations arising from employment contracts and legislation.
7- Data in the category of contact information:
a- Fulfilling obligations arising from employment contracts and legislation,
b- Managing access authorizations,
c- Ensuring activities comply with legislation,
d- Carrying out finance and accounting operations,
e- Monitoring and conducting legal affairs,
f- Carrying out communication activities,
g- Planning human resources processes,
h- Conducting and auditing business activities,
ı- Carrying out occupational health and safety activities,
i- Carrying out retention and archiving activities,
j- Ensuring the security of movable assets and resources,
k- Providing information to authorized persons, institutions and organizations.
8- Data in the category of identity information:
a- Fulfilling obligations arising from employment contracts and legislation,
b- Managing employee benefits and entitlements,
c- Carrying out audit and ethics activities,
d- Managing access authorizations,
e- Ensuring activities comply with legislation,
f- Carrying out finance and accounting operations,
g- Monitoring and conducting legal affairs,
h- Conducting internal audits, investigations and intelligence activities,
ı- Carrying out communication activities,
i- Planning human resources processes,
j- Conducting and auditing business activities,
k- Carrying out occupational health and safety activities,
l- Ensuring business continuity,
m- Conducting procurement processes for goods and services,
n- Conducting goods and services production and operational processes,
o- Carrying out retention and archiving activities,
p- Ensuring the security of movable assets and resources,
r- Providing information to authorized persons, institutions and organizations,
s- Carrying out management activities.
9- Data in the category of professional experience:
a- Fulfilling obligations arising from employment contracts and legislation.
10- Data in the category of personnel records:
a- Fulfilling obligations arising from employment contracts and legislation,
b- Ensuring activities comply with legislation,
c- Carrying out finance and accounting operations,
d- Ensuring physical premises security,
e- Conducting internal audits, investigations and intelligence activities,
f- Carrying out communication activities,
g- Planning human resources processes,
h- Carrying out occupational health and safety activities,
ı- Conducting logistics activities,
i- Carrying out retention and archiving activities,
j- Ensuring the security of movable assets and resources,
k- Providing information to authorized persons, institutions and organizations.
11- Data in the category of health information (explicit consent is obtained to process these data):
a- Fulfilling obligations arising from employment contracts and legislation,
b- Ensuring activities comply with legislation,
c- Monitoring and conducting legal affairs,
d- Carrying out communication activities,
e- Carrying out occupational health and safety activities,
f- Providing information to authorized persons, institutions and organizations.
12- Data in the category of biometric data (explicit consent is obtained to process these data):
a- Carrying out audit and ethics activities,
b- Ensuring physical premises security,
c- Conducting and auditing business activities.
13- Data in the category of location data:
a- Ensuring the security of movable assets and resources,
b- Conducting and auditing business activities.
14- Monitoring and conducting legal affairs.
Shareholders / Partners
1- Data in the category of identity information:
a- Conducting supply chain management processes,
b- Ensuring activities comply with legislation,
c- Carrying out finance and accounting operations,
d- Conducting procurement processes for goods and services,
e- Conducting and auditing business activities,
f- Providing information to authorized persons, institutions and organizations.
2- Data in the category of personnel records:
a- Ensuring activities comply with legislation,
b- Carrying out finance and accounting operations,
c- Providing information to authorized persons, institutions and organizations.
3- Data in the category of contact information:
a- Carrying out finance and accounting operations,
b- Ensuring activities comply with legislation,
c- Conducting contract processes.
Prospective Purchasers of Products or Services
1- Data in the category of physical premises security:
a- Ensuring physical premises security,
b- Monitoring and conducting legal affairs,
c- Providing information to authorized persons, institutions and organizations,
d- Conducting and auditing business activities,
e- Carrying out occupational health and safety activities,
f- Creating and monitoring visitor records.
Supplier Employees and Representatives
1- Data in the category of physical premises security:
a- Ensuring physical premises security,
b- Monitoring and conducting legal affairs,
c- Conducting and auditing business activities,
d- Carrying out occupational health and safety activities,
e- Providing information to authorized persons, institutions and organizations,
f- Creating and monitoring visitor records.
2- Data in the category of contact information:
a- Fulfilling obligations arising from employment contracts and legislation,
b- Carrying out finance and accounting operations,
c- Conducting supply chain management processes,
d- Ensuring activities comply with legislation,
e- Carrying out communication activities,
f- Conducting and auditing business activities,
g- Carrying out occupational health and safety activities,
h- Conducting procurement processes for goods and services,
ı- Conducting goods and services sales processes,
i- Conducting contract processes.
3- Data in the category of identity information:
a- Fulfilling obligations arising from employment contracts and legislation,
b- Ensuring activities comply with legislation,
c- Carrying out finance and accounting operations,
d- Monitoring and conducting legal affairs,
e- Planning human resources processes,
f- Carrying out communication activities,
g- Conducting and auditing business activities,
h- Carrying out occupational health and safety activities,
ı- Conducting procurement processes for goods and services,
i- Conducting contract processes,
j- Conducting logistics activities,
k- Providing information to authorized persons, institutions and organizations,
l- Conducting supply chain management processes.
4- Data in the category of personnel records:
a- Fulfilling obligations arising from employment contracts and legislation,
b- Carrying out finance and accounting operations,
c- Ensuring physical premises security,
d- Planning human resources processes,
e- Conducting procurement processes for goods and services,
f- Ensuring activities comply with legislation,
g- Conducting and auditing business activities,
h- Carrying out occupational health and safety activities,
ı- Conducting logistics activities,
i- Providing information to authorized persons, institutions and organizations,
j- Conducting contract processes.
5- Data in the category of financial information:
a- Fulfilling obligations arising from employment contracts and legislation,
b- Conducting goods and services sales processes,
c- Conducting contract processes.
6- Data in the category of criminal convictions and security measures:
a- Fulfilling obligations arising from employment contracts and legislation (explicit consent is obtained to process the relevant data).
7- Data in the category of philosophical beliefs, religion, denomination and other beliefs:
a- Fulfilling obligations arising from employment contracts and legislation (older identity card photocopies contain a religion field; if such data are identified, they will immediately be redacted and destroyed).
8- Data in the category of visual and audio recordings:
a- Carrying out occupational health and safety activities.
Purchasers of Products or Services
1- Data in the category of financial information:
a- Carrying out retention and archiving activities,
b- Conducting goods and services sales processes.
2- Data in the category of physical premises security:
a- Ensuring physical premises security,
b- Conducting and auditing business activities,
c- Carrying out occupational health and safety activities,
d- Monitoring and conducting legal affairs,
e- Providing information to authorized persons, institutions and organizations,
f- Creating and monitoring visitor records.
3- Data in the category of contact information:
a- Carrying out finance and accounting operations,
b- Carrying out communication activities,
c- Conducting procurement processes for goods and services,
d- Providing after-sales support for goods and services,
e- Conducting goods and services sales processes,
f- Conducting contract processes,
g- Monitoring requests and complaints,
h- Carrying out retention and archiving activities,
ı- Providing information to authorized persons, institutions and organizations.
4- Data in the category of identity information:
a- Carrying out finance and accounting operations,
b- Carrying out communication activities,
c- Conducting procurement processes for goods and services,
d- Providing after-sales support for goods and services,
e- Conducting goods and services sales processes,
f- Conducting contract processes,
g- Monitoring requests and complaints,
h- Carrying out retention and archiving activities,
ı- Providing information to authorized persons, institutions and organizations.
5- Data in the category of personnel records:
a- Carrying out finance and accounting operations,
b- Carrying out communication activities,
c- Conducting procurement processes for goods and services,
d- Conducting goods and services sales processes,
e- Conducting contract processes,
f- Carrying out retention and archiving activities,
g- Providing information to authorized persons, institutions and organizations.
Visitors
1- Data in the category of physical premises security:
a- Ensuring physical premises security,
b- Monitoring and conducting legal affairs,
c- Providing information to authorized persons, institutions and organizations,
d- Carrying out occupational health and safety activities,
e- Conducting and auditing business activities,
f- Creating and monitoring visitor records.
Job Applicants
1- Data in the category of criminal convictions and security measures:
a- Conducting selection and placement processes for job applicants, interns and students (explicit consent is obtained to process the relevant data),
b- Managing job application processes,
c- Planning human resources processes (explicit consent is obtained to process the relevant data),
d- Conducting contract processes (explicit consent is obtained to process the relevant data).
2- Data in the category of philosophical beliefs, religion, denomination and other beliefs:
a- Conducting contract processes (an identity card photocopy is collected for the contract; older identity cards may include a religion field; the data in that field will be destroyed immediately upon receipt of the photocopy or will not be collected at all).
3- Data in the category of financial information:
a- Conducting contract processes.
4- Data in the category of physical premises security:
a- Ensuring physical premises security,
b- Monitoring and conducting legal affairs,
c- Conducting and auditing business activities,
d- Carrying out occupational health and safety activities,
e- Providing information to authorized persons, institutions and organizations,
f- Creating and monitoring visitor records.
5- Data in the category of contact information:
a- Conducting selection and placement processes for job applicants, interns and students,
b- Managing job application processes,
c- Planning human resources processes,
d- Conducting contract processes.
6- Data in the category of identity information:
a- Conducting selection and placement processes for job applicants, interns and students,
b- Managing job application processes,
c- Planning human resources processes,
d- Conducting contract processes.
7- Data in the category of professional experience:
a- Conducting selection and placement processes for job applicants, interns and students,
b- Managing job application processes,
c- Planning human resources processes,
d- Conducting contract processes.
8- Data in the category of personnel records:
a- Conducting selection and placement processes for job applicants, interns and students,
b- Managing job application processes,
c- Planning human resources processes,
d- Conducting contract processes.
9- Data in the category of health information (explicit consent is obtained to process these data):
a- Conducting selection and placement processes for job applicants, interns and students,
b- Managing job application processes,
c- Planning human resources processes,
d- Conducting contract processes.
Interns
1- Data in the category of criminal convictions and security measures:
a- Managing job application processes,
b- Conducting selection and placement processes for job applicants, interns and students (explicit consent is obtained to process the relevant data).
2- Data in the category of contact information:
a- Managing job application processes,
b- Managing access authorizations,
c- Conducting selection and placement processes for job applicants, interns and students.
3- Data in the category of identity information:
a- Managing job application processes,
b- Managing access authorizations,
c- Conducting selection and placement processes for job applicants, interns and students.
4- Data in the category of professional experience:
a- Fulfilling obligations arising from employment contracts and legislation.
5- Data in the category of personnel records:
a- Managing job application processes,
b- Conducting selection and placement processes for job applicants, interns and students.
6- Data in the category of health information (explicit consent is obtained to process these data):
a- Managing job application processes,
b- Managing access authorizations,
c- Conducting selection and placement processes for job applicants, interns and students.
7- Data in the category of education data:
a- Conducting selection and placement processes for job applicants, interns and students.
B) Recipients and Purposes of Transfers of Processed Personal Data
Your personal data processed by our Company may be transferred for the purposes of processing listed above to:
The Company’s business partners and shareholders;
Persons or organizations authorized under the Tax Procedure Law, Social Security Institution legislation, the Court of Accounts, legislation on the prevention of laundering proceeds of crime and money laundering, the Turkish Commercial Code, the Code of Obligations and other applicable legislation;
Legally authorized public institutions and bodies, mediators, lawyers, and administrative and judicial authorities.
Such transfers are carried out accordingly.
C) Method and Legal Grounds for Collecting Personal Data
Your personal data are collected through automated, semi-automated and non-automated methods forming part of a data filing system, directly from you or persons authorized to act on your behalf, including applications submitted to our Company’s official email address;
And through Company personnel, organizations to which we provide or from which we receive support services, natural and/or legal persons with whom we deal under legislation or contracts, and automated systems (official email channel), verbally, in writing or electronically;
On the following legal grounds specified in Articles 5 and 6 of the Law:
1- Expressly provided for by law;
2- Necessary for our Company to comply with a legal obligation;
3- Necessary for the conclusion or performance of a contract and directly related thereto;
4- Necessary for the legitimate interests of our Company, provided your fundamental rights and freedoms are not harmed;
5- Data made public by you;
6- Necessary for the establishment, exercise or protection of a right;
7- Your explicit consent.
Personal data are collected on these grounds.
D) Rights of Data Subjects
If you submit requests concerning your rights under Article 11 of the Law using the methods below, the Company will respond as soon as possible and in any event within thirty days, depending on the nature of your request.
No fee is charged for responses of up to ten pages; a processing fee of TRY 1 is charged for each additional page. If the response is provided on a storage medium such as a CD or USB drive, the fee requested by the Company will not exceed the cost of that medium.
Under Article 11 of the Law, data subjects have the following rights:
1- To learn whether personal data are processed;
2- To request information if personal data have been processed;
3- To learn the purposes of processing and whether data are used in accordance with those purposes;
4- To know the third parties to whom personal data are transferred domestically or abroad;
5- To request correction of incomplete or inaccurate personal data and notification of such correction to third parties to whom the data were transferred;
6- To request deletion or destruction of personal data where the grounds for processing no longer exist, even if the data were processed in accordance with Law No. 6698 and other applicable laws, and to request notification thereof to third parties to whom the data were transferred;
7- To object to a result detrimental to the person arising exclusively from automated analysis of processed data;
8- To claim compensation for damage caused by unlawful processing of personal data.
These are the rights of data subjects.
E) Application Procedure for Data Subjects
Your application must include:
1- Your first and last name and, if the application is in writing, your signature;
2- Your Turkish identity number if you are a citizen of the Republic of Türkiye; if you are a foreign national, your nationality, passport number or identity number, if any;
3- Your residential or business address for notifications;
4- Your email address, telephone number and fax number for notifications, if available;
5- The subject of your request.
This information is MANDATORY; any relevant information and documents should also be attached to the application.
The application form is available at www.cosabella.com.tr.
Written applications, together with the required documents, may be submitted to our Company as data controller at İTOB OSB Mahallesi 10005 Sokak No:19 Menderes/İzmir.
Applications by email may be sent to info@cosabella.com.tr.
Applications via registered electronic mail (KEP) may be sent to alkoraluminyum@hs01.kep.tr.
Depending on the nature of your request, you must provide complete and accurate information and documents enabling us to verify your identity.
If the requested information and documents are not properly provided, this may prevent our Company from conducting a complete and effective review of your request; we reserve our statutory rights.
Your application must therefore contain all information and documents required in light of the nature of your request.
Pursuant to Article 13(1) of Law No. 6698 and the Communiqué on the Procedures and Principles of Applications to the Data Controller, published on 10 March 2018 under No. 30356, you may submit your requests regarding the matters above in Turkish and in writing, or by registered electronic mail (KEP), secure electronic signature, mobile signature, or the email address previously notified to the Company and recorded in our system.
Information will be provided only about the applicant, not third parties. The Company reserves the right to verify your identity before responding.