General Disclosure Statement on Processing and Transferring of Personal Data

We, as ITC GROUP COMPANIES (“Company”), would like to inform and clarify you on our activities of processing personal data in accordance with

the Article 10 of the Law no 6698; Law on the Protection of Personal Data (“LPPD”).

1.  Data Controller and Representative

In accordance with the LPPD, acting as the data controller, ITC GROUP COMPANIES are free to process, save, keep, sort, update your personal data within the scope of aims explained below complying with laws and good faith. Company is also free to unclose and/or transfer your personal data to 3rd parties in the cases allowed by legislations and/or limited to processing purposes.

2.  Purpose of Processing Your Personal Data

Your above mentioned personal data are processed in compliance with the main principles stated in the LPPD and for purposes of carrying out our operational activities, business relations and human resources processes, meeting the demands of related bodies, providing products and services to you in optimal conditions, continuing marketing and technical operations and ensuring business security of the Company and they are securely kept physically or electronically for an appropriate duration according to the purpose of processing.

ITC GROUP COMPANIES act in compliance with specifically LPPD and all other related legislations.

3.  Transfer of Your Personal Data

Your personal data, which are processed within the scope of mentioned purposes, may be transferred to our business partners, our shareholders, authorized state institutions and agencies, private bodies, companies providing services for our activities and independent auditing firms under legal necessities and legal limits by ITC GROUP COMPANIES in compliance with the main principles stated in LPPD and within the personal data processing terms and purposes stated in the 8th and 9th Articles of LPPD.

4.  Data Exporting

ITC GROUP COMPANIES may export your personal data with “direct consent provision” in compliance with the principles stated in the Article 4/2 of LPPD or without “direct consent provision” under existence of cases stated in the Articles 5/2 and 6/3 and to the bodies and institutions settled in countries, which are declared as countries with sufficient protection by the Council of Protection of Personal Data (“Council”), or to the bodies and institutions in countries, which are declared as countries without sufficient protection, by written commitment of sufficient protection by both data controllers in Turkey and the foreign country and limited with the cases where permit of the Council can be obtained for the export in compliance with the rules stated in the 9th Article of the LPPD.

5.  Collection Method of Your Personal Data and Legal Reason

Your personal data are collected with the purpose of improving our services and carrying out our business activities by ITC GROUP COMPANIES via different channels and based on the legal reasons stated above. Within this scope, your personal data may be processed and transferred with direct consent provision in compliance with the principles stated in the Article 4/2 of LPPD or without direct consent provision under existence of cases stated in the Articles 5/2 and 6/3.

6.  Your Rights as Interested Body in Accordance with the 11th Article of LPPD

In case you, as data owner, deliver your demands about your rights to the Company via methods given below; ITC GROUP COMPANIES shall meet your demands within 30 days at the latest varying with the type of the demand. The response shall be free of charge up to 10 pages. 1 Turkish Lira of transaction fee shall be charged for each page over 10 pages. In case the response is delivered in a recording medium, such as CD, flash drive, etc., the fee to be charged by the Company shall not exceed the cost of the recording medium.

Your rights specified by the 11th Article of the LPPD are listed below:

  • To learn whether your personal data are processed or not,
  • To demand related information if your personal data are processed,
  • To learn the purpose of processing personal data and whether they are used fitting to these purposes,
  • To know domestic or foreign 3rd parties to whom your personal data are transferred,
  • To demand correction of personal data in case of imperfect or wrong processing,
  • To demand deletion or clear off of personal data within the frame of terms stated in the Article,
  • To demand informing 3rd parties, whom personal data are transferred, about processes carried out in compliance with the subclauses (d) and (e),
  • To object to the results to the detriment of oneself obtained by exclusive analyses of data via automatic systems,
  • To demand recover of loss in case of a loss because of illegal process of personal data.

You may deliver your demand to use any of the rights stated above in Turkish, written or via registered e-mail (KEP) address, secure electronic signature, mobile signature or e-mail address pre-issued to the Company and recorded in our system in compliance with the 1st Clause of 13th Article of Law numbered 6698 and the Declaration on Methods and Principles of Application to the Data Controller numbered 30356 and dated 10.03.2018.

ITC GROUP COMPANIES reserve their rights to verify your identity before responding.

Following information are required to be involved in your application:

  • Your name, surname and signature if the application is written,
  • TR identity number for Turkish citizens; nationality, passport number or identity number if available for foreigners,
  • Permanent residence or office address,
  • E-mail address, phone and fax numbers if available,
  • Your demand.

In addition to the information listed above; it is required to attach related information and documents to the application.

You may deliver your written applications with their attached documents to the data controller, ITC GROUP COMPANIES residing in the address of Yukarı İmrohor Mah. Natoyolu Cd. No: 190 / G Mamak/ANKARA.

You may deliver your application via e-mail to the e-mail address of "".

It is required that information and documents are provided to us as complete and correct according to the type of your demand. In case failing to provide required information and documents, it is possible to face with setbacks during carrying out investigations in a complete and qualified way. ITC GROUP COMPANIES declares that they reserve their legal rights in such cases.

7.  Qualification of Disclosure Form

Present “General Disclosure Statement on Processing and Transferring of Personal Data” is an inseparable part of the all kinds of written or verbal contracts concluded with ITC GROUP COMPANIES.

* Present Disclosure Statement (“Statement”) is prepared on the date of 08/08/2019. In case of an amendment on the Statement text, those amendments shall be published on the web address of and validity date of the Statement shall be updated in accordance with the amendments.

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