Netaş Whistleblowing Hotline

CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA THROUGH NETAŞ WHISTLEBLOWING HOTLINE

In accordance with the Personal Data Protection Law no. 6698 (“Law”), your personal data can be collected and processed by Netaş Telekomünikasyon A.Ş. (“Netaş”), as data controller, on the Whistleblowing Hotline within the scope stated below.

You can access detailed information on the processing of your personal data from our clarification text that has been shared with the public at https://ntstest.netas.com.tr/pdpb-info/?lang=en.

For What Purposes Your Personal Data Will Be Processed

Your personal data may be processed for the following purposes (“Purposes”) in connection with the notice you have sent:

• Providing Ethics Line management by Netaş


• Receiving and evaluating your notices and notifications


• Taking action and managing the processes in order to analyze the incoming notices and notifications and fulfill the requirements


• Follow-up of incoming notices and notifications


• Reporting within the scope of notices and notifications

The Recipients and Purposes of Personal Data Transfers

Your personal data collected in line with the fulfillment of the above-mentioned purposes can be transferred; to our business partners, suppliers who are the subject of the notice; within the scope if expressly stipulated in the laws and of fulfillment of our legal obligations; to the legally authorized public institutions and legally authorized private persons, to the infrastructure service provider, headquartered abroad ...., of the website where the web form is, in case of existence of your explicit consent and based on your explicit consent, within the framework of the personal data processing conditions specified in Article 5 of the Law, and in accordance with the rules regarding the transfer of personal data specified in Articles 8 and 9 of the Law.

The Method and Legal Basis for Collection of Personal Data

Your personal data is collected through the web form where you will make your notification.

Your personal data may be processed for the following purposes and legal reasons within the scope of the personal data processing conditions specified in Article 5 of the Law.

Based on the legal grounds that, provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller:

• Providing Ethics Line management by Netaş


• Receiving and evaluating your notices and notifications


• Taking action and managing the processes in order to analyze the incoming notices and notifications and fulfill the requirements


• Follow-up of incoming notices and notifications


• Reporting within the scope of notices and notifications

Based on the legal grounds that data processing is mandatory for the establishment, exercise or protection of a right:

• Receiving and evaluating your notices and notifications

In case of your explicit consent:

• If you do not provide anonymous notifications and notifications via the web form, storing your identity, communication, transaction security information and your data relevant to the incident subject to the notification, on the servers of …, the infrastructure provider of the web form, residing abroad.

Your Rights in the 11. Article of the Law

In case you contact us as data subject, by methods set out below, regarding your requests related to your rights, Netaş will process and conclude your requests as soon as possible and in thirty days at the latest, according to nature of the requests. Responses to such requests will be free of charge up to ten pages. 1 Turkish Lira in processing fees will be collected for each page beyond ten. In case the response to the request is presented on a storage environment like a CD or Flash memory the fee charged by our company will not exceed the cost of said storage environment.

Within this scope data subjects have the right to;

Learn whether their personal data is processed or not,

Request information regarding the processing in the case that their personal data have been processed,

Learn the purpose for the processing of personal data and if it has been used according to the purpose,

Know the third parties within Turkey or abroad to whom personal data have been transferred,

Request rectification in case their personal data have been processed incompletely or inaccurately and request notification of the operations made within this context to third parties to whom their personal data have been transferred,

Request deletion or destruction of personal data in case the reasons necessitating their processing cease to exist, even if their personal data have been processed in accordance with Law No.6698 or other relevant laws, and request notification of the operations made within this context to third parties to whom their personal data have been transferred,

Object to a result obtained by means of analyzing the processed data exclusively by automated systems, which is to the detriment of the person themselves,

Claim damages resulting from the unlawful processing of personal data.

 

You can submit your request to exercise your rights stated above, in accordance with the 1. Sub-article of the 13th Article of the Law no. 6698 and Communiqué On The Principles And Procedures For The Request To Data Controller, numbered 30356 and dated March 10, 2018, in Turkish and written form or by using the registered electronic mail (REM) address, secure electronic signature, mobile signature or the electronic mail address previously submitted to Netaş and registered in our system. In such requests only the information directly related to the applicant will be released, information regarding other family members or third parties cannot be obtained. Netaş reserves the right to verify your identity before responding.

Your application must include the following in, along with related information and documents if available;

1. Your name, surname, and if your application is made in writing, your signature,


2. For the citizens of the Turkish Republic your T.R. personal identification number, if you are a foreign citizen, your nationality, passport number and if available, personal identification number,


3. Your residential or work correspondence address for official notice,


4. If available, your electronic mail notification address, telephone and fax number for official notice,


5. The subject of your request.

You can submit written applications attaching the necessary documentation, to data controller, in our Company address at: Yenişehir Mah. Osmanlı Bulvarı No:11 34912. You can find the application form here.

 

You can submit your email applications to our netas@hs02.kep.tr REM address. You can submit your email applications to kvkk@netas.com.tr email address.

 

According to the nature of your request, information and documents that will enable identification must be provided to us in full, without any omissions or errors. In case that the requested information and documents are not duly provided, there can be setbacks in the quality and completeness of the research carried out by Netaş regarding your request. In this case, Netaş declares to reserve its legal rights. For this reason, your application must include the information and documents requested for the purpose of identification in full, according to the nature of your request.