ANADOLU AGENCY TURKISH ANONYMOUS COMPANY
ON THE PROTECTION AND PROCESSING OF PERSONAL DATA
- PURPOSE and SCOPE
1.1. Anadolu Agency Turkish Anonymous Company (“Enlightenment Text”) on the Protection and Processing of Personal Data is prepared to inform and enlighten you in a transparent manner about the ways to collect your Personal Data, purposes of the Personal Data processing activities and its legal reasons, procedures of Personal Data processing, if there is any, and your rights as the Data Owner in accordance with Article 10 of the Law No. 6698 on the Protection of Personal Data (PPD Law) on the usage of the Personal Data obtained from the Personal Data Owners and/or third persons during the usage of websites in the addresses www.aa.com.tr(…) which are owned and managed by Anadolu Agency Turkish Anonymous Company (“Anadolu Agency”).
1.2. For detailed information on Personal Data that are obtained via cookies which are identification files downloaded to devices used by Subscribers and Visitors, who used Anadolu Agency’s websites, please view“ANADOLU AGENCY TURKISH ANONYMOUS COMPANY WEBSITE PRIVACY and COOKIES POLICY”.
1.3. Anadolu Agency may update and amend the provisions of this Enlightenment Text at any time by publishing them via the websites listed above. The updates and amendments made by Anadolu Agency will be effective from the date of publication on the website.
1.4. In this Enlightenment Text, all Subscribers and Users will be referred to hereafter as Visitors separately or together.
- DEFINITIONS and ABBREVIATONS
Following are definitions and abbreviations used in this Enlightenment Text;
Subscriber : Any natural and legal person who benefit from Anadolu Agency’s services privately through subscription system,
Anadolu Agency : Anadolu Agency Turkish Anonymous Company resident at Eti Mahallesi GMK Bulvarı No:132 Çankaya/Ankara Turkey address,
Cookie : Small text files which visited websites store in your device or network server via browsers,
Website : www.aa.com.tr and (...) websites owned and managed by Anadolu Agency,
Personal Data : Any information relating to an identified or identifiable Visitor,
Processing of Personal Data: Any processing performed on data such as obtaining, saving, storing, conserving, changing, re-arranging, explaining, transferring, acquiring, making them obtainable, classifying or preventing its usage by means of fully or partially automatic methods or non-automatic methods, where it is part of a data saving system,
Personal Data Owner : Visitor whose Personal Data is processed,
User : Visitors and Subscribers who use websites by creating user name and password to access Anadolu Agency’s websites,
PPD Law : The Law No. 6698 on Protection of Personal Data, which entered into force when it was published in the Official Gazette on 7 April 2016,
Data Processor : Any natural or legal person who processes Personal Data based on the authority granted by and on behalf of the data controller,
Data Controller : Any natural or legal person who determines the purposes and means of the processing of Personal Data, and who is responsible for the establishment and management of the data saving system,
- DATA CONTROLLER
In accordance with the PPD Law, your Personal Data which you have shared as Visitor or which are obtained from the third persons may be collected and processed within the below stated scope by Anadolu Agency, which is determined as the Data Controller.
- PROCESSED PERSONAL DATA
Your Personal Data which you have shared with Anadolu Agency or Anadolu Agency obtained from third parties are stated below; notwithstanding that your relation with Anadolu Agency and the types and numbers of your Personal Data may change according to the reason of processing.
Name, surname, mobile phone number, home phone number, work phone number, address, e-mail address, invoice information, T.R. identity number, photocopy of identity card and other similar documents.
Membership information of Visitors, passwords used to verify identity and provide access to account, User Name, contact information, User Numbers.
Date of birth, age, gender, marital status, education level, occupation, interests, preferred language data.
Including but not limited to data collected from Visitors’ devices through various software and technological tools; date and time data of usage of Anadolu Agency publications, content read through websites, tags, categories, date of the last visit to the website, visited websites, number of viewed pages, duration of visit and target completion number, search terms entered, categories of news visited, errors and similar problems occurred during the use of service.
Includes data on precise or approximate locations of visitors. Location data obtained from GPS data or IP and port addresses is used when the Visitor uses Anadolu Agency's mobile applications and wants to search for content near his/her location, and upon the Visitor’s permission.
Data such as subscriber invoice and payment information (name, surname, invoice address, T.R. identity number, tax identification number), invoices sent to the member and receipt samples of payments taken from the members, payment number, invoice number, invoice amount, invoice date.
Similar data such as membership information, notification description, solution description, satisfaction, reason for the notification, customer note, subscription renewal date, content of error specified during the use of service, intermediate information status, intermediate information, reason of the search.
- GENERAL PRINCIPLES ON PROCESSING OF PERSONAL DATA, TERMS AND PURPOSES OF PROCESSING PERSONAL DATA
5.1. Your Personal Data are processed in accordance with the general principles set forth in Article 4 of the PPD Law:
· Being in conformity with the law and good faith,
· Being accurate and, if necessary, up to date,
· Being processed for specified, explicit, and legitimate purposes,
· Being relevant, limited and proportionate to the purposes for which data are processed,
· Being stored only for the time designated by relevant legislation or necessitated by the purpose for which data are collected.
5.2. Personal Data cannot be processed without explicit consent of the Personal Data Owner according to Article 5 of the PPD Law. But according to the same article provision, it is possible to process Personal Data without explicit consent of the Data Owner in case of existence of one of the below conditions:
· If it is expressly permitted by any law,
· If it is necessary in order to protect the life or physical integrity of the data subject or another person where the data subject is physically or legally incapable of giving consent,
· If it is necessary to process the Personal Data of parties of a contract, provided that the processing is directly related to the execution or performance of the contract,
· If it is necessary for compliance with a legal obligation which the Data Controller is subject to,
· If the relevant information is revealed to the public by the data subject herself/himself,
· If it is necessary for the institution, usage, or protection of a right,
· If it is necessary for the legitimate interests of the Data Controller, provided that the fundamental rights and freedoms of the Personal Data Owner are not harmed.
5.3. Anadolu Agency processes your Personal Data subject to this Enlightenment Text for the following purposes:
Name and Contact Information :Intra-company evaluation, contact, Visitor registration, obtaining potential Subscriber information, improving post-sales processes, business development, collection, promotion, analysis, complaint management, managing Subscriber satisfaction processes, marketing, research, billing, execution of operational activities, measuring the quality of service, improving them, supervision, control, optimization, customer verification, marketing, sales, detecting and preventing fraud;
Identity Verification Information :User registration, problem/error reporting, control, improving operational activities, carrying them out, improving post-Subscribe processes, business development, collection, intra-company evaluation, customer portfolio management, measuring the quality of service, contact, optimization, supervision, risk management, supervision, customer verification, detecting and preventing fraud;
Demographic Data :Intra-company evaluation, analysis, contact, improving post-sales processes, business development, collection, usage data and interests, favorites, marketing, sales, advertising, supervision and control, risk management, improving post-sales processes, business development, collection, intra-company evaluation, post-sales services, measuring the quality of service, improving them, contact, execution of complaint management processes, execution and improvement of operational activities, registration, problem/error reporting;
Usage Data and Favorites :User registration, problem/error reporting, control, execution and improvement of operational activities, post-sales services and improvement of post-sales processes, business development, collection, intra-company evaluation, online behavioral advertising and marketing, management of Subscriber portfolio, measurement and improvement of the quality of service, contact, optimization, supervision, risk management and control, promotion, analysis, specifying areas of interest, scoring, profiling, marketing, sales, advertising, contact, execution of complaint management processes, registration, problem/error reporting;
Location data :Use of portal functions linked or related to the location, supervision and control, risk management;
Payment Data :Management of billing process, accounting, improvement of post-sales processes, business management, collection, intra-company evaluation, scoring, profiling, customer relations management, post-sales services, contact, marketing, supervision, control, processes carried out with payment service providers;
Content :Business development, optimization, customer relations management, supervision, control, improvement of operational activities, promotion, intra-company evaluation, Subscriber management, analysis, scoring, profiling, improvement of post-sales processes, collection, post-sales services, contact, measuring the quality of service, improving them, execution of complaint management processes.
- METHODS of PERSONAL DATA COLLECTION and its LEGAL REASONS
6.1. Your Personal Data can be collected, processed and transferred by Anadolu Agency with purposes specified in this Enlightenment Text through following means;
· Subscription forms,
· Websites contact forms,
· Websites visits,
· E-newsletter registration forms,
· Membership forms,
· Signed contracts,
and based on different legal reasons in accordance with the basic principles provided by the PPD Law, within the scope of Personal Data processing conditions set forth in Articles 5 and 6 of the PDD Law.
6.2. Your Personal Data subject to this Enlightenment Text are generally processed based on below legal reasons:
Name and Contact Information : Being directly related to conclusion of a contract or its execution.
Identity Verification Information : Being directly related to conclusion of a contract or its execution, being necessary for compliance with a legal obligation which the Data Controller is subject to, being necessary for establishment, usage or protection of a right, being necessary for the legitimate interests of the Data Controller.
Demographic Data : Being directly related to conclusion of a contract or its execution, being necessary for compliance with a legal obligation which the Data Controller is subject to, being necessary for establishment, usage or protection of a right, being necessary for the legitimate interests of the data controller.
Usage Data and Favorites : Being necessary for the legitimate interests of the Data Controller.
Location data : Being directly related to conclusion of a contract or its execution.
Payment Data : Being expressly permitted by laws, being directly related to conclusion of a contract or its execution, being necessary for compliance with a legal obligation which the Data Controller is subject to, being necessary for establishment, usage or protection of a right.
Content : Being directly related to conclusion of a contract or its execution, being necessary for compliance with a legal obligation which the Data Controller is subject to, being necessary for establishment, usage or protection of a right, being necessary for the legitimate interests of the Data Controller.
- TRANSFERRING PERSONAL DATA
7.1. Anadolu Agency can share Personal Data subject to this Enlightenment Text and new data that it will obtain by using these Personal Data, firstly to perform the requirements of the relation/contract with Personal Data Owner, to enhance User experience (including improving and personalizing), to provide safety of Personal Data Owner, to detect and prevent fraud, to improve the services offered, to make operational evaluation research, to correct the errors, to verify the User identities, to improve system performance for being able to realize any of the purposes listed above in the processing purposes section and in the cases set forth in this Enlightenment Text’s Article 5.2; with third natural and/or legal persons including foreign resource service providers, courier companies, law offices, research companies, call centers, software companies on complaint management and safety providing, agencies, consulting firms, companies in printing sector, banks, social media channels and with institutions, organizations, authorities, executive and judicial bodies that are authorized in the scope of legal obligations.
7.2. Anadolu Agency may transfer the Personal Data to third parties in the country as well as abroad within the categories and purposes stated above and as limited and proportionate with these purposes.
8.1. In case the reasons to process are eliminated despite having been processed in line with the provisions of the PPD Law and other relevant laws, Personal Data are deleted, destructed or anonymized by Anadolu Agency.
8.2. Anadolu Agency can retain Personal Data in accordance with the PPD Law for the duration of the statute of limitations determined by the relevant legislation to be used in case of occurrence of any possible conflict. In this case, the Personal Data retained are not accessed for any other purpose but accessed when it is necessary to use them in the relevant legal dispute.
- RIGHTS OF PERSONAL DATA OWNER
9.1. Personal Data owners in the scope of the PPD Law and relevant legislation have right;
· To learn whether the Personal Data has been processed,
· To request information about Personal Data if it has been processed,
· To learn the purpose of processing Personal Data and whether they are used appropriately for their purpose,
· To know the third parties to whom Personal Data are transferred domestically or abroad,
· To request the correction of Personal Data in case of incomplete or incorrect processing and to request third persons to whom Personal Data is transferred to be notified about the processing made within this scope,
· To request the deletion or destruction of Personal Data in case the reasons to process this data are eliminated despite having been processed in line with the provisions of the Law No. 6698 and other relevant laws and to request third persons to whom Personal Data is transferred to be notified about the processing made within this scope,
· To object to the emergence of an adverse outcome through the analysis of processed data exclusively through automatic systems,
· To demand the recovery of the losses in the event of sustaining a loss due to the unlawful processing of Personal Data,
9.2. As the Personal Data Owner, you can deliver your application including your requests in a clear and comprehensible way and by attaching documents that determine your identity and address information; by hand in writing and original signed, by mail or through a notary public to “Eti Mah. GMK Bulvarı No: 132 Çankaya/Ankara” address of Anadolu Agency, which is the Data Controller, or you can e-mail it to (…).
9.3. As well as having right to verify your identity before Anadolu Agency responds, existence of;
· Your name, surname and signature if the application is in writing,
· T.R. identity number for the citizens of the Republic of Turkey, passport number or identity number, if you have one, for the foreign nationalities,
· Notice address of place of residence or business,
· Notice electronic mail address, phone and fax number,
· The subject of your request,
is compulsory and information and documents related to the topic, if any, should to be attached to the application.
9.4. In case you deliver your requests to Anadolu Agency in the way stated above, Anadolu Agency will conclude the request free-of-charge within the shortest period of time depending on the nature of the request and in thirty days at the latest. The response will not be charged up to ten pages. For each page above ten pages, a transaction fee of 1 Turkish Lira will be charged. If the response is given in a recording medium such as CD, flash memory, the fee that will be asked by Anadolu Agency will not exceed the cost of the recording medium.