THE POLICY OF THE PROTECTION AND PROCESSING OF PERSONAL DATA
With Law No. 6698 on Protection of Personal Data (“Law”), which was published in the Official Gazette on 07.04.2016, the procedures and principles to be followed by the obligations of natural and legal persons who process personal data to protect the fundamental rights and freedoms of individuals in the processing of personal data were regulated. The purpose of this policy prepared in this direction is to ensure compliance with the obligations related to the regulations of the Law.
Vona Law Firm’s Policy of the Protection and Processing of Personal Data (“Policy”), includes the statements and declarations of Vona Law Firm regarding the processing of personal data of natural persons other than Vona Law Firm employees, especially the contact persons of our clients and potential clients, visitors, employee candidates and other third parties by Vona Law Firm, within the scope of Law.
Vona Law Firm reserves the right to make amendments in the Policy to provide up-to-date information on practices and legal regulations on the protection of Personal Data. In case of substantial amendments in the policy, Data Owners will be informed through various channels.
Vona Law Firm acts as a data controller in limited circumstances in terms of recruitment processes, legal services provided in the absence of direct client intervention, physical and electronic media security, and information texts it sends.
1) Principles Regarding Data Privacy
By Article 3 of the Law, all kinds of operations performed on the data, such as acquisition, recording, storage, saving, replacement, rearrangement, disclosure, transferring, taking over, making it available, classification or preventing their use of personal data fully or partially by automatic or non-automatic means provided that they are part of any data recording system, are within the scope of the processing of personal data. Vona Law Firm acts by the general principles explained below within the scope of Personal Data Processing activities.
Acting by the law and good faith: Vona Law Firm performs its data processing activities by the law and good faith, especially by the Constitutional Charter, the KVK (Protection of Personal Data) Law, and the relevant legislation.
Accuracy and Actuality: Vona Law Firm provides Data Owners with the opportunity to update their Data and it takes the necessary precautions to ensure the correct transfer of data to databases.
Processing for specific, explicit, and legitimate purposes: Vona Law Firm limits Personal Data Processing activities to specific and legitimate purposes and it informs the Data Owners clearly through the informative texts, regarding the aforementioned purposes.
Being related, limited, and measured for processing: Personal Data is processed by Vona Law Firm as required for the purpose notified to the Data Owner at the time of their acquisition, to this purpose and in a limited manner.
Storage for the period stipulated in the relevant legislation or required for the relevant purpose: Vona Law Firm saves personal data for a limited period stipulated by the Law and related legislation or as required by the purposes of data processing. Following the expiry of the aforementioned periods, the data are deleted, destroyed, or anonymized in line with the procedures of Vona Law Firm.
2) Conditions of Processing Personal Data
Except for the explicit consent of the personal data owner, the basis of the personal data processing activity can be only one of the following conditions or more than one condition can be the basis of the same personal data processing activity. If the processed data is personal data of special nature, the following conditions will apply.
(i) Explicit Consent of the Personal Data Owner
One of the conditions for processing personal data is the explicit consent of the data owner. The explicit consent of the personal data owner should be explained on a specific subject, based on the information and free will.
In the presence of the following personal data processing conditions, personal data can be processed without the explicit consent of the data owner.
(ii) Stipulated in Laws
If the personal data of the data owner is stipulated in the Law, in other words, if there is an explicit provision in the Law regarding the processing of personal data, the existence of this data processing requirement may be mentioned.
(iii) Failure to Obtain Explicit Consent of the Relevant Person Due to Actual Impossibility
Personal data of the data owner may be processed if it is mandatory to process the personal data of the person who is unable to disclose his/her consent or whose consent cannot be given validity due to the actual impossibility, to protect his/her or another person’s life or body integrity.
(iv) Being Directly Related to the Conclusion or Performance of the Contract
Provided that it is directly related to the execution or performance of a contract to which the data owner is a party, if it is necessary to process personal data, this condition may be deemed fulfilled.
(v) Fulfilling its Legal Obligation by Vona Law Firm
If the data processing is mandatory for Vona Law Firm to fulfill its legal obligations, the personal data of the data owner may be processed.
(vi) Making Personal Data Public by Personal Data Owner
If the data owner has made his/her data public, the relevant personal data may be processed in a limited manner to make it public.
(vii) When Data Processing is Mandatory for the Establishment or Protection of a Right
If the data processing is mandatory for the establishment, use, or protection of a right, the personal data of the data owner may be processed.
(viii) Requirement of Data Processing for the Legitimate Interest of Vona Law Firm
Provided that the fundamental rights and freedoms of the personal data owner are not harmed, the personal data of the data owner may be processed if it is necessary for the legitimate interests of the Vona Law Firm.
2) Disclosure of Personal Data Owner
Vona Law Firm, by Article 10 of the Law and secondary legislation, informs personal data owners about who, as the data controller, for what purposes, for what purposes it is shared with whom, with what methods it is collected, the legal reason and the rights of the data owners within the scope of processing their data.
3) Your Data Collected
Your Data collected by Vona Law Firm varies according to the nature of the relationship with Vona Law Firm and legal obligations.
Your Data collected by automatic methods such as our servers and electronic devices and non-automatic methods such as our document archives, but which are part of a data recording system, can be listed as follows:
- Identity Information: Name – Surname
- Contact Information: Address no, E-mail address, Contact address, Registered Electronic Mail Address (KEP), Phone number, etc.
- Special Quality Personal Data: In limited cases, it is the information that can be defined as special quality personal data within the scope of the current legislation, provided that it is provided by you only, to the extent necessary for a certain service we provide or to fulfill our legal obligations.
- Compliance Data: The identity card, passports, or other identity documents and dates of birth you provide us.
- Location: Location information of the place where it is located, etc.
- Legal Transaction Information: Information in correspondence with judicial authorities, information in the case file, etc.
- Visual and Audio Recordings: Photographs, camera recordings, audio recordings, etc.
- Data on Job Candidates: Data regarding job candidates or job opportunities provided by our Site or other offline means that may be subject to a different notification.
- Device data: Computer Internet Protocol (IP) address, single device identifier (UDID), other data connected to a device, and other data about the use of the Site.
The Personal Data types listed do not cover all your data processed and Personal Data similar to the data listed by Vona Law Firm can be processed.
4) Our Purposes of Processing Personal Data
Your Personal Data obtained can be processed by Vona Law Firm within the scope of Personal Data Processing terms specified in Articles 5 and 6 of the Law and within the scope of purposes such as;
- Evaluation of job applications,
- Realization of legal consultancy services,
- Conducting business activities and managing client relations,
- Communicating with you to the extent you consent,
- Sharing updates on legislation and other issues,
- Responding to your questions as soon as possible,
- Informing about event organizations,
- Ensuring the security and effective operation of our site and information technology systems,
- Notifications of legally required transactions/records, fulfillment of obligations, communication with official institutions, informing authorized institutions,
- Carrying out activities aimed at keeping the data accurate and up-to-date.
5) Saving Personal Data
Vona Law Firm determines by taking into account the legislation in force and the purposes of processing the data owner to the process when determining the retention periods of personal data. Within this scope, legal obligations and prescription periods regarding Personal Data Processing are taken into consideration. If the purpose of Personal Data Processing is eliminated, the data are deleted, destroyed, or anonymized unless there is another legal reason or basis that allows the retention of Personal Data.
6) Transfer of Personal Data
Your Personal Data, for the above purposes, can be shared with our suppliers, business partners, financial institutions and authorized public institutions and organizations, and/or legally authorized private persons by the personal data transfer conditions specified in Articles 8 and 9 of the Law No. 6698. In these cases where your Data is shared, Vona Law Firm takes the necessary precautions to ensure that the party with whom the data is shared performs processing and transfer activities by the rules in this Policy and the provisions in the legislation.
7) Security of Data
Vona Law Firm takes reasonable technical and administrative precautions to prevent unauthorized access risks, accidental data loss, deletion, or damage to data to ensure the security of your Personal Data.
8) Rights of Data Owners
According to Article 11 of the Law, Data Owners have the following rights:
- To find out whether Personal Data about him/her is being processed, and if so, to request information about it.
- To find out the purpose of processing Personal Data and whether they are used appropriately for their purpose.
- To know the third parties to whom Personal Data is transferred domestically or abroad.
- To request correction of Personal Data in case of incomplete or incorrect processing.
- To request the deletion or destruction of Personal Data within the framework of the conditions stipulated in the relevant legislation, and to request the transactions made to be notified to third parties to whom Personal Data has been transferred.
- Object to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems.
- To request the compensation of the damage in case of a loss due to the processing of Personal Data in violation of the Law.
9) Exercise of Rights by Data Owners
In case you apply to Vona Law Firm to update your data or state that you do not want your data to be saved, we can make the necessary updates and undertake to delete personal data that are not required and we are not obliged to keep due to a legal obligation, or the periods stipulated for hiding in the Law expire. Deletion, destruction, or anonymization can be carried out by your request in this context or when we consider it is necessary.
Where we process your Personal Data to send you information messages, you have the right to control the processing activity in question. In these information messages, you can choose not to receive such messages at any time by contacting us via the e-mail address in the message or as stated below.
Vona Law Firm: Caddebostan Mah. Prof. Dr. Hulusi Behçet Cad. No:14 K:7 D:8 Kadıköy/İstanbul
Telephone: 0216 372 28 16