Visitor and CCTV System Privacy Notice

This privacy notice has been prepared by Çakmakçı Kıymetli Madenler A.Ş. (hereinafter referred to as the “Company”) in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”), the Communiqué on the Principles and Procedures to be Followed in Fulfilling the Obligation to Inform, the relevant secondary legislation and the decisions and principle decisions of the Personal Data Protection Board in force, in order to provide information on the processing of the personal data of natural persons visiting the Company and of persons present within the Company building and branch premises.

1. Identity of the Data Controller

Your personal data is processed by our company in its capacity as data controller, whose identity and contact details are set out below:

Title: Çakmakçı Kıymetli Madenler A.Ş.
Address: Mollafenari, Nuru Osmaniye Cd. No:58/A Fatih / İstanbul
Phone: 0212 945 99 98
Website: https://www.cakmakcikiymetlimadenler.com/

2. Categories of Personal Data Processed and Purposes of Processing

Within the scope of visits to our company building and branch and of internal security activities, the categories of personal data set out below are processed for the related purposes:

2.1 Image data (closed-circuit television)

Video image recordings obtained through the closed-circuit television (CCTV) system installed in the Company building, the internal areas of the branch and at entry and exit points are processed for the purposes of ensuring the safety of the Company, its employees, customers and visitors, protecting the physical premises and Company assets, preventing crime and irregularities, and fulfilling statutory notification obligations towards the competent public institutions and organisations. The camera system does not record audio. The required warning signs are displayed at the entrances to the areas where the camera system is installed.

3. Legal Basis for Processing Personal Data

Personal data processing activities carried out through visitor entry records and the closed-circuit television system are performed on the basis of the legitimate interests of the data controller pursuant to Article 5/2-f of the KVKK. This legitimate interest consists of ensuring the physical security of the Company, its employees and visitors, protecting Company assets and maintaining order at the workplace. It is assessed that this legitimate interest does not cause disproportionate harm to the fundamental rights and freedoms of the data subjects. In addition, with regard to the obligations arising from MASAK (Financial Crimes Investigation Board) legislation and related public regulations, the legal basis set out in Article 5/2-ç of the KVKK (legal obligation) is also applicable.

4. Transfer of Personal Data

Visitor entry records and camera image data may be shared with the relevant public institutions and organisations and with judicial authorities in the context of judicial and administrative investigations and upon the request of MASAK, the BRSA (BDDK) and other competent supervisory authorities. No transfer is made to any other third party.

5. Retention Periods for Personal Data

Closed-circuit camera recordings: 2 (two) months from the date of recording. Upon expiry of this period, the recordings are automatically deleted from the system.

However, if requested by the relevant authorities in connection with an investigation, lawsuit or administrative proceeding, such data may be retained until the end of the statutory period. Upon expiry of the retention periods or where the purpose of processing ceases to exist, personal data is deleted, destroyed or anonymised.

6. Rights of Data Subjects and Application Procedure

Pursuant to Article 11 of the KVKK, you have the rights set out below:

To learn whether your personal data is being processed,
To request information if it has been processed,
To learn the purpose of processing and whether the data is used in accordance with that purpose,
To know the third parties to whom the data is transferred in Türkiye or abroad,
To request the correction of data processed incompletely or inaccurately,
To request the deletion or destruction of the data within the conditions set out in Article 7 of the KVKK,

To request that the above operations be notified to the third parties to whom the data has been transferred,
To object to a result arising to your detriment as a consequence of the analysis of the processed data exclusively by automated systems,
To claim compensation for damages incurred as a result of unlawful processing.

To exercise the rights set out above, you may apply in person to the Company address stated above with documents proving your identity, or you may submit your request by sending a secure electronic message to [email protected]. Your applications will be concluded within thirty (30) days pursuant to Article 13 of the KVKK.

This privacy notice may be revised in line with changes in legislation or updates to the Company's business processes. The current version is available on the Company's website and on the notice boards at the branch entrances.

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