Clarification text
Last revised: September 2, 2024
Employee/representative of the natural person/legal entity supplier clarification text regarding the protection of your personal data in connection with data protection law (“KVKK”) numbered 6698
We, 5CA Turkey Danışmanlık ve Ticaret Limited Liability Company (“The Company”) validly existing under the Laws of Republic of Türkiye, hereby inform and notify that your personal data will be recorded, stored, retained, altered, transferred to authorized institutions, and transferred to domestic and abroad third parties within the consideration of the terms stipulated under KVKK, adapted, categorized and processed in other ways that defined under KVKK by considering general principles listed as below:
- Lawfulness and fairness; and
- Being accurate and kept up to date where necessary; and
- Being processed for specified, explicit and legitimate purposes; and
- Being relevant, limited and proportionate to the purposes for which they are processed.
Processed data
The personal data of representative/employee of the natural person of “Suppliers” and legal entity of Suppliers to be processed by the Company are presented as below:
| Identity Data | Name-Surname, TR Identity Number, Title, Signature, |
| Contact Data | Phone Number (if provided), E-mail address, Workplace address, Timestamp (date, time), |
| Financial Data | Bank Account Information, Tax Identity Number, Affiliated Tax Administration, Current Account Balance, Credit Card Information, Payment Amount, Invoice Number, Invoice Date, |
| Work-related Data | Company where data subject works, Department/Job/Title, Circular of Signature, |
| Meta Data if your data is stored in the Company systems (e.g., if you have an account). | User ID, Password, Device Details, IP Address, Log Activity, User’s Device Location, Geolocation, OS information. |
Purposes for processing personal data of the employee/representative of the natural person supplier and legal entity supplier
The Company shall process your personal data under the scope of purposes and legal reasons designated as below.
Your personal data shall be retained within the limit of the period that is required under the respect of laws and regulations by the Company.
For the purposes of fulfilling requirements and obligations arising from relevant laws according to provision “It is necessary for compliance with a legal obligation to which the data controller is subject” as it is governed under Article 5 subclause 2(ç) of KVKK and, as the case may be, of “Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract” as it is governed under Article 5 subclause 2(c);
- Making payments of service fees regarding the services provided by the suppliers
- Carrying out purchasing processes
- Receiving products
- Executing new agreement with the suppliers whose agreement is expired
- Preparing agreements
- Sending business offers
- Opening current balance accounts and querying tax liability of the suppliers
- Contacting with the Suppliers due to business relationship
- Collecting the invoice amounts and contacting the suppliers’ employees and representatives if required
Pursuant to provision “Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject” under Article 5 subclause 2(f) of KVKK;
Your personal data shall be stored and retained for the period that is limited the time required for fulfilling the data processing purposes or for the period that is stipulated under respective laws and within the limit of legal prescription period in any case.
Transferring your personal data to third parties
Your personal data will be transferred to third parties in case of the existence of the followings:
- Your personal data may be transferred to affiliated companies and audit companies for the purposes of carrying out the budget management, opening current balance accounts, auditing financial transactions, and reporting activities under the respect of article 5/2/(c) with the purpose of performing the agreement and of article 5/2/(f) in line with the Company’s legitimate interests and the fulfillment of the Company’s legal obligation in Article 5/2/(ç) of the KVKK,
- Your personal data may be transferred to ISP and hosting providers under article 5/2/(f) in line with the Company’s legitimate interests.
In certain circumstances (if applicable):
- Your personal data will be transferred to our lawyers for agreements to be reviewed in accordance with article 5/2/(f) of KVKK,
- Your personal data will be transferred to our lawyers for the Company to use its right of defense and to establish and to protect a right in line with article 5/2/(e) of KVKK and to respective establishments, where lawful, for the purposes of Company to fulfill its legal obligations such as performing a court decision or a proof request pursuant to article 5/2/(ç) of KVKK.
Methods and channels for collecting your personal data
Within the legal reasons we have explained above, your personal data shall be collected through e-mails electronically and through hand delivery in physical environment and shall be retained in physical and electronic environments of the Company.
YOUR RIGHTS ARISING FROM ARTICLE 11 OF KVKK
In accordance with article 11 of KVKK, you shall have the following rights regarding the processed personal data, in case your identity has been verified:
- to learn whether your personal data are processed or not,
- to demand for information as to if your personal data have been processed,
- to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
- to know the third parties to whom your personal data are transferred in country or abroad,
- to request the rectification of the incomplete or inaccurate data, if any,
- to request the erasure or destruction of your personal data under the conditions referred to Article 7,
- to request reporting of the operations carried out pursuant to sub-paragraphs (d) and (e) to third parties to whom your personal data have been transferred,
- to object to the occurrence of a result against you by analyzing the data processed solely through automated systems,
- to claim compensation for the damage arising from the unlawful processing of your personal data.
The Company has its right to evaluate and to determine the most appropriate method to erasure or destruction of your personal data reserved in case you have used your right to request erasure and destruction of your personal data. You may request information regarding the determined method and the reason of determining it.
Pursuant to Art. 11 of the Turkish Data Protection Code, you can forward your requests for implementation of the Law as well as all kinds of requests for information related to processing of your personal data to privacy@5ca.com e-mail address via an e-mail address signed by your individual secure electronic signature or mobile signature, or in writing to 19 Mayıs Mah. Dr. Hüsnü İsmet Öztürk Sok. No: 3 Elit Residence Kat: 20 D: 48, Şişli/İstanbul (through a notary public or by registered letter with return receipt). In addition, if you have an e-mail address that has been previously notified to us by you and is registered in our system, you can also notify us of your requests with this e-mail address. Pursuant to provisions of article 5 of Communique on Procedures and Principles Regarding the Applications Made to the Data Controller, your application must include your name and surname, your signature if your application is in writing, your ID number if you are a citizen of the Republic of Turkey, your passport number or (if any) identity number if you are foreign, your correspondence address or workplace address, your electronic mail address for correspondence (if any), telephone and fax number, and the subject of the request.
The applications to be made by you within this context shall be concluded free of charge and as soon as possible, however within 30 days at the latest. However, if the procedure requires an additional cost, a fee might be collected based on the tariff determined by the Committee for Protection of Personal Data.
Contact information
5CA Turkey Danışmanlık ve Ticaret Limited Liability Company
MERSIS No: 001219653700001
Contact Email: privacy@5ca.com
Address: 19 Mayıs Mah. Dr. Hüsnü İsmet Öztürk Sok. No: 3 Elit Residence Kat: 20 D: 48, Şişli/İstanbul Türkiye