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TRAINEE INFORMATION TEXT ON PROCESSING PERSONAL DATA

Data Supervisor: YASA HOLDING A.Ş.
Küçük Çamlıca, Üçpınarlar Cd. No:40, 34696 Üsküdar/Istanbul

We, as YASA HOLDING Inc. (hereinafter referred to as “YASA”) have prepared this information text to inform you, our trainees, on the processing, storing and transfer of your personal data within the framework of our activities arising from the Law on the Protection of Personal Data (“LPPD”) numbered 6698 and relevant legislation and legal arrangements.
Which of Your Personal Data are Processed and what are the Purposes of Processing Your Personal Data?
Within the scope of our activities and employment purposes, we are gathering following data of our trainees:

Identity Information
Personal Data Processed	Personal Data Processing Purposes
Name Surname Employee registration no Signature Date of Birth Place of Birth Gender Marital Status SSI Registration Number Citizenship Copy of ID card Photograph Turkish ID number Driver’s licence number Copy of driver’s licence Student Certificate Foreign ID Number Vehicle’s Number plate Passport number Licence number	Meeting Employment Contract- and Legislation-driven Obligations to Employees, Conducting Training Activities, Conducting Activities in Compliance with Legislation, Providing Information to Authorized Persons, Institutions and Organizations, Execution of Employee Fringe Benefits and Interests Processes, Execution of Contract Processes, Conducting Occupational Health/Safety Activities, Conducting Audit/Ethical Activities, Providing Physical Environment Security, Execution/Supervision of Business Activities, Conducting Activities to Ensure Business Continuity, Ensuring Security of Movable Goods and Resources, Ensuring the Security of Data Supervisor Operations, Creating and Tracking Visitor Records, Carrying Out Information Security Processes
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is clearly prescribed by law, It is required to process personal data of the parties to the contract, provided that it is directly related to the drawing up or performance of a contract, It is mandatory to enable the data supervisor to fulfil its legal obligation, Data processing is mandatory for the legitimate interests of the data supervisor, provided that it does not harm the fundamental rights and liberties of the person concerned.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms and via electronic systems.

Contact Information
Personal Data Processed	Personal Data Processing Purposes
E-mail Mobile Phone number Residence Address Home Telephone Number Business Address Name/Title of the Company Residency Certificate Business phone number	Meeting Employment Contract- and Legislation-driven Obligations to Employees, Conducting Training Activities, Conducting Activities in Compliance with Legislation, Providing Information to Authorized Persons, Institutions and Organizations, Execution of Employee Fringe Benefits and Interests Processes, Execution of Contract Processes, Conducting Occupational Health/Safety Activities, Conducting Audit/Ethical Activities, Providing Physical Environment Security, Execution/Supervision of Business Activities, Ensuring Security of Movable Goods and Resources, Ensuring the Security of Data Supervisor Operations, Creating and Tracking Visitor Records, Carrying Out Information Security Processes
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is clearly prescribed by law, It is mandatory to enable the data supervisor to fulfil its legal obligation, Data processing is mandatory for the legitimate interests of the data supervisor, provided that it does not harm the fundamental rights and liberties of the person concerned.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms and via electronic systems.

Personnel Information
Personal Data Processed	Personal Data Processing Purposes
Position/Title Information Payroll Data Disciplinary Proceedings Background Information SSI Statement of Employment Leave Data Workability Report References Student Certificate Tally Data Data and Documents on Training Period Certificate of Custodianship SSI Screenshot of Occupational Accident Reports and Documents on Occupational Health & Safety Personal Protection Equipment/ Embezzlement Documents	Meeting Employment Contract- and Legislation-driven Obligations to Employees, Conducting Training Activities, Conducting Activities in Compliance with Legislation, Providing Information to Authorized Persons, Institutions and Organizations, Execution of Employee Fringe Benefits and Interests Processes, Execution of Contract Processes, Conducting Occupational Health/Safety Activities, Conducting Audit/Ethical Activities, Providing Physical Environment Security, Execution/Supervision of Business Activities, Conducting Activities to Ensure Business Continuity
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is clearly prescribed by law, It is mandatory to enable the data supervisor to fulfil its legal obligation, Data processing is mandatory for the legitimate interests of the data supervisor, provided that it does not harm the fundamental rights and liberties of the person concerned.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms.

Legal Transaction Information
Personal Data Processed	Personal Data Processing Purposes
Information contained in Correspondence with Administrative Authorities Information Under Written Warning/ Notice	Meeting Employment Contract- and Legislation-driven Obligations to Employees, Execution of Employee Fringe Benefits and Interests Processes, Conducting Activities in Compliance with Legislation, Follow-up and Execution of Legal Affairs, Execution of Contract Processes, Conducting Occupational Health/Safety Activities, Execution/Supervision of Business Activities
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is clearly prescribed by law, It is mandatory to enable the data supervisor to fulfil its legal obligation.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed forms.

Financial Data
Personal Data Processed	Personal Data Processing Purposes
Bank Account Data Income Data	Meeting Employment Contract- and Legislation-driven Obligations to Employees, Execution of Employee Fringe Benefits and Interests Processes, Conducting Activities in Compliance with Legislation, Execution of Contract Processes
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is clearly prescribed by law, It is mandatory to enable the data supervisor to fulfil its legal obligation.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms.

Data on Relatives
Personal Data Processed	Personal Data Processing Purposes
Name Surname Home Telephone Number Mobile Phone Number Position/Title Information	Meeting Employment Contract- and Legislation-driven Obligations to Employees, Execution of Employee Fringe Benefits and Interests Processes, Conducting Activities in Compliance with Legislation, Execution of Contract Processes
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is clearly prescribed by law, It is mandatory to enable the data supervisor to fulfil its legal obligation.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms.

Professional Experience Data
Personal Data Processed	Personal Data Processing Purposes
Occupational Health and Safety Training Documents	Conducting Occupational Health/Safety Activities, Conducting Audit/Ethical Activities, Conducting Activities in Compliance with Legislation, Providing Physical Environment Security, Providing Information to Authorized Persons, Institutions and Organizations
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is clearly prescribed by law, It is mandatory to enable the data supervisor to fulfil its legal obligation.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms.

Audio and Visual Recordings Data
Personal Data Processed	Personal Data Processing Purposes
CCTV (Image Photographs) Visual Recordings	Conducting Occupational Health/Safety Activities, Conducting Audit/Ethical Activities, Conducting Activities in Compliance with Legislation, Providing Physical Environment Security, Providing Information to Authorized Persons, Institutions and Organizations, Ensuring Security of Movable Goods and Resources, Ensuring the Security of Data Supervisor Operations, Creating and Tracking Visitor Records
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is clearly prescribed by law, It is required to process personal data of the parties to the contract, provided that it is directly related to the drawing up or performance of a contract, It is mandatory to enable the data supervisor to fulfil its legal obligation, Data processing is mandatory for the legitimate interests of the data supervisor, provided that it does not harm the fundamental rights and liberties of the person concerned.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms and CCTV Recordings.

Data on Physical Environment Security
Personal Data Processed	Personal Data Processing Purposes
CCTV Recordings	Providing Physical Environment Security, Ensuring Security of Movable Goods and Resources, Ensuring the Security of Data Supervisor Operations, Creating and Tracking Visitor Records
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is required to process personal data of the parties to the contract, provided that it is directly related to the drawing up or performance of a contract, It is mandatory to enable the data supervisor to fulfil its legal obligation, Data processing is mandatory for the legitimate interests of the data supervisor, provided that it does not harm the fundamental rights and liberties of the person concerned.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms and CCTV Recordings.

Process Security Data
Personal Data Processed	Personal Data Processing Purposes
Exit IP Arrival IP Website name Date/Time Traffic Data Port number MAC Address User’s Name	Executing Information Security Processes, Conducting Activities in Compliance with Legislation, Providing Information to Authorized Persons, Institutions and Organizations
Legal Reasons for Processing Personal Data	Your personal data are processed by YASA in line with the purpose to accomplish the aforesaid purposes, based on the following legal reasons specified in Article 5, LPPD: It is clearly prescribed by law, Data processing is mandatory for the legitimate interests of the data supervisor, provided that it does not harm the fundamental rights and liberties of the person concerned.
Methods of Gathering Personal Data	Your personal data are collected via electronic systems.

What is the Legal Reason for Gathering Your Sensitive Personal Data?

Sensitive personal data include data on race, ethnic origin, political opinion, philosophical belief, religion, and sect or other beliefs, appearance, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data of an individual.

Sensitive personal data require higher protection compared to other data categories. Requirement to give additional information to process such data is regulated in accordance with the LPPD.

Sensitive Personal Data
Health Information
Personal Data Processed	Personal Data Processing Purposes
Physician’s Opinion Report Occupational Accident Report (Treatment Information, Injury Structure, Smoking, Alcohol Use, Chronic Disease Information, Information on Medication taken, Anamnesis Data, Physical Examination and Data on Findings etc) Medical Report (Information on blood group, chronic illness, vaccines made, tetanus/hepatitis/other immunity diseases, medical anamnesis, medical complaint, disease, operations, occupational accident, professional disease, medical workup/ examination, disability, treatment, smoking/alcohol use, physical examination, laboratory analysis, workability, suitability for working, suitability for working at height etc)	Meeting Employment Contract- and Legislation-driven Obligations to Employees, Execution of Employee Fringe Benefits and Interests Processes, Conducting Activities in Compliance with Legislation, Conducting Occupational Health/Safety Activities, Execution of Contract Processes, Conducting Audit/Ethical Activities, Providing Physical Environment Security, Providing Information to Authorized Persons, Institutions and Organizations, Execution/Supervision of Business Activities
Legal Reasons for Processing Personal Data	At YASA, we are processing your health data in line with the aforesaid purpose, based on the legal reason stated under Article 6, LPPD: “Personal data related to health and sexual life can be processed only by persons under confidentiality obligation of secrecy or authorized institutions and organizations for the purpose of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, without seeking the express consent of the relevant person.” Processing of your health data apart from the limitations specified in Article 6, LPPD shall be made only upon obtaining your express consent.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms.

Sensitive Personal Data
Criminal Convictions and Security Measures
Personal Data Processed	Personal Data Processing Purposes
Criminal Record	Meeting Employment Contract- and Legislation-driven Obligations to Employees, Execution of Employee Fringe Benefits and Interests Processes, Conducting Activities in Compliance with Legislation, Conducting Occupational Health/Safety Activities, Execution of Contract Processes
Legal Reasons for Processing Personal Data	At YASA, we are processing your health data in line with the aforesaid purpose, based on the legal reason stated under Article 6, LPPD: “Personal data related to health and sexual life can be processed only by persons under confidentiality obligation of secrecy or authorized institutions and organizations for the purpose of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, without seeking the express consent of the relevant person.” Processing of your health data apart from the limitations specified in Article 6, LPPD shall be made only upon obtaining your express consent.
Methods of Gathering Personal Data	Your personal data mentioned above are collected using printed and electronic forms.

To whom and For What Purposes will Your Personal Data Be Transferred?
Your personal data may be transferred to the following persons and entities:

To our Participations and Subsidiaries on the purpose of planning of Human Resources Processes,
To Competent State Institutions and Organisations on the purpose of conducting activities in compliance with legislation, providing information to competent persons, institutions and organisations, meeting employment contract- and legislation-driven obligations to employees and conducting occupational health/safety activities, within scope specified by legal regulation,
To our Suppliers on the purpose of conducting training activities, providing physical environment security.

If the process for processing of your personal data is related to foreign countries, since overseas services constitute a part of YASA HOLDING Inc, for the purpose of carrying out our activities and assigning our personnel abroad as well as of conducting training activities, personal data, limited to such personnel and processes may be disclosed to participations, subsidiaries, subcontractors and suppliers abroad and to foreign state institutions and organisations if required by legislation of relevant country, by taking necessary technical and administrative measures.

How Long Is Your Personal Data Stored?

If a certain period of time for storing personal data is specified by law or relevant legislation, your personal data must be stored for at least this period. If the law or the relevant legislation do not stipulate any certain period of time, it shall be kept for a reasonable period of time determined, provided that such period is linked to the purposes of processing, is limited and moderate.

What are the rights vested on you, as the concerned?

You have the following rights pursuant to LPPD and relevant legislation:

To be informed about whether personal data is processed or not,
To request information if personal data is processed,
To be informed about the purpose of processing personal data and whether they are used suitable for the respective purpose or not,
To have knowledge about third parties receiving personal data domestically or internationally,
To request, in case personal data are processed incompletely or inaccurately, necessary corrections be made,
To request the deletion or destruction of personal data within the framework of the conditions specified under LPPD
If you request the correction of incomplete or inaccurate data and deletion or destruction of your personal data, to request notification of these circumstances to third parties to whom your personal data has been transferred
In case your personal data are damaged due to the processing thereof in contrary to the Law, to request that the damages are indemnified

How to exercise your rights?

You can send your applications and requests on your personal data to YASA HOLDING Inc via Relevant person Application Form;

By sending the original application and request together with the copy of identity card to Küçük Çamlıca, Üçpınarlar Cd. No:40, 34696 Üsküdar/Istanbul,
By applying in person to YASA HOLDING Inc presenting a valid identity card,
By sending an e-mail to kvkk@yasaholding.com by affixing mobile signature or secure e-signature,
By sending to our e-mail address registered by Yasa@hs03.kep.tr using registered e-mail address and secured e-signature or mobile signature.

In accordance with the Communiqué on Application Procedures and Principles to the Data Supervisor, the application of the relevant person must contain name, surname, signature if the application is made in written, Turkish identification number (if the applicant is a foreign national, passport number or identification number, if any), residence or business address for notification purposes and e-mail address, telephone number and fax number, if any, and information on the subject of the request.
With the application to be presented with the intention of exercising the aforesaid rights and containing the clarification on the right to be exercised, the Relevant Person must clearly and understandably state the subject requested in the application. Necessary information and documents regarding the application must be attached to the application.
Although the subject of the request must be related personally to the applicant, if it is filed on behalf of a third party, the applicant must be specially authorized in this regard and this authorization must be documented (power of attorney). Additionally, the application must contain identity and address information and documents verifying the identity must be attached to the application.
The requests made by unauthorized third parties on behalf of someone else will not be taken into consideration.

What is the Period of Response to Your Requests regarding the Processing of Your Personal Data?

Your claims regarding your personal data are evaluated and answered within latest 30 days from the date of receipt. If your application is negatively evaluated, the reasoned causes of are delivered to the address using one of the methods stated in the Relevant Person Application Form, primarily via e-mail or by mail.