EYLÜL ÇEVİRİ DANIŞMANLIK VE YAYINCILIK HİZM.LTD.ŞTİ. (trading as Translation All World, hereinafter referred to as the Company), acting as the Data Controller, would like to inform you, within the scope of Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (KVKK), about the purposes for which your personal data (Personal Data) is processed, the methods by which it is collected, the legal grounds for processing and your rights. Personal Data may be processed on legal grounds including public disclosure by the data subject, necessity for the establishment or performance of a contract, and necessity for the establishment, exercise or protection of a right, primarily for evaluating quotations, requests and complaints and responding to messages, while respecting fundamental rights and freedoms, particularly the right to privacy.
a) Data Controller and Representative
Pursuant to Law No. 6698 on the Protection of Personal Data, your Personal Data may be processed by the Company, acting as data controller/data processor, within the scope described below.
b) Scope of This Privacy Notice
This Privacy Notice applies to all natural persons whose Personal Data is processed by automated means or by non-automated means provided that the processing forms part of a data filing system, including Company stakeholders, Company representatives, business partners/suppliers, affiliates, employees, job applicants, visitors, customers of the Company and group companies, prospective customers and third parties.
c) Purposes for Which Personal Data Is Processed
Personal Data may be processed lawfully and in accordance with the purposes of the Law for the following Company activities:
- Planning and implementing human resources procedures and policies,
- Planning, conducting and managing commercial partnerships and strategies,
- Ensuring the legal, commercial and physical security of the Company and its business partners,
- Processing Personal Data belonging to the parties where necessary for the establishment or performance of written translation and/or interpreting service agreements,
- Conducting information technology processes,
- Communicating with Personal Data subjects who submit requests and complaints and ensuring the coordination and effective management of requests, quotations, complaints and information flows,
- Informing customers of third parties receiving services about campaigns, discounts, benefits, terms and pricing, where processed in accordance with the instructions of the Data Controller, and verifying identity information where necessary,
- Copying and backing up information to prevent data loss, implementing necessary technical and administrative security measures, improving service quality, providing call centre services and preparing reports,
- Managing relationships with business partners and suppliers,
- Supporting affiliates in recruitment processes and compliance with applicable legislation,
- Conducting internal and certification audit activities,
- Creating and maintaining visitor records, controlling access to and exit from workplaces and ensuring workplace security,
- Fulfilling obligations relating to occupational health and safety,
- Ensuring business operations and business continuity,
- Providing information to institutions where required by applicable legislation.
Personal Data will be processed for the purposes of determining and implementing the Company’s commercial and business strategies within the conditions and purposes for processing Personal Data set out in Articles 5 and 6 of Law No. 6698.
d) Parties to Whom Processed Personal Data May Be Transferred and the Purposes of Transfer
Personal Data collected may be transferred, to the extent necessary, for the provision of the Company’s services; performance of translation and interpreting activities by the relevant departments; implementation of the Company’s human resources and language-service policies; ensuring the legal and commercial security of the Company and persons with whom the Company has business relationships; and determining and implementing the Company’s commercial and business strategies. Within the conditions and purposes specified in Articles 8 and 9 of Law No. 6698, Personal Data may be transferred to suppliers, shareholders, affiliates, legally authorized public institutions and legally authorized private persons.
Parties Necessary for the Performance of Services
To ensure that services provided to you are properly performed, and only to the extent appropriate to the nature of the service, your Personal Data may be shared with banks, notaries, providers of technical, logistics and similar supplementary services, business partners, suppliers, support service providers, external service providers, contracted organizations, independent audit organizations and other legally authorized persons carrying out relevant activities on our behalf. Such third parties are limited to those who require access to the relevant information for the proper provision of the applicable services.
Parties with Whom Sharing Is Required by Law
Your Personal Data may also be transferred, solely to the relevant person or institution, where this is necessary for the Company to fulfil its legal obligations, expressly required by law, or required pursuant to a lawful judicial or administrative order.
Consultants and Auxiliary Service Providers
Where necessary to protect the Company’s rights and/or your rights and to fulfil legal obligations, your Personal Data may be transferred to third parties providing services such as storage, archiving, information technology support, security and call centre services; business partners and service providers; banks and financial institutions; law firms, consultancy firms and other professional advisers providing legal, tax or similar support; and other related parties, authorized institutions and organizations where such transfer is necessary for the stated purposes.
Agencies and Advertisers
Certain Personal Data may be shared with advertisers in aggregated and anonymized form together with information relating to other users for the purpose of tailoring advertisements to relevant audiences. Anonymized data cannot be matched with individual visitors or customers and does not contain information that identifies or makes you identifiable.
e) Sharing Personal Data with Third Parties in Turkey and Abroad
Your Personal Data may be shared with third parties in Turkey or abroad, including companies to which the Company provides services, human resources consultancy companies from which it receives services, financial institutions, information technology companies, notaries, healthcare institutions, professional advisers, lawyers, accountants, occupational health and safety organizations and institutions with which the Company has commercial, administrative or contractual relationships.
f) Method and Legal Basis for Collecting Personal Data
The Personal Data collected may vary depending on the services provided by the Company and may be collected verbally, in writing or electronically through automated or non-automated means, including offices, locations, branches, call centres, the website, social media channels, technical and other methods, mobile applications and similar channels. Your Personal Data may continue to be created, updated and processed for as long as you use the Company’s services. Personal Data may also be processed when you contact our call centre or use our website with the intention of using Company services, visit the Company or its website, or participate in training sessions, seminars or other events organized by the Company.
Personal Data will be processed for the purposes of determining and implementing the Company’s commercial and business strategies within the conditions and purposes for processing Personal Data specified in Articles 5 and 6 of Law No. 6698.
| Personal Data Processed | Legal Basis for Processing |
| Identity information contained in documents such as driving licences, identity cards and passports, including full name, date of birth, place of birth and Turkish ID number | Where services are purchased, such data is processed where required under Article 230 and subsequent provisions of Tax Procedure Law No. 213 and Article 82 of Turkish Commercial Code No. 6102. (Law No. 6698 Art. 5/2-a) Where you register on websites operated by us without purchasing goods/services, the data is processed where necessary for performance of the relevant membership agreement and, in particular, for provision of services under Article 48 of Consumer Protection Law No. 6502. (Law No. 6698 Art. 5/2-c) |
| Email address, postal address, telephone number and other contact information | Where you receive services from us, such data is processed where necessary to provide information relating to those services, establish communication between the parties and perform the contractual relationship. (Law No. 6698 Art. 5/2-c) Where you register on websites operated by us without purchasing services, the data is processed where necessary for performance of the relevant membership agreement and provision of services under Article 48 of Consumer Protection Law No. 6502. (Law No. 6698 Art. 5/2-c) Where you have requested commercial electronic communications from us, the data is processed on the basis of the explicit consent you have provided for that purpose. (Law No. 6698 Art. 5/1) |
| Service history | Your history of products and services received from us is recorded for purposes including improving your customer experience, identifying services relevant to you, improving service quality, service planning and, where requested by you, informing you about relevant products and services. Such data is processed where necessary for the legitimate interests of the Data Controller, provided that the fundamental rights and freedoms of the data subject are not adversely affected. (Law No. 6698 Art. 5/2-f) |
| Voice recordings | Telephone conversations with us may be recorded for customer satisfaction, resolution of potential disputes and security purposes. Such records are processed where necessary for the legitimate interests of the Data Controller, provided that the fundamental rights and freedoms of the data subject are not adversely affected. (Law No. 6698 Art. 5/2-f) |
| CCTV recordings | CCTV recordings are made at Company branches in Turkey and abroad for security purposes. Such records are processed where necessary for the legitimate interests of the Data Controller, provided that the fundamental rights and freedoms of the data subject are not adversely affected. (Law No. 6698 Art. 5/2-f) |
How Long Is Your Personal Data Retained?
Unless longer retention periods are prescribed by applicable legislation, your Personal Data is retained for a maximum of 10 (ten) years pursuant to Article 182 of the Turkish Commercial Code and Article 146 of the Turkish Code of Obligations. CCTV recordings are retained for a maximum of 1 year.
g) Rights of the Data Subject Under Article 11 of Law No. 6698
Pursuant to Article 10 of the Law, the Company informs you of your rights, provides guidance on how those rights may be exercised and implements the necessary internal procedures and administrative and technical arrangements. Under Article 11 of the Law, persons whose Personal Data is processed have the right to:
- Learn whether Personal Data relating to them has been processed,
- Request information if their Personal Data has been processed,
- Learn the purpose of processing their Personal Data and whether it is being used in accordance with that purpose,
- Know the third parties in Turkey or abroad to whom their Personal Data has been transferred,
- Request correction of Personal Data if it has been processed incompletely or inaccurately,
- Request deletion or destruction of Personal Data where the reasons requiring its processing no longer exist,
- Request notification of actions carried out pursuant to items (d) and (e) above to third parties to whom the Personal Data has been transferred,
- Object to an outcome against the person arising from analysis of processed data exclusively through automated systems,
- Claim compensation for damages suffered as a result of unlawful processing of Personal Data.
Data subjects may exercise these rights free of charge by completing and signing our KVKK Data Subject Application Form and submitting it to the Company together with information and documents necessary to verify their identity, using one of the methods below or another method determined by the Personal Data Protection Board:
- Delivering a wet-ink signed copy of the completed application form in person to Koşuyolu Mah. Lambacı Sok. Ateşoğlu Apt. A Blok No 1/5 Koşuyolu, Kadıköy, Istanbul, Turkey,
- Completing the application form, signing it with a secure electronic signature within the scope of Electronic Signature Law No. 5070 and sending the securely signed form via Registered Electronic Mail (KEP) to eylulceviri@hs01.kep.tr,
- Submitting the application form using an email address previously provided by the data subject to the Company and registered in the Company’s systems.
For a third party to submit an application on behalf of a Personal Data subject, a special power of attorney issued by a notary authorizing that person to act on behalf of the data subject must be provided.
Data Controller
| Legal Name | EYLÜL ÇEVİRİ DANIŞMANLIK VE YAYINCILIK HİZM.LTD.ŞTİ. |
| Address | Koşuyolu Mah. Lambacı Sok. Ateşoğlu Apt. A Blok No 1/5 Koşuyolu, Kadıköy, Istanbul, Turkey |
| MERSIS / Trade Registry | 0383004912600017 / 28685 |