TürkçeTrasta ESG Inc.
Clarification Text on Protection of Personal Data
This clarification text has been prepared by Trasta ESG as the data controller due to the legal obligation within the scope of Article 10 of the Personal Data Protection Law No. 6698 (KVKK) and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Disclosure Obligation.
As Trasta ESG A.Ş., we attach utmost importance to the security and protection of personal data. With this awareness, we act sensitively in the processing and storage of all kinds of personal data in accordance with KVKK No. 6698.
We process personal data that we process in the capacity of data controller within the framework of the limitations permitted by the legislation.
1.Data Controller and Representative
Pursuant to KVKK, your personal data may be processed by Trasta ESG as the data controller within the scope described below.
2.Collection and Processing of Personal Data
Your personal data are stored in accordance with the law and good faith, accurately and up-to-date when necessary, for specific, clear and legitimate purposes, in connection with the purpose for which they are processed, in a limited and measured manner, for the necessary periods stipulated in the relevant legislation or for the purpose for which they are processed and for the required periods specified in other legislation. Depending on the service activities provided by Trasta ESG, data may be collected through Trasta ESG’s units and business partners by automatic or non-automatic methods. The personal data required to provide ESG scoring and consultancy services are analyzed and reported by Trasta ESG. Such personal data may be processed through verbal, written or electronic means such as meetings, contracts, digital platforms.
Your collected data may be processed in accordance with the law, for the period stipulated in the relevant legislation related to the purpose for which they are processed or for the period required for the purpose for which they are processed.
3. Purposes of Processing Personal Data
Your Personal Data is processed for the following purposes and legal reasons and within the personal data processing conditions and purposes listed in Article 5 of the KVKK:
3.1. Based on the legal reason that it is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract: Your personal data collected may be processed in order to carry out the services purchased, to complete the service processes and to provide the necessary information, technical and strategic support services related to these services.
3.2. Based on the legal reason that it is clearly stipulated by law and is mandatory for the data controller to fulfill its legal obligation: Your personal data may be processed for the purposes of fulfilling the requests of official institutions; providing information to authorized institutions arising from the legislation; ensuring compliance with the retention obligations stipulated in the legislation, responding to the relevant person applications in accordance with the legislation and carrying out the necessary transactions.
3.3. Based on the legal reason that data processing is mandatory for the establishment, exercise or protection of a right: Your personal data may be processed during the general statute of limitations stipulated for the storage of personal data in order to constitute evidence in possible future disputes; In addition, it may be processed for the purposes of receiving, evaluating and finalizing your requests and complaints.
3.4. Based on the legal reason that data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned: Your personal data may be processed by Trasta ESG for the purposes of carrying out business processes within the scope of the continuation of its commercial activities, fulfilling the procedures, ensuring legal, technical, commercial, cyber business security related to the activity, ensuring customer satisfaction and corporate communication, following legal processes, etc.
3.5. If you give your explicit consent, your data based on your explicit consent: Your personal data may be processed for the purposes of improving the services provided to you, providing additional services not specified in the contract, conducting communication activities, various marketing and advertising activities.
4. Transfer of Personal Data to Third Parties and/or Abroad
Your Personal Data may be transferred to domestic and foreign direct or indirect business and solution partners, legally authorized public institutions and legally authorized private persons within the framework of the personal data processing conditions and purposes specified in Article 8 of the KVKK for the processing purposes related to the processing we carry out in accordance with the processing conditions specified in Article 5 of the KVKK and the foreign transfer rules specified in Article 9. Within the framework of the processing purposes, your personal data may be transferred to tax offices for the fulfillment of tax obligations; invoices and collection receipts during tax audits to the authorities of the Ministry of Treasury and Finance of the Republic of Turkey. Ministry of Treasury and Finance officials; to our relevant business partners, consultants and service providers for the management of financial and accounting processes, detection and evaluation of risks, prevention of frauds; to banks, financial advisors, our business partners and service providers who provide, operate or provide services to our IT infrastructure; our business partners who provide services in the field of risk management and financial reporting processes, lawyers, auditors, forensic IT experts, cyber security consultants, tax consultants and other third parties from whom we receive consultancy and services within the scope of fulfilling our legal obligations; authorized persons, official institutions and organizations such as courts, Consumer Arbitration Committees. Your personal data may be stored in electronic media or on storage, archiving, information technologies (server, hosting, program, cloud computing) servers located at home/abroad by taking necessary measures.
5. Your Rights
If you submit your requests regarding your rights to Trasta ESG, they will be concluded free of charge as soon as possible and within 30 days at the latest. However, if the transaction requires an additional cost, the fee in the tariff determined by the Board may be charged. In case the application is caused by the error of the data controller, the fee charged will be refunded to the person concerned. According to Article 11 of the KVKK, your rights include the following;
a) Learn whether personal data is being processed,
b) Request information if personal data has been processed,
c) To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
ç) To know the third parties to whom personal data are transferred domestically or abroad,
d) To request correction of personal data in case of incomplete or incorrect processing,
e) To request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7,
f) To request notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data are transferred,
g) To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
ğ) In case of damage due to unlawful processing of personal data, to demand the compensation of the damage.
In order to exercise your rights according to paragraph 1 of Article 13 of the KVKK, you can submit your request in writing or by choosing the methods specified in the Communiqué on Application Procedures and Principles to the Data Controller.
Trasta ESG reserves the right to make changes in this clarification text due to possible changes in KVKK.
Personal Data Processing Consent Form
I have read the Clarification Text transmitted by Trasta ESG A.Ş. and give my explicit consent to the processing of the personal data I have transmitted for the purposes specified by Trasta ESG A.Ş.