1. Purpose
As Sebat Endüstri Makina ve Aksesuar Sanayi Ticaret Anonim Şirketi ("Sebat Makina" or the "Company"), we attach importance to the protection of the personal data of our customers, potential customers, employees, job applicants, suppliers, business partners, visitors, and other natural persons.
This Personal Data Protection Policy ("Policy") has been prepared to explain the fundamental principles and practices adopted by Sebat Makina within the scope of the applicable legislation on the protection of personal data, particularly Law No. 6698 on the Protection of Personal Data ("KVKK").
Sebat Makina aims to process personal data lawfully, securely, transparently, and in a manner that respects the fundamental rights and freedoms of the data subject.
2. Scope
This Policy covers personal data processed in relation to;
- ✓ Customers,
- ✓ Potential customers,
- ✓ Suppliers,
- ✓ Business partners,
- ✓ Employees,
- ✓ Job applicants,
- ✓ Visitors,
- ✓ Website (https://sebatmakina.com.tr/) users,
- ✓ Service providers,
- and other natural persons who have any commercial or legal relationship with Sebat Makina
This Policy covers the personal data processed in relation to the persons listed above.
The Policy sets out Sebat Makina's general approach to the processing of personal data.
Detailed information regarding the purposes for which personal data is processed within the scope of a specific processing activity, the categories of data used, legal grounds, data transfers, and the rights of data subjects is provided in the Privacy Notice on the Protection of Personal Data.
3. What Is Personal Data?
Personal data refers to any information relating to an identified or identifiable natural person.
Information that may qualify as personal data within the scope of Sebat Makina's activities may include;
- ✓ name and surname,
- ✓ telephone number,
- ✓ e-mail address,
- ✓ company and job position information,
- ✓ communication records,
- ✓ quotation and request information,
- ✓ machine, accessory, order, and sales information,
- ✓ technical service and maintenance records,
- ✓ invoice and financial transaction information,
- ✓ website usage information,
- ✓ transaction security information
The scope of personal data processed may vary depending on the nature of the relationship established with Sebat Makina and the transaction carried out.
4. Fundamental Principles for the Processing of Personal Data
Sebat Makina adopts the following fundamental principles when processing personal data:
4.1. Compliance with the Law and the Principle of Good Faith
Care is taken to ensure that personal data is processed in accordance with the law and the principles of good faith.
4.2. Being Accurate and Up to Date Where Necessary
Reasonable measures are taken to ensure that personal data is accurate and kept up to date where necessary.
4.3. Processing for Specified, Explicit, and Legitimate Purposes
Personal data is processed for specified, explicit, and legitimate purposes.
4.4. Being Relevant, Limited, and Proportionate to the Purpose of Processing
Personal data is processed only to the extent necessary for the purpose for which it is processed.
4.5. Retention for the Necessary Period
Personal data is retained for the period stipulated in the relevant legislation or required by the purpose of processing.
5. Purposes of Processing Personal Data
Personal data may be processed by Sebat Makina for the following purposes, depending on the nature of its industrial machinery and accessory manufacturing/sales activities:
- ✓ receiving requests for machines, accessories, products, and services,
- ✓ preparing quotations and pricing studies,
- ✓ carrying out sales and marketing processes,
- ✓ managing order and production processes,
- ✓ carrying out after-sales services and maintenance,
- ✓ providing technical service and spare parts services,
- ✓ managing customer and business partner relationships,
- ✓ carrying out contractual processes,
- ✓ managing delivery, transportation, and logistics processes,
- ✓ carrying out finance, accounting, and invoicing processes,
- ✓ carrying out legal processes,
- ✓ managing company activities,
- ✓ ensuring information security,
- ✓ ensuring the secure and effective operation of the website,
- ✓ evaluating requests and complaints,
- ✓ responding to requests received from authorized institutions and organizations,
- ✓ fulfilling legal obligations.
Necessary permissions and legal requirements are separately evaluated with regard to marketing, promotion, campaign, and commercial electronic communication activities.
6. Legal Grounds for Processing Personal Data
Personal data is processed based on the legal ground applicable to the relevant processing activity among the conditions stipulated under the KVKK.
Within this scope, personal data may be processed where;
- ✓ it is expressly provided for by law,
- ✓ it is directly related to the establishment or performance of a contract,
- ✓ it is necessary for compliance with a legal obligation,
- ✓ it has been made public by the data subject,
- ✓ it is necessary for the establishment, exercise, or protection of a right,
- ✓ it is necessary for the legitimate interests of the data controller,
- ✓ the explicit consent of the data subject has been obtained
provided that the relevant conditions stipulated under the KVKK are met.
Sebat Makina does not, to the extent possible, make personal data processing activities that do not require explicit consent conditional upon obtaining explicit consent. Where explicit consent is required, the data subject is provided with the necessary information, and consent is obtained for a specific matter, based on information, and by free will.
7. Special Categories of Personal Data
Sebat Makina processes special categories of personal data specified in Article 6 of the KVKK only where a processing condition stipulated by law that is appropriate for the specific activity exists and provided that adequate measures determined by the Personal Data Protection Board are taken.
Special categories of personal data are not requested or processed unless they are necessary, relevant, limited, and proportionate in relation to the purpose of processing. Cases where explicit consent is required are distinguished from cases under Article 6 of the KVKK where processing is permitted without explicit consent. Where processing is necessary, the required technical and administrative measures are taken within the scope of the applicable legislation.
8. Collection of Personal Data
Personal data may be obtained through channels such as;
- ✓ the https://sebatmakina.com.tr/ website,
- ✓ contact, request, and quotation forms,
- ✓ e-mail and telephone,
- ✓ face-to-face meetings and site visits,
- ✓ contracts,
- ✓ quotation, order, and technical service documents,
- ✓ fairs, exhibitions, and industry events,
- ✓ business partners and suppliers
through automated or non-automated methods. Detailed information regarding personal data processing activities carried out through cookies and similar technologies used on the website is provided within the scope of the Cookie Policy.
9. Transfer of Personal Data
Sebat Makina may share personal data with third parties only where permitted by the applicable legislation and provided that such transfers are related to, limited to, and proportionate with the purposes of processing.
Within this scope, personal data may, where necessary, be transferred to;
- ✓ authorized public institutions and organizations,
- ✓ legal and financial advisors,
- ✓ service providers,
- ✓ suppliers,
- ✓ logistics, courier, and transportation companies,
- ✓ information technology service providers,
- ✓ business partners,
- ✓ manufacturers and producers for which representation or distributorship activities are carried out
The parties to whom personal data may be transferred and the legal grounds for such transfers are separately explained in the relevant Privacy Notice according to the nature of the applicable data processing activity.
Where personal data is transferred abroad, the current transfer regime stipulated under Article 9 of the KVKK is applied. Where no adequacy decision exists, regular or systematic transfers abroad are not carried out unless one of the appropriate safeguards stipulated by law is provided; occasional transfers are evaluated only where the exceptional conditions specified by law are met. Where standard contractual clauses are used, the notification obligations stipulated under the applicable legislation are fulfilled within the prescribed period.
10. Security of Personal Data
Pursuant to Article 12 of the KVKK, Sebat Makina takes the necessary technical and administrative measures appropriate to the nature and risk level of the processed data in order to prevent the unlawful processing of and access to personal data and to ensure the secure retention of personal data.
Within this scope, Sebat Makina takes appropriate technical and administrative measures to prevent;
- ✓ unlawful processing,
- ✓ unlawful access,
- ✓ loss,
- ✓ unauthorized use
of personal data, taking into account the nature of the data processed.
The implementation of necessary security measures is aimed at in areas such as information system security, access authorizations, data security practices, and employee awareness. Sebat Makina aims to improve its security practices in line with technological developments and emerging risks.
11. Retention of Personal Data
Personal data is retained by taking into account;
- ✓ the periods stipulated in the relevant legislation,
- ✓ the period required by the purpose of processing,
- ✓ the period during which legal or commercial obligations continue
Upon expiry of the retention period or disappearance of the purpose of processing, personal data is deleted, destroyed, or anonymized in accordance with the applicable legislation.
12. Explicit Consent
For personal data processing activities where explicit consent is required under the KVKK, explicit consent is obtained from the data subject. Explicit consent is obtained in relation to a specific matter, based on information, and by free will. Detailed explanations regarding activities requiring explicit consent and the relevant consent processes are set out within the scope of the Explicit Consent Text.
As a rule, failure to provide explicit consent does not prevent the data subject from benefiting from services for which explicit consent is not required. However, situations where the relevant data processing activity is mandatory for the provision of the service are evaluated separately.
13. Commercial Electronic Communications and Marketing Activities
Where Sebat Makina carries out commercial communications regarding products, services, campaigns, announcements, and similar matters, the permission, approval, and opt-out mechanisms stipulated under the applicable legislation are taken into consideration.
Permissions relating to the sending of commercial electronic communications are obtained separately from other personal data processing permissions where necessary. The legal requirements applicable to the processing of personal data for marketing and promotional purposes are evaluated separately.
14. Cookies
Cookies may be used on the https://sebatmakina.com.tr/ website in order to ensure the secure and effective operation of the website, improve the user experience, and, where necessary, carry out statistical analyses.
Detailed information regarding the types of cookies, their purposes of use, retention periods, and management is provided in the Cookie Policy.
15. Rights of Data Subjects
Within the scope of Article 11 of the KVKK, data subjects have the right to;
- ✓ learn whether their personal data is being processed,
- ✓ request information if their personal data has been processed,
- ✓ learn the purpose of processing and whether the data is being used in accordance with that purpose,
- ✓ know the third parties to whom personal data has been transferred in Türkiye or abroad,
- ✓ request the correction of incomplete or incorrectly processed personal data,
- ✓ request the deletion or destruction of personal data within the framework of the conditions stipulated under the KVKK,
- ✓ request that correction, deletion, or destruction operations be notified to third parties to whom the personal data has been transferred,
- ✓ object to any adverse result arising from the analysis of personal data exclusively through automated systems,
- ✓ request compensation for damages in the event of suffering loss due to the unlawful processing of personal data
in accordance with the KVKK.
16. Right to Apply
Data subjects may apply to Sebat Makina in order to exercise their rights under the KVKK. Applications must be submitted in accordance with the methods and conditions specified in the applicable legislation.
Contact / Application Channels: Through the Company's official contact addresses and e-mail channels (using the current contact information available at https://sebatmakina.com.tr/)
Website: https://sebatmakina.com.tr/
Applications are concluded free of charge as soon as possible depending on the nature of the request and, in any event, within the maximum period stipulated by the applicable legislation; however, if the transaction requires an additional cost, the fee specified in the tariff determined by the Personal Data Protection Board may be charged.
17. Related Documents
Detailed information regarding Sebat Makina's practices concerning the protection of personal data is provided in the following documents:
- ✓ Privacy Notice on the Protection of Personal Data: Information regarding the purposes, legal grounds, and methods through which personal data is processed.
- ✓ Explicit Consent Text: The consent process relating to personal data processing activities for which explicit consent is required.
- ✓ Cookie Policy: Information regarding cookies and similar technologies used on the website.
Although these documents are independent of one another, together they complement Sebat Makina's general approach to the protection of personal data.
18. Updating the Policy
Sebat Makina may update this Policy in line with changes in the applicable legislation, developments in the Company's activities, technological changes, or changes in personal data processing processes.
The current Policy shall become effective as of the date it is published on the Website.
