As Afer Agro, we attach the highest importance to the security of personal data. We take technical and organisational measures in line with applicable legislation to ensure that personal data are collected, stored and shared lawfully and that your privacy is protected. As the data controller under Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”), we process your personal data as described below and within the limits set by law.
1) Identity of the data controller
Under Article 10 of the KVKK, Afer Agro explains, in its capacity as data controller, the scope in which your personal data may be processed.
2) Purposes of processing personal data
Personal data collected from you may be processed by Afer Agro in line with the fundamental principles set out in legislation for the following purposes, without limitation:
- Carrying out work by our business units so that commercial activities are performed in compliance with laws and company policies;
- Defining and implementing human resources policies and related operations;
- Determining, planning and implementing short-, medium- and long-term commercial policies;
- Ensuring commercial, technical and legal security and maintaining contact with natural and legal persons with whom we have a business relationship;
- Protecting commercial reputation and trust;
- Fulfilling information retention, reporting and notification obligations imposed by public authorities and other legal duties;
- Determining and implementing business strategies, including finance, communication, market research, corporate social responsibility, procurement (request, offer, evaluation, order, budgeting), internal systems and legal operations;
- Examining, evaluating and responding to requests from public authorities or data subjects;
- Physical security and monitoring of premises (e.g. CCTV);
- Using data as evidence in potential future disputes;
- Processing within the conditions and purposes set out in Articles 5 and 6 of the KVKK.
Within our activities, data may be classified in the context of automated decision-making where this is necessary for reporting and documents submitted to authorities.
Processing is often required by law or contract; failure to provide data may make it impossible to run commercial relations, meet statutory notifications, perform HR activities, or ensure legal, technical and commercial security.
3) Recipients and purposes of transfer / transfers abroad
Personal data may be transferred by Afer Agro under Articles 8 and 9 of the KVKK, limited to the purposes listed above, to:
- Business partners and affiliates of Afer Agro;
- Persons and institutions permitted under the Turkish Commercial Code, Turkish Code of Obligations, Labour Code and other applicable laws;
- Legally authorised public institutions and bodies, administrative and judicial authorities, and institutions, organisations, persons and companies required by special legislation;
- Natural and legal persons from whom we obtain products or services or with whom we cooperate, provided that domestic recipients’ compliance with the KVKK and data security is considered before transfer.
Under Article 9 of the Law, transfers abroad may take place where explicit consent exists or where the conditions in the Law are met (including second paragraph of Article 5 and third paragraph of Article 6) for transfers to countries with adequate protection, or where adequate protection is not ensured, when the conditions in the Law are met and adequate protection is contractually guaranteed and the Board’s permission is obtained, as applicable. The Personal Data Protection Board publishes the list of safe countries.
4) Method and legal basis of collection
Personal data are collected through various channels (verbal, written, electronic) for the conduct of our activities, based on legal grounds such as compliance with legislation and company policies, performance of contracts, explicit provision of law, and legitimate interests of the company. Data are processed and transferred in accordance with the principles of the KVKK and the conditions and purposes in Articles 5 and 6, also for the purposes set out in this notice.
5) Retention period
Personal data are retained for the period required by applicable law or for the period necessary for the purpose of processing. When determining maximum retention, criteria such as sector practice, duration of the legal relationship, legitimate interest, legal risk and obligations, need for accuracy, statutory retention and limitation periods are taken into account.
6) Rights of the data subject under Article 11 of Law No. 6698
Data subjects may submit requests regarding their rights through the methods set out in the Afer Agro Personal Data Protection and Processing Policy published on our website. Afer Agro will conclude the request as soon as possible and within thirty days at the latest, depending on the nature of the request. If the procedure incurs a separate cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board. In this framework, data subjects have the right to:
- Learn whether personal data are processed;
- Request information if personal data have been processed;
- Learn the purpose of processing and whether data are used in line with that purpose;
- Know the third parties to whom personal data are transferred domestically or abroad;
- Request rectification of incomplete or inaccurate data and notification of third parties to whom data were transferred;
- Request erasure or destruction of personal data where grounds for processing have ceased despite lawful processing, and notification to third parties;
- Object to outcomes against the person arising solely from automated processing;
- Request compensation for damage arising from unlawful processing.
If the application is rejected, the response is insufficient, or no response is given in time, the data subject may lodge a complaint with the Personal Data Protection Board within thirty days of learning the controller’s response and in any case within sixty days of the application date. Under Article 13 of the Law, the complaint route may not be used before exhausting the application route.
Under international instruments, data subjects may also have the right to request restriction of processing and to withdraw consent to processing or transfer where consent is the legal basis.
You may use our contact page or info@aferagro.com.tr for applications.
Please also see our Privacy & Cookie Policy.