Howden ACP Company Profile
WEBSITE CLARIFICATION TEXT UNDER THE PERSONAL DATA PROTECTION LAW NO. 6698 - HOWDEN ACP SİGORTA VE REASÜRANS BROKERLİĞİ A.Ş.
1. Data Controller
At HOWDEN ACP SİGORTA VE REASÜRANS BROKERLİĞİ A.Ş. (hereinafter referred to as the “Company”), we hereby inform you that we process your personal data in our capacity as the data controller pursuant to the Personal Data Protection Law No. 6698 (hereinafter referred to as “KVKK”) and other related legislation.
2. Processed Personal Data
Your personal data comprised of your identity and contact details (Name-Surname, phone number and email address) will be processed in accordance with KVKK and other related legislation for the purposes and legal grounds stipulated in this Clarification Text.
3. Purposes of Personal Data Processing
Your personal data will be processed for the purposes of:
enabling our business units to perform necessary works to provide you with the products and services offered by our Company
recommending you the products and services offered by your Company, planning and/or performance of the market research activities for the sales and marketing of the products and services
informing the customers using our products and services about the developments in the sector, and the management of those processes
and for the legal grounds as per the lines: “a) It is expressly stipulated by law”, “c) It is necessary to process the personal data of parties to a contract, provided that the processing is directly related to the execution or performance of the contract”, “ç) It is necessary for the data controller to perform their legal obligation”, and “e) It is necessary for the establishment, usage, or protection of a right” stated in Article 5 (2) of KVKK.
4. To Whom and For Which Purposes the Processed Personal Data May be Transferred
Your personal data processed by our Company are not transferred to any organization, real persons or private legal persons. Your personal data may be disclosed to the related state institutions and organizations, when necessary or requested, to satisfy the legal obligations under the related legislation without your explicit consent pursuant to Article 8 (2) (a) of KVKK.
5. Overseas Transfer
Your personal data processed pursuant to the legal grounds stated in Article 5 (2) of KVKK may be transferred to the following countries without your explicit consent in line with the conditions for overseas transfer in Article 9 (2) of KVKK as the sales and marketing activities regarding the products and services of the Company are carried out via online software systems with databases kept abroad:
Foreign countries which are announced by the Personal Data Protection Board (hereinafter referred to as the “Board”) to provide adequate protection (“Foreign Country with Adequate Protection”)
Foreign country and/or countries with written undertakings made by the data controllers in Turkey and those foreign countries to provide adequate protection and a consent from the Board for the related transfer (“Foreign Country with a Data Controller Undertaking to Provide Adequate Protection”).
The overseas transfer of your personal data processed for the foregoing purposes will be made with due care and necessary security measures taken by our Company in compliance with the resolutions made by the Board and the related regulations including in particular KVKK and other related legislation.
6. Method and Legal Ground for Collecting Personal Data
Your personal data are collected with automatic or non-automatic methods in the electronic environment upon the visiting of the Website for the legal grounds stated in Article 5 (2) of KVKK in order to realize the purposes under Paragraph (c) of this text.
7. Your Rights Pursuant to Article 11 of KVKK
You are entitled to certain rights pursuant to Article 11 of KVKK in your capacity as the data subject and you can submit your requests regarding such rights preferably by entirely filling in the Data Subject Application Form available on our website and, pursuant to Article 11 and Paragraph 1 of Article 13 of KVKK and the Communiqué on Principles and Procedures for Applying to Data Controllers, delivering it
by personally visiting our Company located at the address Maslak Mah. Maslak Meydan Sok. Beybi Giz Plaza No:1 Kat:4 Sarıyer 34485 Istanbul, Turkey
in writing through a notary public or with registered letter with return receipt in order for us to ensure your identification and not to give information to wrong persons
by sending an email to [email protected] using your electronic mail address previously shared by you with our Company and registered in our systems (if any)
or by using the other methods to be determined by the Board in the future.
8. Retention Period for Personal Data
The Company deletes, destroys, disposes of or anonymizes the personal data if the processing purpose for personal data is no longer applicable and if the mandatory retention periods for the same under the Laws and other related legislation have ended.
9. Changes and Updates
This clarification text is prepared pursuant to the Personal Data Protection Law No. 6698 and other related legislation. Changes may be made in this clarification text in line with any change in the related legal legislation and/or the purposes and policies of the Company regarding personal data processing.