Personal Data Protection Law

Personal Data Protection Law

Makam Group Personal Data Protection Clarification Text,

This clarification text has been prepared by Makam Grup, as the data controller, within the scope of Article 10 of the Personal Data Protection Law No. 6698 ("Law") and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Disclosure Obligation.

1. Data Controller

processes the personal data of Employees, Employee Candidates, Owners, Interns, Supplier Employees, Supplier Officials, Product or Service Recipients and Visitors in the categories reported to the verbis system, taking into account the issues regarding the privacy of private life. In accordance with the law, the extent to which data may be processed by Makam Grup as the data controller is explained in this information text (“Information Text”).

2.What is the Collection Method and Legal Reason for Personal Data?

Personal information, including special personal data, including health information, is obtained by fully or partially automated or non-automatic means, provided that it is part of any data recording system, from the relevant person himself, from systems that can detect location and from the official of the company where the supplier employees work. Personal data may be processed domestically and abroad for the purposes listed below, in accordance with the basic principles stipulated by the Law, and with the real and legal persons specified in this Information Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law. can be transferred.

3.What are the Situations Where the Data Controller Can Process Personal Data Without Explicit Consent, Pursuant to the Law?

In accordance with Article 5 of the Law, Makam Grup may process the personal data it has received in accordance with the law, without requiring explicit consent, in the following cases:

In cases where it is clearly provided for by law,

  • If the Personal Data Owner is unable to express his/her consent due to actual impossibility, or in cases where the consent is not given legal validity, it is necessary to process personal data to protect the life or physical integrity of the Personal Data Owner or someone else,
  •  It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or execution of a contract concluded between Makam Grup and the Personal Data Owner,
  •  It is mandatory to fulfill a legal obligation with Makam Grup ,
  • Personal data has been made public by the Personal Data Owner,
  • Data processing is mandatory for the establishment, exercise or protection of a right,
  • It is mandatory to process data for Makam Grup's  legitimate interests, provided that it does not harm fundamental rights and freedoms .
  • In addition, in accordance with Article 6 of the Law, Makam Grup  may process special personal data it has received in accordance with the law, without requiring explicit consent, in the following cases:

  • Data regarding individuals' race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data of special quality is personal data.
  • Special categories of personal data, other than the health and sexual life of the personal data owner, are stipulated by law,
  • Special personal data regarding the health and sexual life of the personal data owner can only be used by persons or authorized institutions and organizations under the obligation of confidentiality for the purpose of protecting public health, carrying out preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and their financing. be by.

4.What are the Purposes of Processing Personal Data?

Personal data;

  • Conducting Employee Candidates and Internship Application Processes
  • Fulfillment of Employment Contract and Legislation Obligations for Employees
  • Execution of Fringe Benefits and Benefits Processes for Employees
  • Conducting Educational Activities
  • Execution of Access Authorizations
  • Conducting Activities in Compliance with Legislation
  • Conducting Finance and Accounting Affairs
  • Ensuring Physical Space Security
  • Execution of Assignment Processes
  • Follow-up and Execution of Legal Affairs
  • Carrying out Communication Activities
  • Planning Human Resources Processes
  • Execution/Audit of Business Activities
  • Carrying out Occupational Health / Safety Activities
  • Execution of Service Purchasing Processes
  • Execution of Service After-Sales Support Services
  • Execution of Service Sales Processes
  • Conducting Performance Evaluation Processes
  • Execution of Contract Processes
  • Execution of Wage Policy
  • Providing Information to Authorized Persons, Institutions and Organizations
  • Creating and Tracking Visitor Records

It can be processed by Makam Grup  and other real and/or legal persons specified in Article V for the purpose of

5. To whom is personal data transferred and for what purpose? The personal data collected is transferred to legally authorized public institutions and organizations, natural persons or private law legal entities, authorities, in accordance with the basic principles stipulated by the Law and the personal data transfer conditions specified in Articles 8 and 9 of the Law and for the following purposes. It can be transferred to companies/organizations that will establish a business contract with the Grup  and their business partners, suppliers and service providers.



  • Follow-up and Execution of Legal Affairs
  • Obtaining permissions for personnel to work in the field and carrying out assignment processes
  • Subscription Initiation and Notification of Payment of Invoices
  • Ensuring Physical Space Security,
  • Providing Information to Authorized Persons, Institutions and Organizations
  • Telephone Line Supply
  • Providing Access Authorizations to Business Partners' Software
  • Meeting Tender Entry Requests
  • Fulfillment of Legal Obligations
  • Making SSI Notifications
  • Performing Card Printing
  • Opening Corporate User Accounts
  • Making Personnel Salary Payments
  • Execution of Contract Processes
  • Keeping intern attendance records
  • Creation of E-Prescription after diagnosis

By Makam Grup; Foreign countries that have been declared to have adequate protection by the KVK Board (“Foreign Country with Adequate Protection”) or, in case there is no sufficient protection, foreign countries where the data controllers in Turkey and the relevant foreign country have committed in writing to adequate protection and have the permission of the KVK Board. Personal data can be transferred to countries (“Foreign Country Where the Data Controller Committed to Adequate Protection”).


6.What are the Rights of the Personal Data Owner?


Learning whether personal data is being processed or not,

  • Requesting information if personal data has been processed,
  • Learning the purpose of processing personal data and whether they are used for their intended purpose,
  • Knowing the third parties to whom personal data is transferred at home or abroad,
  • Requesting correction of personal data if it is incomplete or incorrectly processed,
  • Requesting the deletion or destruction of personal data in case the reasons requiring processing of personal data are eliminated in order to be evaluated within the principles of purpose, duration and legitimacy, Requesting the deletion or destruction of personal data,
  • To request the deletion, destruction or anonymization of personal data in case the reasons requiring processing are eliminated, even though it has been processed in accordance with the Personal Data Protection Law No. 6698 and other relevant legal provisions.
  • To request that transactions regarding the correction, deletion or destruction of personal data be notified to third parties to whom personal data has been transferred,
  • Objecting to the emergence of a result that is unfavorable to the individual by analyzing the processed data exclusively through automatic systems,
  • In case of damage due to unlawful processing of personal data, they have the right to demand compensation for the damage.


7.How Does the Personal Data Owner Exercise His Rights?

In accordance with Article 11 of the Law, in order to exercise the above-mentioned rights that the Personal Data Owner has, he/she must fill out the application form completely and submit it to Makam Grup through the channels specified in the form  .

Makam Grup  will finalize the request free of charge as soon as possible and within thirty (30) days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, Makam Group  reserves the right to charge the fee at the tariff determined by the Personal Data Protection Board.


8.How Long Will Personal Data Be Processed?

In accordance with the Law, personal data processed for the purposes specified in this Information Text will be deleted by  Makam Grup when the purpose requiring processing in accordance with Article 7 of the Law no longer exists and/or when the statute of limitations required for the processing of data by Makam Grup in accordance with the legislation expires.It will be destroyed or will continue to be used by anonymizing it.