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Communication Consent Text

1. PURPOSE
As KALEİÇİ TATLICISI GIDA SANAYİ VE TİCARET AŞ (MİLKLAC), we respect the privacy of your personal data and prioritize data security. Ensuring the confidentiality, collection, processing, and protection of personal data belonging to our customers, potential customers, website users, employees, employee candidates, former employees, interns, company shareholders, company executives, business partners, group company employees, and visitors is among our company’s top priorities. We adopt the principles set out in the Law No. 6698 on the Protection of Personal Data (KVKK). Therefore, we recommend that you carefully read this text, which explains how we process your personal data, with whom we share it, and how you can exercise your rights. All personal data of individuals associated with KALEİÇİ TATLICISI GIDA SANAYİ VE TİCARET AŞ (MİLKLAC), including service users, may be collected, stored, updated, and processed as long as the relationship continues, and may be shared with third parties, provided it complies with the law, is fair, for specific, explicit, and legitimate purposes, and in accordance with the Law No. 6698. As defined by the law, we act as a “Data Controller” and determine the information we obtain within the scope of our relationship with you.

2. DEFINITIONS
In this clarification text:

Personal Data: Any information relating to an identified or identifiable natural person.
Processing of Personal Data: Any operation performed on personal data, whether by automatic means or as part of a data recording system, such as collection, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, retrieval, classification, or prevention of use.
KVKK: Law No. 6698 on the Protection of Personal Data, published in the Official Gazette on April 7, 2016.
Authority: Personal Data Protection Authority.
Board: Personal Data Protection Board.
Data Processor: A natural or legal person who processes personal data on behalf of the data controller.
Data Controller: A natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.
Data Subject: The individual whose personal data is being processed.
Contact Person: The person ensuring communication with the Authority and data subjects. This person is not a representative of the Data Controller and is not authorized to act on behalf of the Data Controller.

3. DATA CONTROLLER
Data Controller: KALEİÇİ TATLICISI GIDA SANAYİ VE TİCARET AŞ (MİLKLAC)
Address: AOSB 1st Part, 6th Street, External Door No: 6/1 6/2 (excluding 6/3), Döşemealtı / ANTALYA
Phone: +90 549 170 91 91
Email: kvkkbilgi@milklac.com

4. IMPLEMENTATION
As KALEİÇİ TATLICISI GIDA SANAYİ VE TİCARET AŞ (MİLKLAC), we are committed to protecting the personal data of customers, potential customers, website users, employees, employee candidates, former employees, interns, shareholders, company officials, business partners, dealers, dealer employees, visitors, and third parties. We comply with the Turkish Constitution, international agreements to which Turkey is a party, and primarily the KVKK. We process personal data in accordance with the law, relevant, limited, and proportionate to our activities and purposes. Data may be transferred domestically or internationally, stored, used for profiling, and classified.

5. PURPOSE OF PROCESSING PERSONAL DATA
In accordance with Articles 4, 5, and 6 of the KVKK, your personal data may be processed:

In cases explicitly stipulated by law,
For the performance or establishment of a contract,
To fulfill legal obligations,
To establish, exercise, or protect a right,
Based on legitimate interests,
Or with your explicit consent if the legal grounds do not apply.
All personal data shall be:

Processed lawfully and fairly,
Accurate and up to date,
For specific, explicit, and legitimate purposes,
Relevant, limited, and proportionate to the purposes,
Retained as long as required by law or for the purpose of processing.
Purposes include but are not limited to:

Occupational health and safety,
Planning and tracking business with partners, suppliers, or dealers,
Managing customer records and relations,
Handling customer requests and complaints,
Business continuity,
Monitoring contracts and legal processes,
Ensuring legal and commercial security,
Service improvement,
Market research,
Customer loyalty activities,
Conducting operations and audits,
Managing finance and accounting,
Complying with legal reporting requirements,
Managing job and internship applications and processes,
Creating HR files,
Complying with labor laws and obligations,
Providing training,
Ensuring physical and information security,
Risk management.

6. METHODS AND LEGAL GROUNDS FOR DATA COLLECTION
Personal data may be collected through verbal, written, or electronic means—automatic or non-automatic—via: contact forms, business cards, supplier forms, contracts, job applications, resumes, emails, websites, mobile apps, consumer complaint forms, and from third parties.
We process your data based on:

Article 5/2-c: For the establishment and performance of a contract
Article 5/2-ç: To fulfill legal obligations
Article 5/2-f: For our legitimate interests
Or your explicit consent if required.

7. TRANSFER OF PERSONAL DATA
Your personal data may be transferred, with appropriate safeguards, to:

Authorized public institutions,
Financial intermediaries,
Independent audit firms,
Travel agencies for business trips,
Business partners,
Suppliers,
Shareholders,
Domestic/international affiliates,
Other third parties, based on legal grounds and contracts.

8. DATA STORAGE AND DESTRUCTION
Personal data is retained for legally mandated durations. These durations are detailed in our personal data inventory. Data is stored physically or electronically with security measures. Once the storage period ends, data is destroyed every 6 months via deletion, destruction, or anonymization.

9. YOUR RIGHTS AS A DATA SUBJECT
Under Article 11 of the KVKK, you have the right to:

Learn whether your data is processed,
Request information if it is,
Learn the purpose of processing,
Know third parties to whom it is transferred,
Request correction if it’s incomplete/incorrect,
Request deletion or destruction,
Request notification to third parties of any correction or deletion,
Object to unfavorable outcomes due to automated processing,
Request compensation for damages due to unlawful processing.
You may exercise these rights by submitting a request via:

A written petition with identity and address information (including proof of identity), or
Filling out the contact form at www.milklac.com,
and sending it to our address or emailing kvkkbilgi@milklac.com.
Your request will be answered within 30 days free of charge or at the rate determined by the Board.
According to Article 14 of the KVKK, if your request is rejected or deemed insufficient, or if no response is received, you may file a complaint with the Board within 30 days of receiving the response or within 60 days of the application.

Under Article 28/2, the rights above do not apply in cases such as:

Data processing for prevention or investigation of a crime,
Public data processing by the data subject,
Supervision or regulatory duties of authorized institutions,
Budget, taxation, and financial matters related to national interests.

10. OTHER PROVISIONS
Legal regulations in force take precedence in all matters relating to the processing and protection of personal data. This Clarification Text is published on www.milklac.com and may be updated to comply with changing conditions and regulations.

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