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Personal Data Protection & GDPR Compliance Policy

Privacy Governance · GDPR · KVKK · Corporate Compliance

Personal Data Protection and GDPR Compliance Policy

Transparent Processing · Lawful Basis · Security Controls · Data Subject Rights

Atabaş Group is committed to processing personal data lawfully, fairly, securely and transparently. This policy explains how we collect, use, store, protect and manage personal data in connection with our business operations, website activities, commercial relationships and communications, in line with the General Data Protection Regulation, Regulation (EU) 2016/679, and applicable Turkish personal data protection rules, including Law No. 6698 on the Protection of Personal Data, KVKK, where relevant.

GDPREU 2016/679
KVKKLaw No. 6698
7Core Data Rights
2026Current Revision

Quick Reference

  • Policy ScopeWebsite visitors, customers, suppliers, partners, applicants, contacts
  • Main Legal FrameworkGDPR, KVKK, applicable commercial and tax rules
  • Core Lawful BasesConsent, contract, legal obligation, legitimate interests
  • Main Data CategoriesIdentity, contact, business, technical, transaction, communication
  • International TransfersRestricted, documented and safeguarded where required
  • Security MeasuresAccess controls, encryption, review, training, vendor controls
  • Data RetentionOnly for as long as necessary and legally required
  • Data RightsAccess, rectification, erasure, restriction, objection, portability, consent withdrawal
  • Contact Email[email protected]
  • Last Updated9 March 2026
Policy Objective

A governance standard built on clarity and accountability

A strong data protection page should not read like a generic template. It should explain what is processed, why it is processed, on what legal basis, for how long, with what safeguards and with what rights available to individuals.

This policy is designed to provide a clear and practical explanation of Atabaş Group's personal data protection approach. It applies to personal data processed through our website, contact channels, commercial relations, supplier and customer workflows, recruitment interactions, service and support communications and related business administration processes. It also supports broader privacy governance by aligning operational practice with transparency, data minimization, purpose limitation, storage limitation, integrity and confidentiality principles.

Where local law imposes additional or stricter requirements, we interpret and apply this policy in a way that supports lawful and responsible processing. Nothing in this page is intended to reduce or override rights granted under applicable data protection legislation.

Responsible data protection is not only a legal obligation. It is a trust obligation that strengthens commercial credibility, corporate governance and digital integrity.

Who This Policy Covers

Scope of application, defined with precision

This section keeps the practical scope of the current page, then refines it into a more accurate corporate compliance format.

Category 01
Customers and prospective customers

Individuals acting on behalf of buyers, importers, suppliers, distributors and business contacts who submit inquiries, communicate with us or participate in commercial transactions.

Category 02
Suppliers, service providers and partners

Individuals whose personal data appears in vendor onboarding records, contractual communications, compliance checks, logistics coordination and invoicing related processes.

Category 03
Website visitors and form users

Individuals who browse our website, submit contact requests, use product request forms, manage cookie preferences or interact with web based communication features.

Category 04
Job applicants and professional contacts

Individuals who submit applications, professional profiles, business credentials or introductory documents in connection with employment or collaboration opportunities.

Category 05
Representatives and authorised persons

Company officers, signatories, beneficial owners, delivery contacts or authorised representatives whose information may be processed during contractual and compliance workflows.

Category 06
Other individuals linked to lawful business activity

Any person whose data is reasonably necessary for documented business administration, legal compliance, dispute management, website security or legitimate operational review.

What We Process

Personal data categories, without over collection

Only data that is relevant to a legitimate business or legal purpose should be processed. This section expands the current page but stays within realistic and necessary categories.

Data CategoryExamplesTypical Context
Identity DataName, surname, title, company role, signature authority details where requiredCommercial communication, contracts, verification, onboarding
Contact DataEmail address, phone number, mailing address, company contact detailsSupport, sales, logistics, relationship management
Business and Professional DataCompany name, trade role, tax or registration related information, business credentialsSupplier and customer management, due diligence, documentation
Transaction DataOrders, quotations, invoice data, delivery records, payment related referencesCommercial execution, accounting, legal retention
Communication DataEmails, inquiry forms, complaint messages, meeting notes, service interactionsRelationship handling, record keeping, dispute prevention
Technical and Usage DataIP address, browser type, device information, cookie selections, website logsWebsite security, analytics, consent management, performance
Recruitment DataCV details, career history, references, education and application correspondenceCandidate review and recruitment administration
Compliance and Verification DataScreening results, documentary checks, authority verification, sanctions related review recordsRisk management, legal compliance, controlled commercial onboarding
Data minimization principle: We aim to collect only the data reasonably necessary for the stated purpose, and we do not intentionally request irrelevant or excessive personal information.
Why We Process Data

Purpose limitation, set out clearly

Good privacy governance requires that purposes be specific enough to be understood, yet broad enough to reflect real corporate operations.

Purpose 01
Providing products and services

To manage inquiries, quotations, product request workflows, contracts, shipments, invoicing, customer support and related transaction administration.

Purpose 02
Maintaining commercial communication

To respond to messages, coordinate with buyers and suppliers, arrange meetings, follow up on requests and maintain professional business relations.

Purpose 03
Meeting legal and regulatory obligations

To comply with tax, accounting, commercial, customs, sanctions screening, dispute management and other lawful obligations that apply to our operations.

Purpose 04
Managing website security and performance

To protect our website, prevent misuse, maintain security logs, improve performance and manage consent choices for cookies and related technologies.

Purpose 05
Conducting internal administration

To keep business records, manage vendor relations, maintain document history, support audits and administer corporate operations responsibly.

Purpose 06
Sending updates where permitted

To provide newsletters, insights, event notices or promotional communication when the applicable legal basis exists, including consent where required.

Lawful Basis

The legal grounds that support processing

This section translates the current legal basis list into a stronger policy structure aligned with GDPR Article 6 and comparable lawful basis principles under applicable law.

Lawful BasisHow It AppliesExamples
ConsentWhere an individual gives a clear, informed and voluntary permissionOptional marketing messages, certain cookie categories, voluntary subscription activity
Contractual NecessityWhere processing is needed to enter into, perform or manage a contractQuotation handling, order execution, delivery coordination, payment administration
Legal ObligationWhere we must process data to comply with a legal dutyAccounting retention, tax records, regulatory responses, lawful authority requests
Legitimate InterestsWhere processing is reasonably necessary for a legitimate business purpose and does not override individual rightsCorporate communication, website security, fraud prevention, document management, limited B2B relationship administration
Legal Claims and DefenceWhere necessary to establish, exercise or defend legal rightsDispute handling, evidence preservation, claim response
Important: Where consent is used as the legal basis, consent may be withdrawn at any time without affecting processing already carried out lawfully before the withdrawal.
Sharing and Transfers

How data may be disclosed, only when justified

Data sharing should be limited, purposeful and subject to legal or operational necessity. This section refines the current page into a more credible disclosure model.

Permitted Recipients
Service providers and operational partners

Personal data may be shared with carefully selected service providers such as technology vendors, hosting providers, accountants, legal advisers, logistics providers, payment related service partners and similar business processors, but only where the disclosure is relevant and contractually controlled.

Permitted Disclosures
Authorities and legal process

Where required by law, court order, regulatory obligation or legitimate legal process, data may be disclosed to competent authorities, auditors or enforcement bodies within the scope of the applicable legal requirement.

Where personal data is transferred outside the European Economic Area or outside the primary jurisdiction of collection, such transfers are handled only where there is an appropriate legal basis and adequate safeguards, such as adequacy decisions, standard contractual clauses, contractual protections, technical security controls or another lawful transfer mechanism recognised by applicable law.

Transfer principle: We do not treat international transfers as routine. They are assessed according to operational necessity, destination risk, legal basis and available safeguards.
Retention and Deletion

Storage limitation with documented rationale

Retention periods should reflect legal necessity, operational relevance and defensible record keeping. This section improves the current page with more structured examples while avoiding rigid promises where context may vary.

Record TypeIllustrative Retention LogicTypical Basis
Contracts, invoices and transaction recordsRetained for the period required by accounting, tax, audit and legal record keeping obligations, often up to 7 years or longer where claims requireLegal obligation, contractual necessity, legal defence
Inquiry and business correspondenceRetained only for as long as relevant to business relationship management, follow up or legal record needsLegitimate interests, contractual necessity
Marketing communication recordsRetained until consent is withdrawn, objection is raised or the record is no longer operationally necessaryConsent, legitimate interests where lawful
Website logs and security recordsRetained for a limited period appropriate to security, troubleshooting, misuse prevention and legal needsLegitimate interests, legal obligation where relevant
Recruitment recordsRetained for the duration of the recruitment process and a limited follow up period unless a longer retention basis existsLegitimate interests, pre contractual steps, consent where appropriate

When personal data is no longer required, we aim to delete, anonymise or securely archive it in accordance with legal and operational requirements. Retention periods may vary where legal claims, audits, investigations or regulatory preservation duties apply.

Data Subject Rights

Rights that individuals can exercise with confidence

This section preserves the rights already mentioned on the live page, then expresses them more clearly and with a stronger corporate compliance structure.

Right 01
Access

You may ask whether we process your personal data and request access to the relevant information, subject to lawful limitations.

Right 02
Rectification

You may request correction of inaccurate, outdated or incomplete personal data that relates to you.

Right 03
Erasure

You may request deletion of personal data where a legal basis for continued processing no longer exists, subject to lawful exceptions.

Right 04
Restriction

You may request that processing be limited in certain cases, for example while accuracy or objection issues are being assessed.

Right 05
Portability

Where legally applicable, you may request transfer of certain personal data in a structured and commonly used format.

Right 06
Objection and consent withdrawal

You may object to certain processing activities, especially direct marketing, and you may withdraw consent where consent is the relevant legal basis.

How to exercise your rights: You can submit your request using the contact details listed in this policy. We may ask for reasonable identity verification before disclosing personal data or taking action on a request.
Security Measures

Protecting personal data through technical and organisational controls

A good policy should explain not only rights and legal bases, but also how protection is operationally maintained.

01
Access is limited on a need to know basis
Access to personal data is restricted to authorised personnel, contractors or service providers whose role requires such access for a legitimate and controlled purpose.
02
Transmission and storage are protected
Where appropriate, we use secure transmission methods, hosting protections, controlled storage environments and related safeguards to reduce the risk of unauthorised access or loss.
03
Systems and processes are reviewed
We maintain internal review practices, update workflows and reasonable monitoring measures aimed at reducing security weaknesses, operational errors and uncontrolled disclosure.
04
Third party relationships are considered carefully
Where processors or service providers handle personal data on our behalf, we expect appropriate contractual, confidentiality and security commitments proportionate to the service being provided.
05
Training and awareness are part of governance
Data protection is supported by internal awareness, controlled handling practices and documented escalation paths for privacy and security concerns.
Cookies and Website Tracking

Consent based web preferences, with user control

The current page refers users to the cookie policy. This version keeps that structure while making the role of cookies clearer.

Our website may use cookies, local storage elements, analytics tools and similar technologies to support essential site functions, remember user preferences, measure performance and, where permitted, improve communication and user experience. Not all cookies serve the same purpose. Some are strictly necessary, while others rely on your consent depending on applicable law and configuration.

You may be able to accept, reject or customise certain categories of cookies through our consent interface. For more detailed information about cookie categories, retention logic and browser level controls, please refer to our dedicated Cookie Policy page.

Governance and Complaints

Escalation paths and regulatory recourse

An effective GDPR page should explain what happens if a person has a concern, and where they may turn if they remain dissatisfied.

Internal Route
Contact us first for review

We encourage individuals to contact us directly so we can review the concern, verify the relevant processing context and respond in a practical and documented manner.

External Route
Right to complain to a competent authority

Where permitted by law, individuals may lodge a complaint with the competent supervisory or data protection authority in the jurisdiction that applies to their case.

Contact Details

How to contact us about privacy matters

This section keeps the verified contact points already visible on the live page and reorganises them into a more refined legal page format.

Contact ChannelDetails
Email[email protected]
Main Phone+90 532 065 99 52
Office Phone+90 216 422 24 74
AddressKüplüce Mahallesi Atlas Çiçeği Sokak No: 26/1, Üsküdar, İstanbul, Türkiye
Additional Corporate PresenceÜmraniye and Beşiktaş, İstanbul, and selected international contact presence as published on the website

When contacting us regarding privacy matters, please provide enough detail to identify the relevant relationship, communication or transaction context so that your request can be reviewed accurately.

Frequently Asked Questions

Practical answers for data protection questions

FAQ structure improves readability, search relevance and AI interpretation without adding claims that go beyond the actual policy scope.

Does this policy apply only to website users?

No. It applies more broadly to personal data processed in connection with website use, commercial relations, supplier and customer communications, recruitment processes and related business administration activities.

Does Atabaş Group process personal data for marketing?

Marketing related processing may occur where a lawful basis exists, including consent where required. Individuals can object to direct marketing or withdraw consent where consent is the applicable basis.

Can data be transferred internationally?

Yes, where operationally necessary and legally permitted. Such transfers are assessed carefully and are expected to be supported by appropriate safeguards and security measures.

How long is personal data kept?

Retention depends on the nature of the record, the legal basis for processing and applicable legal obligations. We aim not to keep personal data longer than necessary for the relevant purpose.

How can I exercise my GDPR or privacy rights?

You can contact us using the details listed in this policy. We may ask for identity verification or supporting context before taking action on a request.

Will this policy be updated?

Yes. We may update this page to reflect legal, regulatory, operational or website related changes. The most recent version will be the version published on our website.

Need assistance with a privacy related request?

Contact Atabaş Group for questions regarding data protection, privacy rights and lawful processing

Last updated, 9 March 2026

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