This General Privacy Notice (hereafter the “Notice”) is maintained by Atabaş Grup Dış Tic. Ltd. Şti., a company established under the laws of the Türkiye, with its principle place of business at its Head Quarters, located at YALI MAH. TAYLAN SK. KUZEY YILDIZ C BLOK NO: 6 İÇ KAPI NO: 6 MALTEPE/ İSTANBUL, (Telephone: +90 532 065 99 52) and its wholly owned affiliates (“ATABAS” or “we”, “us”, “our”).
ATABAS is committed to protect and respect your privacy. ATABAS will only collect and process personal data to the extent it is permitted to do so and with your consent (where required by applicable laws and regulations), and will process personal data in a lawful, fair, and transparent manner.
This Notice explains what personal data we collect, for what purpose, to whom we disclose the data, and for how long we keep the data. Additionally, we describe your rights and how you can invoke them. By “personal data” we mean any information through which we can identify you as an individual (e.g. name, telephone number, email or other related information) including sensitive personal data.
This Notice provides information regarding the uniform minimum standard for ATABAS with respect to protection of Personal Data worldwide. Where local laws require stricter standards than those described in this Notice the stricter standards prevail.
WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?
- (Prospective) customers or suppliers and contact persons or representatives of (prospective) customers or suppliers: In order to establish and maintain a business relationship with you we process the following personal data:
- contact information (such as title, name, email, phone, business name, business address, role, industry);
- identifying, authenticating, location and/or professional data (such as completed supplier due diligence or confirmation of screening process);
- financial information (such as bank account or invoicing details); and
- other personal data you disclose in the course of your relationship with ATABAS.
- Website visitors and newsletter subscribers:
- Contact information (name, email, preferences) when you sign up to receive our newsletter;
- Account information (account username, password, contact details, country, business name, function, industry, photo, the services you request through your account, and other information you choose to share with ATABAS) when you register and use online services provided by ATABAS such as the ATABAS Simulation Portal or ColorXpress (“Online Services”); and
- Visitors to ATABAS premises or attendees at ATABAS webinars and events:
- contact information (such as name, email, business address, role);
- video surveillance footage and/or access records (recorded on ATABAS premises by the use of video surveillance equipment (CCTV) or access logging systems)
In addition, ATABAS will only process personal data for the purpose for which it is collected. We will not use your contact information for product or promotional advertising unless you have specifically requested to receive product information.
If you provide us with personal data about other individuals, please ensure that they have given you consent to do so and that they are aware of our Notice.
FOR WHAT PURPOSES AND LEGAL BASES DO WE USE YOUR PERSONAL DATA?
Certain laws, including the EU General Data Protection Regulation (“GDPR”), require that we inform you of the legal bases for our processing of your personal data. In such cases, ATABAS will only process personal data when it has a legal basis for doing so. In particular, ATABAS processes your personal data when the processing is needed for the performance of our contract with you, when ATABAS is legally obliged to do so, or when the processing is necessary for the legitimate interests of ATABAS (or those of third parties). Where required by applicable law, ATABAS will also obtain your consent to process your personal data.
Purposes of processing:
We will process your data for specific and limited purposes which are linked to a legal basis set out above. These purposes are:
- For the performance of our agreement with you: such as to carry out the support and services under the commercial agreement that we concluded or will conclude with you on behalf of your company, for the purposes of billing or invoicing, communicating with you in relation to the agreement, product delivery, processing orders, purchasing materials, supplies and equipment, completing supplier due diligence and customer screening processes, licensing agreements and non-disclosure agreements, etc.
- To comply with legal obligations: monitoring and ensuring compliance with applicable laws and regulatory requirements, communications relating to such obligations, and responding and complying with lawful requests by regulators and law enforcement.
- For ATABAS’s legitimate (business) purposes: such as to manage our internal client database in order to maintain contact with clients and prospects, to keep track of our financials and services, to operate and expand our business activities and services, to develop and improve our services and products, to undertake market research, to improve the effectiveness of our marketing, to engage with third party contractors, suppliers and business partners, to host promotional activities, webinars and events, to offer our Online Services, to operate company policies and procedures, to maintain standards of safety and security in our systems and premises, to resolve disputes or manage enquiries and to enable ATABAS to make corporate transactions.
- To protect our rights: to protect our sites and business operations including to prevent and detect fraud, unauthorized activities and access, or other misuse where we believe it is necessary to investigate, prevent or take action regarding illegal activities, or in cases of suspected fraud or situations involving potential threats to the safety or legal rights of any person or third party, or violations of our agreements or this Notice.
- To communicate with you about ATABAS’s products and activities: to provide newsletters or otherwise contact you about our products or services. We may send you marketing information based on information you have provided to us, products and services that you have previously purchased, or your use of any Online Services which you have registered for (for example, documents or services which you have requested). If you are located in a jurisdiction that requires consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them. In such case, you may opt-out of receiving such marketing messages at any time by following the instructions in the communication you received from us. You may also control your marketing preferences via your profile settings on the Online Services or by reaching out to us using the contact details provided in part 8 (“What are your rights?”) below.
WHAT DO WE DO TO PROTECT YOUR PERSONAL DATA?
ATABAS has taken reasonable and appropriate technical, physical, and organizational measures to protect your personal data against unauthorized access or disclosure, unlawful processing, accidental loss or damage, and unauthorized destruction. Including as appropriate measures such as applying access controls, providing security awareness and training for personnel, setting up security breach procedures, undertaking audits, and implementing controls around data integrity, storage and transmission and disposal of data.
ATABAS requires third party service providers, who process personal data on its behalf, to implement similar security and confidentiality measures.
TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA AND WHY?
To fulfill the purposes above, ATABAS may need to disclose to, transfer or otherwise share your personal data with other ATABAS entities or with a third party. In general, we may disclose, transfer or otherwise share personal data as follows:
- With ATABAS group entities: ATABAS is a global company, your personal data may be shared amongst our affiliated and subsidiary companies, who are subject to this Notice when processing your personal data.
- With service providers: ATABAS may disclose personal data to third party service providers where is it necessary for the provision of a services. These services include data storage and analytics, for web hosting, IT technology, infrastructure and security, handling payment transfers, advisory services, maintenance and other similar services. When ATABAS outsources processing activities, it will ensure the service provider is bound to implement and maintain adequate data protection and security measures and will comply with applicable privacy laws.
- With advertising and marketing partners: ATABAS works with third-party companies to display online advertising that is more relevant. These companies may collect cookie IDs, IP address and other identifiers as well as information about the pages you visit on our sites and other websites, to enable them to display advertising for products and services that may be of interest to you when you visit our website or other websites. For more information about this please refer to section 6.
- Where required by law or to protect our rights: In certain instances and where permitted by applicable law ATABAS may be required to disclose your personal data to comply with legal requirements such as to comply with tax authorities or binding requests from other law enforcement authorities or to protect ATABAS’s legal rights such as to defend a legal claim where permitted by applicable law.
- As part of a corporate transaction: Further, if a ATABAS business unit is sold or transferred as part of a corporate transaction it may be necessary to disclose your personal data to a purchasing entity including related to due diligence conducted prior to such event where permitted by applicable law.
We may share aggregate or anonymous information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA?
In some instances, ATABAS may share personal data to group affiliates or other entities and service provided in countries outside your resident jurisdiction. These countries may have data protection laws that are different to the laws of your country, and in some cases, may not be as protective. In such cases, ATABAS takes measures to ensure an appropriate level of data protection and security including to implement adequate safeguards (and, where necessary, supplementary measures) to ensure that personal data is afforded a level of protection which is essentially equivalent.
COOKIES AND TRACKING
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
As required by law, we will only hold your personal data for as long as necessary to fulfill the purposes for which the data is collected before making it non-identifiable (anonymous) or deleting it. This applies unless there is a contractual or legal requirement to retain data for a longer period (such as required by trade or tax regulations or to defend a legal claim).
WHAT ARE YOUR RIGHTS?
ATABAS is committed to transparently processing your data. Depending upon your jurisdiction and subject to applicable local laws, you have several rights in relation to personal data processed by ATABAS. For example, you may have the right to (subject to limitations) to (i) request access to your personal data or for information about how it is processed, (ii) request rectification/correction, restriction or erasure of such personal data; and (iii) request that the personal data is transmitted to another data controller. Under certain conditions, you may also object to the processing of your personal data or restrict the processing, or deregister your account.
If you have given consent for processing your personal data, you have the right to withdraw your consent. Please note that a withdrawal of consent does not affect the lawfulness of any processing which has taken place prior to your consent being withdrawn and that we can only action your request in accordance with applicable law.
If you wish to exercise your rights, please send your request by email to firstname.lastname@example.org.
ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA
If you are a California resident, please see the additional information regarding the California Consumer Privacy Act (CCPA).
HOW CAN YOU FILE A COMPLAINT?
If you have a complaint regarding the manner in which ATABAS processes your personal data, or suspect that a personal data breach has occurred, please contact us at email@example.com and provide sufficient details for us to revert to you. If, in your view, the complaint is not dealt with satisfactory or you are unsatisfied with how we process your personal data, you may have the right to lodge a complaint with the Data Protection Supervisory Authority established in your country of residence or where you believe your rights have been infringed.
HOW CAN YOU CONTACT US?
ATABAS reserves the right to modify this Notice, for example to comply with changes in laws, regulations, or requirements imposed by local data protection authorities. Any changes will be published and made available here.
CHANGES TO THIS NOTICE
This Notice may be amended due to changes of relevant laws and regulations, changes of terms and conditions, technical reasons, or any other reasonable basis. We will notify you and seek your consent to changes to this Notice where required to do so by applicable laws.