DESONYX PERSONAL DATA PROTECTION AND PROCESSING POLICY
1. Purpose and Scope
DESONYX makes every effort to comply with all applicable legislation regarding the processing and protection of personal data.
Within the framework of Desonyx Personal Data Protection and Processing Policy ("Policy"), the principles adopted by Desonyx in the conduct of personal data processing activities are explained.
The Policy aims to ensure the sustainability of Desonyx's "principle of conducting company activities in accordance with the law and honesty rules and in transparency". In this context, the basic principles adopted by Desonyx in terms of compliance of its data processing activities with the regulations in the Law No. 6698 on the Protection of Personal Data ("KVKK") are determined and the practices fulfilled by Desonyx are explained.
The Policy is intended for natural persons whose personal data are processed by Desonyx through automatic or non-automatic means, provided that they are part of any data recording system.
2. Policy Principles
2.1. General Principles
The Policy is published on the website of Desonyx (https://www.desonyx.com/), which is open to the access of personal data subjects. In parallel with the changes and innovations to be made in the legislation, the amendments to be made in the Policy will be made available in a way that data owners can easily access.
In the event of a conflict between the legislation in force regarding the protection and processing of personal data and this Policy, Desonyx agrees that the legislation in force shall apply.
2.2. Groups of Persons Covered by the Policy
The groups of Data Subjects whose personal data are within the scope of the Policy and whose personal data are processed by Desonyx are as follows:
- Employee Candidates
Persons who have not established a service contract with Desonyx but have applied to Desonyx with the intention of establishing one.
- Officials, Employees of Business Partners
Real person officials, shareholders, employees of the organizations with which Desonyx has commercial relations.
- Company Visitors
Natural persons who visit the premises where Desonyx operates or the websites operated by Desonyx.
- Employees
Natural persons who have a service contract with Desonyx
3. Principles Regarding the Processing and Protection of Personal Data
3.1. Compliance with Data Processing Conditions
While carrying out personal data processing activities, the Company acts in accordance with (i) the basic principles set out in Article 4, (ii) the personal data processing conditions set out in Article 5 and (iii) the special categories of personal data processing conditions set out in Article 6 of the KVKK.
3.1.1. Compliance with Basic Principles
(1) Processing personal data in accordance with the law and good faith
The Company carries out its personal data processing activities in accordance with the law and the rule of honesty in accordance with the Constitution of the Republic of Turkey, in particular, the KVKK and the relevant secondary legislation.
(2) Ensuring the accuracy and currency of processed personal data
While carrying out the processing of personal data by the Company, all necessary administrative and technical measures are taken to ensure the accuracy and timeliness of personal data within the technical possibilities. In this context, the Company has established mechanisms to correct and verify the accuracy of personal data of personal data owners in case their personal data is outdated or inaccurate.
(3) Processing personal data in a purpose-related, limited and measured manner
Personal data are processed by the Company in connection with the data processing conditions and for as long as necessary to fulfill the purpose of processing these services. In this context, the purpose of personal data processing is determined before the personal data processing activity is started, and data processing activity is not carried out with the assumption that it may be used in the future.
(4) Retain personal data for the period stipulated in the relevant legislation or required for the purpose for which they are processed
The Company retains personal data limited to the period stipulated in the relevant legislation or required by the purpose of data processing. In this direction, personal data are deleted, destroyed or anonymized by the Company in the event that the period stipulated in the legislation expires or the reasons requiring the processing of personal data disappear. Personal data are not stored by the Company based on the possibility of future use.
3.1.2. Compliance with Personal Data Processing Conditions
The Company carries out its personal data processing activities in accordance with the data processing conditions set forth in Article 5 of the KVKK. In this context, personal data processing activities are carried out in the presence of the personal data processing conditions listed below:
Explicit Consent of the Relevant Person
Personal data processing activity is carried out by the Company in the event that the Data Subject gives his/her consent to the processing of data about him/her, having sufficient information on a particular subject, freely and in a clear manner that leaves no room for hesitation.
The Personal Data Processing Activity is Explicitly Stipulated in the Laws
In the event that there is a clear regulation in the laws regarding personal data processing, the Company may carry out personal data processing activities limited to the relevant legal regulation.
Failure to Obtain the Explicit Consent of the Data Subject Due to Actual Impossibility and Obligation to Process Personal Data
In cases where the Data Subject is unable to disclose his/her consent or his/her consent is not recognized as valid, if it is mandatory to process personal data for the protection of the life or bodily integrity of persons, data processing activity is carried out by the Company within this scope.
The Personal Data Processing Activity is Directly Related to the Establishment or Execution of a Contract
In cases directly related to the establishment or performance of a contract, if it is necessary to process personal data belonging to the parties to the contract, data processing activity is carried out by the Company.
Desonyx
It is Mandatory to Carry Out Personal Data Processing Activities for 's Fulfillment of its Legal Obligation
In the event that the Company, which has adopted it as a Company policy to show the necessary sensitivity in compliance with the law, has a legal obligation, personal data processing activity is carried out to fulfill the legal obligation.
Publicization of Personal Data by the Data Subject
Personal data publicized (disclosed to the public in any way) by the relevant person himself/herself shall be processed by the Company in accordance with the purpose of publicization.
Data Processing is Mandatory for the Establishment, Exercise or Protection of a Right
In the event that the processing of personal data is mandatory for the establishment, exercise or protection of a right, personal data processing is carried out by the Company in parallel with this obligation.
Execution of Personal Data Processing without prejudice to the Fundamental Rights and Freedoms of the Data Subject
It is Necessary for the Legitimate Interests of
In the event that personal data processing is mandatory for the legitimate interests of the Company, data processing activities may be carried out if the fundamental rights and freedoms of the Data Subject will not be harmed. Within this framework, the existence of a balance between the legitimate interests of Desonyx as the "data controller" and the fundamental rights and freedoms of the Data Subject will be sought.
3.1.3. Compliance with Special Categories of Personal Data Processing Conditions
The Company pays special attention to the processing of sensitive personal data. In this context, in the processing of special categories of personal data by the Company, first of all, it is sensitively determined whether the data processing conditions exist, and the data processing activity is carried out after making sure that the legal compliance condition exists.
Sensitive personal data may be processed by the Company in the following cases, provided that adequate measures determined by the Board are taken:
Processing of Personal Health Data
Personal health data may be processed by the Company in the presence of one of the conditions listed below, provided that (i) taking adequate measures to be stipulated by the Ministry of Health, (ii) acting in accordance with general principles and (iii) being under the obligation of confidentiality:
- Existence of the explicit written consent of the Data Subject,
- Protection of public health,
- Preventive medicine,
- Conducting medical diagnosis, treatment and care services,
- Planning and management of health services and financing.
Processing of Sensitive Personal Data other than Health and Sexual Life
Sensitive personal data other than health and sexual life may be processed by the Company upon the explicit consent of the Data Subject or in cases stipulated by law.
3.1.4. Compliance with Personal Data Transfer Conditions
In the personal data transfers to be carried out by the Company, the personal data transfer conditions regulated in Articles 8 and 9 of the KVKK are complied with.
Domestic Transfer of Personal Data
In accordance with Article 8 of the KVKK, the Company acts in accordance with the data processing conditions (See Policy 3.1.) in data transfer activities to be carried out domestically.
Transfer of Personal Data Abroad
Pursuant to Article 9 of the LPPD, personal data may be transferred abroad by the Company; (i) in accordance with the personal data processing conditions (See Policy 3.1.) and (ii) if the country of transfer is one of the countries with adequate protection declared by the Board or if there is no adequate protection in the relevant foreign country, the data controllers in Turkey and in the relevant foreign country undertake an adequate protection in writing and with the permission of the Board.
(3) Groups of Persons to whom Personal Data is Transferred by the Company
In accordance with Articles 8 and 9 of the KVKK, the Company may transfer the personal data of the data owners within the scope of the Policy (See Policy 2.2.) to the groups of persons listed below for the specified purposes:
To third party service providers who process personal data on behalf of the Company, limited to the fulfillment of the Company's commercial activities,
Limited to the business partners of the Company for the purpose of ensuring the establishment and maintenance of the business partnership,
Company suppliers,
Desonyx's limited to the fulfillment of its commercial activities,
Authorized public institutions and organizations and authorized private law persons, limited to the purpose requested within the legal authority of the persons concerned,
To third parties, in accordance with the conditions of personal data transfer.
4. Illumination of Personal Data Owners
In accordance with Article 10 of the KVKK, the Company carries out the necessary processes to ensure that data owners are informed during the acquisition of personal data. In this context, the lighting texts presented by the Company to the data holders are mainly listed below:
(1) Company's title,
(2) For what purpose the personal data of the data owners will be processed by the Company,
(3) To whom and for what purpose the processed personal data may be transferred,
(4) The method and legal reason for collecting personal data,
(5) The person concerned has the following rights;
– Learning whether personal data is processed, and,
– Request information on this if the personal data has been processed,
– To learn the purpose of processing personal data and whether it is used in accordance with their purpose, and,
– Knowing third parties to whom personal data is transferred domestically or abroad, and,
– Request correction of personal data if it is incomplete or incorrectly processed and request notification of the transaction to third parties to whom the personal data is transferred, and,
– Although processed in accordance with the provisions of KVKK and other relevant laws, the reasons that require its processing are eliminated, request the deletion or destruction of personal data and request that the processing is notified to third parties to whom the personal data is transferred, and,
– Object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems, and,
– Request removal of damages if the personal data is damaged due to unlawful processing.
5. Finalization of the Claims of Personal Data Owners
In the event that the data owners submit their requests for personal data in writing to the Company by filling out the application form at https://www.desonyx.com/ and depositing the identity documents, in accordance with Article 13 of the KVKK as the company data controller, according to the nature of the request, it carries out the necessary processes to ensure that it is finalized as soon as possible and within thirty (30) days at the latest.
Within the scope of data security, the Company may request information to determine whether the applicant owns the personal data subject to the application. The Company may also direct questions regarding its application to the Relevant Person in order to ensure that the application of the Relevant Person is concluded in a manner appropriate to the request.
The application of the Person concerned; the possibility of blocking the rights and freedoms of other persons, the fact that it requires a disproportionate effort, the information is a public information, can be rejected by explaining the reason of the Company.
5.1. Rights of Personal Data Owners
In accordance with Article 11 of KVKK, you can make a request by applying to the Company on the following issues:
(1) Learning whether your personal data is processed or not,
(2) If your personal data has been processed, request information about it, and,
(3) To learn the purpose of processing your personal data and whether it is used in accordance with its purpose, and,
(4) Learning third parties to whom your personal data is transferred domestically or abroad, and,
(5) Request correction of your personal data in case of incomplete or incorrect processing and request notification of the transaction made in this context to third parties to whom your personal data is transferred, and,
(6) Although it has been processed in accordance with the provisions of the KVKK and other relevant laws, it, to request the deletion and destruction of your personal data in case of the disappearance of the reasons that require the processing, and to request notification of the transaction made in this context to third parties to whom your personal data is transferred, and,
(7) Object to the emergence of a result against you by analyzing your processed data exclusively through automated systems, and,
(8) Request the removal of damages if you are harmed by the unlawful processing of your personal data.
5.2. Legislation Requirement Conditions Other than the Rights of Personal Data Owners
As per Article 28 of the KVKK, the following states are not covered by the KVKK, it will not be possible for personal data owners to assert their rights in the following matters:
(1) The national defence of personal data, national security, public security, public order, economic security, privacy of private life or personality rights, provided that they do not violate or constitute a crime, art, history, history, processing for literary or scientific purposes or within the scope of freedom of expression.
(2) Processing of personal data for purposes such as research, planning and statistics by making it anonymous with official statistics.
(3) Preventive, conducted by public institutions and organizations that have been mandated and authorized by law to ensure national defense, national security, public safety, public order or economic security of personal data, processing within the scope of protective and intelligence activities.
(4) Processing of personal data by judicial authorities or enforcement authorities in relation to the investigation, prosecution, trial or execution proceedings.
In accordance with Article 28/2 of the KVKK; it will not be possible to assert the rights of the personal data owners, except to request the removal of the damage in the following cases:
(1) Personal data processing is necessary for the prevention of crime or criminal investigation.
(2) Processing of personal data acquired by the Person concerned.
(3) Based on the authority given by the law of personal data processing, by the competent public institutions and organizations and professional organizations that are public institutions, etc, is required for disciplinary investigation or prosecution through the conduct of supervisory or regulatory duties.
(4) Personal data processing is necessary to protect the economic and financial interests of the State in relation to budget, tax and financial matters.
6. Roles & Responsibilities
6.1. The Top Committee for the Protection of Personal Data (KVK)
The European Committee on Chemistry, Protection and Processing of Personal Data is responsible for the implementation of the Policy in all Company-wide activities and processes within the Company and the European Committee on Chemistry KVK. In order to fulfill this responsibility, the Company has established the European Committee for the Protection of Chemical Personal Data, which will provide the necessary coordination within the Company within the scope of ensuring, maintaining and maintaining compliance with the personal data protection legislation within the Company. Meeting under the Presidency of Risk Management Coordinatorship and Head of Financial Affairs, Legal Affairs Presidency, Audit Department, Human Resources Presidency, Turkey, The Committee on the Protection of Personal Data for Desonyx, consisting of representatives from the Coordinator of Corporate Relations and Communication and Information Technologies, will prepare the necessary regulations and guidelines within the scope of KVKKna compliance throughout Desonyx. All employees of Desonyx and its implementation of Politics.
6.2. The Company KVK Committee
Within the scope of ensuring, maintaining and maintaining compliance with the personal data protection legislation, the "Company KVK Committee" has been established by the Company, which will provide the necessary coordination within the Company. The Company KVK Committee is responsible for ensuring unity among the units of the Company, carrying out and improving the systems established to ensure that the activities carried out are in compliance with the legislation on the protection of personal data.
In this context, the basic tasks of the Company KVK Committee are stated below:
– To prepare and implement basic policies on the protection and processing of personal data within the company,
– To decide how the implementation and supervision of policies regarding the protection and processing of personal data within the company will be carried out and to provide internal commissioning and coordination within this framework,
– To identify the issues that need to be done in order to ensure compliance with KVKK and related legislation; to observe its implementation and to ensure its coordination,
– To raise awareness about the protection and processing of personal data within the company and the cooperated institutions, and,
– To ensure that necessary measures are taken by identifying the risks that may occur in the personal data processing activities of the company; to provide improvement suggestions,
– To design and carry out trainings on the protection of personal data and the implementation of policies, and,
– To decide the applications of personal data owners,
– Personal data owners; To coordinate the implementation of information and training activities to ensure that the Company is informed about personal data processing activities and legal rights, and,
– To follow the developments and regulations on the protection of personal data; to advise senior management on what needs to be done in the Company operations in accordance with these developments and regulations, and,
– Managing relations with the Institution and the Board,
– To perform other duties of the KVK Top Committee on the protection of personal data.
– To the KVK Senior Committee of the Company, KVKKIya to make regular reporting on compliance.
– The company educates and raises awareness of its employees regarding the law of protection of personal data.
– In cases where personal data is subject to transfer, it is ensured that the contracts concluded by the Company with the persons to whom the personal data is transferred will be added to the records that the party to whom the personal data is transferred will fulfill the obligations to ensure data security.
– The personal data processing activities carried out by the company are examined in detail and periodically reviewed and updated when necessary. In this context, the steps to be taken are determined in order to ensure compliance with the personal data processing requirements stipulated in the KVKK.
– The company identifies the applications that need to be fulfilled in order to ensure compliance with KVKKna, organizes these applications with internal policies and updates them when necessary by reviewing them periodically.
Desonyx to Ensure that Personal Data is Processed Legally and to Prevent Illegal Access to Personal Data
Technical Measures Taken by
– As far as technology enables the protection of personal data by the company, reasonable technical measures are taken and the measures taken are updated and improved in parallel with the developments.
– In technical matters, specialist personnel are employed if necessary or support is obtained from expert advisors.
– Regular inspections are carried out for the implementation of the measures taken.
– Software and systems are installed to ensure security.
– The authority to access personal data processed within the company is limited to the relevant employees for the specified processing purpose.(3) Conducting Audit Activities for the Protection of Personal Data by the Company
The functioning of the technical and administrative measures taken by the company within the scope of the protection and security of personal data is supervised and practices are carried out to ensure the continuation of the operation. The results of the audit activities carried out within this scope are reported to the Company KVK Committee and the related department within the Company. In line with the results of the audit, activities are carried out to ensure the development and improvement of the measures taken for the protection of the data
(4) Measures to be Taken in the Case of Disclosure of Personal Data in Unlawful Ways
Within the scope of the personal data processing activity carried out by the Company, in cases where it is determined that the personal data was obtained illegally by unauthorized persons, the situation will be notified to the Board and the relevant data owners without losing time.
8. Purposes of Processing Personal Data and Personal Data Groups Subject to Data Processing Activity
8.1. Personal Data Categories
Personal data in the following groups is processed by the Company in a partially or fully automated manner or non-automatically as part of the data recording system.
| Categories of personal data | Description |
| Credential | Personal data containing information about the identity of the person; name-surname, T.C. identification number, nationality information, maternal name, birth place, date of birth, gender, documents such as population wallets and passports, as well as tax number, SGK number, signature information, vehicle license plate etc. |
| Contact Information | Contact information; personal data such as telephone number, address, e-mail address, fax number. |
| Physical Space Security Information | Personal data on records and documents taken during stay in physical space at the entrance to physical space; camera records, fingerprint records and records taken at security point etc. |
| Transaction Security Information | In carrying out the commercial activities of the Company, personal data processed to ensure the technical, administrative, legal and commercial security of the Company, both in the relevant Personality and in the case of the Company. |
| Risk Management Information | Personal data processed through methods used in accordance with the generally accepted legal, commercial practices and honesty rule in these areas for the management of commercial, technical and administrative risks. |
| Financial Information | Any financial information, documents and personal data related to the records created within the scope of the legal relationship between the Company and the Person concerned and the bank account number, IBAN number, credit card information, financial profile, financial profile, personal data such as assets data, income information. |
| Legal Transaction and Compliance Information | Personal data processed within the scope of the legal receivables of the Company and the determination of its rights, follow-up and performance of its debts and legal obligations and compliance with Company policies. |
| Audit and Inspection Information | Personal data processed within the scope of the legal obligations of the Company and compliance with the policies of the Company. |
| Special Qualified Personal Data | Data specified in Article 6 of the KVKK (for example; health data including blood type, biometric data, religion and association information of the member) |
| Request/Complaint Management Information | Personal data regarding the receipt and evaluation of any claims or complaints directed to the Company. |
| Reputation Management Information | Personal data that is associated with the Person and collected for the purpose of protecting the business reputation of the Company (for example; shares made with the Company) |
8.2. Purposes of Processing Personal Data
Personal data are processed by the Company for the following purposes in accordance with the data processing terms and principles. The existence of the following purposes may vary with each Person concerned.
The personal data obtained are processed by the Company within the scope of the personal data processing conditions specified in Articles 5 and 6 of the KVKK and within the purposes listed below:
– Planning and/or Execution of In-house Training Activities,
– Planning and Execution of Emergency Management Processes,
– Planning and Execution of Corporate Sustainability Activities, Turkey,
– Planning of Human Resources Processes,
– Follow-up of Legal Affairs,
– Planning and Execution of Business Activities,
– Creation and Management of Information Technology Infrastructure,
– Planning of Information Security Processes,
– Planning and Execution of Corporate Relations and Communication Activities,
– Planning and Execution of In-house Orientation Activities,
– Planning and/or Execution of Activities for the Performance/Efficiency and/or Reliability Analysis of Business Activities, and,
– Ensuring that Data is Accurate and Current, and,
– Recruitment /Employment,
– Supply of Security of Company Residences and/or Facilities, and,
– Creation and Follow-up of Visitor Records, and,
– Follow-up of Contract Processes and/or Legal Claims, and,
– Planning and/or Execution of Business Continuity Activities,
– Planning and Execution of Company Audit Activities,
– Planning and Execution of Operational Activities Required to Ensure that Company Activities are Conducted in accordance with Company Procedures and/or Related Legislation, and,
– Execution of Companies and Partnership Law Transactions,
– Supply of Security of Company Operations,
– Management and/or Supervision of Relationships with Affiliates,
– Execution of Personnel Supply Processes,
– Corporate Governance Planning and Execution of Activities,
– Execution of Strategic Planning Activities,
– Planning and Execution of Non-Company Training Activities.
8.3. Shared Party Categories
Desonyx, in accordance with the principles contained in the KVKK and, in particular, the articles 8 and 9 of the KVKK, the data holders within the scope of the Policy (See. Section 2.2.) may transfer personal data to the following groups of persons for the purposes stated:
– To company suppliers,
– To company business partners,
– To third parties that process personal data on behalf of the Company,
– Authorized public institutions and organizations and authorized private law persons, with,
– To other third parties, in accordance with the terms of data transfer.
The scope and possible data transfer purposes of the above mentioned persons given in the transfer are indicated below.
| DATA TRANSFER PERSONS TO BE MADE | DESCRIPTIONS | DATA TRANSFER PURPOSE |
| Business Partner | Parties to which the Company has established business partnerships for purposes such as the conduct of its commercial activities | Limited in order to ensure that the purposes of the establishment of the business partnership are met |
| Supplier | Within the scope of the execution of the commercial activities of the Company, the parties providing services to the Company in accordance with the orders and instructions of the Company and on a contract basis | The Company provides outsourced to the supplier and limited to ensure that the services required to perform the Company's commercial activities are provided to the Company |
| Affiliates | Companies in which the company is a shareholder | The Company is limited to ensuring that its business activities, which also require the participation of its subsidiaries, are carried out |
| Lawfully Authorized Public Institutions and Institutions | Public institutions and organizations authorized to receive information and documents from the Company according to the provisions of the relevant legislation | Limited to the purpose requested within the legal authority of the relevant public institutions and organizations |
| Legal Authorized Private Law Persons | Private legal persons authorized to receive information and documents from the Company according to the provisions of the relevant legislation | Limited to the purpose requested by the relevant private law persons within their legal authority |
9. Closed Circuit Camera (CCTV) Usage
Desonyx, in the building where the company center is located, prevention of criminal behavior, internal, environmental, vehicles and equipment, for the purposes such as ensuring the safety of visitors and employees, visual and audio data can be obtained through the closed circuit camera system and stored only for the time necessary for these purposes. Any technical and administrative measures necessary to ensure the security of personal data obtained through the closed circuit camera system shall be taken by the Company.
10. Use of the Website
To ensure that people who visit these sites on the websites owned and managed by the Company make their visits to the sites appropriate for the purposes of visiting, to provide them with customized content, to provide social media features, if they visit the relevant website again, internet movements within the site are recorded in order to facilitate the visit by being remembered.
The Company may cease to use the cookies it uses on the websites it owns and manages, change their types or functions, or add new cookies.
The Company will process the personal data obtained through such cookies in accordance with the terms and conditions of KVKKya and this Policy.
In terms of these websites, detailed explanations on the protection and processing of personal data are included in the "Privacy Policy" texts of the relevant websites.
11. Reviewing
This Policy will be updated if necessary by the Company's KVK Committee at least once a year. The Company's KVK Supreme Committee is authorized and responsible for the entry into force, amendment, execution and repeal of this Policy.
12. Definitions
The definitions for terms used in politics are listed below:
| Explicit Consent | Consent on a particular subject, based on information and explained by free will. |
| Anonymization | To make personal data unrelated to a specific or identifiable natural person in any way even by matching with other data. |
| The Regulation on the Processing of Personal Health Data | Regulation on Processing of Personal Health Data and Ensuring Privacy, dated 20 October 2016 and published in the Official Gazette numbered 29863 |
| Personal Health Data | Any health information relating to an identified or identifiable natural person. |
| Personal Data | Any information relating to an identified or identifiable natural person. |
| Person Concerned | The real person whose personal data is processed. For example; Customers and employees. |
| Personal Data Processing | Obtaining, recording, storing, storing, changing, rearranging, disclosing, transferring, transferring, transferring personal data by non-automated means, whether fully or partially automated or part of any data recording system, any action taken on the data, such as its acquisition, making it available, classification or prevention of its use. |
| KVKK | The Law on the Protection of Personal Data dated 7 April 2016 and published in the Official Journal numbered 29677, dated 24 March 2016 and numbered 6698. |
| COMMITTEE | The Personal Data Protection Board |
| INSTITUTION | The Personal Data Protection Authority |
| Special Qualified Personal Data | Race, ethnicity, political thought, philosophical belief, religion, denomination or other beliefs, disguise clothing, association foundation or union membership, health, sexual life, etc, biometric and genetic data with data on criminal conviction and security measures. |
| Policy | Desonyx Personal Data Protection and Processing Policy |
| Desonyx Business Partners | While conducting commercial activities of Desonyx, the. |
| Desonyx Suppliers | Parties providing services to Desonyx on a contractual basis. |
| CONSTITUTION OF THE REPUBLIC OF TÜRKİYE | Published in the Official Gazette dated 9 November 1982 and numbered 17863; the Constitution of the Republic of Turkey dated 7 November 1982 and numbered 2709. |
| Penal Code Of TÜRKİYE | Published in the Official Gazette dated 12 October 2004 and numbered 25611; dated 26 September 2004 and numbered 5237 Turkish Penal Code. |
| Data Controller | It is the person who determines the purposes and means of the processing of personal data and manages the place where the data is kept in a systematic way. |