Clarification Text on Protection and Processing of Personal Data

Data Supervisor : Multipak Ambalaj ve Gıda Sanayi ve Ticaret A.Ş. (Referred to as “MULTIPAK”), Yazıbaşı  Mahallesi Batı Beton Caddesi  No:10/1  Yazıbaşı- Torbalı / İZMİR
We, MULTIPAK respect the personal data we manage while carrying out the activities of our Company and we approach with maximum sensitivity to the security of personal data. We care particularly the discretion of your private life as well as protection of your fundamental rights and freedom and with this clarification text, we would like to inform you regarding the collection method of the personal data, its processing purposes, legal cause and mutual rights and obligations of the parties within the framework of respective legislation mainly the Law on the Protection of Personal Data no. 6698 (“LPPD”). Your personal data shall be collected, recorded, stored, disclosed, transferred to third parties or abroad to the extent permitted by the legislation or shall be processed in other ways by MULTIPAK AMBALAJ VE GIDA SAN.  TİC. A.Ş. ("MULTIPAK ") and its affiliated companies, as the data supervisor, in accordance with the provisions of the LPPD and in the framework described below.

Collection of Personal Data, Processing and Purpose
Your collected personal data shall be processed by MULTIPAK, pursuant to principals set forth in the Law and in connection with the conditions and purpose of processing specified in articles 5 and 6 of LPPD.
Your personal data shall be collected in writing or in electronic environment for the purposes detailed herein below; which may also vary depending on the products and services provided by our Company and its commercial activities; by automatic or non-automated methods, our company units and offices, MULTIPAK AMBALAJ VE GIDA SAN. TİC. A.Ş. as well as its affiliated companies, website, social media, mobile applications, through trainings, seminars and organizations and similar means. For the purpose of physical security, our company conducts monitoring activities in offices, facilities and educational institutions; our visitors are registered in their entries and exits. Internet search history information of the beneficiaries of our company's internet services is stored in accordance with the requirements of the law. Your personal data may be updated and processed as long as you benefit from the products and services offered by our Company and our affiliated companies.
Your personal data is processed for the below purposes;
Conducting and carrying out necessary activities by relevant units of MULTIPAK in order to perform commercial activities and services carried out by MULTIPAK in accordance with the legislation and Company Internal Policies and Procedures;  detection, planning and implementation of MULTIPAK’s commercial policies; ensuring legal and commercial security of MULTIPAK and its affiliated companies and natural or legal persons in business relations with MULTIPAK (administrative operations regarding communication carried out by MULTIPAK, providing physical security and supervision of all locations of MULTIPAK office premises and similar facilities, evaluation of MULTIPAK and its affiliated company clients, complaints management processes related to the products etc, reputation research processes, event management, legal compliance process, internal and external audits, financial affairs etc.)
Design and implementation of all kinds of human resources activities and supporting of the same; protection of commercial reputation and trust of MULTIPAK and its subsidiaries.
Should you request further information on the purpose of the processing your personal data, you may kindly visit our official website www.multipak.com.tr  in the section Policy of Personal Data Protection and Processing of MULTIPAK.

Transfer of Processed Personal Data
Within the framework of the personal data processing conditions and objectives specified in Articles 8 and 9 of the LPDP, your collected personal data shall be transferred to supervisory and regulatory authorities, relevant public institutions, professional bodies and similar organizations, and persons or organizations authorized by the Turkish Commercial Code, other relevant legislation, to legally authorized public and / or private law legal entities, limited to the purpose and authority , to MULTIPAK   AMBALAJ VE GIDA SAN.TIC.A.Ş. and its affiliates, to our direct and indirect domestic/foreign subsidiaries, consultants, auditors and /or service providers within the framework of relevant legal provisions; in order to carry out the commercial activities by MULTIPAK to comply with the legislation and in accordance with the Company's Internal Policies and Procedures, taking necessary actions by the relevant authorities of MULTIPAK and carrying out such activities in this direction, identifying, planning and implementing commercial policies of MULTIPAK; ensuring the legal and commercial guarantee of MULTIPAK and its affiliated companies and natural or legal persons in business relations with MULTIPAK (administrative operations regarding communication carried out by MULTIPAK, to provide physical security and supervision of MULTIPAK's offices, facilities and similar locations, evaluation of customers of MULTIPAK and its affiliates, complaint management processes related to products and etc, reputation research processes, event management, legal compliance process, internal and external audits, financial affairs, etc.), to design and execute  MULTIPAK's all kinds of human resources activities and to support these activities , to preserve the commercial reputation and trust of MULTIPAK and its affiliates.

Method and Legal Cause of Personal Data Collection
Your personal data is collected in all kinds of verbal, written or electronic environment in line with the purposes outlined above in order to product, training and services in order to be able to present in the legal framework determined and to fulfill the responsibilities and obligations of the Company under the contract and the law completely and accurately. Collected personal data of yours for this legal reason may be processed and transferred for the purposes specified in this clarification text and within the framework of the personal data processing requirements and purposes set out in Articles 5 and 6 of the LPDP.

Cases That Require Explicit Consent On Personal Data And/or Special Categories of Personal Data
According the Article 5/2 of the LPDP, MULTIPAK has the right process the personal data (personal data other than health and sexual life) without obtaining the explicit consent of the data subject if it is expressly permitted by any law, it is necessary in order to protect the life or physical integrity of the data subject or another person where the data subject is physically or legally incapable of giving consent, it is necessary to process the personal data of parties of a contract, provided that the processing is directly related to the execution or performance of the contract, it is necessary for compliance with a legal obligation which the supervisor is subject to, the relevant information is revealed to the public by the data subject herself/himself, it is necessary for the institution, usage, or protection of a right, it is necessary for the legitimate interests of the data supervisor, provided that the fundamental rights and freedoms of the data subject are not harmed.

Your personal data, including your special categories of personal data, shall not be processed without your explicit consent, except for the above-mentioned exceptions. Prior to obtaining your explicit consent, you must be informed in detail about the reason for the processing of your data.

Data Security
We care to protect the privacy and security of all the personal data you provide to us. In this respect, we take all necessary technical and administrative security measures to protect your personal data against unauthorized access, loss, loss or disclosure risks.

Rights of Personal Data Subject in Accordance the Article 11 of the LPDP 
As a personal data subject, you shall have the following rights;

You may contact us in accordance with using these rights in writing or any other method which shall be determined by the Personal Data Protection Board.
You shall deliver your written requests in person to the address of Yazıbaşı Mahallesi Batı Beton Caddesi  No:10/1 Yazıbaşı-Torbalı / İZMİR along with your identifying documents or you shall send your request with secure electronic signature to the e-mail address of info@multipak.com.tr
In the application, which you will file to exercise the above specified rights as a personal data subject, and which includes descriptions about the right you wish to exercise, the subject of your request must be clear and comprehensible, the issue you request for must be related to you, or in case if you are acting on behalf of any other person, you must be specially authorized, and your authorization must be documented, the respective application must include identity and address details and it must be attached with documents proving your identification.