Lockton Omni Sigorta ve Reasürans Brokerlik Hizmetleri Limited Şirketi
DISCLOSURE DECLARATION AND THE PERSONAL DATA PROTECTION POLICY
General Disclosure on the Law on the Protection of Personal Data
Law No. 6698 on the Protection of Personal Data (hereinafter referred to as “KVKK”) was adopted on March 24, 2016, and was published in the Official Gazette dated April 7, 2016 and numbered 29677. A part of the KVKK became effective on the date of publication and the remaining part became effective on October 7, 2016.
Disclosure in the Capacity of Data Officer
In accordance with KVKK no. 6698 and in the capacity of Data Officer, your personal data will be recorded, stored, updated, and disclosed/transferred to third parties where permitted by the legislation, classified and processed as specified in KVKK within the framework as explained in this page.
How Your Personal Data Can Be Processed
Pursuant to KVKK no. 6698, your personal data that you share with our Company may be obtained, recorded, stored, modified, rearranged wholly or partially, automatically or non-automatically, provided that it is a part of any data recording system, in short, your data may be processed by us for any process that may be performed on the data. Any transaction performed on the data within the scope of KVKK is considered as “processing of personal data".
The purposes and legal reasons for processing your personal data
Personal data you share may be processed in accordance with KVKK no. 6698 and related secondary regulations
• To be able to fulfill the requirements of the services we provide for our customers in accordance with the requirements of the contract and technology, and to be able to improve our products and services;
• To record the identity, address and other required information so as to determine the details of the transaction owner within the scope of the Law on the Regulation of Electronic Trade No. 6563, Law on Consumer Protection No. 6502 and the Regulation on Service Providers and Intermediary Service Providers in Electronic Trade prepared based on these regulations and published in the Official Gazette dated 26.08.2015 and numbered 29457, the Regulation on Distance Contracts published in the Official Gazette dated 27.11.2014 and numbered 29188 and other relevant legislation;
• To regulate all records and documents that will be the basis of payment systems, electronic contracts or paper processing which are obligatory in the field of Banking and Electronic Payment; to comply with the information storage, reporting, and disclosure requirements required by the legislation and other authorities;
• To provide information to public prosecutors, courts and related public officials upon request and in accordance with the legislation on public security issues and legal disputes.
Disclosure on the third persons or organizations to whom your personal data may be transferred. For the purposes provided above, the persons/organizations to whom your personal data you share with our Company may be transferred are suppliers, persons or organizations related to the services provided, such as cargo companies, the program partner organizations, domestic/international organizations and other third parties that we cooperate with in order to carry out our activities and/or obtained services in the capacity of Data Processor.
How do We Collect Your Personal Data
Your personal data may be processed and collected as follows:
• Information such as name, surname, TR ID. No., address, phone, business or private e-mail address via the website of our company or the forms on our mobile applications; preferences in the pages logged in using a user name and password, IP records of transactions performed, the cookie data, navigation time and details and location data collected by the browser;
• Data collected from verbal, written or electronic means by our sales and marketing department employees, branches, suppliers, other sales channels, paper forms, business cards, digital marketing and call centers;
• Data obtained in physical or virtual environments, face to face or at a distance, oral or written or in electronic form the persons who share their personal data by providing business cards and resumes (CV) to establish a commercial relations with our company, to apply for a job, to submit a quote;
• Additionally, data obtained indirectly from different channels, from (micro) web sites used for websites, blogs, competitions, surveys, games, campaigns, and similar purposes and from social media, e-bulletin reading or clicking movements, data provided by public databases, public profiles and data available on social media platforms.
Your personal data obtained before the effective date of KVKK
Lockton Omni Sigorta ve Reasürans Brokerlik Hizmetleri Limited Şirketi part of the Lockton Group of Companies. Disclosure Declaration and the Policy on the Protection of Personal Data - Version 1
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Your personal data obtained before April 7, 2016 through membership, electronic message permission, product/service purchases or other legal methods may be processed and collected in accordance with the terms and conditions set forth herein.
Transferring Your Personal Data Abroad
Your personal data may be transferred to the service intermediaries abroad (in countries accredited by the Personal Data Board and having sufficient protection with regards to personal data) within the scope of KVKK after being processed in Turkey or to be processed and stored outside Turkey.
Storage and Protection of Personal Data
Your personal data will be kept confidential in the database and systems of our Company in accordance with Article 12 of KVKK and shall not be disclosed to third parties in any way other than legal obligations and the regulations specified in this document. Pursuant to Article 12 of KVKK, our company is obliged to prevent the unlawful processing of and unauthorized access to your personal data stored in our company systems and databases and to take software measures and physical security measures such as access management. In case the company becomes aware that the personal data has been illegally obtained by third parties, this shall be immediately notified in writing to the Personal Data Protection Board in accordance with legal regulations.
Keeping Personal Data Up-to-Date and Accurate
Pursuant to Article 4 of KVKK, our Company is obliged to keep your personal data accurate and up to date. Within this scope, our customers are required to share accurate and up-to-date data or update their data via the website/mobile application so that our company can fulfill its obligations arising from the current legislation.
Rights of Personal Data Owner under KVKK No. 6698
Article 11 of the KVKK no. 6698 became effective on October 07, 2016 and the rights of the Personal Data Owner after this date are as follows:
Personal Data Owner may contact our Company (data controller) and
1. Learn whether their Personal Data is processed or not,
2. Request information about their Personal Data if they have been processed,
3. Learn the purpose of processing the Personal Data and whether they are used appropriately for their purpose,
4. Know the third parties to whom personal data is transmitted in the country or abroad,
5. In case personal data is processed deficiently or incorrectly, request the correction of such,
6. Request the deletion or destruction of Personal Data pursuant to the conditions stipulated by the KVKK,
7. In case personal data is corrected, deleted and/or destroyed, request this situation to be notified to any third parties whom such data was shared with,
8. Object to the occurrence of a consequence against the individual through analyzing the processed Data exclusively on automated systems,
9. Request the remedy of damages in case of any damages suffered due to illegal processing of the Personal Data.
Lockton Omni Sigorta ve Reasürans Brokerlik Hizmetleri Limited Şirketi registered in Istanbul Chamber of Commerce with registration no. 669164, having central registration system number 0642-0752-5300-0001 with registered address Levent Mahallesi Çalıkuşu Sokak No:13 Beşiktaş / Istanbul is the Data Controller under KVKK.
Personal Data Owners can submit their questions, opinions and/or requests using any of the following contact channels:
Contact Details: Yasemin Yorgancı
E-mail: yasemin.yorgancı@locktonomni.com
Phone: +90 212 315 6400
Switchboard: +90 212 315 6400
Fax: +90 212 380 1780
