As Sibel Uluslararası Taşımacılık ve Dış Ticaret Limited Şirketi, within the scope of the Law on the Protection of Personal Data ("KVKK), we prepared this disclosure text in order to inform our customers, business connections and our users using our website in terms of the processing, storage and transfer of your personal data within the framework of our activities conducted in business Law, Social Security, SSI incentives, finance and business management sector.

What is General Data and Private Personal Data?

Any information relating to a specific or identifiable real person is defined as personal data.

Data in relation to race, ethnic origin, political opinion, philosophic belief, religion, sect or other beliefs, appearance, membership to associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data.

The processing of private personal data without the express consent of the relevant person is prohibited. Personal data other than health and sexual life may be processed without needed the express consent of the person concerned in the circumstances stipulated in the law. Personal data relating to health and sexual life; can only be processed for the purposes of protection of public health, operation of preventive medicine, medical diagnosis, treatment and caring services, planning and management of health-care services as well as their financing, by any person or authorized institutions and organizations that have confidentiality obligation, without seeking explicit consent of the data subject, In the processing of private personal data , it is also necessary to take adequate measures determined by the board.

What Data is Collected and What is Our Purpose to Collect Data?

Within the scope of the services we provide in the logistics sector, we collect the following data:

1.      Identity Information
2.      Contact Informations
3.      Personal information (Entity)
4.      Location data
5.      Legal Process
6.      Customer Process
7.      Physical Venue Security
8.      Process Security
9.      Professional Experience
10.    Audio-visual records.
11.    Health Information
12.    Conviction and Security Measures

Data Category	Identity Information
Description	are the data related to the identification of the person.
whom collected from	It is collected from workers, company partners, trainees, supplier employees, officials, people who buy products or services.
Content	is such as Name- Surname, RoT ID number, Tax Number, SSI registry number, ID copy, signature
Purpose of Data Collecting	Fulfilment of Obligations Arising from the Labour Contract and Legislation for Employees Conducting Processes for Fringe Benefits and Interests for Employees Conducting Audit / Ethics Activities Conducting Training Activities Conducting Access Authorizations Conducting Activities in compliance with Legislation Conducting Financing and Accounting affairs Conducting Assignment Processes Following-up and Conducting Legal Affairs Planning Human Resources Processes Conducting / Supervising Business Activities Conducting Occupational Health / Safety Activities Conducting Logistics Activities Conducting Goods / Services Production and Operation Processes Execution Of Storage And Archive Activities Conducting Contracting Processes Follow-up of Requests / Complaints Informing Authorized Persons, Institutions and Organizations Conducting Management Activities

Data Category	Contact Informations
Description	Are the personal data which enables contact with the person.
whom collected from	It is collected from workers, company partners, trainees, supplier employees, officials, people who buy products or services.
Content	Is data such as home and work address, mobile phone number, home phone number, postal address and e-mail address.
Purpose of Data Collecting	Conducting Processes of Information Security Management Fulfilment of Obligations Arising from the Labour Contract and Legislation for Employees Conducting Processes for Fringe Benefits and Interests for Employees Conducting Training Activities Conducting Access Authorizations Conducting Activities in compliance with Legislation Conducting Financing and Accounting affairs Conducting Assignment Processes Following-up and Conducting Legal Affairs Conducting Communication Activities Planning Human Resources Processes Conducting / Supervising Business Activities Conducting Occupational Health / Safety Activities Conducting Logistics Activities Conducting Processes of procurement of Good / Service Conducting Goods / Services Sale Processes Conducting Goods / Services Production and Operation Processes Execution Of Storage And Archive Activities Conducting Contracting Processes Execution Of Supply Chain Management Processes Informing Authorized Persons, Institutions and Organizations Conducting Management Activities

Data Category	Personnel Data
Description	is worker data that must be kept by the employer as required by legislation.
whom collected from	It is collected from workers
Content	Such as, ID informations, contact information, Position/Title Information, diplomas and certificates, work history, details, previous work received from the service/working document Resume, Let (administrative and annual leave), Photography, about running official correspondence, statement of SSI, SSI declaration of departure from work, criminal record, military service discharge Information, health report, minimum living allowance informations.
Purpose of Data Collecting	Fulfilment of Obligations Arising from the Labour Contract and Legislation for Employees Conducting Processes for Fringe Benefits and Interests for Employees Conducting Training Activities Conducting Access Authorizations Conducting Activities in compliance with Legislation Conducting Financing and Accounting affairs Conducting Assignment Processes Following-up and Conducting Legal Affairs Conducting Communication Activities Planning Human Resources Processes Conducting / Supervising Business Activities Conducting Occupational Health / Safety Activities Conducting Logistics Activities Execution Of Storage And Archive Activities Conducting Contracting Processes Follow-Up Of Claims/Complaints Conduct Of Talent / Career Development Activities Informing Authorized Persons, Institutions and Organizations Conducting Management Activities

Data Category	Location Data
Description	It is the necessary information to maintain the logistics activities that are our main activity without any problems.
whom collected from	Location data is collected from the vehicles used by our company drivers and supplier drivers.
Content	Within the scope of our road transport activity, location information of vehicles such as trucks and drivers is accessed in order to track their freight positions.
Purpose of Data Collecting	Fulfilment of Obligations Arising from the Labour Contract and Legislation for Employees Conduct Of Audit / Ethical Activities Conducting Activities in compliance with Legislation Following-up and Conducting Legal Affairs Conducting Communication Activities Conducting / Supervising Business Activities Conducting Occupational Health / Safety Activities Conducting Logistics Activities Conducting Goods / Services Production and Operation Processes Execution Of Storage And Archive Activities Conducting Contracting Processes Ensuring Safety of Movable Goods and Resources Informing Authorized Persons, Institutions and Organizations Conducting Management Activities

Data Category	Legal Process
Description	is the legal data collected to ensure the legal security of the company within the scope of obligations arising from the legislation.
whom collected from	It is collected from workers, company partners, trainees, supplier employees, officials, people who buy products or services.
Content	Documents such as articles from official institutions, articles from courts, notices of foreclosure, information and documents related to lawsuits filed
Purpose of Data Collecting	Fulfilment of Obligations Arising from the Labour Contract and Legislation for Employees Conducting Processes for Fringe Benefits and Interests for Employees Conducting Audit / Ethics Activities Conducting Activities in compliance with Legislation Conducting Financing and Accounting affairs Following-up and Conducting Legal Affairs Planning Human Resources Processes Conducting / Supervising Business Activities Conducting Occupational Health / Safety Activities Execution Of Storage And Archive Activities Conducting Contracting Processes Follow-up of Requests / Complaints Informing Authorized Persons, Institutions and Organizations Conducting Management Activities

Data Category	Customer Process
Description	Customers' request, invoice, stamp-signature information and suppliers ' stamp-signature information.
whom collected from	It is collected from supplier employees, supplier officials, product or service recipients.
Content	Customers' request, invoice, stamp-signature information and suppliers ' stamp-signature information.
Purpose of Data Collecting	Conducting Activities in compliance with Legislation Conducting Financing and Accounting affairs Following-up and Conducting Legal Affairs Conducting Communication Activities Conducting / Supervising Business Activities Receiving and Assessing Suggestions for Improvement of Business Processes Conducting Business Continuity Activities Conducting Logistics Activities Conducting Processes of procurement of Good / Service Conducting Goods / Services Sale Processes Conducting Goods / Services Production and Operation Processes Execution Of Storage And Archive Activities Conducting Contracting Processes Ensuring Security of Data Controller Operations Informing Authorized Persons, Institutions and Organizations Conducting Management Activities

Data Category	Physical Venue Security
Description	Measures to ensure the security of the physical space
whom collected from	is collected from employee candidates, employees, company partners, potential product or service buyer, trainee, supplier employee, supplier officer, product or service buyer, visitors.
Content	Camera records
Purpose of Data Collecting	Ensuring Physical Space Security Conducting / Supervising Business Activities Conducting Occupational Health / Safety Activities Conducting Logistics Activities Ensuring Safety of Movable Goods and Resources

Data Category	Process Security
Description	it is the data such as IP address information, internet site entry and exit information,  password and keyword
whom collected from	It is collected from workers and company partners.
Content	it is the data such as IP address information, internet site entry and exit information,  password and keyword
Purpose of Data Collecting	Conducting Processes of Information Security Management Conducting Activities in compliance with Legislation Following-up and Conducting Legal Affairs Conducting / Supervising Business Activities Execution Of Storage And Archive Activities Ensuring Security of Data Controller Operations

Data Category	Professional Experience
Description	it is data such as diploma information, courses attended, vocational training information, certificates, transcript information, work experience
whom collected from	It is collected from workers
Content	it is data such as diploma information, courses attended, vocational training information, certificates, transcript information, work experience
Purpose of Data Collecting	Fulfilment of Obligations Arising from the Labour Contract and Legislation for Employees Conducting Processes for Fringe Benefits and Interests for Employees Conducting Training Activities Conducting Assignment Processes Planning Human Resources Processes

Data Category	Audio-visual records.
Description	Measures to ensure the security of the physical space
whom collected from	is collected from employee candidates, employees, company partners, potential product or service buyer, trainee, supplier employee, supplier officer, product or service buyer, visitors.
Content	Camera records
Purpose of Data Collecting	Ensuring Physical Space Security

Data Category	Health Information
Description	It is the health data that workers need to be able to work.
whom collected from	It is collected from workers
Content	Disability Information, blood group information, personal health information, equipment and prosthetics information etc.
Purpose of Data Collecting	Fulfilment of Obligations Arising from the Labour Contract and Legislation for Employees Conducting Processes for Fringe Benefits and Interests for Employees Conducting Occupational Health / Safety Activities Planning Human Resources Processes

Data Category	Conviction and Security Measures
Description	Information on criminal convictions and security measures etc.
whom collected from	It is collected from workers
Content	Information on criminal convictions and security measures etc.
Purpose of Data Collecting	Fulfilment of Obligations Arising from the Labour Contract and Legislation for Employees Planning Human Resources Processes

What is the Legal Reason for the Collection of Your Data?
We process personal data for reasons arising from our obligations under the relevant legislation (legal obligation), contractual relations, obligations under the law and legitimate interests within the scope of our services performed in the logistics sector.

How We Collect Your Data?
We collect data through printed forms, sometimes directly via electronic forms or through meetings / negotiations.

Transfer of Your Personal Data to a Third Party
Your personal data is shared, where necessary, with persons and institutions authorized by a court order or at the request of an administrative authority expressly authorized by law, in accordance with our obligations set forth in the legislation, in cases specified in the legislation. In addition, data can be shared with suppliers and related third parties in order to maintain our business activities.

Transfer Of Personal Data Abroad
Your personal data may only be transferred abroad if there is one of the following limited circumstances:

• If you have express consent,
• If there is sufficient protection in the country where the data will be transferred and the conditions stipulated in the KVKK
• Although the conditions envisaged in the KVKK and the country where the data will be transferred do not have adequate protection, there is a commitment made by the relevant country and the permission of the Personal Data Protection Board ("Board") to provide adequate protection.

Retention Times Of Your Personal Data
The retention periods of your personal data are as follows:

• If a provision in the law or related legislation determines a period of time for the data to be stored, the data must be kept at least for that period. The data in question is deleted at the end of the specified period.
• If no period of time has been set by law regarding the storage of the data we process, such data shall be stored in accordance with the relationship between us and for the period specified in the contract to which we are parties and shall be deleted-without your request - if this relationship ends or the period specified in the contract expires.
• If a period of time is stipulated in the legislation regarding the storage of data and you request that such data be deleted before that time, this request cannot be made. Where the time period for storing data is not determined in the legislation, your data will be deleted immediately and within 30 days at the latest if you have a request to delete the data.

Your Rights Regarding Your Personal Data
Your rights regarding your personal data are as follows:

• to know whether your personal data is being processed or not,
• Request for information if your personal data is processed,
• Find out what the purpose of processing your personal data is and whether this purpose is adhered to,
• To know the third parties to whom your personal data are transferred at domestic or abroad,
• To request your personal data correction  if it is incomplete or misinterpreted,
• to request that your personal data be deleted or destroyed in accordance with the provisions of the KVKK,
• If you request that your personal data be deleted or destroyed by the correction of incomplete or incorrect data, we request that you be notified of this to third parties to whom we have transferred your data
• Taking objection against this situation in case there is a situation against you via analyzing your personal data through automatic systems and
• Requesting for removal of damage in case you have suffered damage due to the unlawful processing of your personal data

Usage of Rigths
You may submit your requests for the exercise of your rights regarding your personal data by this method if a separate method has been determined by the KVK Board, without prejudice to other methods determined by the board or with an application form of Sibel Uluslararası Taşımacılık ve Dış Ticaret Limited Şirketi or address Ferhatpaşa District 77. Street No: 61/1 Ataşehir/İstanbul
Ataşehir/İstanbul address in written and wet signature or to our you may forward it by sending it to our registered e-mail address sibel@hs01.kep.tr signed with a secure electronic signature. No: 61/1 Ataşehir/İstanbul address in written and wet signature or to our you may forward it by sending it to our registered e-mail address sibel@hs01.kep.tr signed with a secure electronic signature.

We reserve the right to refuse the relevant application if there is a mistake/error in the transmitted information and documents or if the application is unauthorized.

Response Time to Regarding Requests the Processing of Personal Data
We evaluate your claims regarding your personal data and respond within 30 days at the latest from the day your claims are received. If our response to your request is negative, we send the reasoned refusal to the address you specified by e-mail or by mail.

How You may Reach Detailed Information about Processing Your Personal Data?
For detailed information about Processing Your Personal Data, you may request us with the "Application Form" on our website.

1. GENERAL INFORMATION ABOUT COOKIES
This Cookie Policy (hereinafter referred to as "Policy") includes the website managed by Sibel Uluslararası Taşımacılık ve Dış Ticaret Limited Şirketi and encloses descriptions about the use of cookies. By using our site, you certify the use of cookies as specified in this Policy.

1.1. What means cookie?
Cookies are small text files that are stored on the visitor's device (such as a computer or phone) and can contain data in name-value format when a website is visited. The text files in question can be understood by browsers and servers that can access them, and in this way, various information about the device on which the visit is made to the website and thus various information related to user can be obtained. Today, cookies are used in almost every site.

1.2. For what purpose are cookies used?
The cookies are used for many different aims. If giving an example is necessary, cookies are mostly used for the purposes stated below:
· For functioning of website properly (For example; for displaying of the contents on the site like text, photograph, connection on the right places)

· For providing a more personalized and more engaging experience for visitors
(For example; providing services specialized to your preferences)

· For optimizing the website by developing (For example; operationalising the pages, on which the fault is found or operationalising the pages, that are not preferred) and

· For remembering the preferences of visitors (the information you enter when logging into our website, language preference and other preferences)

1.3. What are the types of cookies?

Type of Cookie
Cookies according to their validity periods
Session cookies	They refer to temporary cookies held on your devices until you leave the website

Persistent cookies	They are the type of cookies that remain on the hard disk of your device for a long time, and their usage period can vary from a few days to a few years.
Cookies according to their functions
Imperative cookies	Mandatory cookies are cookies that are required to be used in order for the website to function properly and for the users to benefit from the services and navigating features offered on the site.
Functional and Analytical cookies	They are cookies that contain data about how visitors use the site, such as remembering your preferences, using the website effectively, optimizing the site to respond to user requests. By nature, such cookies may contain your personal data. For example; Cookies that record your language preference on our site are functional cookies.

1.4. From where can I reach more information related to the cookies?
The content of cookie texts is often in a qualification that only engineers can handle. The visitors who want to get more information about cookies through a detailed and understandable language are recommended to visit www.allaboutcookies.org or www.aboutcookies.org (in English).

2. SİBEL ULUSLARARASI TAŞIMACILIK VE DIŞ TİCARET LİMİTED ŞİRKETİ OUR COOKIE USAGE

2.1. Who sends cookies within The Scope of Using Our Website and how?

The cookies are forwarded
1. by Sibel Uluslararası Taşımacılık ve Dış Ticaret Limited Şirketi and/or
2. by third persons if some contents on website visited like video or photographs are obtained, and through the communication established between the scanners (Google Chrome, Safari etc.) and communication servers situated on your device during your navigating.

2.2. How do we use the information that we received from your device?

Cookies help in recalling of
· the navigating and use preferences made by you during your visit on our website
· the information and results relating to evaluation and questionnaire answered by you on our website
· the information relating to your preferences
In addition, we use for statistical purposes by anonymizing the articles, news, and content on our website the frequency of clicks during your visits and usage data for the pages visited by you.

In order for your authentication, we don’t use your data picked up by us through the cookies.
Cookies are not used for other purposes than those specified in this policy, and are not processed in violation of data protection legislation.

2.3. How can I control the cookies?
You do not have to accept cookies in order to use our website, but in this case, the quality of your user experience may decrease.

You can delete cookies or set your internet browser to block cookies, but some services on our website may not work as they should.

For detailed information about your browser's settings related to cookies:

Chrome https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=tr
Firefox https://support.mozilla.org/tr/kb/web-sitesi-tercihleri-cerezleri-acip-kapatma
Safari Browser https://support.apple.com/tr-tr/guide/safari/sfri11471/mac
Opera Bowser https://www.opera.com/tr/terms
Microsoft Internet Edge Browser https://support.microsoft.com/tr-tr/help/17442/windows-internet-explorer-delete-manage-cookies

Purpose

• Personal Data Storage & Disposal Policy ("Policy") is prepared with the purpose of determining the procedures and principles regarding jobs and operations of the storage and destruction activities of Sibel Uluslararası Taşımacılık ve Dış Ticaret Limited Şirketi. ("Sibel")

In Sibel processing personal data of employees and potential employees, supplier officials, visitors and other third persons in accordance with Turkish Constitution, International Contracts, Personal Data Protection Law (KVKK) no.6698 and other related legislation, and enabling related persons to use their rights effectively is of utmost importance. 

Where do we save the personal data?

Personal data are stored in the following mediums in accordance with the law.

Electronic Platforms Servers (domain, back-up, e-mail, database, web, file sharing etc.) Softwares (office softwares, portals, EBYS, VERBİS.) Information Security Devices (firewallü, attack detection and prevention, daily log file, antivirus etc.)  Personal Computers (Desktop, laptop)ü  Mobile Devices (Phone, tablet etc.)ü Optical disks (CD, DVD, etc.)ü Removable Memories (USB, Memory Cardü etc.)    Printer, Scanner, Photocopy Machine

Non Electronic Mediums Paper Manual data logging systems (survey forms, üvisitor entrance log) written, printed, visual mediums

 Descriptions Regarding Storage
Your personal data is stored for the du

Processing Purposes That Requires Storing
Sibel stores the personal data it processes within its regular activities for the following purposes. 

· Managing human resources processes
·  Managing communication processes
·  Providing protection
·  Executing works and operations upon signed contracts and protocols.
· In scope of VERBIS; determining the preferences and needs of employees, data controllers, contact persons, data controller agents and data processors; arranging the services accordingly and updating them if necessary. 
· Ensuring legal obligations are fulfilled as required by legal regulations. 
· Fulfilling legal obligations
·  Obligation to demonstrate as evidence in future legal disputes.

Reasons Requiring Disposal
·  Purpose that requires the processing or storage of personal data, loses validity.
·  When related person revoke their open consent if the processing of personal data only takes place with open consent condition 
· Sibel accepting the persons application made within their rights, regarding the disposal and destruction of their personal data in accordance with Article 11 of the law. 
· A person filing a complaint and Board approving this complaint. 
· The time requiring the storage of personal data being passed and no other condition remains that justifies storing of the personal data.

Upon these situations, the data will be disposed, erased, or anonymized upon the request of related person.

TECHNICAL AND ADMINISTRATIVE MEASURES
Sibel takes technical and administrative measures; to store personal date safely, and to dispose of the date in accordance with the law to prevent illegal access & process of the data; according to regulations.

Technical Measures
The technical measures taken by Sibel regarding the personal data it processes are as follows: 

·Leakage (Penetration) tests Sibel's information systems, surfacing risks, threats, weaknesses and vulnerabilities if any and necessary precautions are taken. 
·As a result of real-time analysis with information security incident management, risks and threats that will affect the continuity of information systems are constantly monitored. ·Access to Information Systems and authorization of users is done through security policies through the access and authorization Matrix and through the corporate Active Directory.
· Necessary precautions are taken for the physical security of information systems equipment, software and data. 
·Hardware-wise (access control system that provides access of authorized personnel only, 24/7 monitoring system, providing physical security of edge keys that forms the local network, fire extinguishing system, air conditioning system), and software-wise (firewalls, attack prevention systems, network access control, systems that prevent malware etc.) precautions are taken 
·Risks of preventing illegal processing of personal data, taking techincal measures fit for these and risks and technical controls regarding these measures are done. 
·Access procedures are formed with Sibel to report the access to personal data and analysis studies are conducted 
·Access to storage units containing personal data are logged and inappropriate accesses or access trials are controlled. Sibel takes precautions to ensure that the the deleted personal data is inaccessibale and unusable.  
·An appropriate system and infrastructure is formed by Sibel to notify the use and the Board if the personal data is accessed illegaly by others.
·Security breaches are followed and appropriate security patches are loaded and information systems are kept up-to-date.  Strong passwords are used in electronic mediums in which personal data is processed.
·Safe logging systems are used in electronic mediums in which personal data is processed. 
·Data backup programs are used that ensures personal data is stored safely. 
·Access to stored personal data, whether stored electronical or non-electronical mediums, is limitied in accordance with access principles.  Access to Sibel webpage is encrypted with SHA 256 Bit RSA algorithm by using safe protocol (HTTPS). 
·A different policy is determined for the security of sensitive personal data.
·  The necessary trainings are given about sensitive personal data security to personnel working in sensitive personal data storing processes, nondisclosure agreements are signed, users with access are authorized. 
·The electronic mediums in which sensitive personal data is processed, stored and/or accessed are kept safe with cryptographic methods, cryptographic keys are kept in safe mediums, all processes are logged, security updates of mediums are followed, necessary security tests are done regularly and test results are logged. 
·The physical mediums in which sensitive personal data is processed, stored and/or accessed are secured as required, and physical security is ensured by preventing unauthorized access.                         
·If sensitive personal data are to be transferred via e-mail, it should be sent via corporate mail address or KEP account, encrypted. If it is to be transferred via mediums like memory stick, CD, DVD it should be cryptographically encrypted and cryptographical keys should be kept apart. If the transfer is in between servers that are in different physical locations, a VPN should be set up between servers or sFTP method should be used for data transfer. If the transfer must be through paper, necessary precautions should be taken against risks like stealing, losing and the document being seen by unauthorized people and the documents should be sent "confidentially".

Administrative Measures
The administrative measures taken by Sibel regarding the personal data it processes are as follows: 

·To improve the qualifications of the workers trainings on prevention of unlawful processing of personal data, prevention of unlawful access of personal data, provision of protection of personal data, communication techniques, technical skills and related legislation. 
· Nondisclosure Agreements are signed by employees regarding the activities of Sibel. 
·Disciplinary Procedure is prepared for the employees not conforming with security policies and procedures. 
·Clarification obligation must be fulfilled by Sibel before processing personal data. 
·Personal data processing inventory was prepared.
· Periodical and random internal audits are made.
· Information security trainings are given to employees.

METHODS OF DISPOSAL OF PERSONAL DATA
After the storing period of the personal data that is provided in related regulations or required by the purpose of processing; the personal data are deleted by Sibel after related persons application by themselves or ex officio, in accordance with the regulations, with the following methods.

Disposal of Personal Data
Your personal data are deleted with the following methods:

Logged Medium of Data	Description
Personal Data in Servers	The personal data in servers of which that doesn't need to be stored anymore, the access authorization of related are removed and deletion is done.
Personal Data in Electronic Medium	The personal data in electronic mediums of which that doesn't need to be stored anymore are made inaccessible and unusable to other employees (related users) except for the database manager.

Personal Data in Physical Medium	The personal data in physical mediums of which that doesn't need to be stored anymore are made inaccessible and unusable to other employees except for the manager responsible for document archives. Moreover, black-out is applied by drawing/painting/erasing making it unreadable
Personal Data in Portable Medium	The personal data in portable mediums of which that doesn't need to be stored anymore are encrypted by system manager and kept safe with the encryption key only giving access to system manager.

 

Destruction of Personal Data
Your personal data are destroyed with the following methods. 

Logged Medium of Data	Description
Personal Data in Physical Medium	The personal data in paper mediums of which that doesn't need to be stored anymore are destroyed irreversibly with paper shredders.
Personal Data in Optical/Magnetic Medium	The personal data in optical and magnetic mediums of which that doesn't need to be stored anymore are destroyed physically with methods like melting, burning or pulverizing. Moreover, data in magnetic medium are made unreadable with a special device that applies high magnetic field on the medium.

 
Anonymization of Personal Data
Anonymization personal data is to make personal data unrelated to an identified or identifiable person by any means, even if it is matched with other data. To anonymize personal data, it must be rendered unrelated to an identified or identifiable person, and keeping it unrelated even by using appropriate techniques for the recording environment and related field of activity.

STORAGE & DISPOSAL PERIODS
Storage & disposal periods are as follows.

Personal Data	Storage Period	Distruction Period
Identity Data	10 years	In the first periodical disposal after its storage period ends
Communication Data	10 years	In the first periodical disposal after its storage period ends
Location Data	5 years	In the first periodical disposal after its storage period ends
Personal Data	10 years	In the first periodical disposal after its storage period ends
Legal Transaction Data	10 years	In the first periodical disposal after its storage period ends
Customer Transaction Data	10 years	In the first periodical disposal after its storage period ends
Physical Place Secuirty Data	6 months	In the first periodical disposal after its storage period ends
Transaction Security Data	5 years	In the first periodical disposal after its storage period ends
Professional Experience Data	10 years	In the first periodical disposal after its storage period ends
Audio-visual records.	6 months	In the first periodical disposal after its storage period ends
Health Data	10 years	In the first periodical disposal after its storage period ends
Data on Criminal Convictions and Security Measures	10 years	In the first periodical disposal after its storage period ends

 
Periodic Disposal Period 
Sibel determined the periodic disposal period as 6 months according to Article 11 of the regulation.

Updating The Policy
The policy will be reviewed and parts necessary will be updated.

As Sibel Transportation Import Export Co Ltd we collect from visitors, or use of our websites within the scope of protecting the privacy of our members is approaching and the precision of the data in question data collection, transfer and use in the privacy standards within the framework of nationally and internationally accepted procedures and principles with you that we have adopted this Privacy Policy (“Policy”) through which we share.

• Definitions 
  
  In scope of this Policy hereby,

• KVK Policy: The Personal Data Protection & Process Policy of Sibel Uluslararası Taşımacılık ve Dış Ticaret Limited Şirketi
• Policy: The Privacy Policy of Sibel Uluslararası Taşımacılık ve Dış Ticaret Limited Şirketi.
• Visitor: Means the person or persons who use the services of our website.
• The personal data you share with us while using The Websites

are; via Instant Offer form through, https://www.sibel.com.tr/ as

• Name - Surname
• Contact Information (e-mail, phone, company)

• Collected via Internet sites and these data are processed within the scope of KVK Policy and personal data is stored, deleted, destroyed or made anonymous according to Sibel Uluslararası Taşımacılık ve Dış Ticaret Limited Şirketi storage and Disposal Policy.

 

• Data About Children
• As Sibel Uluslararası Taşımacılık ve Dış Ticaret Limited Şirketi, our websites are intended to be used by adults and are not intended for children. Members and visitors of all activities carried out through our Web Site in accordance with the law of the appeal of legal action and activities that must be done by minors only legal persons (18 years older than the condition) and Minors (18 years younger, especially) can only take action through their parents or legal representatives.

Individuals of not legal age sharing their personal data with us in responsibility of parent or guardian.

As a parent or legal representative, you can contact us at  https://www.sibel.com.tr/ regarding the data shared through the websites without your consent.

• Our purposes in processing your personal data

 

Personal data is used but not limited to, for the purposes of 

• improving the services we offer through The Websites,
• Sending newsletters or notification,
• Providing an efficient customer service by answering the complaints,
• To ensure communication with customer request, suggestion, complaint and help requests,
• To take the necessary legal measures within the scope of the Prevention of illegal content and
• Fulfillment of the contract with the contracted company,

• Sharing personal data
  Within the scope of the KVK Policy, in accordance with this Policy and as per the Law on the Protection of Personal Data and other legislation in force, your personal data may be anonymized and shared with our companies as required; moreover, these may be transferred within the domestic borders and abroad with our business partners, business connections, contractors and subcontractors in cases when specified by the relevant legislation, regulatory, supervisory institutions and official authorities or for the purpose of the development of a service we provide .
  
  

• Links to third party websites or applications via our websites
  Links to third party websites, mobile applications and portals such as Facebook, LinkedIn, Twitter, Instagram are provided through our websites. Your personal data collected in the context of the use of such web site and applications is not covered by this policy. Therefore, it is recommended that third-party websites and mobile applications process personal data and examine privacy policies.

• Cookies
  Your data is also collected through technical communication files called cookies, which enable our websites to operate properly, provide services to users in a personalized manner, and improve the user experience. For detailed information about Cookie Usage, please check our SİBEL ULUSLARARASI TAŞIMACILIK VE DIŞ TİCARET LTD. ŞTİ. COOKIE POLICY.

• Other information’s we collect automatically
  We may collect personal data about you in order to improve the hardware and software technologies we use and other services we offer, to adapt them to the individual or corporate demands and needs of our customers, users and visitors, to address technical problems encountered during the performance of such services, and to control our infrastructure. For example, our servers automatically store certain information, such as the IP addresses of devices accessing our websites, the pages they access, the dates of visits, and the browser type and language.

• Data Security
  We take all reasonable technical and administrative measures, including physical security measures, vulnerability screening tests, virus protection software, and network security systems, to ensure that the personal data you share with us is processed, stored and accessible only by authorized persons, in accordance with the law. However, the systems used for the processing and storage of personal data are updated and reviewed (controlled) periodically. We also undertake to report and notify the relevant persons and authorities in the event of deletion or alteration or access of existing personal information and data by third parties in violation of the law.

• Electronic messages
  You may opt out of the text message, e-mail or instant messaging services that we send to you for information and communication purposes by forwarding the relevant messages.

• Updating Policy
  The provisions of this policy may be amended or renewed, in whole or in part, to enter into force on the date of publication of our websites. You are not notified about this situation so, we suggest you to follow mentioned environments.

• Contact Information’s
  You may submit your questions, reservations or complaints regarding the interpretation or implementation of this policy to
  registered email address sibel@hs01.kep.tr and/or to the address  Ferhatpaşa District 77. Street No:  61/1  Ataşehir/İstanbul