CLARIFICATION TEXT IN ACCORDANCE WITH GDPR AND THE PERSONAL DATA PROTECTION LAW NO. 6698 (KVKK)

As CHARMENKO MÜZİK ORGANİZASYON INC. (“Company”), we value the personal data of our customers, product and service suppliers, employees, employee candidates, visitors, and other third parties. As the Data Controller, we process the personal data in our responsibility in accordance with the law and in good faith, within the limits set by the GDPR and Personal Data Protection Law No. 6698 (PDPL).

Your Processed Personal and Special Categories of Personal Data

Your personal and special categories of personal data of the following types are processed by our company. At this point, we would like to emphasize that we do not collect all the following data from each data owner, we collect and process different data specific to different groups of people.

PERSONAL DATA
Type of Data	Received Data
1-Identity	Name-Surname, Identity Number, Parent’s name, Identity information on the identity card and driver’s license, such as gender and signature statement
2-Communication	Your residential address, work address, telephone number and e-mail address, registered e-mail address (KEP), and, if available, your mobile phone number, fax number, or other communication channels that you have provided with your consent so that we can contact you.
3- Location	Location data of electronic devices such as phones and computers provided to employees by the Company.
4-Personnel	The information regarding the working period of our employees, the wages, and the job. Social Security Institution (SGK) registration number, statement of employment, statement of dismissal, payroll, leave information, identity register copy, and the information of foreign employees such as residence, and work permit documents.
5- Employment and Education Information	Information provided to the Company by sending the job application forms to the official e-mail addresses of the Company or by using other online or physical application methods provided by the Company for any kind of application to the Company (job application, internship application…) such as identity information, information about your job status, contact information and information about your educational status, information about the course/seminars you have attended, your certificate information and national or international exam results, and your foreign language certificates.
6-Legal Transactions	Personal legal information included in the case files filed against/by our Company and in correspondence with judicial authorities.
7-Interview Records	Records of the interviews and correspondence made within the scope of the Company’s business activities.
8- Transaction Security	IP address information, website login and logout information.
9-Finance	Information obtained for the purposes of payment of salaries and side benefits, return of overpayments and improper payments, and making payments for external assignments; such as bank name and branch information, bank account number information, IBAN no information, debt reason, debt amount, Insurance Registry No, tax identification number.
10-Visual and Audio Recordings	In concerts, shows, conferences, seminars, theatres, exhibitions, debates, and similar events organized by the Company; for purposes such as promoting, announcing, and popularizing the event; static or flowing images and/or audio of the place where the event takes place and the participants can be recorded. The audio/visual information obtained at the events can be used on the Company’s website, on the social platforms used by the Company, and in the works published by the Company, without exceeding the Company’s activities. Or it can be sent to third parties (printing house, publisher, institution, organization…) to be printed/published with the permission and under the control of the Company.
11-Marketing	Data obtained through campaigns, cookie information.
12-Other	Debit minutes for items delivered to employees.
SPECIAL CATEGORIES OF PERSONAL DATA
Type of Data		Received Data
13-Health Information		Health information of the employee, such as health suitability reports, photocopies of blood group cards, and health reports.
14- Criminal Conviction and Security Measures		Criminal records of our employees and employee candidates.

Purposes of Processing Your Personal Data and Special Categories of Personal Data

Our company processes the personal data of the persons concerned for the following purposes:

Execution of Emergency Management Processes
Execution of Information Security Processes
Execution of Employee Candidate / Intern / Student Selection and Placement Processes
Execution of Application Processes of Employee Candidates
Execution of Employee Satisfaction and Loyalty Processes
Fulfilment of Employment and Legislation Obligations for Employees
Execution of Side Benefits and Interest for Employees
Execution of Audit / Ethic Activities
Execution of Training Activities
Execution of Access Authorizations
Execution of the Activities in Compliance with the Legislation
Execution of Finance and Accounting Affairs
Execution of Company / Product / Services Commitment Processes
Ensuring Physical Space Security
Execution of Assignment Processes
Follow-up and Execution of Legal Affairs
Execution of Internal Audit / Investigation / Intelligence Activities
Execution of Communication Activities
Planning of Human Resources Processes
Execution / Supervision of Business Activities
Execution of Occupational Health / Safety Activities
Execution of the Activities Regarding Business Continuity
Execution of Logistics Activities
Execution of Goods / Services Procurement Processes
Execution of Goods / Services After-Sales Support Services
Execution of Goods / Services Sales Processes
Execution of Goods / Services Production and Operation Processes
Execution of Customer Relationship Management Processes
Execution of Activities for Customer Satisfaction
Execution of Performance Evaluation Processes
Execution of Advertising / Campaign / Promotion Processes
Execution of Risk Management Processes
Execution of Social Responsibility and Civil Society Activities
Execution of Agreement Processes
Conducting the Processes Regarding Requests / Complaints
Ensuring the Security of Movable Property and Resources
Execution of Wage Policy
Execution of Talent / Career Development Activities
Providing Information to Authorized Persons, Institutions, and Organizations
Execution of Management Activities
Creating and Tracking Visitor Records

The Method of Collection of Personal and Special Categories of Personal Data and Legal Basis for Our Processing of Your Data

PDPL lists the conditions for the processing of personal data in paragraph 2 of Article 5. The Company does not engage in any personal data processing activities that do not fall within the scope of personal data processing conditions. The legal bases of the Company regarding data processing activities are as follows:

When the Company has the explicit consent of the person concerned,
When it is clearly stipulated in the laws,
When it is compulsory for the protection of the life or physical integrity of the person, who is unable to express his/her consent due to actual impossibility or whose consent is not legally valid,
When it is necessary to process the personal data of the parties to the agreement, provided that it is directly related to the establishment or performance of an agreement,
When it is mandatory for the data controller to fulfill its legal obligations,
When the data have been made public by the data owner himself/herself,
When data processing is mandatory for the establishment, exercise, or protection of a right,
When it is necessary to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data owner.

The Company collects and processes personal data in fully or partially automatic ways or in non-automatic ways provided that it is a part of any data recording system. Data are collected through systems such as job application forms, various information, and documents submitted to the Company; information and documents created by the Company in human resources, accounting, and business processes such as invoices, waybills, price offer forms, mail and e-mails sent to the Company; persons and companies that the Company provides or receives services from and their business partners; third parties such as companies to which service/product is supplied by the Company, corporate communication accounts, etc.

Sharing Your Personal Data with Third Parties Located in Turkey

Our company may share the data obtained as a data controller for the above-mentioned purposes within the scope of the legal justifications listed in Article 8 of the Law No. 6698.

Limited to the data necessary for the realization of the above-mentioned purposes; It can be transferred to group companies, authorized institutions, and organizations.

PARTIES THAT YOUR DATA MAY BE SHARED WITH	EXAMPLES OF SHARING
Legally Authorized Public/Private Institution or Organization	Data may be shared with official institutions and organizations such as the Ministry of Treasury and Finance, Internal Audit Coordination Board, Court of Accounts, judiciary and enforcement authorities, other public and foundation companies, and notaries.
Supplier/Partner/Consultant	Data may be shared with the consultants, organizations and parties that the company receives complementary services and cooperates with, limited to the purposes of the activities they carry out. In order to make the salary payments, the name, surname, and IBAN information of the employees are shared with the bank, in addition to this, personal information is shared with financial advisors. Identity, communication, and legal transaction information regarding potential labor lawsuits are shared with the contracted lawyers.

Sharing Your Personal Data with Third Parties Located Abroad

Our company does not share any personal data with third parties abroad.

Your Rights Regarding Your Personal Data

Persons whose personal data are processed by our Company have all the rights specified in Article 11 of the Personal Data Protection Law. Within the framework of Article 11 of the Law, the persons concerned can apply to the Company for the following purposes:

To learn whether their personal data are processed, to request information about it if their personal data have been processed,
To learn the purpose of processing personal data and whether they are used in accordance with its purpose,
To know the third parties to whom personal data are transferred domestically or abroad,
Requesting correction in case of incomplete or incorrect data processing,
Requesting the deletion or destruction of personal data,
Requesting notification of the requests regarding the correction, deletion or destruction of personal data to the third parties to whom the personal data have been transferred,
Objecting to the emergence of a result occurred against the person himself/herself due to processing data exclusively through automated systems,
Demanding compensation for the damages in case of loss due to unlawful processing of personal data.

Your Requests Regarding Your Personal Data

You can submit your requests within the scope of your rights listed in Article 11 of Law No. 6698, using one of the following methods in accordance with Article 13 of the Law and Article 5 of the Communique on The Principles And Procedures For The Request To Data Controller. Your requests will be answered free of charge within 30 days in accordance with Article 13 of Law No. 6698. However, if the transaction requires a separate cost, no fee other than the fee specified in the aforementioned Communiqué will be charged.

You can make your applications by submitting them by hand, through a notary public, with your Registered E-Mail Address, or by e-mail. The communication channels of the Company are as follows:

Communication Channels
Address:	Hüseyinağa Mah. Atıf Yılmaz Cad. İstiklal AVM No: 5/63 Beyoğlu/İstanbul
E-Mail:	info@charm-music.com
Registered E-Mail Address:	Charmenko@hs03.kep.tr

The applicant shall apply together with the documents that prove his/her identity. In the applications must include name, surname, identity number, place of residence or workplace address; e-mail address, telephone, fax number, if any, and the subject of the request, and if the application is written, a signature. If these documents/information are not included in the application, no positive response shall be given.