• • INTRODUCTION 
  • PURPOSE  :

As KIVILCIM ASSOCIATION (referred to as KIVILCIM), we show utmost sensitivity to the security of your data. Personal Data Protection Law No. 6698 (from now on referred to as KVKK or the Law) entered into force on April 7, 2016. With this KIVILCIM Association Information Text on the Protection and Processing of Personal Data, KIVILCIM Association and ‘Kıvılcım PinPoint Economic Enterprise’, which is affiliated with KIVILCIM Association and does not have a legal entity, fulfill the obligations regarding the protection and processing of personal data, determine the principles to be followed and aims to enlighten people from every aspect determine the data owner whose personal data is processed.

With this awareness, KIVILCIM Volunteers/Volunteer candidates, namely KIVILCIMs and Candidate KIVILCIMs, donors, scholarship holders, people in need, KIVILCIM members and member candidates, and all applicants and members without discrimination will be coded/processed within KIVILCIM and We attach great importance to the processing, preservation, and destruction of personal data per the secondary regulations enacted and/or to be enacted by law and the binding decisions taken and/or to be taken by the Personal Data Protection Board and the destruction policy established by the law.

In line with the principles determined by the law and all secondary legislation, we hereby inform you that, as the “Data Controller”, your data will be processed in the manner and under the conditions specified in this clarification text, and in this context, KIVILCIM Association and the entities established within this association by the relevant legislation carry out all personal data processing activities within the scope of the law. All your data is processed under the conditions specified in this information text and within the limits prescribed by the relevant legislation.

The concept of “personal data” in this document is used to include special personal data. We would like to point out that we will not have any liability within the scope of KVKK and other legislation regarding the information and documents you submit to us, other than the information requested from you during application and/or registration.

• • INFORMATION OF THE DATA CONTROLLER

KIVILCIM ASSOCIATION, registered in the Registry of Associations by the law and residing at the address “Ikitelli OSB Mahallesi Giyim Sanatkarları 2C Blok K:6 D:609/2 Başakşehir 34490 İstanbul-Türkiye”, is the data controller.

KIVILCIM Association is the data controller for all entities with and/or without legal entity, including the Kıvılcım PinPoint Economic Enterprise, which will be established under the legal entity of KIVILCIM Association.

• •  PERSONAL DATA PROCESSING POLICY
    • DATA CONTACTS::

WHOSE PERSONAL DATA DO WE PROCESS? 
By this policy, KIVILCIM is concerned with all personal data of individuals processed by automatic and/or non-automatic means. The persons whose personal data may be processed with this policy are listed below but are not limited to them, and all rights regarding the processing of personal data that they have communicated with KIVILCIM or by any means are reserved.

• KIVILCIM Association Members/Member Candidates
• KIVILCIM Association Volunteers/Volunteer Candidates
• People in Need Who Apply Through All Channels of KIVILCIM
• Kıvılcım PinPoint Economic Enterprise PinPoint Website Users and Members,
• Scholars
• Donors
• All relevant real persons, including those who share their data with KIVILCIM through legal/illegal means

• PROCESSED PERSONAL DATA:

WHAT PERSONAL DATA DO WE PROCESS?

• Identity Information (Name, Surname, TR-ID No., Date of Birth, Place of Birth)
• Contact Information (Phone, E-Mail Address, etc.)
• Address Information (Home Address, Work Address, etc.)
• Information Regarding Education, Business and Professional Life (Educational Status and Graduation Information, Profession, Working Status)
• Personal Information (Marital Status, Child Information, Disability Status, Veteran/Martyr Status, Relevant Information if Guardian, etc.)
• Bank Information (Sending the scholarship for scholarship holders, bank information of those in need – if necessary – etc.)
• Documents Regarding Income Status (For applicants requesting assistance: Income Certificate, Poverty Certificate, SSI Statement records, Tax Certificate, etc.)
•  Health Documents (For applicants requesting Health Assistance; prescription, official document showing medical need, doctor, and hospital reports, etc.)

• PROCESSING OF SPECIAL PERSONAL DATA:

WHAT IS SPECIAL PERSONAL DATA AND HOW DO WE PROCESS THEM?
Sensitive personal data is given special importance within the scope of the Law due to the risk of causing victimization or discrimination when processed unlawfully. These special categories of personal data are as follows; data regarding race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, appearance and clothing, association, foundation or union membership, health, sexual life, criminal conviction, and security measures, as well as biometric and genetic data.
Special categories of personal data are processed by the Kıvılcım Association by the principles specified in this Policy and by taking all necessary administrative and technical measures, including the methods determined by the KVK Board, and if the following conditions are met. According to the provisions of the relevant law, special personal data can only be processed with the explicit consent of the data subject. However, if there is a provision in other legal legislation, the data may be processed without the explicit consent of the data subject. In this regard, all our legal rights are reserved.

• PURPOSE OF DATA PROCESSING:

FOR WHAT PURPOSE DO WE PROCESS YOUR DATA?

Your personal data is processed by KIVILCIM for the following purposes;

• To ensure the registration of your data by the Law on Associations and all relevant legislation,
• To carry out our activities in line with the purposes defined by the Kıvılcım Association Charter,
• To provide opportunities such as participation, e-bulletins, benefiting from events and to carry out all necessary actions to make them available to you,
• Keeping records and communicating with Kıvılcım Association Volunteers and/or Volunteer Candidates,
• Planning and managing e-commerce service activities within Kıvılcım PinPoint Economic Enterprise,
• To provide support to those in need who apply and to manage all related processes,
• Providing scholarships to students who apply for scholarships and managing all processes related to this,
• The purpose of fulfilling all legal obligations by ensuring communication in terms of donors’ information and expressing gratitude for the donation,
• Being able to organize,
• Communicating with those in need within the scope of the projects,
• Providing information about new projects and collaborations,
• Carrying out relations with suppliers and other third parties,
• Planning and carrying out risk management and quality improvement studies,
• Following and executing sponsorship processes,
• To ensure the fulfillment of legal obligations, as required or required by legal regulations,
• For all other purposes specified in KVKK. 

• PERSONAL DATA PROCESSING POLICY: 

HOW DO WE PROCESS YOUR DATA?
Your data is collected by KIVILCIM verbally, in writing, or electronically, by automatic and/or non-automatic methods, such as e-mail, telephone, website, and/or forms kept on paper.

In this context, all your general and special personal data are processed for the legitimate interests of the data controller, provided that they are made public by the relevant person himself by paragraphs 2/d-e-f of Article 5 of the Law and do not harm the fundamental rights and freedoms of the relevant person and Data processing is processed based on legal reasons that are mandatory.
KIVILCIM is not responsible for the personal data sent by the data subject via e-mail and all other online communication channels, in terms of documents that are not submitted physically and/or through the KIVILCIM official website, and in such cases, KIVILCIM is not responsible and will not be held responsible for any transfers abroad that may occur if the data providers are not located in Turkey.

• THOSE WHO HAVE ACCESS TO PERSONAL DATA:  

WHO CAN ACCESS YOUR DATA?

WITHIN THE ASSOCIATION;

• Kıvılcım Association Full and Alternate Board Members
• Kıvılcım Association Principal and Substitute Audit Board Members
• Kıvılcım Association Social Service Coordinators
• Kıvılcım Association Volunteer Coordinators
• Kıvılcım Association & Kıvılcım PinPoint Economic Enterprise Employees

OUTSIDE THE ASSOCIATION;

• Association Software Employees
• Association Contracted Lawyer
• Association Contracted SMM

• TRANSFER OF PERSONAL DATA:

TO WHOM AND FOR WHAT REASONS DO WE TRANSFER YOUR PERSONAL DATA?

DOMESTIC TRANSFER OF PERSONAL DATA ?

• DOMESTIC TRANSFER OF PERSONAL DATA

As KIVILCIM, we act in accordance with the regulations stipulated in the KVKK and the decisions taken by the KVK Board regarding the transfer of personal data. Without prejudice to the legal compliance reasons in the legislation, personal data and sensitive data will not be transferred to third parties without the express consent of the relevant person

• THIRD PARTIES TO WHICH PERSONAL DATA IS TRANSFERRED BY KIVILCIM

Personal data may be transferred to the categories of persons listed below within the scope of the rules specified in this Policy: :

• KIVILCIM Officials,
• KIVILCIM Officials,
• KIVILCIM Suppliers,
• Relevant Donors,
• Within the Scope of the Project, KIVILCIM Collaborators,
• Within the Scope of the Project, KIVILCIM Collaborators,
• Legally Authorized Private Law Real/Legal Persons
• Third persons and institutions that can be transferred in cases deemed appropriate by law.

• TRANSFER OF PERSONAL DATA ABROAD

As a rule, personal data cannot be transferred abroad without the explicit consent of the relevant person. However, if one of the reasons for compliance with the law stated in this Policy exists;

• Personal data may be transferred if third parties abroad are located in countries with adequate protection declared by the KVK Board
• If third parties abroad are in countries without adequate protection, personal data may be transferred abroad without explicit consent, provided that the data controllers in Turkey and the foreign country in question undertake adequate protection in writing and have the permission of the KVK Board.

If one of the situations mentioned above does not exist, personal data may be transferred abroad by applying for the express consent of the individuals. However, KIVILCIM cannot be held responsible for situations arising from the fact that personal data sent via e-mail and/or various online platforms is not under the control of KIVILCIM, and the hosting providers of the said channels are abroad.

•  STORAGE OF PERSONAL DATA
  • STORAGE PERIOD OF PERSONAL DATA

HOW LONG DO WE PROCESS/STORE YOUR DATA?
As KIVILCIM, we do not retain your data for the period necessary for the purpose for which they are processed, and the minimum period stipulated in all other legal legislation to which our association is subject. In this context, our association first determines whether a period is stipulated in the relevant legislation for the storage of personal data, and if a period is determined, it acts per this period.
If there is no legal period, personal data is stored for the period necessary for the purpose for which they are processed. At the end of the specified storage periods, personal data is destroyed by the periodic destruction periods or the data owner’s application and with the specified destruction methods (deletion and/or destruction and/or anonymization).

• STORAGE OF PERSONAL DATA::

HOW DO WE STORE YOUR DATA?

• If your data is automatically processed data:

It is stored on the data server and database of turhost.com, which is within Aerotek Bilişim Sanayi ve Ticaret AŞ.

• KIf your data is not processed automatically / processed physically:

It is kept in specially prepared compartments at KIVILCIM’s association headquarters. In addition, a separate and highly secure area has been allocated to store your sensitive data. The majority of physical documents are also scanned and stored safely on KIVILCIM’s data server.

• SECURITY OF PERSONAL DATA:

WHAT PRECAUTIONS DO WE TAKE TO PROTECT YOUR DATA?

As KIVILCIM, by Article 12 of the Law, we take the necessary measures, depending on the nature of the data to be protected, to prevent unlawful disclosure, access, transfer of personal data, or security deficiencies that may occur in other ways. In this context, our legal team, working in agreement with our association, takes administrative measures, carries out inspections, or has them carried out to ensure the necessary level of security following the guides published by the Personal Data Protection Board.

In addition, technical and administrative measures taken to protect personal data are carefully implemented in terms of special personal data and necessary controls are provided.

KIVILCIM takes appropriate and necessary measures, such as software systems and physical security measures, to prevent the unlawful processing of personal data, to prevent unlawful access, and to ensure their preservation, by KVKK Article 12 of information systems containing personal data. We prevent the unlawful processing of personal data by third parties. If personal data is obtained by others through illegal means, the notification specified in Article 12 of the KVKK will be made by KIVILCIM by legal regulations.

• DISPOSAL POLICY

The Destruction Policy is operated in the ways stipulated by the Law and secondary legal legislation, and your data is destroyed by legally determined situations. To summarize, data that is processed automatically and is not physically available is destroyed by software means, while data that is processed by non-automatic means and is physically available is destroyed by burning.

• RIGHTS AND APPLICATIONS OF DATA SUBJECTS
  • RIGHTS OF THE DATA SUBJECT:

WHAT ARE YOUR RIGHTS?
Data subjects have the following rights:

• Learning whether personal data is processed or not,
• Requesting information if personal data has been processed,
• Learning the purpose of processing personal data and whether they are used for their intended purpose,
• Knowing the third parties to whom personal data is transferred at home or abroad,
• Requesting correction of personal data in case of incomplete or incorrect processing and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,
• Requesting the deletion or destruction of personal data in case the reasons requiring processing no longer exist, even though it has been processed by the law and other relevant legal provisions, and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,
• Objecting to the emergence of a result that is unfavorable to the person by analyzing the processed data exclusively through automatic systems,
• Requesting compensation for the damage in case of damage due to illegal processing of personal data. 

• APPLICATION METHODS

HOW CAN YOU USE YOUR RIGHTS?

In order to exercise your rights listed above and arising from the law, you can apply to our association by filling out the Kıvılcım Association KVK Application Form below and using one of the methods included in the form; https://kivilcimdernegi.org/
kvkk/.docx
In order to exercise your rights listed above and arising from the law, you can apply to our association by filling out the Kıvılcım Association KVK Application Form below and using one of the methods included in the form;