1. PREAMBLE AND LEGAL BASIS

Birleşik Textile (hereinafter referred to as the “Company”) adopts the principle of protecting the privacy of visitors, customers, and employee candidates as a fundamental corporate value. This Privacy Policy (“Policy”) has been prepared in strict compliance with:

• The Law on Protection of Personal Data No. 6698 (“KVKK”) of the Republic of Türkiye.

• The General Data Protection Regulation (EU) 2016/679 (“GDPR”) for our European stakeholders.

This Policy serves as a binding declaration detailing how we process, store, transfer, and destroy data collected through birlesiktextile.com.

2. DEFINITIONS

To ensure transparency, the following terms are defined:

• Data Subject: The natural person whose personal data is processed (Visitor, Candidate, Client).

• Explicit Consent: Consent that relates to a specified issue, declared by free will and based on information.

• Data Controller: The legal entity (Birleşik Textile) determining the purposes and means of processing personal data.

3. COMPREHENSIVE DATA INVENTORY

We collect specific categories of data strictly based on “Legal Reasons” defined in KVKK Art. 5 and GDPR Art. 6:

3.1. Identity & Contact Information

• Collected Data: Name, surname, T.C. Identity Number (only if required for billing), e-mail address, telephone number, corporate title, registered address.

• Legal Basis: Establishment and performance of a contract; Legal obligations (Tax/Commercial Laws).

3.2. Human Resources & Recruitment Data

• Source: Data collected via the “Careers” / “Join Our Team” forms.

• Collected Data: CV/Resume, diploma/degree details, professional history, reference contacts, and interview notes.

• Legal Basis: “Establishment of a Contract” (Processing is necessary for the performance of pre-contractual measures at the request of the data subject) and “Legitimate Interest” of the Company regarding candidate evaluation.

3.3. Digital Trace & Technical Security Data

• Collected Data: IP address, browser type, access logs, duration of visit.

• Legal Basis: Legal Obligation (Law No. 5651 on Regulation of Publications on the Internet).

3.4. Marketing & Commercial Communication

• Collected Data: E-mail address for newsletters (if applicable).

• Legal Basis: Explicit Consent (ETK – Law on Regulation of Electronic Commerce). You may opt-out/unsubscribe at any time.

4. PURPOSES OF PROCESSING

 Your personal data is processed strictly limited to the following purposes:

• Execution of Goods/Services: Managing textile manufacturing, export operations, and logistics.

• Legal Compliance: Fulfilling obligations arising from Turkish Commercial Code and Tax Laws.

• Communication: Responding to inquiries submitted via contact forms.

• Recruitment: Managing the employee selection and placement processes.

• Security: Ensuring the security of the Data Controller’s operations.

5. TRANSFER OF PERSONAL DATA

5.1. Domestic Transfer

Your data may be shared with authorized public institutions (e.g., Revenue Administration), our legal counsels, financial advisors, and contracted logistics partners within Türkiye.

5.2. International Cross-Border Transfer

As a global exporter, the Company may transfer necessary data to servers or business partners located abroad.

• Compliance: Such transfers are conducted in accordance with KVKK Art. 9 (Amended) and GDPR Chapter V.

• Safeguards: We rely on Adequacy Decisions, Standard Undertakings approved by the KVKK Board, or Standard Contractual Clauses (SCCs) to ensure your data receives the appropriate level of protection.

6. RETENTION AND DESTRUCTION POLICY

The Company adheres to the principle of “Storage Limitation.”

• Job Applications (Negative Evaluation): Retained for 1 Year for potential future openings, then securely destroyed.

• Job Applications (Hired): Retained for 10 Years in the personnel file as per Labor Law.

• Accounting & Billing Records: Retained for 10 Years (Turkish Commercial Code).

• Traffic & Log Records: Retained for 2 Years (Law No. 5651).

7. COOKIE POLICY & TRACKING

Our website uses cookies to enhance user experience.

• Strictly Necessary Cookies: Essential for security.

• Analytical/Performance Cookies: Google Analytics (Anonymized).

• Marketing Cookies: Disabled by default unless you give explicit consent via our Cookie Banner.

You can manage your preferences or disable cookies via your browser settings.

8. DATA SECURITY

The Company employs high-level technical and administrative measures (SSL encryption, firewalls, restricted access) to prevent unlawful processing of personal data. In case of a data breach, we notify the relevant authorities (KVKK Board) and affected individuals within 72 hours.

9. RIGHTS OF THE DATA SUBJECT

In accordance with Article 11 of KVKK and GDPR Articles 15-22, you have the right to:

• Learn whether your data is processed and request information.

• Request correction of incomplete/inaccurate data.

• Request deletion or destruction of data (“Right to be Forgotten”).

• Object to automated decision-making processes.

• Withdraw your consent for marketing communications.

10. APPLICATION AND CONTACT INFORMATION

To exercise your rights under Article 11 of the KVKK, you may verify your identity and submit your requests using one of the following methods, in accordance with the Communiqué on the Principles and Procedures for the Request to Data Controller:

• In Writing (Via Notary or Certified Mail): Hürriyet, Atatürk Cd. No:1, 34209 Bağcılar/İstanbul, Türkiye

• Via Registered Electronic Mail (KEP): birlesiktekstil@hs01.kep.tr

• Via E-mail: info@birlesiktextile.com

We will verify your identity to prevent unauthorized data sharing and respond within 30 (thirty) days free of charge.