Frigian Privacy Policy


1. Introduction

  • 1.1. Purpose of Policy: Law No. 6698 on the Protection of Personal Data (“Law”) Frigian Information Services and Technologies Inc. (“Frigian” or “the Company”) prioritize the legal processing and protection of personal data. We follow the same priority in all our planning and business activities. In this context, to enlighten you in accordance with Article 10 of the Law, we hereby submit this Personal Data Processing and Protection Policy (“Policy”) for your information in order to inform you of all administrative and technical measures that we will implement in the processing and protection of personal data.


  • 1.2 Scope: This Policy sets the conditions for the processing of personal data and sets out the principles adopted by Frigian in the processing of personal data. In this context, Policy; It covers all personal data processing activities, all personal data processed and the owners of these data under the Law carried out by Frigian.


1.3 Definitions

Outdoor Consent: Consent based on information on a particular subject, which is free-willed.

Anonymous: Making the data previously associated with a person unmatched in any way, even by pairing with other data, cannot be associated with an identifiable or identifiable real person.

Employee Candidate: Real persons who do not work within the Frigian but who are working candidate status.

Personal Data: Any information relating to an identifiable or identifiable natural person.

Data Owner: Real person whose personal data is processed.

Processing of Personal Data: Obtaining, storing, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, classifying or using personal data completely or partially automatically or provided that it is part of any data recording system. any processing performed on data such as

Law: Law No. 6698 on the Protection of Personal Data, published in the Official Gazette dated April 7, 2016 and numbered 29677.

Policy: Frigian Information Services and Technologies Inc. Personal Data Processing and Protection Policy

Company / Frigan: Frigian Information Services and Technologies Inc.

Data Processing: It is a natural and legal person who processes personal data on behalf of the person responsible for the data.

Data Officer: It is the person who determines the purposes and means of processing personal data and manages the place where the data is kept in a systematic way.

Data Recording System: It is a recording system in which personal data is structured and processed according to certain criteria.

Work partners: Persons with whom Frigian has established a contractual relationship within the framework of its commercial activities.


1.4 Enforcement of Policy

This Policy, issued by Frigian, came into force on 1 October and was made public. In case of any contradiction between the legislation in force and the regulations in this Policy, particularly the Law, the provisions of the legislation shall apply.


Frigian reserves the right to make changes to the Policy in accordance with legal regulations. The current version of Policy is available on the Frigian (www.shiptier.net) website.


2. Information on Frigian s Personal Data Processing Activities

  • 2.1 Data Owners

    Policyholders are all natural persons except Frigian employees whose personal data is processed by Frigian. In general, data owners can be listed as follows:

    Data Owner CategoriesExplanation
    CustomersRefers to real persons who benefit from Frigian s products and services.
    Potential CustomersIt refers to real persons who are interested in the products and services offered by Frigian and who have the potential to become customers.
    Employee CandidatesRefers to natural persons applying for a job by sending a CV to Frigian or by other means.
    Third PartiesThe data categories mentioned above refer to real persons except Frigian employees.

    The data owner categories described in the table above are stated for general information sharing purposes. The fact that the data owner is not covered by any of these categories does not eliminate the qualification of the data owner as specified in the Law.


    2.2 Purposes of processing personal data

    • 2.2.1

      The relevant units shall carry out the necessary work and carry out the business processes in order to benefit the persons concerned from the products and services offered by Frigian:

      • Planning and executing sales processes of products and / or services,
      • Planning and / or performing after-sales support services activities,
      • Planning and executing customer relationship management processes,
      • Monitoring of contractual processes and / or legal requests,
      • Tracking of customer requests and / or complaints.
    • 2.2.2

      Planning and executing Frigian human resources policies and processes:

      • Planning and execution of talent-career development activities,
      • Fulfillment of obligations arising from employment contract and / or legislation for the employees of the Company,
      • Planning and executing benefits and benefits for employees,
      • Planning and conducting internal orientation activities,
      • Planning and execution of personnel exit procedures,
      • Compensation Management
      • Planning human resources processes,
      • Management of personnel procurement processes,
      • Planning and executing appointment-promotion and quitting processes for the company,
      • Planning and executing employee performance evaluation processes,
      • Monitoring and / or supervision of the business activities of the employees,
      • Planning and / or conducting internal training activities,
      • Planning and executing employee satisfaction and / or loyalty processes,
      • Planning and conducting the processes of receiving and evaluating suggestions for improving the work and / or production processes of the employees,
      • Internship and / or student recruitment, placement and operation planning and / or execution.
    • 2.2.3

      To carry out the necessary work by the relevant business units in order to carry out the commercial activities carried out by Frigian and conduct the related business processes:

      • Event management,
      • Planning and execution of business activities,
      • Planning and executing corporate communication activities,
      • Planning and executing supply chain management processes,
      • Planning and execution of production and / or operation processes,
      • Planning, auditing and executing information security processes,
      • Establishment and management of information technology infrastructure,
      • Planning and execution of business partners access to information,
      • Monitoring of finance and / or accounting works,
      • Planning and executing corporate sustainability activities,
      • Planning and executing corporate governance activities,
      • Planning and / or carrying out business continuity activities,
      • Planning and execution of logistics activities.
    • 2.2.4

      Planning and carrying out the activities necessary for the products and services offered by Frigian to be offered to the relevant persons by being customized according to their taste, usage habits and needs:

      • Determining and / or evaluating the people to be the subject of marketing activities in line with consumer behavior criteria,
      • Designing and / or performing customized marketing and / or promotional activities,
      • Designing and / or executing advertising and / or promotional and / or marketing activities in digital and / or other media,
      • Designing and / or carrying out activities to be developed on customer acquisition and / or value creation in existing customers in digital and / or other media,
      • Planning and / or conducting data analytical studies for marketing purposes,
      • Planning and executing the marketing processes of products and / or services,
      • Planning and / or executing the processes of establishing and / or increasing the commitment to the products and / or services offered by the company.
    • 2.2.5

      Planning and executing Frigian s commercial and / or business strategies:

      • Managing relationships with business partners.
    • 2.2.6

      Ensuring the legal, technical and commercial occupational safety of Frigian and the persons involved in the business relationship with Frigian:

      • Follow-up of legal affairs
      • Planning and carrying out the necessary operational activities to ensure that the company s activities are carried out in accordance with the company procedures and / or the relevant legislation,
      • Giving information to the competent authorities from the legislation,
      • Creation and follow-up of visitor records,
      • Planning and executing emergency management processes,
      • Realization of company and partnership law transactions,
      • Planning and carrying out audit activities of the Company,
      • Planning and / or performing occupational health and / or safety processes,
      • Realization of credit processes risk management,
      • Ensuring the security of company premises and / or facilities,
      • Ensuring the security of company operations,
      • Planning and / or executing financial risk processes of the company,
      • Ensuring the security of company assets and / or resources.

    2.3 Personal Data Categories

    Data CategoryExplanation
    IdentificationInformation on documents such as driving license, birth certificate, residence, passport, legal identity, marriage certificate.
    Communication informationInformation used to contact the person (eg e-mail address, phone number, mobile number, address).
    Location informationInformation for locating the owner of the data (eg location information obtained during driving).
    Customer informationInformation on customers who benefit from our products and services (eg customer ID, occupational information, etc.).
    Customer transaction informationInformation on any transactions performed by customers who benefit from our products and services.
    Physical space safety informationPersonal data related to records and documents such as camera records, fingerprint records taken during the entrance to the physical space during the stay in the physical space.
    Transaction security informationPersonal data processed to ensure technical, administrative, legal and commercial security in the conduct of Frigian s commercial activities.
    Financial informationPersonal data processed in relation to the information, documents and records showing all financial results created according to the type of legal relationship that Frigian has established with the personal data owner.
    Employee candidate informationPersonal data relating to individuals who have applied to become Frigian employees or are considered as candidates for employment in accordance with human resources needs in accordance with commercial custom and honesty rules or who are in a working relationship with Frigian.
    Legal and compliance informationFrigian s determination of legal receivables and rights, follow-up and execution of debts, legal obligations and personal data processed within the scope of compliance with the company s policies.
    Inspection and inspection informationPersonal data processed in accordance with Frigian s legal obligations and compliance with company policies.
    Special dataData about the race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, disguise and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures and biometric and genetic data.
    Marketing knowledgeThe personal data processed for the marketing of the products and services offered by Frigian in accordance with the usage habits, tastes and needs of the personal data owner and the reports and evaluations created as a result of these processing results.
    Request / complaint management informationPersonal data relating to the receipt and evaluation of any request or complaint addressed to Frigian.
    Reputation management knowledgeInformation collected in order to protect Frigian s commercial reputation, and evaluation reports and actions taken.
    Event management informationPersonal data processed in order to take necessary legal, technical and administrative measures to protect the rights and interests of Frigian s commercial rights and interests and to protect the rights and interests of its customers.

3. Terms and Conditions for the Processing of Personal Data

Frigian, in accordance with Article 4 of the Law on the processing of personal data; conducts personal data processing in a limited and measured manner in accordance with the purpose, in accordance with the law and with the rules of honesty, with correct and up-to-date, specific, clear and legitimate purposes. Frigian maintains personal data for as long as required by law or for the purpose of personal data processing.

  • 3.1 Principles Regarding the Processing of Personal Data

    Frigian is to enlighten the data owners in accordance with Article 10 of the KVK Law, and in cases where consent is required, they request their consent from the data owners and process this personal data on the basis of the following principles.

    • 3.1.1 Processing of Data in Accordance with Law and Integrity Rule

      Frigian complies with the general principles of trust and honesty in the processing of personal data. In accordance with the principle of honesty, Frigian takes into account the interests and reasonable expectations of the persons involved in its efforts to achieve its goals in data processing.

    • 3.1.2 Ensuring that personal data is accurate and up-to-date when necessary

      Accurate and up-to-date retention of personal data is essential to the Frigian s protection of the person s fundamental rights and freedoms. Frigian has an active obligation to ensure that personal data is accurate and up-to-date when necessary. For this reason, all communication channels are open in order to keep the information of Frigian s contact person accurate and up-to-date.

    • 3.1.3 Processing of Data for Specific, Clear and Legitimate Purposes

      Frigian sets out the purpose of legitimate and lawful personal data processing. Processes as much personal data as is necessary for and in connection with the commercial activity it is conducting.

    • 3.1.4 Data should be limited, limited and related to the purpose for which it was processed

      Frigan; processes personal data for the purposes of its business and for the purposes of its business. Therefore, it processes personal data in a manner that is suitable for the achievement of the specified objectives and avoids the processing of personal data that is not or is not required to achieve the purpose.

    • 3.1.5 Retention of data for the period required for the purpose foreseen or processed by the applicable legislation

      Frigian maintains personal data only for the time required for the purpose for which they are specified or processed in the applicable legislation. In this context; firstly, it determines whether a period is stipulated in the relevant legislation for the storage of personal data, acts in accordance with this period if a period is determined, and if it is not determined, it stores the personal data for the period required for the purpose for which they are processed. The personal data is deleted, destroyed or anonymized by Frigian after the end of the purpose of personal data processing or after the expiry of the period prescribed by the legislation.


    3.2 Conditions for the Processing of Personal Data

    Your personal data is processed by Frigian in the presence of at least one of the personal data processing conditions set out in Article 5 of the Act.

    • 3.2.1 The express consent of the owner of the personal data

      One of the conditions for the processing of personal data is the express consent of the owner. The express consent of the personal data holder should be disclosed on a particular subject, based on information and free will.

    • 3.2.2 The explicit provision of personal data processing activities in the law

      The personal data of the data owner may be processed in accordance with the law without the express consent of the data owner if expressly provided for in the law.

    • 3.2.3 Failure to obtain explicit consent of the person due to actual impossibility

      The personal data of the data owner may be processed if it is necessary to process the personal data of the person who is unable to disclose his consent due to the impossibility or whose consent will not be validated, or to protect the life or body integrity of another person.

    • 3.2.4 Personal data is directly related to the establishment or performance of a contract

      Provided that a contract is established or directly related to its performance, it is possible to process personal data if it is necessary to process the personal data of the parties to the contract.

    • 3.2.5 Frigian fulfills its legal obligations

      If Frigian has to be processed to fulfill its legal obligations as data officer, the personal data of the data owner can be processed.

    • 3.2.6 Publicizing the data owner s personal data

      If the data owner has publicized his personal data, the relevant personal data may be processed.

    • 3.2.7 Data processing is mandatory for the establishment or protection of a right

      If it is necessary to process data for the establishment, use or protection of a right, the personal data of the data owner may be processed.

    • 3.2.8 Mandatory processing of data for Frigian s legitimate interest

      Without prejudice to the fundamental rights and freedoms of the personal data holder, the personal data of the data holder may be processed if Frigian is required to process data for legitimate interests.


    3.3 Processing of Personal Data

    In the processing of personal data determined by Frigian as “special quality” by the KVK Law, the regulations stipulated in the KVK Law are strictly observed.


    By Frigian; personal data of special nature are processed in the following cases, provided that adequate measures are taken by the KVK Board:


    • If the personal data owner has explicit consent, or
    • If the personal data owner does not have explicit consent; Except for the health and sexual life of the personal data owner, personal data of a special nature are required by law.

    The personal data of the personal data owner s health and sexual life, but only for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, health services and financing planning and management of the persons who are under the obligation of secrecy or authorized institutions and organizations processed by.


4. Transferring Personal Data

Frigian is able to transfer the data owner s personal data and private personal data to third parties in Turkey or abroad by taking the necessary security measures in accordance with the lawful personal data processing purposes. In this respect, Frigian acts in accordance with the provisions of Article 8 of the KVK Law.

  • 4.1 Transfer of personal data to third parties in the country

    Your personal data may be transmitted by Frigian in the presence of at least one of the data processing conditions set out in Articles 5 and 6 of the Law and under Title 3 of this Policy, provided that you comply with the basic principles of data processing conditions.


  • 4.2 Transfer of personal data to third parties abroad

    Frigian may transfer the personal data of the personal data owner and private personal data to third parties abroad in the presence of at least one of the data processing conditions described in Chapter 3 of this Policy and taking necessary security measures. Personal data by Frigian; KVK Directors declared as having adequate protection by foreign countries Adequate Protection with Foreign Countries or in case of the absence of adequate protection commits an adequate protection of responsible data in Turkey and in the foreign countries in writing and to foreign countries where the KVK Board s permission Foreign Country in which the Data Officer is Committed to Adequate Protection is transferred. In this respect, Frigian acts in accordance with the regulations stipulated in Article 9 of the KVK Law.


  • 4.3 Third parties to whom personal data are transferred and the purposes for which they are transferred

    In accordance with the general principles of the Law and the data processing conditions of Articles 8 and 9, Frigian may transfer data to the parties categorized in the following table:


    Data Transferable ContactsDefinitionGoal
    Business partnerThe parties with which Frigian establishes a business partnership in carrying out its commercial activitiesLimited sharing of personal data to ensure the fulfillment of the objectives of the partnership
    ShareholdersShareholders authorized to design Frigian s business strategies and audit activities in accordance with the applicable legislationDesigning strategies for Frigian s commercial activities and sharing personal data for audit purposes
    Company officialsMembers of the Board of Directors and other authorized personsDesigning strategies for Frigian s commercial activities, ensuring the highest level of management, and sharing personal data for audit purposes
    Legally Authorized Public Institutions and OrganizationsPublic institutions and organizations legally authorized to receive information and documents from FrigianLimited personal data sharing by relevant public institutions and organizations for information request
    Legally Authorized Private Law PersonsLegal persons who are legally authorized to receive information and documents from FrigianLimited sharing of data for the purpose requested by the relevant private law persons within the legal authority

5. Data Owner Rights and the Use of Related Rights

  • 5.1 Rights of the personal data owner:

    • To learn whether personal data is processed or not,
    • Request information if personal data is processed,
    • Learning the purpose of processing personal data and whether they are used in accordance with their purpose,
    • Knowing the third parties to whom personal data is transferred at home or abroad,
    • If the personal data is incomplete or incorrectly processed, to request their correction and to inform the third parties to whom the personal data is transferred,
    • To request the deletion or destruction of personal data in the event that the reasons that require processing are eliminated, although it has been processed in accordance with the provisions of the KVK Law and other relevant laws, and to request that the transaction carried out within this scope be notified to the third parties,
    • Objection to this result if the processed data is analyzed exclusively through automated systems, if a result arises against the person himself,
    • In case of damages due to unlawful processing of personal data, to demand damages.

    If personal data is not obtained directly from the data owner; (2) if the personal data will be used for the purpose of communicating with the person, within a reasonable period of time from the receipt of the personal data by Frigian, (3) if the personal data will be transmitted, activities regarding the disclosure of data owners are carried out during the transfer.


  • 5.2 In cases where the personal data holder cannot claim his or her rights

    Personal data holders cannot assert their rights listed in 5.1 in these matters as the following cases are excluded from the scope of the KVK Law in accordance with Article 28 of the KVK Law:

    • The processing of personal data by the natural persons within the scope of activities related to him or his family members living in the same dwellings, provided that they are not passed on to third parties and the data security obligations are complied with,
    • Processing of personal data for purposes such as research, planning and statistics through anonymization with official statistics,
    • Processing of personal data for art, history, literature or scientific purposes or within the scope of freedom of expression, provided that it does not violate national crime, national security, public security, public order, economic security, privacy of private life or personal rights or constitute a crime,
    • Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to provide national defense, national security, public security, public order or economic security,
    • The processing of personal data by judicial authorities or enforcement authorities with respect to investigations, prosecutions, proceedings or executions.

    According to the article; personal data holders cannot assert any other rights listed in 5.1, except for the right to claim damages:


    • Personal data processing is necessary for crime prevention or crime investigation,
    • Processing of personal data publicized by the personal data owner itself,
    • Personal data processing is required for the conduct of supervisory or regulatory duties, and for disciplinary investigation or prosecution by authorized and authorized public institutions and organizations and professional organizations in the nature of public institutions, based on the authority granted by law,
    • That personal data processing is necessary to protect the economic and financial interests of the State in relation to budget, tax and financial matters.

6. Deletion, Destruction, Anonymization of Personal Data

Although it has been processed in accordance with the provisions of the relevant law as provided for in Article 138 of the Turkish Penal Code and Article 7 of the KVK Law, personal data will be erased and destroyed upon the request of the Frigian or in case the reasons requiring the disappearance are eliminated or anonymous. In this context, Frigian takes necessary technical and administrative measures within the Company to fulfill its obligation; has developed the necessary functioning mechanisms in this regard; In order to act in accordance with these obligations, it educates the relevant business units, and assigns them and ensures their awareness.


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