The disclosure text aims to inform you about how we, as ININAL PAYMENT AND ELECTRONIC MONEY SERVICES INC. (Ininal), process personal data within the scope of Article 10 of the Personal Data Protection Law No. 6698 ("PDPL" or "Law"). We care about the security and protection of the personal data you share with us. Ininal is a "Data Controller" as stipulated in the Law. In this regard, we process your personal data in accordance with the Law and take appropriate, measured and adequate administrative and technical measures to protect your personal data. Since it is a payment service organization operating within the scope of Law No. 6493, video recordings are taken by means of security cameras located at various points within Ininal offices in order to ensure the security of physical space and financial transactions. Records are only stored on Ininal servers and are only audited by authorized employees. Your personal data in the category of physical space security is processed automatically based on the legal reasons "it is mandatory for the data controller to fulfill its legal obligation" and "it is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject" in Article 5 of the Law.
The personal data in question may be transferred to judicial authorities or relevant law enforcement agencies upon request to resolve legal disputes or in accordance with the relevant legislation.
You are required to contact the Tower management regarding the CCTV recordings installed in the common areas within the Trump Towers.
1. WHO ARE WE AS THE DATA CONTROLLER?
|ININAL PAYMENT AND ELECTRONIC MONEY SERVICES INC.
|Mecidiyeköy Yolu Caddesi No:12 Trump Towers 2. Kule Kat:9 N:448 Şişli/Istanbul
|0850 311 77 01
|e-mail (for Data subject application):
2. WHOSE AND WHICH DATA DO WE PROCESS?
Since it is a payment service organization operating within the scope of Law No. 6493, we may process your personal data in the following categories due to your visit to our Ininal office:
Identity (name and surname), Contact (tel), Physical Space Security (camera recording), Other (such as person visited, purpose of visit date)
3. FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?
Execution of Information Security Processes, Ensuring Physical Space and Financial Transaction Security, Creating and Monitoring Visitor Records. Your personal data are not used for purposes other than these purposes and are processed based on the legal reason of the legitimate interest of the data controller regulated in Article 5/2 (f) of the Law.
4. WHY AND WITH WHOM DO WE SHARE PERSONAL DATA?
In principle, we do not share your personal data we collect with any third party or organization. Nevertheless, we may share it with public institutions and organizations and judicial authorities in order to meet the requests from legally authorized institutions in order to fulfill the legal obligations set out in Article 5/2(ç) of the Law. Your data is disposed of after the purpose for which it was collected has ended.
5. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?
You have the right to claim the followings as the data owner by applying to us as Ininal;
6. HOW CAN YOU EXERCISE YOUR RIGHTS REGARDING PERSONAL DATA?
You may submit your requests regarding your rights listed above and the application of the Law in writing in person. We will conclude your request free of charge as soon as possible and within 30 (thirty) days at the latest - up to ten pages - depending on its nature. You can contact the Tower Management about the personal data you shared at the entrance of Trump Tower.
You may submit your requests within the scope of Article 11 of the Law regulating the rights of the data subject in writing to our address Mecidiyeköy Yolu Caddesi | No:12 Trump Towers 2. Kule | Kat:9 N:448 Şişli | İSTANBUL in accordance with the "Communiqué on the Procedures and Principles of Application to the Data Controller" or to our e-mail address email@example.com via your personal e-mail.
Sincerely yours,ININAL PAYMENT AND ELECTRONIC MONEY SERVICES INC.