PERSONAL DATA PROTECTION LAW CLARIFICATION TEXT
Your privacy is respected, and your data security is prioritized at GROUP SAGUN AND OUR AFFILIATED COMPANIES (Kemal Balıkçılık İhracat Ltd. Şti, Tsm Deniz Ürünleri Sanayi ve Ticaret A.Ş, Marines Gıda Ürünleri Sanayi ve Ticaret A.Ş, Merlion Deniz Ürünleri Sanayi ve Ticaret A.Ş, Sagun Aqua Kültür Balıkçılık Sanayi ve Ticaret A.Ş, Sagun Su Ürünleri Ltd. Şti, Feed Co Yem Hammaddeleri Katkı Malzemeleri İthalat İhracat Ticaret A.Ş).
In this context, this clarification text has been prepared to explain, inform, and illuminate you regarding the processing of your personal data, particularly for the purpose of protecting fundamental rights and freedoms, including the privacy of private life, under the Personal Data Protection Law No. 6698 (“KVKK”) and other applicable legislation.
You may access more detailed information on the processing of your personal data in the Group Sagun Personal Data Protection and Privacy Policy (KVK) available on our homepage.
1. INFORMATION
The Personal Data Protection Law No. 6698 (“KVKK”) was adopted on March 24, 2016, and published in the Official Gazette on April 7, 2016.
Article 32 titled “Enforcement” stipulates that Articles 8, 9, 11, 13, 14, 15, 16, 17, and 18 entered into force on October 7, 2016.
The Law aims to protect fundamental rights and freedoms, especially the privacy of private life, in the processing of personal data and to regulate the obligations of persons who process personal data and the procedures and principles to be followed.
This clarification text is presented to fulfill the obligation of informing and to provide visitors with information regarding the “Protection of Personal Data and Personal Data Sharing Consent.”
Group Sagun undertakes not to sell, rent, or make available to third parties your name, e-mail address, home or work address, telephone number, or other personal data submitted through the forms on this site.
2. PURPOSE OF PROCESSING PERSONAL DATA
Your personal data is processed by our Company:
To enable relevant persons to benefit from our services and products,
To carry out necessary work and related business processes within relevant departments,
To conduct commercial activities and related processes,
To plan and execute business and/or commercial strategies,
To ensure the legal, technical, and commercial security of our Company or persons involved in a business relationship with our Company,
To create a membership record and perform identity verification on our website,
To provide and improve services offered through our website,
To develop suitable software versions,
To respond to communication requests submitted via our website,
To fulfill obligations inherent to the services offered on our website,
pursuant to Articles 5 and 6 of the KVKK.
3. FUNDAMENTAL PRINCIPLES IN PROCESSING PERSONAL DATA
Our Company complies with the general principles and legal requirements in the legislation and acts in accordance with the principles below to ensure that personal data is processed lawfully and in accordance with the Constitution and KVKK.
3.1. Principle: Personal Data Processing is Prohibited Unless Allowed
Our Company processes personal data only within the limits permitted by legislation and based on the following legal grounds:
Explicit Consent of the Data Subject
Explicit consent must relate to a specific subject, be informed, and be given freely.
If other legal grounds below apply, explicit consent is not required.
Explicitly Provided by Law
Personal data may be processed without consent if explicitly permitted by legislation.
Inability to Obtain Consent Due to Actual Impossibility
If it is necessary to process personal data to protect someone’s life or physical integrity when consent cannot be given.
Processing is Necessary for Establishment or Performance of a Contract
Processing is Necessary to Fulfill a Legal Obligation of the Company
Personal Data Made Public by the Data Subject
Processing is Necessary for the Establishment, Use, or Protection of a Right
Processing is Necessary for Legitimate Interests of the Company, provided fundamental rights are not violated.
If the processed personal data is special-category personal data, it may only be processed with explicit consent or with adequate safeguards determined by the Board.
3.2. Compliance with Law and Principles of Good Faith
Our Company processes personal data lawfully, fairly, and transparently in accordance with Article 4 of the KVKK.
3.3. Purpose Limitation, Data Minimization, and Proportionality
Our Company determines the purposes for processing personal data and avoids processing irrelevant or unnecessary data.
3.4. Accuracy and Up-to-Date Data
Our Company ensures that processed personal data is accurate and up to date, relying on the declarations of the data subjects.
3.5. Data Processed for Specific, Explicit, and Legitimate Purposes
Our Company collects and processes personal data only for legitimate and lawful purposes and retains them only for the period required.
3.6. Data Security Principle
Our Company takes all necessary technical and administrative measures to ensure the security of personal data.
4. METHOD AND LEGAL GROUNDS FOR COLLECTION OF PERSONAL DATA
Personal data may be collected:
During commercial transactions, negotiations, and contract execution,
During recruitment processes,
Throughout employment,
When granting dealership or authorized service agreements,
Via security camera recordings and visitor forms,
During visits to our offices, branches, stores, or website,
Through call center communications for warranty or service processes,
Through participation in company events, seminars, trainings, or organizations.
Personal data may be collected verbally, in writing, or electronically, using automated or non-automated methods.
Such data may be processed and transferred pursuant to Articles 5 and 6 of the KVKK.
5. PARTIES TO WHOM PERSONAL DATA MAY BE TRANSFERRED AND PURPOSES OF TRANSFER
Personal data may be transferred domestically or abroad to:
Group companies and subsidiaries of our Holding,
Shareholders,
Business partners,
Suppliers,
Authorized public institutions and private persons,
pursuant to Articles 8 and 9 of KVKK.
6. DATA SECURITY MEASURES AND COMMITMENTS
Our Company undertakes to:
Prevent unlawful processing of personal data,
Prevent unlawful access to personal data,
Ensure the secure retention of personal data,
Take necessary technical and administrative measures and conduct required audits.
Our Company will not disclose personal data to third parties or use it for purposes other than those stated in this Clarification Text and applicable legislation.
Links on our website to third-party applications are not under our Company’s responsibility.
7. RIGHTS OF THE DATA SUBJECT
Under Article 11 of KVKK, every individual may apply to our Company to request:
Confirmation of whether personal data is processed,
Information regarding processed personal data,
Purpose of processing and whether data is used accordingly,
Information about third parties to whom data is transferred domestically or abroad,
Correction of incomplete or inaccurate personal data,
Deletion or destruction of personal data under Article 7,
Notification of actions taken to third parties to whom data was transferred,
Objection to results arising from automated processing,
Compensation for damages suffered due to unlawful data processing.
According to Article 13 of the KVKK, applications must be submitted in writing or by methods determined by the Personal Data Protection Board. Since the Board has not yet defined alternative methods, applications must currently be submitted in writing.
You may send your written applications, including identity information and explanations regarding your rights under Article 11 of the KVKK, to:
GROUP SAGUN
Osmangazi Mh. Battalgazi Cd. No:21 Sancaktepe / İstanbul
— by hand delivery,
— via notary public,
— or by sending a secure electronic signature to: sagun@sagun.com
© 2025 GROUP SAGUN.