PDPL

CUSTOMER / CLIENT DISCLOSURE TEXT ABOUT 
PERSONAL DATA PROTECTION LAW

This Disclosure Text is drafted and issued by Ankara Patent Bürosu A.Ş. (“Ankara Patent”), acting as and in the capacity of data supervisor, in order to make clarifications and give information to Ankara Patent’s clients in respect of processing of personal data of Ankara Patent clients in accordance with the pertinent provisions of the Personal Data Protection Law no. 6698 (“Personal Data Protection Law”). Detailed information regarding processing of your personal data shared with Ankara Patent may be reached in Ankara Patent Personal Data Protection and Processing Policy (“Personal Data Protection Policy”) published at the address of https://ankarapatent.com/.

Pursuant to and under the Personal Data Protection Law, all kinds of information which identify you or make you identifiable and all of your personal data, including your special personal data, may be processed by Ankara Patent as the data supervisor (“Data Supervisor”). 

Processing of personal data refers to and encompasses all kinds of transactions affected on data, such as acquisition, registration, storage, keeping, modification, rearrangement, disclosure, transfer, classification or prevention of use of personal data.

Protecting your personal data bears great importance for us. We would like to represent and warrant that we are going to take all kinds of measures and to continue acting as transparently as possible in connection therewith.

Ankara Patent (Data Supervisor) hereby reserves its right to make all kinds of updates, changes and amendments in this “Disclosure Text About Personal Data Protection Law” as and when required under and pursuant to the provisions of the Personal Data Protection Law and other applicable laws and regulations. 

Now and therefore, in accordance with article 10 of the Personal Data Protection Law, we would like to inform you about our activities regarding processing of personal data:

• Personal Data Concept

According to the Personal Data Protection Law, personal data refers to all and any data and information about identified or identifiable natural persons or contact persons working for and in legal entities. Such information covers details as to first name, surname, date of birth, gender, identity number,  e-mail address, residence/delivery address and telephone number of a particular person, and as they can be used for making a person identifiable, they are termed as personal data in our applicable laws and regulations.

• Your Personal Data Processed by Data Supervisor

• Identity of Data Supervisor

Ankara Patent acts as a data supervisor in reliance upon the Personal Data Protection Law. We, as Ankara Patent acting as and in the capacity of Data Supervisor, are taking care of security and protection of your personal data. Accordingly, we are showing maximum care to make sure that all kinds of your personal data are processed, recorded, registered, stored and kept in compliance with good faith and good will rules, and are disclosed/transferred to third parties only for the originally intended purposes as detailed hereinbelow and only to the extent permitted hereunder and subject to the condition of assuring the security of your personal data and in strict compliance with the applicable laws pertaining thereto. 

• Purpose of Processing and Transfer of Personal Data and To Whom Personal Data May be Transferred

• Your personal data, identity data, address information, communication data and other information are directly or indirectly obtained and recorded; safely stored and kept in physical or electronic media for a period fit to the original purpose of processing; modified, updated and rearranged; disclosed and transferred; acquired, classified, processed, or prevented to be used by third parties, in strict compliance with the applicable laws and regulations relating thereto. Solely for the purposes enuremated hereinbelow, and in accordance with the Personal Data Protection Law and other laws and regulations, your personal data are processed by our relevant departments for reporting and statistics purposes, conduct of business processes, legal and commercial security of persons and entities entering into business relations with us, provision of legal advice and counseling services to our clients and management of their legal proceedings, financial and accounting transactions and processes, performance of the obligations of notification to the related/authorized public bodies and entities, maximization of customer satisfaction, payments and various other transactions regarding the aforesaid services, conduct and development of operations, performance of our obligations and liabilities arising out of contracts entered by us with you, and enforcement of Human Resources policies, and for the same purposes, they may be disclosed and transferred to our Experts, Expert Assistants, Lawyers and Advisors, particularly all departments of units of Ankara Patent Office, and to the Authorized Public Entities/Administrations, and to intermediary financial institutions for the purpose of assessment of financial risks, and to Independent Audit Firms for conduct of audit processes, and to Local / International Organizations / Offices from which we receive services and support in our business processes, in reliance upon and in compliance with the applicable laws and regulations, and within the frame of your explicit consent and approval.

• Exceptions listed in article 5/2 of the Personal Data Protection Law are, however, reserved. As per said exceptions as listed below, your personal data may be processed without your explicit consent:

• If it is clearly stipulated so in the pertinent laws; and 

• If it is essentially required for protection of life or bodily integrity of a person who cannot express or declare his or her consent due to factual impossibility or whose consent is not considered and treated as legally valid under the available conditions or of a third party related thereto; and 

• If personal data belonging to parties to a contract are required to be processed, providing that it is directly related to or concerned with establishment or performance of that contract; and 

• If it is essentially required for performance of legal obligations of data supervisor; and 

• If the data are already made public by the related person himself; and

• If processing of data is essentially required for establishment, use or protection of a right; and 

• If processing of data is essentially required for legitimate interests of data supervisor, without prejudice to the fundamental rights and freedoms of related person.

• Method of Collection of Your Personal Data

Your personal data are collected by Ankara Patent verbally, in writing or via electronic media through various statements made by you with written documents/forms such as information forms, communication forms, agreements and other types of documents in reliance upon different legal reasons. 

• Data Transfer

• Data Transfer to Abroad

Ankara Patent may transfer the personal data obtained as above also to third parties, either natural persons or legal entities, resident abroad with an explicit consent of the related person as a rule. However, it is not mandatorily required to get explicit consent in cases specified in article 5/2 and 6/3 of the Personal Data Protection Law.

In order for personal data to be transferable abroad, aside from the conditions of transfer at home, the following conditions must also be satisfied in the foreign country to which personal data will be transferred:

• Adequate protection must have been granted to personal data.

• In case of lack of adequate protection thereat, Ankara Patent may transfer personal data abroad without an explicit consent of the related person, providing that data supervisors in Turkey and in the related foreign country agree and undertake in writing to provide adequate protection thereto, and a prior permission of the Board is taken in relation therewith.  

• In strict compliance with the rules listed in article 9 of the Personal Data Protection Law, personal data may be transferred to any persons or entities required to be contacted and communicated abroad as stipulated hereinabove, or after the foreign countries providing adequate protection for personal data (European Union Member States) are announced by the Personal Data Protection Board (“Board”), only to persons or entities resident in those countries as stipulated hereinabove, or as for the countries failing in providing adequate protection for personal data as duly determined and announced, personal data may be transferred thereto in reliance upon documents to be received from the Turkish Patent and Trademark Agency and only if and when such documents can be received.  

• Data Transfer at Home

Personal data of related person may be transferred to third parties, either natural persons or legal entities, resident at home without an explicit consent of the related person, and to authorized persons in strict compliance with the laws and specifically for the intended purposes. 

• If it is clearly stipulated so in the pertinent laws; and 

• If it is essentially required for protection of life or bodily integrity of a person who cannot express or declare his or her consent due to factual impossibility or whose consent is not considered and treated as legally valid under the available conditions or of a third party related thereto; and 

• If personal data belonging to parties to a contract are required to be processed, providing that it is directly related to or concerned with establishment or performance of that contract; and 

• If it is essentially required for performance of legal obligations of data supervisor; and 

• If the data are already made public by the related person himself; and

• If processing of data is essentially required for establishment, use or protection of a right; and 

• If processing of data is essentially required for legitimate interests of data supervisor, without prejudice to the fundamental rights and freedoms of related person.

• Actions and Measures Taken for Security of Personal Data of Data Owners

Ankara Patent hereby declares, agrees and undertakes to establish and build the required systems and supervision mechanisms in respect of deletion, destruction or anonymization of personal data obtained by it, and to prevent illegal processing of personal data, and to prevent illegal access to data, and to assure safekeeping of data, and to take all kinds of technical and administrative actions and measures in relation therewith, and in the case of processing of personal data within its own organization or by other natural persons or legal entities, to conduct or cause others conduct the required audits, and also to take all and any technical and administrative measures as required thereinfor. 

If and when the processed personal data are illegally acquired or obtained by third parties, Ankara Patent shall as soon as possible report this event to the related person and the Personal Data Protection Board pursuant to the related articles of the Personal Data Protection Law.

In accordance with article 12 of the Personal Data Protection Law no. 6698, for the sake of data security, Ankara Patent takes all and any technical and administrative actions and measures up to the required security level in order: 

• To prevent illegal processing of personal data, and 
• To prevent illegal access to / illegal sharing and transfer of personal data, and 
• To ensure safekeeping of personal data.

• Your Rights Listed in Article 11 of the Personal Data Protection Law

Article 11 of the Personal Data Protection Law grants the following rights to you as a personal data owner:

• To learn whether your personal data are processed or not; and

• If your personal data are processed, to request information about processing; and

• To learn the purpose of processing of your personal data and whether your personal data are used for the intended purposes or not; and 

• To learn the identity of third parties to whom your personal data are transferred at home or abroad, and the purpose underlying the transfer of your personal data to them; and

• If your personal data are processed incompletely or improperly, to request correction or completion of them; and

• To request deletion or destruction of your personal data under the conditions specified in article 7 of the Personal Data Protection Law; and

• To request notification of the transactions executed as per subparagraphs (d) and (e) hereinabove to third parties to whom your personal data are transferred; and

• To raise objections against probable results that may be obtained against you through analysis of your processed personal data solely by means of automatic systems; and

• To claim indemnification of your damages and losses, if any, incurred by you due to illegal processing of your personal data.

• Application to Data Supervisor

Person whose personal data are processed hereby declares and acknowledges that if and when he wishes to raise a claim for use of any one of his rights in respect of his personal data processed or learned to be processed by Ankara Patent, then and in this case, he is under obligation to file an application to Ankara Patent, as data supervisor, within the most appropriate period of time in connection with use of his rights.  

Related Person further accepts to be obligated to submit his applications to Ankara Patent under the heading of “Request of Information About Personal Data Protection Law” in writing by registered mail, return requested, or via a notary public, or by e-mail. 

For the sake of use of the rights listed hereinabove in article 7 titled “Rights of Related Person”, pursuant to article 5/2 of the Communiqué on Procedures and Principles of Application to Data Supervisor promulgated in the Official Gazette edition 30356 on 10.03.2018 with immediate effect, in order for the applications filed to Ankara Patent to be responded in accordance with the applicable laws and regulations, the mandatory information required to be given in your application is listed below for your information: 

• Name and surname, and if the application is in writing, signature; and 

• For citizens of the Republic of Turkey, T.R. identity number, and for foreigners, nationality, passport number or if any, identity number; and

• Residence address or office address for notifications; and

• If any, electronic mail address, telephone and facsimile numbers for notices; and 

• Subject of request.

The information and documents listed above and the petition of request containing explanations about the requested rights may either be sent by mail to Ankara Patent’s mail address “Kavaklıdere Mahallesi Bestekar Caddesi No:10 06680 Çankaya/Ankara” or be sent by email to its email address mailto:kvkk@ankarapatent.com/. 

Ankara Patent hereby declares, agrees and undertakes to respond to the requests set forth in your application as soon as possible and in any case within 30 (thirty) days at the latest, depending on the kind of request. If an application is replied in writing, pursuant to article 7 of the aforementioned Communiqué, no fee will be charged on the related person for replies up to 10 (ten) pages, but a transaction fee of 1.00 Turkish Lira will be charged for each page in excess of 10 (ten) pages.

If reply to an application is given in a recording medium such as CD or flash memory, then fee that may be charged by the data supervisor will be proportional to the cost of such recording medium used thereinfor.  

Ankara Patent, as data supervisor, is entitled to accept the request of the related person for use of its aforesaid rights or to reject such request by explaining its reasons of rejection. If the request in application is accepted, the data supervisor hereby declares, agrees and undertakes to be liable to satisfy the request.

In the event that an application is rejected, or the reply given to application is found inadequate, or an application is not responded in a timely manner, i.e. within 30 (thirty) days, the related person is empowered to file a complaint to the Personal Data Protection Board within 30 (thirty) days after he learns the reply of data supervisor or in any case within 60 (sixty) days following the date of application. If the application is attributable to a fault of Ankara Patent, the fee charged thereinfor will be refunded to the related person.

• Updating Period

This “Disclosure Text About Personal Data Protection Law” may at all times be revised and changed in line with an economic and commercial decision of Ankara Patent or upon resolutions of the Personal Data Protection Board.

COMMUNICATION DATA
Ankara Patent Bürosu Anonim Şirketi
Mersis No: 0070069403200001
Communication Link: https://ankarapatent.com/ 
Address: Bestekar Mahallesi No:12/11 Kavaklıdere Çankaya/ANKARA