GDPR - General Data Protection Regulation

GDPR – General Data Protection Regulation

Data Controller: Neomena Trade Platform L.L.C-FZ

Company Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.

As Neomena Trade Platform (hereinafter referred to as “Neomena”), within the scope of activities arising from the Personal Data Protection Law No. 6698 (“GDPR”) and related legislation and legal regulations, we are responsible for the processing, storage, and transfer of your personal data.

Our Employees,
Our Employee Candidates,
Our Supplier Representatives,
Our Visitors,
Individuals Who Purchase Products or Services,
Potential Individuals Who May Purchase Products or Services,

with this information notice.

What Personal Data Is Processed and What Are the Purposes of Processing Your Personal Data?

Job Applicants

Identity Information

Processed Personal Data

First Name, Last Name, Date of Birth, Turkish ID Number, Signature

Purposes of Personal Data Processing

Execution of Job Applicant Application Processes, Execution of Job Applicant/Intern/Student Selection and Placement Processes, Execution of Activities in Compliance with Legislation, Execution of Activities to Ensure Business Continuity, Execution of Contract Processes, Planning of Human Resources Processes

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena in line with the purposes listed above, as specified in Article 5 of the GDPR;

The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.

The processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data, as specified in the categories above, is collected through job application forms, documents declared by you, and private employment agencies (e.g., LinkedIn, Kariyer.net, etc.).

Contact Information

Processed Personal Data

Email Address, Home Phone Number, Mobile Phone Number, Turkish ID Number, Home Address

Purposes of Personal Data Processing

Conducting Communication Activities, Planning Human Resources Processes, Conducting Employee Candidate Application Processes, Conducting Employee Candidate/Intern/ Student Selection and Placement Processes, Conducting Activities in Compliance with Legislation, Conducting Business Continuity Activities, Conducting Contract Processes

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena in line with the purposes listed above, as specified in Article 5 of the GDPR;

The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
The processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data, specified in the categories above, is collected through job application forms, documents declared by you, and through private employment agencies (e.g., LinkedIn, Kariyer.net, etc.).

Personal Information

Processed Personal Data

Education Status, Work History and Details, Position Applied For, Salary Expectation Information, Military Service Status Information

Purposes of Personal Data Processing

Personal data is collected for the purposes of planning human resources processes, executing the application processes of job candidates, executing the selection and placement processes of job candidates/interns/students, executing activities to ensure business continuity, and executing contract processes.

Legal Grounds for Processing Personal Data

Your personal data is processed by NeomenaNeomena for the purposes listed above, in accordance with Article 5 of the GDPR, which states that

The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
The processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data, as specified in the categories above, is collected through job application forms, documents submitted by you, and private employment agencies (e.g., LinkedIn, Kariyer.net, etc.).

Professional Experience Information

Processed Personal Data

Diploma Information, Courses and Training Attended, Certificates, Foreign Language Skills, Work Experience

Purposes of Personal Data Processing

Planning Human Resources Processes, Executing Employee Candidate Application Processes, Executing Employee Candidate/Intern/Student Selection and Placement Processes, Executing Activities in Compliance with Legislation, Executing Activities to Ensure Business Continuity, Executing Contract Processes

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena in line with the purposes listed above, as specified in Article 5 of the GDPR;

The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
The processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Reference Information

Processed Personal Data

Name, Surname, Phone Number, Profession, Company, Position, and Title

Purposes of Personal Data Processing

Based on your consent, Planning Human Resources Processes, Executing Employee Candidate Application Processes, Executing Employee Candidate/Intern/Student Selection and Placement Processes, Executing Activities in Compliance with Legislation, Executing Business Continuity Activities – Execution of Contract Processes

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above, in accordance with your consent given pursuant to Article 5/1 of the GDPR and pursuant to Article 5/2;

It is processed based on the legal grounds that the processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Supplier Representatives

Identity Information

Personal Data Processed

First Name, Last Name, Turkish ID Number, Tax ID Number, Signature

Purposes of Personal Data Processing

Ensuring Business Continuity, Conducting Sales Processes for Goods/Services, Conducting Production and Operational Processes for Goods/Services, Conducting Finance and Accounting Operations, Conducting Business Activities/ Auditing, Conducting Activities in Compliance with Legislation, Conducting Contract Processes, Providing Information to Authorized Persons, Institutions, and Organizations, Conducting Supply Chain Management Processes, Conducting Communication Activities, Conducting Goods/Services Purchase Processes

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena in line with the purposes listed above, primarily as specified in Article 5 of the GDPR;

The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
The processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through contracts, printed forms, or digital forms.

Contact Information

Processed Personal Data

Email Address, Work Phone Number, Mobile Phone Number, Work Address, Work Place Name/Title, Registered Electronic Mail (KEP) Address

Purposes of Personal Data Processing

Conducting Communication Activities, Conducting Business Continuity Activities, Conducting/Monitoring Business Activities, Conducting Goods/Services Sales Processes, Conducting Communication Activities, Conducting Activities in Compliance with Legislation, Providing Information to Authorized Persons, Institutions, and Organizations, Conducting Goods/Services Purchase Processes,

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above, primarily in accordance with Article 5 of the GDPR;

The necessity of processing personal data belonging to the parties to a contract, provided that it is directly related to the establishment or performance of the contract,
The necessity of processing data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through contracts, printed forms, or digital forms.

Financial Information

Processed Personal Data

Bank Account Information, Bank Card Information, Credit Card Information

Purposes of Personal Data Processing

Execution of Financial and Accounting Operations, Execution/Audit of Business Activities, Execution of Contract Processes, Execution of Goods/Services Production and Operation Processes, Execution of Goods/Services Sales Processes, Monitoring and Execution of Legal Affairs,

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above, primarily in accordance with Article 5 of the GDPR;

Explicitly stipulated by law,

Directly related to the establishment or performance of a contract, provided that the processing of personal data belonging to the parties to the contract is necessary,

It is mandatory for the data controller to fulfill its legal obligations.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through contracts, printed forms, or digital forms.

Our Patients

Identity Information

Processed Personal Data

Name, Surname, Turkish ID Number, Tax ID Number, Population Registry Card/ID Copy

Purposes of Personal Data Processing

Ensuring Business Continuity, Conducting Operations, Conducting Goods/Services Sales Processes, Conducting Customer Relationship Management Processes

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena in accordance with the relevant legislation and, in particular, Article 5 of the GDPR, for the purposes listed above:

Where explicitly provided for by law,

It is necessary for the data controller to fulfill its legal obligations,

It is necessary for the establishment or performance of a contract, provided that it is directly related to the contract,
It is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through printed forms.

Contact Information

Processed Personal Data

Address, Telephone, Email

Purposes of Personal Data Processing

Execution of After-Sales Support Services for Goods/Services, Execution of Contract Processes, Tracking of Requests/Complaints

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above in accordance with the relevant legislation and, in particular, Article 5 of the GDPR, which states:

It is explicitly provided for by law,

Being necessary for the data controller to fulfill its legal obligations,

Being necessary for the establishment or performance of a contract, provided that it is directly related to the contract and the processing of personal data belonging to the parties to the contract,
Being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through printed forms.

Financial Information

Personal Data Processed

Bank Account Information, Bank Card Information, Credit Card Information

Purposes of Personal Data Processing

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above, primarily based on the legal grounds specified in Article 5 of the GDPR:

Explicitly stipulated by law,

Necessary for the establishment or performance of a contract, provided that it is directly related to the contract and the processing of personal data belonging to the parties to the contract is required,
Being necessary for the data controller to fulfill its legal obligations.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through contracts, printed forms, or digital forms.

Health Information

Processed Personal Data

Device and Prosthesis Information Used

Purposes of Personal Data Processing

Execution/Supervision of Business Activities, Execution of Contract Processes, Execution of Goods/Services Sales Processes, Execution of Goods/Services Production and Operation Processes, Execution of Finance and Accounting Operations

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above, with your explicit consent as specified in Article 5 of the GDPR.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through printed forms and contracts.

Product and Service Recipient

Identity Information

Processed Personal Data

First Name, Last Name, Turkish ID Number, Tax ID Number, Passport Number, ID Card/ID Copy, Passport Copy, Signature, Position/Title Information, Photo

Purposes of Personal Data Processing

Ensuring Business Continuity, Conducting Sales Processes for Goods/Services, Conducting Customer Relationship Management Processes, Conducting Supply Chain Management Processes, Conducting Communication Activities, Conducting Finance and Accounting Operations, Execution of Goods/Services Sales Processes, Execution of Goods/Services Production and Operations Processes, Execution of Customer Satisfaction-Oriented Activities, Tracking of Requests/Complaints, Execution of Goods/Services After-Sales Support Services, Execution of Contract Processes, Organization and Event Management,

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena in line with the purposes listed above, in accordance with the relevant legislation and, in particular, Article 5 of the GDPR, which states:

It is explicitly provided for by law,

Being necessary for the data controller to fulfill its legal obligations,

Being necessary for the establishment or performance of a contract, provided that it is directly related to the contract and the processing of personal data belonging to the parties to the contract,
Being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through printed and electronic forms, contracts, and the Call Center.

Contact Information

Processed Personal Data

Work Address, Work Name/Title, Email Address, Work Phone Number, Mobile Phone Number, Social Media Account Names

Purposes of Personal Data Processing

Conducting Communication Activities, Conducting Business Continuity Activities, Conducting/Monitoring Business Activities, Conducting Product/Service Marketing Processes, Advertising/ Campaign/Promotion Processes, Conducting Activities Aimed at Customer Satisfaction, Tracking Requests/Complaints, Conducting After-Sales Support Services for Goods/Services,

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena in accordance with the relevant legislation and, primarily, Article 5 of the GDPR, for the purposes listed above:

The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
The processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through printed and electronic forms, contracts, and the Call Center.

Customer Transaction Information

Processed Personal Data

Call center records, Order information, Request information

Purposes of Personal Data Processing

Execution/Supervision of Business Activities, Execution of Goods/Services Sales Processes, Execution of Communication Activities, Tracking of Requests/Complaints, Execution of Activities Aimed at Customer Satisfaction, Execution of Customer Relationship Management Processes, Execution of Business Continuity Activities, Provision of Information to Authorized Persons, Institutions, and Organizations, Execution of Goods/Services Sales Processes, Tracking of Requests/Complaints, Execution of Customer Relationship Management Processes,

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena in line with the purposes listed above, in accordance with the relevant legislation and, in particular, Article 5 of the GDPR, which states that

The necessity to process personal data belonging to the parties to a contract, provided that it is directly related to the establishment or performance of the contract,
The necessity to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through printed and electronic forms and via the Call Center.

Financial Information

Processed Personal Data

Bank Account Information, Bank Card Information, Credit Card Information, Invoice, promissory note, check information

Purposes of Personal Data Processing

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena in accordance with the relevant legislation and, primarily, Article 5 of the GDPR, for the purposes listed above:

Explicitly stipulated by law,

Necessary for the data controller to fulfill its legal obligations,
Necessary for the establishment or performance of a contract, provided that it is directly related to the contract and the processing of personal data belonging to the parties to the contract,

Methods of Collecting Personal Data

Your personal data mentioned above is collected through your declarations.

Legal Transaction Information

Processed Personal Data

Information in the Case File Information within the scope of the Notice/Warning Letter

Purposes of Personal Data Processing

Follow-up and Execution of Legal Affairs, Execution of Audit/Ethics Activities, Execution of Customer Relationship Management Processes, Provision of Information to Authorized Persons, Institutions, and Organizations,

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above, based on the relevant legislation and the legal grounds specified in Article 5 of the GDPR, namely:

Explicitly stipulated by law,

Necessary for the data controller to fulfill its legal obligations.
Methods of Collecting Personal Data
Your personal data mentioned above is collected through judicial and administrative correspondence.

Marketing Information

Processed Personal Data

Survey responses Information obtained through campaign activities

Purposes of Personal Data Processing

Execution of Advertising/Campaign/Promotion Processes, Ensuring Business Continuity, Execution of Activities

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above in accordance with the relevant legislation and, primarily, Article 5 of the GDPR, which states:

The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
The processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

The personal data mentioned above is collected through your previous purchase records, survey responses, statements, and printed/electronic forms.

Visual and Audio Recordings

Processed Personal Data

Visual Recording, Audio Recording

Purposes of Personal Data Processing

Organization and Event Management, Execution of Advertising/Campaign/Promotion Processes, Execution of Talent/Career Development Activities, Execution of Product/Service Marketing Processes

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above, based on your explicit consent in accordance with Article 5 of the Personal Data Protection Law.

Methods of Collecting Personal Data

Your personal data mentioned above is collected via electronic devices.

Our Visitors

During your visits to the Neomena building, your images are recorded through closed-circuit camera recording systems (CCTV) that we use to ensure physical security in our legitimate interest and may be shared with authorized persons, institutions, and organizations if we have a legal obligation to do so. The relevant records are deleted when the system’s storage capacity is full.

Potential Product and Service Recipient

Identity Information

Processed Personal Data

First Name, Last Name, Turkish ID Number, Tax ID Number, Passport Number, ID Card/ID Copy, Passport Copy, Signature, Position/Title Information, Photo

Purposes of Personal Data Processing

Ensuring Business Continuity, Executing Sales Processes for Goods/Services, Executing Customer Relationship Management Processes, Execution of Supply Chain Management Processes, Execution of Communication Activities, Tracking of Requests/Complaints, Organization and Event Management, Execution of Marketing Analysis Studies, Execution of Advertising/Campaign/Promotion Processes, Execution of Customer Relationship Management Processes

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena in line with the above-mentioned purposes, in accordance with the relevant legislation and, in particular, Article 5 of the GDPR, which states that:

It is explicitly stipulated by law,

Being necessary for the data controller to fulfill its legal obligations,

Being necessary for the establishment or performance of a contract, provided that it is directly related to the contract and the processing of personal data belonging to the parties to the contract is necessary,
Being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
Methods of Collecting Personal Data
Your personal data mentioned above is collected through printed and electronic forms, contracts, and the Call Center.

Contact Information

Processed Personal Data

Email Address, Work Phone Number, Mobile Phone Number

Purposes of Processing Personal Data

Conducting Communication Activities, Conducting Business Continuity Activities, Conducting Product/Service Marketing Processes, Conducting Advertising/Campaign/Promotion Processes, Conducting Customer Satisfaction Activities, Tracking Requests/Complaints,

Legal Reasons for Processing Personal Data

Your personal data is processed by Neomena in accordance with the relevant legislation and, primarily, Article 5 of the GDPR, for the purposes listed above.

The necessity to process personal data belonging to the parties to a contract, provided that it is directly related to the establishment or performance of the contract,
The necessity to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through printed and electronic forms, contracts, and the Call Center.

Marketing Information

Processed Personal Dat

Survey responses, information obtained through campaign activities

Purposes of Personal Data Processing

Execution of Advertising/Campaign/Promotion Processes, Execution of Business Continuity Activities, Execution of Marketing Activities for the Company/Products/Services

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above, based on the legal grounds specified in Article 5 of the GDPR, primarily: Processing data 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.

Methods of Collecting Personal Data

Your personal data mentioned above is collected through printed and digital forms.

Visual and Audio Recordings

Processed Personal Data

Visual Recording, Audio Recording

Purposes of Personal Data Processing

Organization and Event Management, Execution of Advertising/Campaign/Promotion Processes, Execution of Talent/Career Development Activities, Execution of Product/Service Marketing Processes

Legal Grounds for Processing Personal Data

Your personal data is processed by Neomena for the purposes listed above, based on your explicit consent in accordance with Article 5 of the GDPR.

Methods of Collecting Personal Data

Your personal data mentioned above is collected via electronic devices.

To Whom and for What Purposes May Your Personal Data Be Transferred Within the Country?

Your personal data is shared with persons expressly authorized by the legislation, primarily the Social Security Institution, in accordance with legal regulations and the legislation to which we are subject. In addition, your personal data is shared with authorized persons or institutions upon a court order or the request of authorized administrative authorities.
Your personal data will be shared with third parties processing the data for the purpose of fulfilling the obligations under our employment contract (e.g., sharing your health data with our workplace physician under the Occupational Health and Safety Law No. 6331).
Your personal data may be shared with our suppliers for the purpose of executing supply chain management processes and fulfilling the contract in relation to products or services to be procured from suppliers under the service contract between us.
Your personal data may be shared with our business partners with whom we collaborate under the service contract between us for the purpose of conducting business activities and fulfilling the contract.
Your personal data may be shared with our group companies, affiliates, and subsidiaries for the purpose of conducting business activities, carrying out recruitment processes, and fulfilling the contract.

Are Your Personal Data Transferred Abroad?

Your personal data may be transferred to our Global Headquarters in the course of our business processes.

How Long Are Your Personal Data Stored?

Your personal data is stored for the legal periods within the scope of the processing purpose. After the specified period has passed, your data is deleted, destroyed, or anonymized without any request from you.

What Are Your Rights as the Data Subject?

Within the scope of the GDPR and related legislation, regarding your personal data;

The right to learn whether your personal data is being processed,
The right to request information about the processing of your personal data,
The right to learn the purpose of processing personal data and whether it is being used for its intended purpose,
The right to know the third parties to whom your personal data has been transferred within or outside the country,
The right to have your personal data corrected if it has been processed incompletely or incorrectly.
Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the GDPR legislation,
When you request the correction of incomplete or incorrect data and the deletion or destruction of your personal data, you have the right to request that this situation be communicated to third parties to whom we have transferred your personal data.
You have the right to object to the analysis of processed data exclusively through automated systems resulting in a decision against the individual.
You have the right to request compensation for any damage you suffer due to the unlawful processing of your personal data.

How Can You Exercise Your Rights?

You may submit your applications and requests regarding your personal data via the Relevant Person Contact Form;

By sending a letter with a wet signature and a photocopy of your ID to Neomena Trade Platform Address Istanbul;
By applying in person to Neomena Trade Platform, located at Neomena Trade Platform Address Istanbul, with a valid ID document;
By sending it to our registered electronic mail (KEP) address emailadresi@hs03.kep.tr using a registered electronic mail address and a secure electronic signature or mobile signature,

You can communicate it to Neomena.

In accordance with the Communiqué on the Procedures and Principles for Applying to the Data Controller, the Relevant Person must include their name, surname, signature (if the application is in writing), Turkish ID number (passport number if the applicant is a foreigner), address of residence or place of work for notification purposes, and, if available, the address for notification purposes.

The Data Subject must clearly and comprehensively state the subject matter of the request in the application, including explanations regarding the rights they intend to exercise and the specific right they wish to exercise. Information and documents related to the application must be attached to the application.

The subject of the request must relate to the applicant personally; however, if the request is made on behalf of another person, the person making the request must be specifically authorized to do so and this authorization must be documented (special power of attorney). In addition, the request must include identity and address information, and documents verifying the identity must be attached to the request.

Requests made by unauthorized third parties on behalf of others will not be considered.

How Long Does It Take to Respond to Your Requests Regarding the Processing of Your Personal Data?

Your requests regarding your personal data rights will be evaluated and responded to within 30 days of the date we receive them. If your request is rejected, the reasons for the rejection will be sent to the address you specified in your request via email or post, or by one of the methods selected in the Relevant Person Request Form.