Privacy Notice

This is an English translation of the Turkish personal data notice published by VH Medya. The Turkish notice is also available.

VH Medya Anonim Şirketi — Information Notice on the Processing of Personal Data

The following sections explain how personal data may be processed by VH Medya Anonim Şirketi (“VH Medya and its affiliated group companies”).

About the data controller

Your personal data may be processed by VH Medya within the scope of the Turkish Personal Data Protection Law No. 6698 (“the Law”). VH Medya is considered the data controller under the Law. Website: vhmedya.com.

Purposes of processing personal data

Your personal data is processed in accordance with the conditions listed in Articles 5 and 6 of the Law. Purposes include, without limitation, ensuring the legal and commercial security of VH Medya, its group companies or business partners; conducting VH Medya’s commercial activities; and managing human resources and employment policies.

Necessary technical and administrative measures are taken to prevent unlawful processing, prevent unlawful access and maintain personal data securely.

Sharing personal data

Your personal data may be shared with VH Medya and its shareholders, business partners, affiliates, suppliers, external service providers and legally authorised public institutions and organisations, in accordance with the conditions stated in Articles 8 and 9 of the Law.

Purposes of sharing include, without limitation, ensuring the legal and commercial security of VH Medya or its business partners, conducting commercial activities and managing human resources processes and employment policies. Necessary security measures are taken when personal data is shared.

Collection methods and legal grounds

To conduct its activities, VH Medya collects personal data through various channels, including surveys, websites, representatives and similar means, and processes it on different legal grounds in accordance with the conditions listed in Articles 5 and 6 of the Law.

Your rights under the Law

Under the Law, you have the following rights concerning your personal data:

1. To learn whether personal data is processed.
2. To request information if personal data has been processed.
3. To learn the purpose of processing and whether the data is used for that purpose.
4. To know the third parties to whom personal data is transferred in Türkiye or abroad.
5. To request correction of incomplete or inaccurate processing.
6. To request deletion or destruction under the conditions provided in Article 7.
7. To request notification to the relevant third parties of the actions taken in connection with the correction, deletion or destruction requests described above.
8. To object to a result against you arising from analysis performed exclusively through automated systems.
9. To request compensation for damage resulting from unlawful processing.

You may apply to VH Medya in writing to exercise these rights, using the contact information below. If the Personal Data Protection Board establishes new application methods, VH Medya will announce them.

Applications will be concluded as soon as possible and within a maximum of 30 days. The published Turkish notice states that these applications are currently free of charge, but that a fee may be charged in accordance with a tariff established by the Personal Data Protection Board.

The Turkish notice asks applicants to submit their request in writing, state their identity information and explain the right they wish to exercise, and refers to a form at vhmedya.com. It states that a signed copy may be delivered to “Ağaoğlu Maslak 1453 Residence, Maslak Mah. Taşyoncası Sok. T4B Blok -8 Kat Daire:130 Maslak, Istanbul”, or sent by email to kvkk@vhmedya.com, provided that identity information can be verified.

The company reserves the right to request the costs incurred in responding to rights requests in accordance with the tariff determined under Article 13 of the Law, concerning applications to the data controller.

Cases not requiring consent under Law No. 6698

The Turkish notice states that, under Article 5(2), the company may process personal data without explicit consent where processing is expressly provided for by law; necessary to protect the life or physical integrity of a person unable to express consent because of actual impossibility or whose consent is not legally recognised; necessary for processing data of the parties directly related to the establishment or performance of a contract; necessary for the data controller to fulfil a legal obligation; made public by the person concerned; necessary to establish, exercise or protect a right; or necessary for the legitimate interests of the data controller, provided that the person’s fundamental rights and freedoms are not harmed.

The Turkish notice also states that the company may disclose, transfer or process relevant information without obtaining consent in cases such as information appearing in financial statements or activity reports under the principle of transparency; information subject to a public disclosure obligation; fulfilment of legal obligations arising from applicable legislation; mandatory transfers to persons or institutions specified by law; and similar circumstances in which a confidentiality obligation does not apply.

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