As NUHPANEL A.Ş. we take the greatest care over the security of personal data.

Within the framework of the relevant legislation, NUHPANEL A.Ş. takes the highest possible security measures to ensure that your personal data is collected, stored and shared lawfully and that your privacy is protected. Aware of that responsibility, we process your personal data as data controller under Law No. 6698 in the manner explained below and within the framework of the legislation.

1. Identity of the data controller and its representative

The scope within which your personal data may be processed by NUHPANEL A.Ş. as data controller, under Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK"), is explained below.

2. Purposes of processing personal data

The personal data collected may be processed by NUHPANEL A.Ş. for the purposes below, in accordance with the fundamental principles set out in the legislation:

  • Carrying out the necessary work by the business units of our Company and conducting its activities accordingly, so that the commercial activities of NUHPANEL A.Ş. are performed in accordance with the legislation and Company policies;
  • Determining the human resources policy of NUHPANEL A.Ş. and conducting and executing its activities;
  • Determining, planning and implementing the short, medium and long-term commercial policies of NUHPANEL A.Ş.;
  • Ensuring the commercial, technical and legal security of the persons with whom NUHPANEL A.Ş. has a business relationship, and maintaining contact with those natural and legal persons;
  • Protecting the commercial reputation of NUHPANEL A.Ş. and the trust it has established;
  • Complying with the obligations of record keeping, reporting and notification set out by public authorities under the relevant legislation, and fulfilling the legal obligations to which we are subject in relation to the use of those services;
  • Managing, for the purpose of determining and implementing the commercial and business strategies of our Company: financial operations, communications, market research and social responsibility activities, purchasing operations (requests, quotations, evaluation, orders, budgeting), internal system and application management operations, and legal operations;
  • Examining, evaluating and responding to requests from public authorities or from data subjects;
  • Ensuring the security and supervision of the Company's physical premises by camera recording and other systems;
  • Fulfilling the burden of proof as evidence in any future legal dispute.

Your personal data is processed within the scope of the conditions and purposes for processing personal data set out in Articles 5 and 6 of the KVKK. Within the scope of our activities, and for the purpose of processing the necessary work and information, your data is classified within the scope of automated decision making. This is a requirement for the reports to be produced and the documents to be submitted to the relevant institutions.

The processing of your personal data is a legal and contractual requirement. If your data is not provided, it will become impossible to conduct the commercial activity of the natural and legal persons in a business relationship with the company, to fulfil the notifications and obligations required under the legislation, to carry out human resources activities, and to ensure legal, technical and commercial security.

3. To whom and for what purpose data may be transferred

Personal data is transferred by NUHPANEL A.Ş. to the persons below, limited to the purposes listed above and within the scope of Articles 8 and 9 of the KVKK:

  • Persons and institutions permitted by the Turkish Commercial Code, the Turkish Code of Obligations, the Labour Law and the provisions of other relevant laws and legislation,
  • Legally authorised institutions and organisations, administrative and judicial authorities, and the institutions, organisations, persons and companies required by specific legislation,
  • The natural and legal persons from whom we procure products and services and with whom we cooperate.

Where a transfer is made, it will be made after asking whether the domestic institution or business receiving the data is compliant with the KVKK and has data security in place.

3.1. Data processed through NUH AI

When the NUH AI assistant on the site is used, the e-mail address, the messages written and the answers given by the assistant are recorded. The record is kept so that the conversation can be continued from where it left off on later visits and so that the same information is not asked for again. Recording depends on consent; the conversation does not begin until the consent box is ticked.

The messages are transmitted to the artificial intelligence service provider so that an answer can be produced, and are processed abroad. The content transmitted is limited to the messages written. The legal basis for this transfer is explicit consent under Article 9 of the KVKK; the consent given by ticking the box covers this transfer as well.

The e-mail address is stored in a signed cookie in the browser and expires by itself after four hundred days. The conversation record remains until deletion is requested.

The record can be deleted at any time: select "Delete my data" on the chat screen, and when confirmed the record is deleted irreversibly.

When a quotation is requested through the assistant, the name, telephone, region and project information are passed to the sales team. That transfer is the same as the transfer from the quotation form and is subject to the same rules.

Your personal data is collected by our Company through different channels (oral, written and electronic) in order to conduct our activities, on the legal grounds of ensuring compliance with the legislation and Company policies, performance of contracts, express provision of the law, and the legitimate interest of the company.

Your personal data may also be processed and transferred for the purposes stated in this information notice, in accordance with the fundamental principles set out by the KVKK and within the scope of the conditions and purposes for processing personal data set out in Articles 5 and 6 of the KVKK.

5. Retention period

Your personal data is retained for the period set out in the relevant legislation or required for the purpose for which it is processed. The following criteria are taken into account when determining the maximum period:

  • The period generally accepted as customary in the sector in which the data controller operates, for the purpose of processing that category of data,
  • The period for which the legal relationship established with the data subject, which makes the processing of that category of personal data necessary, will continue,
  • The period for which the legitimate interest to be obtained by the data controller, depending on the purpose of processing that category of data, will remain valid in accordance with the law and the rules of good faith,
  • The period for which the risks, costs and liabilities created by retaining that category of data, depending on the purpose of processing, will legally continue,
  • Whether the maximum period to be determined is suitable for keeping that category of data accurate and, where necessary, up to date,
  • The period for which the data controller is obliged to retain the personal data in that category by reason of a legal obligation,
  • The limitation period determined by the data controller for asserting a right connected with the personal data in that category.

6. Rights of the data subject under Article 11 of Law No. 6698

If, as data subjects, you submit your requests concerning your rights to NUHPANEL A.Ş. by the methods set out in the NUHPANEL A.Ş. Policy on the Protection and Processing of Personal Data, published at www.nuhpanel.com.tr, our company will conclude the request as soon as possible and within thirty days at the latest, according to the nature of the request. However, where the process requires a separate cost, NUHPANEL A.Ş. will charge the fee in the tariff set by the Personal Data Protection Board.

Within this scope, data subjects have the right to:

  • Learn whether their personal data is processed,
  • Request information if their personal data has been processed,
  • Learn the purpose of processing their personal data and whether it is used in accordance with that purpose,
  • Know the third parties to whom their personal data is transferred, in Türkiye or abroad,
  • Request the correction of their personal data if it has been processed incompletely or inaccurately, and request that the action taken be notified to the third parties to whom the data has been transferred,
  • Request the erasure or destruction of their personal data where the grounds requiring its processing have ceased, even though it has been processed in accordance with the KVKK and other relevant legal provisions, and request that the action taken be notified to the third parties to whom the data has been transferred,
  • Object to a result arising against them from the analysis of the processed data exclusively by automated systems,
  • Claim compensation for damage suffered as a result of the unlawful processing of their personal data.

Where an application is rejected, the response is found inadequate, or no response is given within the period, the data subject may complain to the Personal Data Protection Board within thirty days of learning the response of the data controller and in any case within sixty days of the date of application. Under Article 13 of the Law, a complaint cannot be made before the application route has been exhausted.

Under international legislation the data subject also has, beyond the rights listed above, the right to request the restriction of the processing of their personal data and to withdraw consent to the processing or transfer of their personal data.

You can make applications concerning the rights listed above using the Application Form for the Data Controller available at www.nuhpanel.com.tr.