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Within the scope of the Personal Data Protection Law, as ONYX PARTNERS GLOBALLLC., we attach great importance to the protection of personal data and/or personal data of special nature. We are sensitive about keeping all personal data and/or special quality personal data transmitted to our company through various means. In this context, especially the Law on the Protection of Personal Data No. 6698 to comply with the provisions of the Constitution and other legislation, we have taken the necessary technical and administrative measures. We would like to emphasize that we shall protect your rights that are guaranteed by the laws. In this context, you can safely share and forward your suggestions, complaints, and hesitations to us.Here is our Privacy Policy, which has been put into effect within our company.
ONYX PARTNERS GLOBAL LLC.
1. DEFINITIONS
| DATA CONTROLLER | ONYX PARTNERS GLOBALLLC. which determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system |
| DATA OWNER-RELEVANT PERSON | This refers to the real person whose personal data is processed |
| COMPANY | ONYX PARTNERS GLOBALLLC. |
| LAW | Law No. 6698 on the Protection of Personal Data |
| PERSONAL DATA | Any information expressed relating to a real person that makes the identity specific or identifiable |
| SPECIAL QUALIFIED PERSONAL DATA | Data on ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership in associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are of special qualified means personal data |
| BOARD | Refers to the Personal Data Protection Board |
| POLICY | This is referred to as the “Privacy Policy” |
| PROCESSING OF PERSONAL DATA | Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying, preventing the use of personal data in whole or in part by automatic or non-automatic means provided that it is a part of any data recording system etc. any operation performed on the data |
| EXPLICIT CONSENT | Consent on a specific subject, based on information and expressed with free will |
| ANNIHILATION | Making personal data inaccessible, irretrievable and reusable by anyone in any way |
| DELETING | Making personal data inaccessible and unusable for the relevant users in any way |
| ANONYMIZATION | This means that personal data cannot be associated with an identified or identifiable natural person under any circumstances, even if it is matched with other data |
| DESTRUCTION | This refers to the deletion, annihilation or anonymization of personal data |
| DATA | Personal data and special qualified personal data are expressed together |
2. PURPOSE OF PRIVACY POLICY
Protecting personal data and complying with the law is our basic principle. ONYX PARTNERS GLOBAL LLC. (hereinafter referred to as “Onyx” or “Company”), the personal data and/or special quality personal data we receive from you in all our works are kept confidential and not shared with third parties. In this context, our company has always shown the necessary sensitivity regarding the protection of personal data and/or sensitive personal data. Again, by the Law on Protection of Personal Data No. 6698 (hereinafter referred to as “Law“), our in-house regulations have been re-made; technical and administrative measures were taken. As Onyx, we accept, declare and undertake to comply with the obligations imposed by the law in the ongoing process.
3. SCOPE OF PRIVACY POLICY
This Privacy Policy has been prepared by the Law on the Protection of Personal Data No. 6698. Personal data and/or sensitive personal data are processed with your consent or within the scope of compliance with the law. Personal Data;
– Ensuring company security
– To provide you with a complete service
– To carry out our commercial activities
– Quick resolution of your problems
– It is used to increase our service quality
Some personal data and/or sensitive personal data coming from you are depersonalized and anonymized by the procedures stipulated by the Law. The data used for statistical purposes are currently not included in the regulation of the Law and the scope of our policy. As Onyx, we have the right to change this policy to protect personal data within the scope of compliance with the Law.
The privacy policy aims to protect the data obtained by any means of real and legal persons, customers, employees and all other persons with whom Onyx is a solution partner. In this context, it includes various regulations to achieve the intended target.
4. BASIC PRINCIPLES OF PROCESSING PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA
Our basic principles regarding the processing of personal data and/or special categories of personal data are as follows. In this context, these principles shall apply to the data that Onyx processes based on express consent or within the scope of compliance with the Law.
– Compliance with the Law: Onyx questions the source and legality of the personal data and/or special quality personal data received from natural and legal persons and collected through various means. In this context, Onyx needs to obtain the data by the law.
– Compliance with the Rules of Integrity: Onyx questions the source of personal data and/or personal data of special nature that it receives from natural and legal persons and that it collects through various means. In this context, Onyx needs to obtain the data within the framework of honesty rules.
– Limited, Measured and Connected to the Purpose for which they are Processed: Onyx uses the personal data and/or special quality personal data obtained from various ways by the purpose for which they are processed, limited for processing in a measured manner, and to the extent required by the performance of the service.
– Accuracy of Personal Data and/or Special Quality Personal Data: Onyx attaches importance to the fact that the personal data received from natural and legal persons and collected through various means and/or sensitive personal data do not contain false information and are correct. However, Onyx is not obliged to investigate the accuracy of the personal data and/or sensitive personal data declared by its customers or real and legal persons with whom it is in contact, because this is not possible legally nor in line with our working principles.
– Updating When Necessary: Onyx attaches importance to communicating the change to the company and updating the data if there is a change in the personal data obtained in various ways and/or in the personal data of special nature.
– Processing for Specific and Legitimate Purposes: Onyx processes personal data and/or sensitive personal data without the express consent of the data owner or within the framework of exceptions stipulated by law. The purpose of processing each data is specific and personal data processing is not carried out for any illegitimate purpose.
– Preservation for as long as required by law and/or for the purpose for which they are processed: Onyx stores the personal data and/or sensitive personal data it obtains for the periods stipulated in the relevant laws and/or necessary for the purpose for which they are processed. When the said purposes are over, it anonymizes, annihilates or deletes the data.
5. DELETING, ANNIHILATION AND MAKING PERSONAL DATA ANONYMIZATION
Personal data and/or sensitive personal data shall be deleted, annihilated or anonymized when the statute of limitations and storage periods stipulated in the Law expires, the judicial processes are completed or other relevant requirements are terminated. Deletion, annihilation and anonymization processes are carried out at the request of the relevant data owner or by Onyx ex officio (spontaneously).
6. PRINCIPLE OF MISSING
The principle of stinginess, also known as the principle of maximum savings, personal data and/or special quality personal data, received through various means, are transferred to our company’s system. By the said principle, the data is processed into the system as much as necessary.
The data to be collected by Onyx is determined by the purpose and varies. In this context, data is collected by the purpose, and data that is not parallel to the purpose are not collected. Redundant data other than its purpose is not recorded in the company system, it is deleted, annihilated or anonymized. However, this data can be used for statistical purposes.
7. DATA PRIVACY AND SECURITY
As Onyx, we attach importance to the confidentiality of personal data and/or private data. In this context, personal data and/or sensitive personal data that reach our company by any means are confidential. Onyx respects the confidentiality of the data in question at every stage of its commercial activities. In this context, this company’s privacy policy is fully complied with.
Necessary technical and administrative measures are taken to ensure that personal data and/or sensitive personal data collected through various means do not fall into the hands of unauthorized persons, that the rights of the data owner are not harmed, that they are not victims, and that the data is protected. In addition, data protection is requested from third parties with whom we share personal data and/or sensitive personal data by the law, when necessary. Again, our software programs are updated and constantly renewed. To provide a high level of protection, technological requirements are fulfilled and compliance with standards is ensured.
8. CURRENCY OF DATA
In Onyx, the principle of timeliness is essential. Because, personal data obtained in various ways and/or special quality personal data can be updated when necessary or upon request. Necessary measures regarding the update are also taken by Onyx.
9. ACCURACY OF DATA
The principle of accuracy of declared personal data and/or special quality data has been adopted by Onyx. Onyx is not obliged to investigate the accuracy of personal data and/or sensitive personal data declared by its customers or real and legal persons with whom it is in contact, because this is not possible legally nor in line with our working principles. In this context, transactions are carried out on the basis that the declared data is correct.
10. PURPOSE OF PROCESSING PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA
The processing of personal data and/or special quality personal data is carried out in line with the purposes in the Clarification Texts of Onyx. The aforementioned Clarification Texts may vary according to the personal data processed and/or the personal data of special nature. Parallel to the difference in the Clarification Texts, the purposes of processing personal data and/or special quality personal data may also vary.
11. PROCESSING PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA FOR ADVERTISING PURPOSES
Electronic messages sent for advertising purposes must be approved by the recipient. In this context, emails for advertising purposes can only be sent to people with prior consent. The subject in question is also clearly regulated in the “Law on the Regulation of Electronic Commerce” and the “Regulation on Commercial Communication and Commercial Electronic Messages“.
Onyx acts by the above-mentioned legislation while sending commercial electronic messages for advertising purposes. Obtaining approval by the legislation and the details of the approval are also respected, said consent; it can be received in the physical environment by all kinds of electronic communication tools or in written form.
Approval from the clients, marketing, promoting the company’s services, promoting its business, ensuring its recognition, celebration, wish and congratulation, etc. It includes all commercial electronic messages sent to electronic communication addresses to increase the recognition of the contents.
12. COLLECTION AND PROCESSING OF PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA WITHIN THE CONTRACT RELATIONSHIP
If a contractual relationship is established with clients, the personal data collected under the contract may be processed by Onyx without express consent. In the case of processing sensitive personal data, data can be processed based on express consent or legal reasons within the scope of Article 6 of the Law. The said data is used within the framework of the performance of the goods and/or services, the execution of the contract, the execution of the commercial activity. This data can be updated at any time by contacting customers.
13. PERSONAL DATA AND/OR SPECIAL DATA PROCESSED THROUGH AUTOMATIC SYSTEMS
Data gathered from information obtained through automated systems without the explicit consent of individuals cannot be used against individuals. Onyx acts following the provisions of the relevant legislation in personal data and/or special quality personal data processed through automatic systems.
14. TRANSFER OF PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA IN DOMESTIC AND ABROAD
Onyx can transfer data within the country and abroad by the conditions stipulated in the Personal Data Protection Law and within the framework of the principles determined by the Board, within the scope of compliance with the law, or with the express consent of the person concerned.
Onyx acts by Articles 8 and 9 of Law No. 6698 when transferring personal data and/or sensitive personal data. In addition, it fulfills the necessary disclosure and expresses consent obligations.
15. SUPERVISION AND PROCESS SECURITY
Necessary technical and administrative measures are taken to ensure that personal data and/or sensitive personal data collected through various means do not fall into the hands of unauthorized persons, that the rights of the data owner are not harmed, that they are not victims, and that the data is protected. In addition, data protection is requested from companies with whom we share personal data and/or sensitive personal data within the framework of legal compliance, when necessary. Again, our software programs are updated, constantly renewed, and developed. To provide a high level of protection, all technical requirements are fulfilled and compliance with standards is ensured. In parallel with all these, Onyx has all necessary internal and external audits carried out to protect personal data and/or sensitive personal data.
16. NOTICE OF DATA VIOLATIONS
In case of any breach of data, Onyx immediately takes action to do its part to remedy the breaches reported to him/her. It takes the necessary measures to minimize the harm of the person concerned. You can apply for notification of violations according to the procedures specified on our company’s website. In addition, in the event that personal data and/or sensitive personal data are obtained from outside by unauthorized third parties, the company notifies the Personal Data Protection Board directly.
17. RIGHTS OF THE DATA OWNER RELATED PERSON REQUESTING INFORMATION
A- GENERAL INFORMATION ABOUT THE APPLICATION AND YOUR RIGHTS
The rights of the data owner are stipulated in Article 11 of the Law on the Protection of Personal Data No. 6698. In the law, the data owner is deemed to be the “relevant person“; The right to make certain requests regarding the processing of the data is foreseen.
Your requests regarding your rights arising from the Law on Protection of Personal Data No. 6698 explained above shall be answered by Onyx as soon as possible or within thirty days at the latest, depending on the nature of the request. Applications must be made by the data owner oneself. Onyx shall only consider the application made by the data owner.
B- APPLICATION PROCEDURE
Onyx, who is the data controller, can make your requests regarding your rights mentioned above in writing or by using the registered e-mail (KEP) address, secure electronic signature, mobile signature, or the e-mail address previously notified to the data controller by the data controller and registered in the data controller’s system.
C-INFORMATION REQUIRED IN THE APPLICATION
The information that should be included in your application is as follows:
Name and Surname
T.R. Your ID Number
If you are a foreign national, your Nationality, Passport Number / Identity Number,
If a written application is to be made, your wet signature at the bottom of the request form,
Content and Subject of Your Request in accordance with Article 11 of the KVKK,
Telephone and Fax Number(s) We Can Reach You,
Your e-mail address where we can reach you,
Domicile or Workplace Address Based on Notification,
OUR COMPANY’S INFORMATION IS AS FOLLOWS;
Data Controller: ONYX PARTNERS GLOBAL LLC.
Address: NO: 4/13, DR. CEMIL BENGU STREET, HURRIYET DISTRICT, KAGITHANE/ISTANBUL
E-mail: info@onyxpglobal.com
Website: www.onyxpglobal.com
| Policy Update Date | Changes |
| – | – |
COOKIE POLICY
1. WHAT IS THE COOKIE POLICY?
Cookies are small text files that are stored on your computer or mobile device when you visit a website. ONYX PARTNERS GLOBAL LLC. (hereinafter briefly referred to as “Onyx” or “Company“), make use of certain cookie technologies in order to increase your experience and use in the extensions of our website, our website, digital media, mobile applications (hereinafter referred to as “MEDIA“).
The use of cookies is carried out in accordance with the Law on Protection of Personal Data No. 6698 (hereinafter referred to as “Law“) and various relevant laws.
2. PURPOSE OF COOKIE POLICY
The Cookie Policy has been prepared to inform media users about cookies and the types of cookies used, and to guide them on how to manage their cookie preferences. For this reason, we inform and enlighten you about the processing of personal data through the cookies used during access with the Cookie Policy. We would like to state that we reserve the right to change our policy at any time.
We would like to point out that Onyx processes your personal data within the scope of the cookie policy as “Data Controller” in accordance with Article 3 of the Law on Protection of Personal Data No. 6698. The information of the data controller is as follows:
Data Controller: ONYX PARTNERS GLOBAL LLC.
Address: NO: 4/13, DR. CEMIL BENGU STREET, HURRIYET DISTRICT, KAGITHANE/ISTANBUL
E-mail: info@onyxpglobal.com
Website: www.onyxpglobal.com
3. COOKIES USED
Different cookies can be used to serve you in the environment. We would like to point out that the cookies used in every way comply with the Privacy Policy and the provisions of the Personal Data Protection Law. Cookies are divided into different types according to criteria, such as the time they are stored on mobile devices and by whom they are placed. Follows;
– Functionality Cookies: When you visit the website again, your language preferences, region selection, etc. allow it to be remembered.
– Targeting/Advertising Cookies: Onyx uses different first-party and third-party cookies for targeting and advertising purposes on its website. It is possible to block these cookies by changing your browser settings or by changing your cookie preferences as shown in this policy.
– Mandatory Cookies: These are technical cookies that enable the website to function correctly and allow you to use its features. They are in the session cookie category. If these cookies are blocked, it shall result in the inability to use the website features. Your consent is not required
| COOKIE SERVICE PROVIDER | COOKIE NAME | PURPOSE OF COOKİE | COOKIE TYPE | COOKIE DURATION |
| AA (SAMPLE) | xxx | It stores the language option that the user uses on the site | Necessary | 1 Year |
| AA (SAMPLE) | xxx | Indicates whether the user is redirected to the mobile view when entering the website from mobile devices | Necessary | End of Session |
for the use of mandatory cookies.
– Analytical Cookies: Analytical cookies are used to improve your website experience. Analytical cookies allow you to understand how you use the website (which pages you visit, duration of visit, etc.). You can improve the content we offer or change the website design.
4. CHANGE OF COOKIE PREFERENCES
You have the opportunity to change the cookie preferences. So much so that it is possible to personalize or completely block cookies by changing the settings of the browser you use. However, we would like to remind you that some features of the media may lose their functionality if cookies are not allowed. If you do not approve of the use of cookies, we ask you not to continue using the media or to change your cookie preferences as shown in this policy.
The steps to follow for different browsers are as follows. If your browser is different from the mentioned browsers, you can review the help or support page of the relevant browser.
| GOOGLE CHROME | https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=tr |
| ADOBE ANALYTICS | http://www.adobe.com/uk/privacy/opt-out.html |
| GOOGLE ADS | https://support.google.com/ads/answer/2662922?hl=en |
| GOOGLE ANALYTİCS | https://tools.google.com/dlpage/gaoptout |
| INTERNET EXPLORER | https://support.microsoft.com/tr-tr/help/17442/windows-internet-explorer-delete-manage-cookies |
| YANDEX | https://yandex.com.tr/support/browser-classic/personal-data-protection/cookies.xml |
| MOZILLA FIREFOX | https://support.mozilla.org/tr/kb/cerezleri-silme-internet-sitelerinin-bilgilerini-kaldirma |
| SAFARI | Choose Safari > Preferences, click Privacy, then choose your preferred option and do any of the options that appear there. |
| OPERA | https://www.opera.com/browser/tutorials/security/privacy/ |
5. PURPOSE OF PERSONAL DATA PROCESSING WITHIN THE SCOPE OF COOKIES
We process your personal data by Onyx through cookies. Our purposes for processing the said personal data are as follows:
– Providing information to authorized persons, institutions and organizations
– Execution of marketing processes of products and services
– Execution of advertisement, campaign, promotion, personalization, targeting processes
– Execution of activities for client satisfaction
– Execution of client relationship management processes
– Execution of activities in accordance with the legislation
– Ensuring that the website performs its basic functions
– Analysing the website and improving its performance
– Increasing the functionality of the website
– Facilitating the use of the website
– Execution of information security processes
6. PERSONAL DATA COLLECTION METHOD AND LEGAL REASONS
Your personal data is collected through media and processed automatically.
Personal data, which we collect through the website, are processed based on legal reasons, in case of the following situations, by the 2nd paragraph of the 5th article of the Law No. 6698. These, provided that it is stipulated in the law, is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract, the data controller must fulfill its legal obligation, the data processing is mandatory for the establishment, exercise or protection of a right, the fundamental right of the data subject, it is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm their rights and freedoms.
7. THE PARTIES THAT PERSONAL DATA MAY BE TRANSFERRED AND THE PURPOSE OF TRANSFER
Personal data may be transferred to suppliers, authorized public institutions and organizations, legally authorized private law legal entities, and judicial authorities for the legal reasons specified in this clarification text regarding data processing within the scope of Article 8/2(a) of Law No. 6698 these legal reasons are as follows; fulfillment of contractual requirements, ensuring the performance of goods and services, carrying out communication activities, ensuring business continuity, conducting business processes, conducting public relations, press-media processes, realizing commercial activities carried out by the company. In addition, it is possible to transfer personal data in question to our suppliers located abroad and/or have servers abroad to increase our service quality and continuity, based on the express consent condition within the scope of Article 9/1 of the Law.
CONTACT
You are completely free to accept or reject the processing of your personal data so that we can serve you better in accordance with this privacy and personal data processing policy. If you continue to use our website, we will assume that you have accepted our policy. For more detailed information, please do not hesitate to contact us via info@onyxpglobal.com.
Onyx Partners Global is Turkey’s leading independent residence and citizenship advisory firm.
Office No: 1, Building No:5, Talatpasa St., Esentepe Dist., Sisli, Istanbul/Turkey
Email: info@onyxpglobal.com
Working Hours: 09:00 – 18:00
Copyright © 2022 Onyx Partners Global. All rights reserved.