PRIVACY POLICY

We fully recognize the utmost importance you attach to the security of your data. In this regard, the rigorous protection of your data, as well as the absolute guarantee of its confidentiality, constitute top priorities for our organization. As a company incorporated under Turkish law and acting in its capacity as Data Controller, CSM Metalurji İmalat Sanayi ve Mühendislik Ltd. Şti (hereinafter referred to as “CSM Metalurji” or “we”) undertakes to strictly respect your personal data as well as all your confidential information. We take all reasonable and appropriate measures to ensure the security of such information and to comply with the legal requirements regarding data protection.

The purpose of the CSM Metalurji Privacy Policy is to provide you with comprehensive information regarding the purposes for which your data is processed by CSM Metalurji, the methods of such processing, as well as the third parties with whom such data may be shared, where applicable.

This Privacy Policy applies exclusively to the services provided through the domain name www.csmmetal.com.tr (hereinafter referred to as the “Site” or the “Website”). In the event that your personal data is processed by CSM Metalurji through our Website, such data shall be processed in accordance with the provisions of this Privacy Policy.

THE USE OF THIS WEBSITE IMPLIES THE UNRESERVED ACCEPTANCE OF THE PRIVACY POLICY AND THE ASSOCIATED TERMS OF USE.

Users are strongly advised to review our Privacy Policy each time they visit our Website. Indeed, the Privacy Policy may be modified by CSM Metalurji at any time and for any reason whatsoever. By using our Website, you acknowledge that you have read the most recent version of our Privacy Policy and accepted its amended terms. Any modifications made to the Privacy Policy shall automatically enter into force upon their publication on the Website. Each updated version shall also affect information previously collected.

Any update to the Privacy Policy shall be published on the homepage of www.csmmetal.com.tr, on the privacy notice page, as well as in any other location deemed appropriate, in order to inform users of the manner in which their personal information is collected, used, or shared.

Processing of Your Data and Personal Data

Data consists of information relating to all types of facts, whether numerical, such as age, height, or weight, or categorical, such as brand, channel name, country, or city. Such data is collected, analyzed, and interpreted in order to be presented. Data also includes your personal data.

Personal data includes any information relating to an identified or identifiable natural person, including but not limited to name, address, e-mail address, telephone number, date of birth, and IP address. The processing of your personal data shall be carried out in strict compliance with the Law on the Protection of Personal Data, in addition to this Privacy Policy. In the event of any inconsistency between this Privacy Policy and the applicable legislation, the applicable legislation shall prevail.

CSM Metalurji and its contractual service providers use your personal data in order to evaluate your applications, review and respond to your complaints, questions, and opinions, provide solutions tailored to your needs, send you commercial offers in accordance with your quotation requests, provide you with high-quality service, facilitate the use of our Website, share advertising and marketing activities with you, request your feedback, and develop campaigns, products, or offers specifically tailored to you.

Certain sections of the Site may require the disclosure of some of your personal data. In this context, you will be requested to provide your personal data solely for the purpose of enabling the execution of the services and activities related to the relevant section. The disclosure of your personal data in such cases is entirely at your own discretion, and if you choose not to provide such data, you may not be able to benefit from the relevant services or activities.

CSM Metalurji processes the personal data that you have voluntarily disclosed and transmitted, as well as your personal data where the processing conditions stipulated by the applicable legislation are fulfilled, in accordance with the applicable general principles.

We do not impose the provision of your personal data as a prerequisite for accessing our Site; the information requested from you is reasonable in scope and does not require the disclosure of additional information. For the information that we are required to obtain in order to provide our services, you may identify a small red asterisk (“*”). Any information not marked with this sign may be provided at your discretion.

With regard to your personal data, CSM Metalurji:

Upon receipt of your applications, we collect the following information: first name and surname, contact address, place of birth, year of birth, telephone number, e-mail address, gender, level of education, name of the institution, graduation date, foreign language, foreign language proficiency level, professional experience, position held, last employer, duration of employment, reason for leaving, the first name and surname of the authorized person within the relevant company, as well as their contact details.

Within the contact section, we collect the following information: first name and surname, e-mail address, telephone number, company name, as well as the messages that users wish to transmit.

Within the scope of the services and activities included in these sections, we may conduct various inquiries concerning you and, within this framework, process the data obtained.

We also collect your preferences regarding products or services, your past experiences, as well as your addresses and contact details.

Pursuant to Article 5 of the Law on the Protection of Personal Data, CSM Metalurji processes your personal data in the following cases:

Where expressly provided for by law;

Where necessary for the protection of the life or physical integrity of the data subject or another person, in cases where the data subject is unable to provide consent due to actual impossibility or where such consent cannot be legally recognized;
The processing of the personal data of contractual parties is permitted where such processing is directly related to the conclusion or performance of a contract and is necessary for its execution. In addition, processing is permitted where the data controller is required to carry it out in order to fulfill its legal obligations. The processing of data made public by the data subject himself/herself, as well as processing necessary for the establishment, exercise, or protection of a right, is also permitted;

The data controller is entitled to process all of your non-sensitive personal data without obtaining your consent, provided that such processing does not violate your fundamental rights and freedoms and is necessary for the pursuit of the legitimate interests of the data controller;

The processing of sensitive personal data, such as data relating to racial or ethnic origin, political opinions, philosophical beliefs, religion, sect, or other beliefs, appearance and clothing, membership in an association, foundation, or trade union, criminal convictions and security measures, as well as biometric and genetic data, is strictly regulated by law. The processing of such sensitive data is subject to the implementation of adequate measures determined by the competent Authority;

Your sensitive personal data relating to health and sexual life shall only be processed by persons subject to a confidentiality obligation or by authorized institutions and organizations, exclusively for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, as well as the planning and management of healthcare services and their financing. Outside these cases, such data shall only be processed with your explicit consent;

CSM Metalurji shall process your personal data, under all circumstances, in accordance with the principles of lawfulness and good faith. Processing shall be carried out accurately and, where necessary, kept up to date, for specified, explicit, and legitimate purposes. It shall also be carried out in an adequate, relevant, and limited manner in relation to the purposes for which the data is processed, and such data shall be retained for the period prescribed by the applicable legislation or required for the purposes of processing;

Separate information notices have been prepared for each area in which your personal data is collected, as well as for the cookies used on the Site. You may access these information notices through the relevant sections and via the links entitled “Human Resources Department Information Notice”, “Contact Section Information Notice”, and “Cookie Information Notice”.

We collect your personal data through the following means:

The Site server automatically collects information such as your Internet Protocol (IP) address, the type and language of your browser, as well as the date and time of access to the application. Such data is collected in order to enable the monitoring of user activities on the application and the identification of trends.

Cookies may be assigned (sent) to your device in order to facilitate your access to the Site and personalize your online experience. The Site uses cookies in order to closely monitor certain information that you enter when visiting or using the Site. Cookies are very small files stored on your computer for recording purposes, allowing data to be retained and thereby enabling the Site to identify you. The Site also uses cookies to provide users with new content and information tailored to their interests. Cookies are widely used on many websites and are not linked to your personal information. If your browser settings are configured to reject all cookies, the Site may not function properly. For more detailed information regarding cookies, please click here.

CSM Metalurji, or third parties such as its consultants responsible for defining its advertising and marketing strategies, as well as its service providers, may use standard Internet tools such as pixel tags (web beacons). These tools enable the monitoring of your use of the Site and the collection of information allowing the personalization of the services we provide and the advertisements we display. Pixel tags (also referred to as “clear gifs”, “web beacons”, or “web bugs”) are tiny images containing a unique identifier, having a function similar to cookies, used to track users’ online movements or to access cookies. Unlike cookies, which are stored on the user’s hard drive, pixel tags are invisibly embedded within web pages or e-mails and are approximately the size of the period at the end of this sentence. Pixel tags may be used to transmit or communicate with cookies in order to count users visiting certain websites and to analyze usage patterns. The Site may also use pixel tags when sending promotional e-mails (or other types of messages) or newsletters in order to determine whether such messages have been opened and interacted with. In addition, if you access the Site www.csmmetal.com.tr through an advertisement viewed on another website, the Site shall receive an anonymous identifier.

Purpose of the Processing of Your Personal Data

CSM Metalurji undertakes to process your personal data for the purpose of providing the offered services in a complete and flawless manner, continuously improving such services, developing new services, as well as in cases where the conditions stipulated in paragraph 2 of Article 5 and paragraph 3 of Article 6 of the Law on the Protection of Personal Data are fulfilled.

CSM Metalurji processes your personal data for the following purposes:

       - Evaluation of your applications;

       - Review and response to your complaints, questions, and opinions;

       - Fulfillment of our obligations relating to the provision of our services;

       - Creation of databases, execution of listing, reporting, verification, analysis, and evaluation operations, production of statistical information and, where applicable, sharing such information with experts in compliance with confidentiality requirements;

       - Analysis of the use of our Website and our other communication channels, and personalization of such channels in order to optimize service quality;

       - Personalization of advertisements and content viewed by you on the Site, and facilitation of the use of the Site;

       - Study and development of our products and services, as well as your related personalized choice opportunities;

       - Detection of abusive use of the Site and fraudulent activities, and implementation of protective measures against such activities.

We reserve the right to contact you within the scope of market research studies, either directly or through partners from whom such services are obtained, using the communication channels that you have previously provided. This process aims to identify the products and services most suited to your needs in order to optimize the quality of our services.

Furthermore, we undertake to share advertising and marketing activities with you, request your opinions, and develop campaigns, products, or offers personalized according to your preferences. We also endeavor to promote our related services or products and to inform you about new products, special offers, or any other subject or product that may be of interest to you.

Data integrity constitutes an absolute priority for CSM Metalurji. We undertake to ensure that the data collected is accurate, complete, up to date, and relevant for its intended purpose of use. We continuously strive to improve our processes in order to maintain the quality of our data.

We acknowledge our legal obligation not to share your personal data with third parties without your explicit consent, except in cases provided for under the legislation relating to the protection of personal data.

CSM Metalurji reserves the right to disclose to third parties the personal information of users collected through the Site, in cases provided for under the applicable legislation. Such disclosure is intended to ensure compliance with applicable laws, judicial decisions and proceedings, injunctions, and other legal procedures, as well as to prevent any harm to the interests of the company. It also aims to protect the security, rights, and legitimate interests of CSM Metalurji, its employees, representatives, and users of the Site.

CSM Metalurji may transfer your personal data to its employees, contractual service providers, third-party companies involved in the production of products and services, authorized distributors, suppliers, and affiliates assisting in the conduct of its activities, as well as to the competent administrative authorities and any other relevant person or organization, in accordance with legal obligations, both nationally and internationally.

The companies with which we share your data are required to comply with the applicable legislation and to preserve the confidentiality of the information transmitted to them. However, CSM Metalurji disclaims all responsibility in the event of unlawful conduct on the part of such third parties.

Our service providers include entities such as data analysts, advertising agencies, server providers, companies specialized in data storage, as well as information technology and cybersecurity companies. SMS or e-mail infrastructure services, as well as customer relationship services, are also included. These service providers are essential to the provision of the services we offer and contribute to the improvement of their quality. We maintain professional relationships with each of them governed by strict confidentiality agreements.

Commercial Transfer

In the event of a merger, acquisition, and/or transfer of assets of CSM Metalurji, or a change of ownership, the personal information of users of the Site may be shared with the relevant third parties.

Transfer of Data Abroad

Subject to obtaining your consent, the transfer of information to CSM Metalurji and/or to third parties, potentially including personal information, may involve the transfer of such data from one jurisdiction to another. The transfer of your personal data shall only be carried out provided that an adequate level of protection is ensured in the destination country. In the absence of such a level of protection, the transfer shall only be carried out if the data controllers in Türkiye and/or in the relevant foreign country undertake in writing to ensure adequate protection, and subject to the authorization of the competent Authority.

Other Provisions

All personnel of CSM Metalurji acknowledge that they are aware of this Privacy Policy and undertake to comply with it strictly. CSM Metalurji undertakes to examine any complaint relating to a violation of the Privacy Policy and to initiate the necessary procedures in the event that such a violation is identified.

The Site may contain hyperlinks to third-party websites, including advertisers, which are not owned by CSM Metalurji. In such cases, CSM Metalurji disclaims all responsibility regarding the content of such websites, the accuracy of the information they provide, or their operation.

The links are provided in good faith, and CSM Metalurji cannot be held responsible for subsequent modifications made to such third-party websites. The presence of links to other websites shall in no way constitute an endorsement of such websites by CSM Metalurji. The user’s participation in advertisements accessible through links on the Site or in prize draws or promotions organized by sponsors, as well as the individual or commercial relationships maintained with such websites (including the delivery and payment of goods and services, the voluntary disclosure of personal information to such advertisers and sponsors, and the acceptance of any contractual commitments), shall remain exclusively the responsibility of the user.

The user expressly acknowledges and accepts that any potential damages or losses arising from such relationships, the sharing of information with such third parties, or the presence of links to such entities on the Site shall not engage the liability of CSM Metalurji. Users are strongly advised to consult and carefully review the legal notices and privacy policies of all other websites they visit.

CSM Metalurji reserves the right to authorize third-party advertising partners or advertising networks to display advertisements on the Website. Such companies or networks may use tracking tools, such as cookies, in order to collect information regarding the computers used to view or interact with such advertisements. It is important to specify that CSM Metalurji does not transmit any personal data to such companies or networks.

All intellectual and industrial property rights relating to all information and content available on the Site, as well as their organization and partial or total use, are exclusively owned by CSM Metalurji.

It should be noted that this Privacy Policy applies solely to online information collection and dissemination practices relating to the Site and does not concern practices carried out offline.

Your Rights Regarding Your Personal Data

With regard to the processing of your personal data by CSM Metalurji, you are entitled to submit a request to CSM Metalurji (or directly to the data controller in cases where CSM Metalurji acts as a data processor) in order to:

       a) Obtain confirmation as to whether your personal data is being processed.

       b) Request information regarding the processing of your personal data, where applicable.

       c) Learn the purpose of the processing of your personal data and verify whether such data is used in accordance with said purpose.

       d) Identify the third parties to whom your personal data is transferred, whether in Türkiye or abroad.

       e) Request the rectification of your personal data if it has been processed incompletely or incorrectly.

       f) Request the deletion or destruction of your personal data in accordance with the provisions of Article 7 of the Law on the Protection of Personal Data.

       g) Request notification to third parties to whom your personal data has been transferred regarding the operations carried out pursuant to points (d) and (e).

       h) Object to the occurrence of a result detrimental to you arising from the analysis of your data processed exclusively through automated systems.

       i) Request compensation in the event of damage suffered as a result of the unlawful processing of your personal data.

Options / Unsubscription

Users have the right to make choices and/or modify their preferences by following the methods indicated below.

You have the option to refuse the disclosure of your optional personal data in order to access the services and activities offered by the Site. By accepting this option, you acknowledge that access to certain services and/or functionalities of the Site may be restricted.

You may request the update or deletion of the personal data that you have communicated through the relevant sections of the Site, as well as the deletion of your requests recorded within such sections.

To unsubscribe from newsletters and promotional communications relating to the Site, please click on the “Unsubscribe” link located at the bottom of each e-mail received. Furthermore, in order to modify your SMS communication permissions, please follow the instructions provided in the SMS messages we send you, including by sending an SMS containing “RED” followed by the requested text to the indicated number.

Being aware that this option may result in limitations regarding access to certain services and/or functionalities of the Site, you may configure your browser settings in order to delete and/or reject cookies.

Updating and Rectification of Your Personal Data

To obtain a copy of the information you have communicated to CSM Metalurji, or to report any inaccuracy or request the deletion of information concerning you, please contact us by e-mail at: info@csmmetalurji.com.

In order to process your request, our information technology staff may, prior to carrying out any modification or deletion of information, request that you verify your identity as well as certain details, including your personal identification information.

Following the evaluation of your request in accordance with the principles of proportionality, data quality, and reasonableness, actions such as the modification, rectification, or deletion of inaccurate data shall be implemented. In this context, all requests that you submit to the Site shall be handled diligently and in a manner appropriate to the nature of your request.

In order to optimize the processing of your requests and provide you with more effective assistance, we invite you to use our KVKK Request Form (Law on the Protection of Personal Data), specifically designed for this purpose.

Security of Your Personal Data

CSM Metalurji attaches paramount importance to protecting the confidentiality of your data. Appropriate security systems are implemented in order to prevent the loss, alteration, and unauthorized use of the data under our control. In addition, the forms through which you transmit data to us are protected by an encrypted communication channel using the 128-bit SSL (Secure Socket Layer) protocol, which encrypts information during transmission and thereby provides an additional security measure.

Once such data reaches CSM Metalurji, it is protected in accordance with our rigorous security and confidentiality standards. In order to benefit from the SSL protocol, your Internet browser must be SSL-compatible and the SSL options of your browser must be enabled.

We implement all administrative measures deemed necessary in order to protect and preserve your personal data. Access to your personal data is strictly limited to duly authorized employees within the scope of the performance of their duties relating to our services. For this purpose, our personnel receive the required training and assume their duties following a complete and appropriate information process.

However, it should be emphasized that, given the inherent nature of the information technology sector and the risks inherent in any online data transmission, the implementation of a level of security compliant with the standards established by CSM Metalurji cannot guarantee the total absence of unauthorized access.

Consequently, CSM Metalurji disclaims all responsibility for any damages and/or losses resulting from a security breach or technical issues arising in accordance with the provisions of this Privacy Policy. Likewise, CSM Metalurji shall not be held liable for any damage resulting from disclosures of information due to undesirable and/or unforeseeable causes.

The commitment of CSM Metalurji consists in providing an appropriate information security policy compliant with the standards defined by the Personal Data Protection Authority and, in any event, with a generally accepted level of security. This commitment shall in no way constitute a preventive guarantee.

In the event of any suspicion of a breach of the security of the Website, please contact us at the following address: info@csmmetalurji.com. 

Use of Cookies

CSM Metalurji reserves the right to use cookies on its Website in order to optimize the user experience. It is important to specify that the cookies used do not collect any information from your system or hard drive. Your identity, including your name or e-mail address, is not identified on our Website. However, upon your first connection, a unique numerical identifier shall be assigned to you.

Cookies are small data files placed on your computer by a web server through your browser. When a connection is established between your browser and the server, the Website is able to recognize you through such cookies. The use of cookies is intended to simplify and improve the user experience on the Website. Four types of cookies are distinguished according to their purpose: session cookies, performance cookies, functional cookies, and advertising and third-party cookies.

CSM Metalurji uses session cookies, performance cookies, functional cookies, as well as advertising and third-party cookies on its Website. Session cookies are temporary cookies retained in the user’s browser until the browser is closed. Other cookies remain in the user’s browser until deleted. The lifespan of such cookies is determined by the browser settings configured by the user.

Users have the option to accept or refuse cookies by modifying the settings of their Internet browser. To obtain instructions regarding the modification of your browser settings or the deletion of cookies, please consult the documentation provided by your browser manufacturer. It is important to note that certain functionalities of the Site may not be accessible when cookies are disabled.

For more detailed information, please consult the CSM Metalurji Cookie Policy.

Information regarding the blocking of third-party cookies on the following Internet browsers is available:

       - Mozilla Firefox

       - Internet Explorer

       - Google Chrome

       - Opera

       - Safari

Contact

For any comments or questions regarding this Privacy Policy and/or the general privacy practices of CSM Metalurji, please contact us through the following means:

       - E-mail: info@csmmetalurji.com

       - MERSIS: 0215012465400011

Subject: Privacy Policies, Entire Agreement

Users of the Site acknowledge and undertake that, in the event that a provision of this Privacy Policy is declared invalid by a competent jurisdiction, the valid provision producing the effect closest to that of the contested provision and best reflecting the actual intention of the parties shall apply, without prejudice to the validity and enforceability of the other provisions of this Privacy Policy.

With regard to any dispute that may arise between users of the Site and CSM Metalurji, the policy of our company is to prioritize the resolution of such disputes through conciliation between the parties, while ensuring user satisfaction. For any questions, users are invited to submit their complaints and requests through the dedicated section of the Website.

Furthermore, users may, if they wish, submit their requests relating to disputes to a mediation procedure. Resorting to mediation shall in no way constitute a waiver of the right to pursue other legal remedies.

Within this framework, users may bring legal actions before the commercial courts of first instance of their place of residence or of the relevant location; in the absence of a commercial court within such jurisdiction, they may apply to the competent civil court of first instance.