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Disclosure on PDPL for the Supplier Companies in Duty

Disclosure on PDPL for the Supplier Companies in Duty

Disclosure on Protection and Processing of Personal Data

i) Data Protection

Our electricity supply license owner companies, Enerjisa Istanbul Anadolu Yakası Elektrik Perakende Satış A.Ş., Enerjisa Başkent Elektrik Perakende Satış A.Ş., Enerjisa Toroslar Elektrik Perakende Satış A.Ş. (hereinafter together will be referred to as “ENERJISA”.), would like to inform you about your below-mentioned personal data processed by ENERJISA in this Disclosure herein pursuant to the article 10 titled “Obligation of Data Controller to Inform” of Personal Data Protection Law (“PDPL”) published in the Official Gazette no. 29677, dated April 7, 2016 with the purpose of protecting fundamental rights and freedoms of persons, particularly the right to privacy, with respect to processing of personal data; and Communique on Principles and Procedures to be Followed in Fulfilment of the Obligation to Inform published in the Official Gazette no. 30356, dated March 10, 2018.

Our policy related to protection of personal data is applied to all natural persons in connection with ENERJISA, operating in the electricity supply sector, pursuant to Electricity Market Law no. 6446 (“Electricity Market Law”) and the secondary legislation. The purpose of the disclosure herein is to inform about the purposes of storing, processing the personal data and sharing them with third parties and the legal grounds, persons and institutions that the data can be transferred, methods of personal data collection as well as the rights and power ENERJISA, as the Data Controller, is entitled as part of PDPL.

ii) What is Personal Data?
As per PDPL, personal data refers to any information relating to an identified or identifiable natural person. This means your name, surname, e-mail address and phone number are considered to be personal data.

iii) Which Personal Data Do We Collect?

PERSONAL DATA CATEGORY DESCRIPTION
ID Name-surname, date and place of birth, T.R. ID number, ID card and driving license information,
Subscription Information Meter information, subscription group, contract number, contact number, index and consumption information
Contact Information Phone number (extension, mobile), home address, e-mail address, company contact information, national electronic mail address
Location Address, location information
Legal ActionInformation within the correspondence to legal authorities, information in case files
Customer Transactions Call centre records, information on bills, bonds, cheques, counter receipts, ordering information and demand information
Physical Location Security Records of visitors entering-exiting the venue, cam records
Transaction Security IP address, password, website use, user name and login information
Risk Management Information processed for management of commercial, technical, administrative risks
Finance Information on financial statements, financial performances, credits and risks, assets, account numbers, IBAN
Marketing Questionnaires, cookies
Professional Experience Information related to diplomas, courses taken, professional training, certificates, transcripts
Visual and Audio Records Camera views, photos, audio records


iv) What is the Method and Legal Ground of Collecting Personal
Data?
Your personal data is collected through manual channels that are partially or fully automatic or provided that these channels are parts of any data system including any and all kinds of verbal, written, digital communication, headquarters of our company, our website, etc.; through any agreements and forms filled out by your party in the physical environment; and via digital channels including phones, mobile applications, call centres, IVR calls, grievance management systems, website cookies. ENERJISA may process the data acquired in its premises; also, may transfer the data for below-mentioned purposes; and transfer and process the data in its operations, affiliated companies or partners. Your personal data is collected based on the legal grounds defined under article 5 of PDPL as “Requirement to process personal data of parties of a contract, provided that it is directly related to drawing up or executing the contract,” “Requirement of personal data processing for the legitimate interests of data controller, provided that it does not damage fundamental rights and liberties of the relevant person,” and “Being mandatory for the data controller to fulfil their legal obligations”; and processed as per the legal grounds stated herein.

v) Why Do We Process Your Personal Data?
It is of great significance for ENERJISA to collect, use and process your personal data to carry out its activities, fulfil its liabilities in line with the legislation in particular, in the best possible way. Your personal data is processed limited with the following purposes;

  • Fulfil our obligations from the legislation that our Company is subject to including Electricity Market Law and the secondary legislation,
  • Fulfil obligations related to providing information and reporting in the event of a request from official and/or governmental organisations, including Energy Market Regulatory Authority, Ministry of Energy and Natural Resources, etc.,
  • Provide electricity supply services as per the Electricity Market Law and carry out electricity supply activities in compliance with the related legislation,
  • Provide services stated in the electricity contracts as part of our electricity supply operations and improve the quality of these services, carry out retail, support after retail and marketing activities of the company, prepare demand forecasts, carry out stabilisation & reconciliation market activities,
  • Use the data to carry out data enrichment, market survey, profiling/segmentation activities with the purpose of conducting required works to suggest the products and services provided by our Company to the personal data owners after customising these products and services according to their inclination, usage habits and requirements,
  • Provide legal and commercial security,
  • Manage legal processes with regulation and compliance,
  • Audit of the electricity market activities by the related organisations,
  • Sustain relations with public institutions and other organisations,
  • Carry out and implement health and safety and customer relations as well as call centre processes,
  • Carry out liabilities, customer satisfaction, corporate communication operations with support services,
  • Plan and carry out processes related to corporate sustainability, corporate governance, strategic planning and data security,
  • Prepare applications,
  • Execute financial operations and follow up financial issues,
  • Reply consumer grievances,
  • Proceed litigation and execution processes for debts that our Company is a party to,
  • Monitor the records of the Company premises to ensure security and supervision,
  • Implement consultancy, business partnership, procurement, tender and retail procedures.

Your personal data is used and processed in compliance with and under the governance of PDPL with utmost confidentiality and the purpose of ENERJISA to provide you service. ENERJISA follows legislation and ethics while processing your personal data and pays utmost attention to have accurate data, avoid misuse, process in compliance with the legal grounds, keep the data updated and store the data for a reasonable period required for the purpose.

v) Why and To Whom Do We Transfer Your Personal Data?
Your personal data can be shared with the aforementioned purposes, to the extent the legislation allows and is required by our work processes, with the parties that it must be shared with as well as legal authorities, organisations and institutions, including but not limited to, Energy Market Regulation Authority, Ministry of Energy and Natural Resources, Elektrik Piyasaları İşletme A.Ş., Türkiye Elektrik Dağıtım A.Ş., Türkiye Elektrik İletim A.Ş. and related public entities, allowed by the Electricity Market Law and other related legislation; as well as companies that we have parent - affiliate relationships, our partners - subsidiaries nationwide and abroad, banks and financing agencies, organisations that we are provided service, establish partnerships and collaborations to sustain electricity supply activities as a matter of course of the activities we carry out as part of the practices conducted to improve the quality of the service we provide in line with the requirements and purposes of personal data processing defined under articles 8 of PDPL. The data is processed for a period required by our electric supply activities in accordance with our policies and procedures defined in compliance with the By-Law on Erasure, Destruction or Anonymisation of Personal Data; and erased when your relationship with ENERJISA ends, and no other legal requirement or compliance exists.

vi) Cookies on Our Website
When you visit the website of ENERJISA, data to be processed can be collected via cookies in line with the aforementioned purposes. The technical communication files, called cookies, are small text files sent by the websites to the browsers of the users’ computers or mobile phones.

The purpose of using cookies is to provide convenience to users who visit our website. Cookies can also be used to accelerate the experiences and activities to be carried out through our websites in the future. Cookies are used to understand for which purposes people use our websites and help us enhance the structures and contents of our websites. The information acquired does not include any data to reveal your identity.

The expiration times of cookies vary depending on the browser settings of the user. Many internet browsers are set to automatically accept cookies by default. You can change these settings to block cookies or to be notified when your device receives cookies. Please refer to your browser's instructions or help to get further details on how to manage your browser settings.

vii. What Are Your Rights, as Data Owner, As Per Article 11 of PDPL?
Please kindly be informed that as per Article 11 of PDPL you are entitled to;

  • Know whether or not your personal data is processed,
  • Ask further information if your personal data is processed,
  • Request information on the purpose of processing and if your data processed is misused,
  • Know the third parties nationwide and abroad to which your personal data is transferred,
  • Ask your personal data to be revised if there is any information processed is missing or incorrect,
  • Ask your personal data to be erased or destructed in the event that the grounds for the data to be processed are no longer valid, although the data was processed in compliance with the provisions of PDPL and other related legislation,
  • Ask the third parties that data is transferred about the processes carried out pursuant to the aforementioned paragraphs (e) and (f),
  • Object to have an outcome not in your favour by means of exclusive analyses through automatic systems,
  • Ask for compensation of your damages in the event of any damages due to illegal processing.

viii. How to Claim Your Rights Related to Your Personal Data Submitted?
As part of article 11 of PDPL, you can claim your right to apply regarding your personal data by sending the documents proving your ID and a petition consisting of the details of your request in written to the following addresses in written; or by sending an e-mail to our registered electronic mail (“KEP”) with your safe electronic signature or mobile signature or to the following addresses by using your previously defined and registered e-mail address in ENERJISA’s system.

Enerjisa Group Companies Address E-Mail Address KEP Address
Enerjisa Başkent Elektrik Perakende Satış A.Ş. Barbaros Mah. Begonya Sokak Nida Kule Ataşehir Batı Sitesi No:1/1 Ataşehir İstanbul kvk.baskenteps@enerjisa.com enerjisaeps@hs01.kep.tr
Enerjisa İstanbul Anadolu Yakası Elektrik Perakende Satış A.Ş. Barbaros Mah. Begonya Sokak Nida Kule Ataşehir Batı Sitesi No:1/1 Ataşehir İstanbul kvk.ayesas@enerjisa.com istanbulaesas@hs01.kep.tr
Enerjisa Toroslar Elektrik Perakende Satış A.Ş. Barbaros Mah. Begonya Sokak Nida Kule Ataşehir Batı Sitesi No:1/1 Ataşehir İstanbul kvk.toroslareps@enerjisa.com toroslarepsas@hs01.kep.tr

Your application shall include the following information as per article 5 paragraph 2 of Communique on the Principles and Procedures for the Request to Data Controller (“Communique”);

a) Name, surname and signature, if the request is in writing,
b) For Turkish citizens, Turkish ID number; for foreigners, nationality, passport number or ID number, if exists,
c) Residential and business address for notification,
ç) Electronic mail address, telephone, fax number for notification, if exists,
d) Subject of request.

Please use Data Controller Application Form for related requests. Your application shall be accepted by ENERJISA following the identity verification and the related parties shall be informed in writing or digitally within the legal periods. As per article 7 of the Communique, if your application is to be responded in writing, no fee will be charged up to ten pages. Please kindly be informed that 1 Turkish Lira shall be charged per page over ten pages in compliance with the Communique.

ix) Amendments
ENERJISA reserves the right to make any revisions in its policies and procedures to comply with the amendments made in the related legislation.

Yours faithfully,

Enerjisa Istanbul Anadolu Yakası Elektrik Perakende Satış A.Ş.
Enerjisa Başkent Elektrik Perakende Satış A.Ş.
Enerjisa Toroslar Elektrik Perakende Satış A.Ş.
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