Personal Data Protection Law

As the International Pickleball Federation Turkey Representative, we continue to carry out our work on the Protection of Personal Data, which we have attached great importance to since the day we were founded, with an approach parallel to the "Personal Data Protection Law (KVKK)". In this context, some terms expressed in the law and information about our data processing processes in order to fulfill our obligations are presented below.

What is KVKK?

The Personal Data Protection Law (KVKK) was accepted by the Turkish Grand National Assembly on 24.03.2016 and entered into force by being published in the Official Gazette dated 07.04.2016 and numbered 29677.

The Law is based on the compliance of all persons and institutions processing personal data within the framework of basic purposes such as ensuring the confidentiality of personal data, protecting it and preventing unauthorized use. Our company, like all organizations, is obliged to comply with this Law and the personal data processed in all processes of our Company are within this scope.

What is Personal Data?

Data sets that make a person directly or indirectly identifiable are considered personal data. Name, Surname, Turkish ID Number, Place/Date of Birth, Gender, Phone Number, Education, CV, Photo, and identifying information belonging to or created on behalf of the person can be given as examples.

What is Data Processing?

Any operation performed on personal data is considered as “data processing”. Therefore, archiving, storing, changing, reorganizing, disclosing, transferring, analyzing and classifying data falls within the scope of data processing.

Who is the Relevant Person / Data Owner?

One of the expressions frequently used in the law and our corporate policies is “relevant person” or “data owner”. It refers to the real persons whose personal data is processed.

Who is the Data Controller?

The data controller is the real or legal person who determines the purposes and methods of processing personal data and is responsible for the establishment and management of the data recording system. At this point, the International Pickleball Federation Turkey Representative Office becomes the Data Controller in terms of the data of our trainees, visitors and employees.

Who is the Data Processor?

The data processor is the real or legal person who processes data on behalf of the data controller. These persons may also be a separate real or legal person authorized by the data controller to process personal data.

Data Processing Conditions

All data controllers have the right to process data only if the following conditions are met or if the relevant person gives explicit consent:

It is clearly provided for in the laws

It is directly related to the establishment or execution of a contract

The data controller is able to fulfill its legal obligation

It has been made public by the relevant person

Data processing is mandatory for the establishment, exercise or protection of a right

The legitimate interest of the data controller

Meeting Data Owner Requests

The KVKK grants the relevant persons the right to request which personal data is processed in which processes and the current status of this data. As the International Pickleball Federation Turkey Representative, we are also obliged to respond to requests from data owners within 30 days.

According to Article 13 of the Law on the Protection of Personal Data No. 6698, which regulates “Application to the Data Controller”, the relevant person/data owner must submit their requests regarding the implementation of the Law to the data controller in writing. Therefore, in order for your request to be evaluated, you must apply to the International Pickleball Federation Turkey Representative Office or submit a written application through our fastest accessible direct channel.

Data controllers or data processors are obliged by the Law to inform data owners about the personal data they process.

Our information text regarding the personal data we process as the International Pickleball Federation Turkey Representative Office is presented below.

The purpose of this policy is to inform the Relevant Persons by explaining the Personal Data Processing activities and related systems carried out by the International Pickleball Federation Turkey Representative Office in accordance with the law as the KVKK Data Controller; and thus to ensure transparency regarding Personal Data. In this context, our Representative Office has explained the Personal Data processing activities within the scope of the KVKK and the rights of the relevant persons subject to the Processing of Personal Data in detail in this Policy.

Regular control and follow-up procedures regarding the issues within the scope of the Policy will be carried out according to the performance tracking and monitoring criteria to be established by our Representative Office.

Our Representative Office adopts the following principles regarding the processing of Personal Data in accordance with the 2nd paragraph of Article 4 of the KVKK and within the scope of the purposes specified in the 'Purposes of Processing Personal Data' section of this policy;

Compliance with the law and rules of honesty,

Accurate and up-to-date when necessary,

Processed for specific, clear and legitimate purposes,

Related to the purpose of processing, limited and proportionate,

Stored for the period stipulated in the relevant legislation or required for the purpose of processing.

DATA PROCESSED BY OUR REPRESENTATION

Personal Data is processed within our company through the explicit consent obtained from the relevant persons or in accordance with Articles 5 and 6 of the Decree Law, only within the framework of the purposes specified in the 'Purposes of Processing Personal Data' section of this Policy. The categories of Personal Data that vary and differentiate depending on the type and nature of the relationship between our company and the Relevant Person, the communication channel used and the purpose of Processing Personal Data and are processed in accordance with the principles in this Policy are generally as follows:

Camera control permission,

CV

T.R. ID number,

Mobile phone number,

E-mail address,

Address information,

Family information,

Educational status,

Bank account numbers,

Photo,

These data are defined on Verbis through the Personal Data Inventory.

PURPOSES OF PROCESSING PERSONAL DATA

Personal Data can be processed by our Representative Office within the scope of the purposes exemplified below and can be stored for as long as these purposes and the relevant legal periods stipulate;

Continuing the annual activities of our representative office without fail,

Conducting activities within the scope of legal and administrative obligations,

Negotiating, creating and executing contracts,

Providing support to the Relevant Person within the scope of requests and questions,

Risk analysis studies conducted by our representative office in accordance with risk criteria,

Making developments for the needs of trainees and customers,

Conducting candidate evaluation and recruitment processes,

Conducting human resources management of our representative office,

Planning and executing corporate sustainability activities,

Conducting commercial activities for the purposes of conducting business partnerships and partnerships of our representative office,

These purposes are detailed on Verbis through the Personal Data Inventory.

TRANSFER OF PERSONAL DATA

Our Representative Office transfers data to affiliates, suppliers and business partners within the framework of the purposes exemplified in the 'Purposes of Processing Personal Data' section of this Policy and in accordance with Articles 8 and 9 of the KVKK, and Personal Data can be processed and stored in the servers and electronic environments used within this scope.

COLLECTION OF PERSONAL DATA

In order to meet the purposes exemplified in the 'Purposes of Processing Personal Data' section of this Policy, our Representative Office may obtain Personal Data directly from employees and customers, suppliers, business partners, affiliates and other physical environments within the framework of the conditions stipulated in Articles 5 and 6 of the KVKK, as well as collect Personal Data through websites, mobile applications, social media and other publicly available channels or organized trainings, organizations and similar events.

PERSONAL DATA STORAGE PERIOD

Personal Data is stored within our Representative Office for the duration of the relevant legal retention periods or for the period required for the activities related to this data and the purposes specified in this Policy. Personal Data whose purpose of use has ended or whose legal retention period has expired is destroyed in accordance with the Data Storage and Destruction Policy.

PERSONAL DATA SECURITY

Our Representative Office attaches importance to protecting the confidentiality and security of Personal Data. In this regard, the necessary technical and administrative security measures are taken to protect Personal Data against unauthorized access, damage, loss or disclosure. In this regard, the necessary system access controls, data access controls, secure transfer controls, business continuity controls and other necessary institutional controls are implemented.