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We provide heat exchanges that the air conditioning and energy sector needs.

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Information Security Policy

To provide the heat exchanges needed by the air conditioning, cooling and energy sector,

Research - Based on development and original design; Using our creative skills in cooperation with universities and other scientific organizations, first of all products that make a difference to the market, to guarantee the success of the customer and to achieve results above expectations,

Creating benefits and prosperity for all stakeholders of the institution,

Plant, production activities and the negative impact of our products on the environment to make continuous improvements and developments to minimize.

Air Conditioning and Energy sector needs heat exchanges, the society's comfort and health conditions, energy needs and safe food transportation serving. In line with their values, vision and mission; In order to maintain the confidentiality, integrity and accessibility of the existence of knowledge by considering the benefits and expectations of all stakeholders;

• Systematic management of risks and opportunities for information assets/processes, taking action,

• To fulfill all the requirements of the law and contract related to information security,

• Organizing trainings to increase information security awareness,

• To ensure that the information infrastructure works uninterruptedly for work continuity,

In line with the principles of ISO27001 Information Security Management System, we undertake to implement the requirements of the standard and continuously improve the system.

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As Friterm Termik Cihazlar Sanayi ve Ticaret A.Ş. (“Friterm”), we attach great importance to protecting the privacy and security of personal data belonging to data subjects, in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”).

In this context, we ensure that necessary technical and administrative security measures are taken to protect personal data against unauthorized access, damage, loss, or disclosure. We implement appropriate system access and data access controls, secure transfer protocols, business continuity measures, and other essential corporate security controls.

This information notice applies to:

  • individuals who apply for a job at Friterm,
  • those who visit our website to obtain information about Friterm products and services,
  • those who use the website for submitting requests, suggestions, or complaints, or for exploration purposes,
  • customers and potential customers,
  • suppliers, job candidates, former employees, subcontractors and their personnel,
  • business partners, and corporate customer representatives of Friterm.

DEFINITIONS

Personal Data: Any information relating to an identified or identifiable natural person.

Special Categories of Personal Data (Sensitive Personal Data): Data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.

Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

Processing of Personal Data: Any operation performed on personal data, whether wholly or partially by automated means, or by non-automated means provided that it is part of a data recording system; such as collection, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, acquisition, making available, classification, or prevention of use of personal data.

PRINCIPLES OF PERSONAL DATA PROCESSING

Friterm processes personal data in accordance with Article 4 of Law No. 6698 on the Protection of Personal Data (KVKK), acting in line with the following principles:

  • Lawfulness and fairness,
  • Accuracy and being up to date when necessary,
  • Processing for specific, explicit, and legitimate purposes,
  • Being relevant, limited, and proportionate to the purposes for which they are processed,
  • Retention for the period stipulated in the relevant legislation or required for the purpose for which the data are processed.

DATA PROCESSED BY FRITERM TERMİK CİHAZLAR SANAYİ VE TİCARET A.Ş. AND PERSONAL DATA COLLECTION CHANNELS

The nature and scope of the personal data processed by Friterm vary depending on the type and nature of the relationship between Friterm and the data subject, the communication channels used, and the intended purposes of data processing. These may include:

  • Website Visits: When visiting Friterm’s website, cookies that perform data tracking may be used. Personal data such as identity, contact details, educational/professional background, and health data may be collected via internship/thesis application forms and job application forms submitted by the data subject. Similarly, identity and contact information may be submitted via product request or service support forms.
  • Customer Service Interactions: Identity and contact information may be collected verbally from the data subject to provide effective customer service and manage feedback, suggestions, and complaints.
  • Events, Fairs, Media: Identity, contact, and visual data may be collected from participants in fairs and events organized by Friterm, as well as from media representatives, local authorities, and other media institutions (including social media), either through physical documents, verbal declarations, or electronic formats.
  • Job Applications: CVs submitted by job candidates in physical or electronic formats may include personal data such as contact details, employment history, skills and competencies, affiliations with NGOs, unions, or associations, as well as references. This information may also be obtained via human resources service providers.
  • Former Employees: Identity and contact information, financial data, union membership, travel and expense data, employment history, family information, and health data may be processed based on information previously obtained from former employees and in compliance with legal requirements.
  • Contractual Partners: Personal data of representatives of suppliers, subcontractors, dealers, and business partners with whom Friterm has contractual relationships, including basic contact information. In the case of subcontractor employees, additional data such as identity, health, financial, education, qualifications, criminal record, communication, and family information may be collected.
  • Customer Communications: Basic contact information may be processed for customers and prospective customers using any communication method, including telephone calls and email correspondence, in relation to Friterm products.

All personal data listed above are processed in accordance with the principles outlined earlier.

PURPOSES OF PERSONAL DATA PROCESSING

Personal data may be processed by Friterm for the following purposes and may be retained for the duration required by these purposes and the relevant legal periods:

For Website Visitors:

  • Recording conversations with data subjects for the purpose of ensuring service/transaction security,
  • Ensuring the security of the websites.

For Job Applicants and Their References:

  • Identifying suitable candidates for open positions,
  • Conducting reference checks of candidates,
  • Executing human resources policies and processes.

For Customers / Business Partners / Consumers:

  • Carrying out communication activities,
  • Conducting sponsorship activities in social responsibility projects, seminars, events, and organizations,
  • Offering gifts or promotions,
  • Organizing events, inviting customers, tracking participation, and handling required reservation processes,
  • Conducting activities aimed at ensuring customer satisfaction,
  • Investigating, identifying, preventing, and reporting violations of contracts or laws to the relevant administrative or judicial authorities,
  • Conducting strategic planning activities.

For Suppliers / Subcontractors and Their Employees:

  • Tracking payments to suppliers/subcontractors, managing financial status, pricing, invoicing, and similar processes,
  • Organizing events, inviting suppliers, tracking participation, and managing necessary reservations,
  • Executing goods, services, production, and operational processes,
  • Investigating, identifying, preventing, and reporting violations of contracts or laws to the relevant administrative or judicial authorities,
  • Carrying out communication activities,
  • Managing supply chain processes,
  • Exercising and protecting Friterm’s legal rights and managing contractual obligations.

TRANSFER OF PERSONAL DATA

In line with the activities conducted by Friterm and the purposes stated above, personal data may be shared with the following parties:

  • Internal departments within Friterm to ensure coordination, collaboration, and operational efficiency,
  • Companies providing support for technological systems used by Friterm, including system administrators,
  • Human resources firms within the scope of recruitment services,
  • Legal advisors for the execution of legal and compliance-related activities,
  • Payment service providers, tax offices, banks, audit firms, and public authorities to carry out payment and billing processes,
  • Third parties that host or operate Friterm websites, analyze data, provide customer service, or deliver services on behalf of Friterm for the purpose of evaluating requests, complaints, or suggestions,
  • Agencies managing social media accounts,
  • Associations, foundations, and non-governmental organizations for the purpose of improving sectoral employment,
  • Universities and consultancy firms for conducting research and development activities and fulfilling legal obligations,
  • In the event of business transfers, personal data may be shared with third parties involved in the sale or acquisition of company assets, subsidiaries, or new business ventures.

Personal data may also be shared with relevant legal authorities under the following circumstances:

  • If required by applicable law and believed in good faith to be necessary,
  • Upon request by government officials for the purpose of investigating,
  • To verify or enforce applicable policies,
  • To detect and protect against fraud, technical failures, or security vulnerabilities,
  • To respond to emergencies,
  • To protect the rights, property, or safety of Friterm, its websites, or public third parties.

 

TRANSFER OF PERSONAL DATA ABROAD

Friterm may transfer personal data abroad for the purposes outlined in this notice. In such cases, personal data may be processed and stored on servers and electronic platforms located outside of Türkiye.

Personal data may only be transferred to:

  • Foreign countries declared by the Turkish Data Protection Board to have adequate protection,
  • Or, in the absence of adequate protection, to foreign countries where the data controllers in Türkiye and the relevant foreign country provide a written commitment of sufficient safeguards and obtain approval from the Turkish Data Protection Board.

Necessary measures are taken to ensure that personal data is protected appropriately during such transfers.

Where required for the purposes stated in the "Purposes of Personal Data Processing" section of this notice, personal data may be transferred abroad in compliance with legal regulations for processing, storage, administration, or other specified uses. All transfers are carried out with due precautions to ensure proper protection of the data.

RETENTION PERIOD OF PERSONAL DATA

Personal data is retained by Friterm for the duration required by applicable legal retention periods, and for as long as necessary to fulfill the activities related to such data and the purposes stated in this notice.
Once the purpose of processing ends and the legal retention period expires, the relevant personal data is deleted, destroyed, or anonymized by Friterm.

SECURITY OF PERSONAL DATA

In accordance with Article 12 of the Law on the Protection of Personal Data (KVKK), Friterm commits to taking the necessary technical and administrative security measures to prevent personal data from being processed or accessed by unauthorized persons.

As part of this commitment:

  • Information security controls are implemented as a core component of personal data protection,
  • Physical and environmental security measures are reinforced at all Friterm premises,
  • Awareness programs are developed for employees and suppliers regarding their roles and responsibilities in personal data protection.

In addition to administrative measures, technical security controls are also prioritized. These include:

  • Authorization and approval mechanisms for all types of access, regularly reviewed and logged,
  • Periodic audits to identify vulnerabilities in the systems,
  • Use of cryptographic methods to prevent unauthorized access during data transfer,
  • Risk analyses to anticipate potential security incidents,
  • Logging and resolution of any data breach or security event.

DATA SUBJECT RIGHTS UNDER KVKK

Pursuant to Law No. 6698, individuals whose personal data is processed have the following rights with respect to Friterm:

  • To learn whether personal data is being processed,
  • If personal data has been processed, to request information regarding such processing,
  • To learn the purpose of data processing and whether the data is being used for its intended purpose,
  • To know the third parties in Türkiye or abroad to whom personal data has been transferred,
  • To request the correction or update of personal data if it is incomplete or inaccurate,
  • To request the deletion or destruction of personal data if the reasons requiring its processing no longer exist,
  • To request that any correction or deletion made be notified to third parties to whom the data has been transferred,
  • To object to a result against the data subject arising solely from automated processing,
  • To request compensation in case of damage due to unlawful processing of personal data.

If data subjects wish to exercise any of the rights listed above, they are required to complete the application form available at https://www.friterm.com/tr-TR/kvkk-aydinlatma-metni/52335, and submit it via one of the following methods:

  • By sending a notification through a notary public to the address provided below,
  • By applying in person with a valid ID at one of the company premises listed below,
  • By applying from their registered email address (KEP) to the company’s KEP address provided below.

Friterm will evaluate requests from data subjects and respond within no later than 30 days. Responses may be delivered either in writing or electronically, depending on the nature of the request.

Contact Information for Data Protection Officer

KEP Address: friterm@hs01.kep.tr

FRİTERM TERMİK CİHAZLAR SANAYİ VE TİCARET A.Ş.
İstanbul Deri Organize Sanayi Bölgesi Dilek Sok. No:10 X-12 Özel Parsel Tuzla, İstanbul
Phone: +90 216 394 12 82