As ENKA Sports, Education and Social Aid Foundation Enterprise ENKA Private Preschool, Primary School, Middle School and High School (the “Institution”), we consider the security of your personal data and give high importance to process and keep all kinds of personal data of all people related with the Institution including the ones benefiting from our services as an Institution in accordance with the constitution first and then Personal Data Protection Law #6698 (“KVK Law”).
Within this scope and according to the Personal Data Protection Law #6698 (“KVKK”), we, as ENKA Sports, Education and Social Aid Foundation Enterprise ENKA Private Preschool, Primary School, Middle School and High School, as the responsible of the data, your data within the framework explained below will be provided, recorded, stored, via different channels and legal grounds and shared with/transferred to the third parties as permitted by the law, all necessary administrative and technical precautions are taken to ensure the security of your personal data and to prevent unauthorized access.
1) Which of Your Data We Will Process
Your child/dren’s name, surname, address, phone number, e-mail , audiovisual information, information about marital and family status , nationality, religion, gender, custody and family court decisions, identity card / passport, and the grades that your child receives during his/her education, in addition to your name, surname, address , telephone information, gender, marital status, identity card information, signature, occupation, educational status, place of work, information about the siblings of the student (together “personal information”). We collect other information that may be necessary in order to better offer the services to be provided under the contract signed with you.
In addition, the name and contact information of the parent to be called in an emergency, health information, vaccination information, and blood type will be shared so that a health-related intervention can be made for your child by the school doctor and in any necessary situations by competent health personnel and authorities.
If you apply for Financial Assistance/Scholarship at our school, in addition to the above , the following data will be collected for the evaluation of your aid/scholarship application: the title deed of the house you live in, rent information and documents, current rent information, your vehicle and real estate information, all your property information, salary, monthly income information, information about your other children, your child’s and your health information, your family’s private health insurance information and information about the tax you pay, This information can only be shared with the authorized departments and authorities for this expressed purpose.
Throughout the academic year, photos and/or video of students may be used in non-commercial applications such as on the school’s website, social media platforms (Facebook, Instagram, Linkedin, Twitter, etc.); in electronic and printed bulletins, the school brochures, recordings of school events, and the yearbook for the purpose of promoting the school, presenting the school’s service quality, and to celebrate student achievements to the public. Photos and/or video of students may be used as reposts from news published on the social media accounts of other official institutions.
2) Method and Legal Reasons of Collecting Personal Data
Your personal data can be collected verbally, in writing, or electronically, through the relevant departments and offices of ENKA Sports Education and Social Aid Foundation Enterprise, ENKA Group companies, our websites, internet applications, mobile applications.
Your personal data is obtained through the above channels for the purpose of providing the education and other services we provide by our Institution and our commercial activities within the determined legal framework, and in this context, for our Institution to fulfill its contractual and legal responsibilities completely and accurately.
In this context, your children’s and – as parents – your personal data are processed and transferred with the reasons below because of the reasons stated in the third article of this text:
- It is legally compulsory.
- It is directly related to establishing or execution of a contract.
- It is necessary to meet legal liabilities.
- It is compulsory to establish a right, to execute that right, or to protect it.
- There is a legally legitimate interest of ENKA Schools regarding your personal information that should not infringe on your rights and freedoms.
3) Purposes of Processing Personal Data
Your and our students’ personal data can be collected by ENKA Sports Education and Social Aid Foundation Enterprise in accordance with the regulations automatically or non-automatically for providing education and other services in addition to providing services about different commercial activities or contracts, in order to meet liabilities in the contracts that you and/or we have drawn up; for planning, statistics, customer satisfaction studies and security, and to allow you to benefit from the services that are provided by our Institution or by third parties who have a business relationship with our Institution.
4) To Whom and For What Purpose the Processed Personal Data Can Be Transferred
To ensure the continuity of the services that we provide with the Ministry of National Education, SGK, Ministries, Judicial Authorities and other authorized public and private institutions, in accordance with the procedures and principles contained in the legal regulations to which we are subject, your personal data collected by our institution. It can be transferred to the real or legal persons with whom we have a contractual relationship, our suppliers, the service providers from which we receive services for educational and communication purposes, our legal, financial or other consultants, our school officials and other third parties with your express consent for the purpose of providing services in the nature of the contract.
We share your personal data only with the persons and parties involved in the provision of services under the contract you signed with our Institution.
5) Transfer of Personal Data Abroad
Yours and your student’s personal data and transcripts may be transferred to the institutions and organizations we are accredited abroad, for the admission of students to other educational institutions abroad, to provide our education service in a high quality manner, to prepare for the travels of our students abroad and for the organizations they will attend, and for the other purposes listed above.
The basic principle in data transfer abroad is that there is sufficient legislation on the protection of personal data in the country where the data is transferred. However, if there is no adequate protection in this regard in the countries to which we transfer data, the data controller undertakes in writing that adequate protection will be provided for the personal data and the data will not be used other than for the purpose of transferring the data in the relevant country, and the necessary permission procedure before the Personal Data Protection Board is completed.
6) How long the processed information will be kept?
If a certain period of time is stipulated in the legal regulations to which your personal data is subject, your personal data may be processed for the period in question or for the period required to achieve the purposes specified in this text.
In the event that the legal periods or the purposes for which your personal data are collected expire, these data will be deleted, destroyed or anonymized ex officio by our Institution, unless there is a legally legitimate reason and period.
Your right to apply for the deletion, destruction or anonymization of your personal data is reserved, as given below.
7) Precautions Taken for the Security of Your Personal Data
We take necessary technical and administrative measures to prevent the unlawful processing and access to your personal data, such as encryption, physical security measures, and the establishment of a hierarchy of authority have been defined and necessary security measures such as signing a confidentiality agreement in order for the personnel who have access to this data not to be disclosed to others unlawfully and used outside the processing area.
8) Rights of the Personal Data Owner
As personal data owner, you always have the right:
- To learn whether personal data is processed or not;
- To request information if the information has been processed;
- To learn the purpose of processing personal data and whether they are used in accordance with the purpose;
- To know which third parties to whom personal data is transferred within the country or abroad;
- To request correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred;
- To request the deletion or destruction of personal data in the event that the reasons requiring its processing cease to exist despite the fact that it has been processed in accordance with the provisions of the KVK Law and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred;
- To object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated system; and/or
- To demand the compensation of the damage in case of loss due to unlawful processing of personal data.
If you submit your requests regarding your rights listed above to our Institution through the methods set out below, our Institution will conclude the request free of charge within thirty days at the latest, depending on the nature of the request.
Personal data owners can submit their requests regarding their rights mentioned above by filling out and signing the form Data Subject Personal Data Application Form with the information and documents that will determine their identities and send it to our Institution with the methods specified in the form.
In order for third parties to request an application on behalf of personal data owners, a special power of attorney issued by the data owner on behalf of the person who will apply through a notary public must be present.
Please be advised that the data controller of ENKA SPOR EĞİTİM VE SOSYAL YARDIM VAKFI collects, processes and, in case of need, transfers the personal data of its employees. ENKA, as a responsible employer, displays sensitivity at highest level to the protection of your personal data, and, in compliance with the principles of good governance, attaches great importance and acts with discernment in the processing and storage of the personal data of all its employees in accordance with the provisions of the Law No. 6698 on Protection of Personal Data.
In addition to personal identification information, contact information as well as information on age, gender, state of health, divorce decisions, information about family status, copies of identity cards, medical reports, IP numbers, marital status and demographic information such as country of origin of the employees of our Institution, which are considered as personal data under the relevant laws, also any further information thereon such as their history of employment by our Company, their levels of education, any seminars and any in-works trainings they participated in as well as any information needed for the fulfillment of our legal taxation and social security obligations, are processed and stored by our Company always in compliance with the relevant applicable legal provisions.
ENKA performs the collection and processing of the personal data of its employees only on the condition that it is:
- Mandatorily provided for by the applicable laws to do so;
- Directly related to the conclusion or fulfillment of a contract;
- Mandatory for us to be able to perform our legal obligations;
- Mandatory for the establishment, exercise or protection of any rights of ENKA;
- Based on the existence of a legitimate interest of ENKA, provided that your fundamental rights and freedoms are not violated thereby;
and, moreover, any personal data are only then transferred by ENKA if it is mandatory for the protection of the life or of the bodily integrity of its employees or of any other person.
Any specific information that are identified as private information of confidential and special nature in the Law on Protection of Personal Data are processed and transferred only if clearly provided for by laws to do so, and any information on the state of health or the sexual life just for the purposes of protecting the public health, operations of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of health-care services as well as their financing.
Your personal data are either provided to us by yourself in the documents you presented at the time of your job application such as your curriculum vitae (CV), copy of your identity card, your medical report, criminal record etc., or requested by us from yourself for the completion of your employment process, or collected by us by virtue of correspondence with public agencies and institutions or via third party firms involved in.
Please be advised that your personal data will be processed, stored and safekept by our Company throughout your term of employment if no longer period of time is provided by the applicable laws, without prejudice to the statute of limitation for legal proceedings, i.e. the prescription. Moreover, please be also advised that our Company will not use your personal data, without your explicit consent, for any other purpose as provided herein, and that your personal data will be made available and transferred, in accordance with the applicable legal provisions, only to public agencies and institutions and judicial authorities if so requested by them within the applicable legal periods of time, as well as to our business partners and group companies in compliance with our human resources policies. The necessary safety and security measures required to be taken for preventing any unauthorized access to and any illegal processing of your recorded and safekept personal data are duly identified, and for the purpose of preventing any illegal disclosure and any misuse of your personal data by the personnel having access thereto for processing purpose, all the necessary administrative and technical measures such as limitation of the authorizations of and conclusion of confidentiality agreements with such personnel having access to your personal data, are duly taken. Should any amendments be made in the applicable legislation, also the principles specified hereunder will be amended accordingly. In case of any such amendment, you will be informed properly thereabout.
Please be advised that you are entitled, in accordance with the provisions of the Law No. 6698 on Protection of Personal Data, Article 11, regarding your rights on protection of your personal data, to apply to our Company via e-mail to firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com in order to:
- Get detailed information about your rights on protection of your personal data;
- Learn whether your personal data are processed or not;
- Request information if your personal data are processed;
- Learn the purpose of processing of your personal data and whether they are used for the intended purposes;
- Learn whether your personal data are transferred or not, and if transferred, the third party(ies) to whom they are transferred;
- Request the rectification of any incomplete or inaccurate personal data, if any;
- Request the erasure or destruction of your personal data under such conditions as laid down in the applicable legislation;
- Request the notification of your aforementioned requests for rectification, erasure or destruction of your personal data to such third party(ies) to whom your personal data is transferred to;
- Request compensation for any damage, if any, arising from any unlawful processing of your personal data.
Wishes and Demands of Data Subjects (i.e. persons whose personal data are processed)
In accordance with the provisions of the Law on Protection of Personal Data, Article 10, ENKA informs the Data Subjects about their rights on protection of their personal data and leads them the way how to make usage of such rights. For the purpose of assessment of the rights of Data Subjects and providing them the necessary information, all required company-internal steps are being taken and all administrative and technical regulations are being made by ENKA in compliance with the provisions of the Law on Protection of Personal Data, Article 13.
In this respect, Data Subjects may lodge, in writing, to ENKA their applications about their demands concerning their rights specified in the ENKA Personal Data Protection and Processing Policy, by filling in and signing the so-called Data Subject Personal Data Application Form provided at the address “Data Subject Personal Data Application Form” and following such method as stated therein or designated by the Personal Data Protection Board, and adding thereto their identification information and documents.
Such application may also be made by virtue of a third party for and on behalf of the Data Subject upon presentation of a notarial authentication, i.e. power of attorney by the Data Subject to such third party.
|THE CLARIFICATION TEXT ABOUT THE PROCESS OF PERSONAL DATA||Covid Tracking Form
PARENT & CHILD/REN
|Clarification Text Regarding the Processing of This Personal Data; Applies to the data held by our Schools of the relevant person group(s) specified in the upper right box:|
|WHY DO WE SEND THIS TEXT ?||With this “Notification” letter, ENKA Spor Eğitim ve Sosyal Yardım Vakfı İşletmesi Private Preschool, Primary School, Middle School, and High School, as the data supervisor, and according to the Law on Protection of Personal Data No. 6698 (“KVKK”) and the notification regarding the procedures and principles to be complied with, the Law on Protection of Personal Data which was published in the Official Gazette No. 30356 on 10.03.2018, in line with the following articles: art. 10 “Informing Obligation of Data Supervisor”, art. 11 “Rights of the Relevant Person”, and the Principles and Procedures to be Complied with in Fulfilling the Clarification Obligation within the framework of Articles 4 and 5, please be informed that it hs been arranged to provide information about the purpose for which your personal data will be processed, to whom and for what purpose your processed personal data can be transferred, the method and legal reason for the collection of your personal data, and your other rights listed in Article 11 of the KVKK.|
THE CLARIFICATION TEXT IS ABOUT :
|· Which of your data is collected
· For what purpose your data is processed
· Who your data is shared with
· Legal reason for collecting your data
|· Destruction of your data
· Rights you have under KVKK
|WHICH PERSONAL DATA WILL BE PROCESSED ?||Per your explict consent ;
HES Code of Parent and Child/ren
Other Personal Data
Name-Surname, ID number, contact number, date of birth, gender, e-mail address
In addition, if you give your explicit consent, this personal data will be sent to health institutions in case of a possible Covid-19 case and/or contact, due to the fact that students, staff and parents are at the same address (in İstinye – ENKA Istanbul Schools) and in the same environment. It may be shared with ENKA ENKA Spor Eğitim ve Sosyal Yardım Vakfı İktisadi İşletmesi and/or our preschhol, primary, middle and high school in order to provide information and maintain a healthy working environment within the facility and workplaces.
|WITH WHOM AND FOR WHAT PURPOSES DO WE SHARE YOUR PERSONAL DATA?||Your personal data in case of legal obligations or the conditions of Articles 8/2 and 9/2 of the KVKK; due to the fact that students, parents and staff are at the same address (ENKA Istanbul Schools – İstinye) and in the same environment in a mixed manner; In order to identify contacts in case of a possible Covid-19 case and/or contact, to provide information to health institutions when necessary and to maintain a healthy working environment within the facility and workplaces, conducting fringe benefits and benefits processes for employees, following and executing legal affairs, conducting communication activities doğrultusunda ENKA Spor Eğitim ve Sosyal Yardım Vakfı private Preschool, Primary School, Middle School, High School and/or it is shared with ENKA Spor Eğitim ve Sosyal Yardım Vakfı İktisadi İşletmesi, courts, prosecutors’ offices, enforcement offices and other judicial authorities, authorized public institutions and organizations requesting information, legal consultants, occupational health and safety consultancy firm, and workplace doctor.|
|WHAT IS THE COLLECTION METHOD AND PROCESSING OF YOUR PERSONAL DATA?||
We collect your personal data by filling out the Covid Tracking Form, keep it physically in a locked cabinet and transfer it to ENKA Spor Eğitim ve Sosyal Yardım Foundation and Schools in the cases described above.
|WHAT ARE THE PURPOSE OF PROCESSING YOUR PERSONAL DATA?||Since Spor Eğitim ve Sosyal Yardım Vakfı Private Preschool, Primary School, Secondary School, High School students, parents and staff are at the same address (ENKA Istanbul Schools – İstinye) and in the same environment; In order to identify contacts in case of a possible Covid-19 case and/or contact, to provide information to health institutions when necessary and to maintain a healthy working environment within the facility and workplaces, conducting fringe benefits and benefits processes for employees, following and executing legal affairs, conducting communication activities, personal datas are processed for the purposes of conducting / auditing business activities, informing authorized persons, institutions and organizations, executing emergency management processes, conducting occupational health and safety processes.|
|WHAT IS THE LEGAL PURPOSE OF DATA PROCESSING ?||· Legimate Interest
· Fullfillment of Legal Obligation
· You have given your consent for your personal data mentioned above.
|RIGHTS YOU HAVE UNDER KVKK
|By applying to our school about your personal data;
a) you can learn whether it has been processed,
b) request information if processed,
c) learn the purpose of processing and whether it is used in accordance with its purpose,
ç) to know the third parties to whom it was transferred in the country / abroad,
d) request correction if it is incomplete / incorrectly processed,
e) To request deletion / destruction within the framework of the conditions stipulated in Article 7 of the KVKK,
f) To request notification of the transactions made in accordance with subparagraphs (ç) and (d) above, to the third parties to which it has been transferred,
g) object to the emergence of a result against you due to the analysis exclusively by automated systems,
ğ) demand the compensation of the damage in case you suffer damage due to unlawful processing.
|MEASURES THAT ARE TAKEN TO PROTECT YOUR PERSONAL DATA||Protection of personal data is an important issue for our School. Our school takes the necessary technical and administrative measures to protect personal data from unauthorized access or loss, misuse, disclosure, alteration or destruction. Our school undertakes to keep your personal data confidential, to take all necessary technical and administrative measures and to show due diligence to ensure confidentiality and security.
Although our schools take the necessary information security measures, if personal data is damaged as a result of attacks on the website and the system, or if it is in the hands of third parties, our Schools will immediately notify you and the Personal Data Protection Board.
|KEEPING YOUR PERSONAL DATA CORRECT AND UP-TO-DATE||Those who share their personal data with our Schools know that the accuracy and up-to-date preservation of this information is important both for their rights over their personal data in terms of the Law on the Protection of Personal Data No. 6698 and other relevant legislation, and they will be entirely responsible for providing false information, accepted and declared.
In this context, personal data owners can submit their requests regarding their rights set forth in ENKA’s Personal Data Protection and Processing Policy; They will be able to fill and sign the Data Owner Personal Information Application Form and send it to our Institution with information and documents that will identify them, by filling out the form available at www.enka.k12.tr, using other methods specified in the form or determined by the Personal Data Protection Board.
In order for third parties to request an application on behalf of personal data owners, a special power of attorney issued by the data owner on behalf of the person who will apply through a notary public must be present.
|DELETING, DESTROYING OR MAKING YOUR PERSONAL DATA ANONYMOUS||Your personal data processed for the purposes specified in this Information text; When the purpose that requires processing according to KVKK Article 7/f.1 disappears and the periods determined by the Law, if any, expire; In line with the Personal Data Retention and Destruction Policy of our schools, it will be deleted, destroyed or anonymized by us, ex officio or upon your request, and will continue to be used.|
THE IDENTITY OF THE DATA SUPERVISOR
|ENKA Spor Eğitim ve Sosyal Yardım Vakfı İşletmesi Private Preschool, Primary School, Middle School and High School
Address: Poligon Mah. Sarıyer Cad. 121/1 İstinye 34460 İstanbul