PDPL
General Information and Data Subject Rights
Publication date: 22.10.2026 | Last updated: 22.10.2026
The common provisions in this section apply to all eight privacy notices. Please read them together with the section relevant to you.
1. Identity and contact details of the data controller
Data controller: DENER MAKİNA SANAYİ VE TİCARET ANONİM ŞİRKETİ
Address: Sultansazı OSB, 6. SK No:12, 38560 İncesu / Kayseri
Registered electronic mail (KEP): dener@hs06.kep.tr
Email: info@dener.com
Website: https://www.dener.com
2. General conditions for processing and collection
Your personal data is processed for the purposes specified in the relevant section below, provided that a valid legal condition exists for each processing activity.
Depending on the relevant process, personal data may be obtained by fully or partially automated means or by non-automated means, provided that it forms part of a data filing system. Where data is not obtained directly from the data subject, the required information is provided in accordance with the procedures and time limits prescribed by legislation.
Your personal data may be transferred to the recipient groups specified in the relevant section below, limited to the purpose of processing and provided that the relevant legal conditions are met.
3. Retention period and disposal
Your personal data is retained for the period necessary for the relevant processing purpose and in accordance with the retention periods prescribed by applicable legislation. Where the purpose of processing ceases to exist and there is no other legal ground requiring retention, personal data is erased, destroyed or anonymized in accordance with legislation. Retention and disposal procedures are carried out within the framework of the Company's relevant retention and disposal policies and applicable legal obligations.
4. Rights of the data subject
Under Article 11 of the Personal Data Protection Law (KVKK), you may exercise the following rights by applying to our Company:
- Learn whether your personal data is being processed.
- Request information about the processing of your personal data, if it has been processed.
- Learn the purpose of processing your personal data and whether it is being used in accordance with that purpose.
- Know the third parties to whom your personal data has been transferred domestically or abroad.
- Request rectification of your personal data if it has been processed incompletely or inaccurately.
- Request the erasure or destruction of your personal data under the conditions set out in Article 7 of the Law.
- Request notification of rectification, erasure or destruction to third parties to whom your personal data has been transferred.
- Object to a result arising to your detriment through the analysis of processed data exclusively by automated systems.
- Request compensation for damage suffered as a result of unlawful processing of your personal data.
5. Application method and contact details
You may submit requests regarding your rights to our Company in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller:
Written application: By personal delivery to Sultansazı OSB, 6. SK No:12, 38560 İncesu / Kayseri, through a notary public, or by other written application methods permitted by legislation.
Registered electronic mail (KEP): To dener@hs06.kep.tr, using the secure electronic signature required by the application method.
Email: To info@dener.com, using the email address previously provided to our Company and registered in our system.
Other methods: By other application methods recognized by legislation and meeting the prescribed conditions.
Your application must include the information necessary to verify your identity and evaluate your request, together with the subject of your request. Applications are finalized as soon as possible, depending on the nature of the request, and within thirty days at the latest. If the procedure requires an additional cost, a fee may be charged under the conditions prescribed by legislation.
6. Updates to the privacy notices
These notices may be updated if there are changes to our Company's personal data processing activities, systems used, service providers or relevant legislation. If the purposes of personal data processing change, the required information is provided before the relevant activity begins.
Privacy Notice for Employees
This notice has been prepared to provide information on the scope within which the personal data of individuals employed by our Company is processed. The common provisions in the General Information and Data Subject Rights section form part of this notice.
Categories of personal data processed
| DATA CATEGORY | DATA THAT MAY BE PROCESSED |
|---|---|
| Identity and contact data | Full name, contact details, address and identity information required for the relevant transaction. |
| Human resources and personnel data | Job and position details, education and professional experience, personnel file records, salary and benefits information, and other information required to maintain the employment relationship. |
| Physical premises security data | Security camera footage, facility entry and exit records, and access records. |
| Transaction security and information systems data | User account, IP address, access and session records, system and network logs, connection times, and technical records required for information systems security. |
| Special categories of personal data | Health information or data relating to criminal convictions and security measures, where required by the employment relationship and actually processed. |
Purposes of processing and legal grounds
| DATA CATEGORY | PURPOSE OF PROCESSING | LEGAL GROUND |
|---|---|---|
| Identity and contact data | Maintaining communication with the employee, establishing and managing the employment relationship, and fulfilling statutory obligations. | Depending on the nature of the processing, subparagraphs (c) and (ç) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraph (e) where the establishment, exercise or protection of a right is required; and subparagraph (f) where its conditions are met. |
| Human resources and personnel data | Conducting human resources and personnel procedures, implementing the employment contract, managing salary and benefits processes, and fulfilling occupational health and safety and statutory obligations. | Depending on the nature of the processing, subparagraphs (c), (ç), (e) and (f) of Article 5(2) of the Personal Data Protection Law (KVKK). |
| Physical premises security data | Ensuring the security of Company facilities and individuals, and detecting and investigating unauthorized access and security incidents. | Subparagraph (f) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraph (ç) where a specific legal obligation exists. |
| Transaction security and information systems data | Ensuring information systems and network security, detecting unauthorized access, resolving technical issues, and fulfilling applicable record-keeping obligations. | Subparagraphs (a), (ç) and (f) of Article 5(2) of the Personal Data Protection Law (KVKK), provided that they are applicable to the relevant record. |
| Special categories of personal data | Fulfilling occupational health and safety or relevant statutory obligations only to the extent necessary for the relevant business process and where the statutory conditions are met. | These data are processed only where they are actually processed and one of the conditions under Article 6 of the Personal Data Protection Law (KVKK) is met. Additional information is provided where necessary. |
Method of collecting personal data
Your personal data may be obtained verbally, in writing or electronically through forms and documents submitted upon commencement of employment and throughout the employment relationship, personnel processes, internal written and electronic communications, relevant information systems, access records and security cameras.
Recipients and purposes of transfer
- The Company's human resources department, relevant managers and authorized departments, to the extent necessary to maintain the employment relationship.
- Authorized public institutions and organizations within the scope of statutory obligations or duly submitted requests.
- Financial advisers, independent auditors and legal advisers for accounting, auditing and legal processes, only to the extent necessary.
- IT, software and technical support service providers for the operation, maintenance and security of information systems, only to the extent necessary.
The review of the Company's current processes was based on the information that no personal data is transferred abroad. This will be reassessed if the systems used, service providers or server locations change; if a transfer abroad is envisaged, the conditions under Article 9 of the Personal Data Protection Law (KVKK) will apply.
Privacy Notice for Job Applicants
This notice has been prepared to provide information on the processing of the personal data of candidates applying for employment with our Company during recruitment and candidate assessment processes. The common provisions in the General Information and Data Subject Rights section form part of this notice.
Categories of personal data processed
| DATA CATEGORY | DATA THAT MAY BE PROCESSED |
|---|---|
| Identity and contact data | Full name, telephone number, email address and other contact details necessary to assess the application. |
| Application and professional qualification data | CV, educational background, professional experience, position applied for, and other information submitted by the candidate as part of the application. |
| Special categories of personal data | Special categories of personal data only where genuinely necessary for the relevant position or legal process and where the legal conditions are met. |
Purposes of processing and legal grounds
| DATA CATEGORY | PURPOSE OF PROCESSING | LEGAL GROUND |
|---|---|---|
| Identity and contact data | Communicating with the candidate, receiving the application and conducting the recruitment process. | Subparagraph (c) of Article 5(2) of the Personal Data Protection Law (KVKK) for pre-contractual steps taken following the application; subparagraph (f) where its conditions are met. |
| Application and professional qualification data | Reviewing the application, assessing suitability for the position, conducting interviews and assessment processes, and protecting legal rights where necessary. | Depending on the nature of the processing, subparagraphs (c), (e) and (f) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraph (ç) where a specific legal obligation exists. |
| Special categories of personal data | Conducting assessments only to the extent necessary for the relevant recruitment procedure and where the statutory conditions are met. | Special categories of personal data are not processed unless one of the conditions under Article 6 of the Personal Data Protection Law (KVKK) exists. Additional information is provided where necessary. |
Method of collecting personal data
Your personal data is obtained through application forms, CVs and other application documents, email, telephone, written or electronic communication channels, and information you provide directly to us during the application process. If data is to be obtained from another source, that source and the timing of the relevant privacy information must be assessed separately.
Recipients and purposes of transfer
- The Company's human resources department, relevant recruitment team and managers authorized to assess the application for the relevant position.
- Authorized public institutions and organizations where required by legislation.
- IT or technical support service providers for information systems used in application processes, only to the extent necessary.
- Legal advisers where necessary for legal disputes or the protection of a right.
The review of the Company's current processes was based on the information that no personal data is transferred abroad. The transfer status will be reassessed if recruitment systems or service providers change.
Privacy Notice for Customers
This notice has been prepared to provide information on the personal data of individuals purchasing products or services from our Company, as well as the representatives and employees of customer companies contacted in connection with their transactions. The common provisions in the General Information and Data Subject Rights section form part of this notice.
Categories of personal data processed
| DATA CATEGORY | DATA THAT MAY BE PROCESSED |
|---|---|
| Identity and contact data | Full name, business contact details, telephone number, email address, address and other information required for the relevant transaction concerning the customer or the person communicating on behalf of the customer company. |
| Commercial transaction data | Quotation, order, contract, delivery, invoice and payment information, business correspondence, product or service requests, request and complaint records, and related transaction documents. |
| Transaction security data | Technical records such as user account, IP address, access and system logs generated in connection with systems used to conduct customer transactions, only where the relevant system is used. |
Purposes of processing and legal grounds
| DATA CATEGORY | PURPOSE OF PROCESSING | LEGAL GROUND |
|---|---|---|
| Identity and contact data | Managing customer relationships, quotation and order processes, contracts, delivery, after-sales services, and the assessment of requests and complaints. | Depending on the nature of the processing, subparagraphs (c) and (ç) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraph (e) for the establishment, exercise or protection of a right; and subparagraph (f) where its conditions are met. |
| Commercial transaction data | Conducting sales and delivery transactions, concluding and performing contracts, invoicing, accounting and financial processes, after-sales services, handling legal disputes and fulfilling statutory obligations. | Subparagraphs (c) and (ç) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraphs (e) or (f), depending on the circumstances of the particular case. |
| Transaction security data | Conducting customer transactions securely, detecting unauthorized access and resolving technical issues. | Subparagraphs (a), (ç) and (f) of Article 5(2) of the Personal Data Protection Law (KVKK), provided that they are applicable to the relevant record. |
Method of collecting personal data
Your personal data may be obtained from customers or representatives of customer companies, quotation and order documents, contracts and business correspondence, email, telephone, the website and other online channels. Where the relevant data is obtained through a dealer, supplier or business partner, it is processed only lawfully and within the limits of the relevant processing purpose.
Recipients and purposes of transfer
- The Company's authorized departments and business partners, to the extent necessary to conduct the relevant commercial process.
- Authorized public institutions and organizations within the scope of statutory obligations or duly submitted requests.
- Financial advisers, independent auditors and legal advisers for accounting, auditing and legal processes.
- Courier, logistics and similar service providers for delivery and operational processes, to the extent required for the relevant transaction.
- IT, software and technical support service providers for the operation, maintenance and security of information systems, to the extent required.
The review of the Company's current processes was based on the information that the Company does not transfer personal data abroad. Receiving data from dealers or business partners abroad is not the same operation as the Company transferring its own data abroad. The status of transfers abroad will be reassessed if systems or service providers change.
Privacy Notice for Prospective Customers
This notice has been prepared to provide information on the personal data of individuals who contact our Company to obtain information about products or services, request a quotation or establish a potential business relationship. The common provisions in the General Information and Data Subject Rights section form part of this notice.
Categories of personal data processed
| DATA CATEGORY | DATA THAT MAY BE PROCESSED |
|---|---|
| Identity and contact data | Full name, telephone number, email address, role/title and business affiliation information relating to the company represented by the person making contact, to the extent necessary for the relevant request. |
| Request and business communication data | The product or service of interest, the content of the requested quotation, correspondence, meeting notes and records relating to the contact request. |
Purposes of processing and legal grounds
| DATA CATEGORY | PURPOSE OF PROCESSING | LEGAL GROUND |
|---|---|---|
| Identity and contact data | Responding to information and quotation requests, maintaining communication, conducting a preliminary assessment of the requested product or service, and managing a potential contracting process. | Subparagraph (c) of Article 5(2) of the Personal Data Protection Law (KVKK) for the requested pre-contractual steps; subparagraph (f) where its conditions are met. |
| Request and business communication data | Fulfilling the request, providing information about the product or service, preparing a quotation, following up on the request, and protecting legal rights to the extent necessary. | Depending on the nature of the processing, subparagraphs (c), (e) and (f) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraph (ç) where a specific legal obligation exists. |
Method of collecting personal data
Your personal data may be obtained through website contact forms, email, telephone, written communications and information requests you submit directly to our Company. Where data is obtained through another company, dealer or business partner, the data source and the timing of the privacy information are assessed for the specific process concerned.
Recipients and purposes of transfer
- The Company's authorized sales, technical and relevant business departments, to the extent necessary to handle the request or quotation process.
- Authorized public institutions and organizations within the scope of statutory obligations or duly submitted requests.
- Legal advisers where necessary for the relevant process.
- IT, software and technical support service providers for contact forms or information systems, to the extent necessary.
The review of the Company's current processes was based on the information that the Company does not transfer personal data abroad. This will be reassessed if the systems or service providers used change.
Privacy Notice for Suppliers
This notice has been prepared to provide information on the processing of personal data of our Company's existing or prospective suppliers and the representatives and employees communicating on behalf of supplier companies. The common provisions in the General Information and Data Subject Rights section form part of this notice.
Categories of personal data processed
| DATA CATEGORY | DATA THAT MAY BE PROCESSED |
|---|---|
| Identity and contact data | Full name, business contact details, telephone number, email address, role/title and other information required for the relevant transaction concerning the supplier or the person communicating on behalf of the supplier company. |
| Commercial transaction and financial data | Quotation, order, contract, invoice, payment, delivery, business correspondence, request and complaint records, and related transaction documents. |
Purposes of processing and legal grounds
| DATA CATEGORY | PURPOSE OF PROCESSING | LEGAL GROUND |
|---|---|---|
| Identity and contact data | Managing supplier relationships, obtaining and evaluating quotations, order and contract processes, communication, and the assessment of requests/complaints. | Depending on the nature of the processing, subparagraphs (c) and (ç) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraph (e) for the establishment, exercise or protection of a right; and subparagraph (f) where its conditions are met. |
| Commercial transaction and financial data | Conducting purchasing and procurement processes, concluding and performing contracts, invoicing, accounting and financial processes, handling legal disputes and fulfilling statutory obligations. | Subparagraphs (c) and (ç) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraphs (e) or (f), depending on the circumstances of the particular case. |
Method of collecting personal data
Your personal data may be obtained through quotations, orders, contracts, invoices, delivery documents, email, telephone, written communications and documents involved in the relevant commercial processes.
Recipients and purposes of transfer
- The Company's authorized departments and relevant business partners, to the extent necessary to conduct purchasing and procurement processes.
- Authorized public institutions and organizations within the scope of statutory obligations or duly submitted requests.
- Financial advisers, independent auditors and legal advisers for accounting, auditing and legal processes.
- Courier, logistics and similar service providers required for the relevant delivery and operational processes.
- IT, software and technical support service providers for the operation, maintenance and security of information systems, to the extent necessary.
The review of the Company's current processes was based on the information that the Company does not transfer personal data abroad. This will be reassessed if systems or service providers change.
Privacy Notice for Business Partners
This notice has been prepared to provide information on the processing of personal data of our Company's business partners and the representatives or employees communicating on their behalf. The common provisions in the General Information and Data Subject Rights section form part of this notice.
Categories of personal data processed
| DATA CATEGORY | DATA THAT MAY BE PROCESSED |
|---|---|
| Identity and contact data | Full name, business contact details, telephone number, email address, role/title and other information required for the relevant business activity concerning the business partner or the person communicating on behalf of the business partner company. |
| Business relationship and correspondence data | Contract and agreement records, quotation/order information, business correspondence, request and complaint records, and documents necessary to conduct the collaboration. |
Purposes of processing and legal grounds
| DATA CATEGORY | PURPOSE OF PROCESSING | LEGAL GROUND |
|---|---|---|
| Identity and contact data | Establishing and maintaining the business relationship, communication, coordination of collaboration processes, assessment of requests and management of relevant business processes. | Depending on the nature of the processing, subparagraphs (c) and (ç) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraph (e) for the establishment, exercise or protection of a right; and subparagraph (f) where its conditions are met. |
| Business relationship and correspondence data | Conducting collaboration and commercial processes, concluding and performing contracts, following up on relevant requests, fulfilling statutory obligations and protecting legal rights. | Subparagraphs (c) and (ç) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraphs (e) or (f), depending on the circumstances of the particular case. |
Method of collecting personal data
Your personal data may be obtained through contracts, quotation and order documents, business correspondence, email, telephone, the website and other online communication channels, or from the relevant business partner.
Recipients and purposes of transfer
- The Company's authorized departments and relevant customers, suppliers or business partners, to the extent necessary to conduct the collaboration.
- Authorized public institutions and organizations within the scope of statutory obligations or duly submitted requests.
- Financial advisers, independent auditors and legal advisers for accounting, auditing and legal processes.
- IT, software and technical support service providers for the operation, maintenance and security of information systems, to the extent necessary.
The review of the Company's current processes was based on the information that the Company does not transfer personal data abroad. The receipt of data by the Company from business partners abroad is not the same operation as the Company transferring its own data abroad. The transfer status will be reassessed if systems or service providers change.
Privacy Notice for Visitors
This notice has been prepared to provide information on the personal data of individuals visiting Company facilities that is processed for physical premises security purposes. The common provisions in the General Information and Data Subject Rights section form part of this notice.
Categories of personal data processed
| DATA CATEGORY | DATA THAT MAY BE PROCESSED |
|---|---|
| Visitor and entry/exit data | Visitor records and facility entry and exit information; the time of the visit and other information necessary for the visit, where maintained in the recording system. |
| Security camera footage | Footage obtained through security cameras located at Company facilities. |
Purposes of processing and legal grounds
| DATA CATEGORY | PURPOSE OF PROCESSING | LEGAL GROUND |
|---|---|---|
| Visitor and entry/exit data | Ensuring the security of Company facilities, employees and visitors, recording visits, preventing unauthorized entry and investigating security incidents. | Subparagraph (f) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraph (ç) where a specific statutory obligation exists. |
| Security camera footage | Ensuring physical premises security, detecting and investigating incidents, and providing information to competent authorities where necessary. | Subparagraph (f) of Article 5(2) of the Personal Data Protection Law (KVKK); subparagraph (ç) where a specific statutory obligation exists. |
Method of collecting personal data
Your personal data may be obtained by automated or non-automated means through security cameras, visitor registration systems and entry and exit records at Company facilities.
Recipients and purposes of transfer
- The Company's authorized departments for security and facility management purposes.
- Authorized public institutions and organizations for the investigation of security incidents or within the scope of statutory obligations.
- Service providers for the operation of camera or visitor registration systems, only where such services are used and the transfer is necessary.
The review of the Company's current processes was based on the information that the Company does not transfer personal data abroad. The transfer status will be reassessed if security systems or service providers change.
Privacy Notice for Website Users
This notice has been prepared to provide information on the processing of personal data of individuals who visit our Company's website or use the contact form or similar online channels available through the website. The common provisions in the General Information and Data Subject Rights section form part of this notice.
Categories of personal data processed
| DATA CATEGORY | DATA THAT MAY BE PROCESSED |
|---|---|
| Contact form and request data | Full name, email, telephone number, and the content of messages and requests submitted through the contact form or online channels, only where the relevant fields are completed. |
| Technical access and transaction security data | IP address, access time, technical access records and logs necessary for the operation and security of the website. |
| Cookie data | Information obtained through cookies used on the website. The type, provider, purpose and duration of cookies are determined according to the cookies actually used. |
Purposes of processing and legal grounds
| DATA CATEGORY | PURPOSE OF PROCESSING | LEGAL GROUND |
|---|---|---|
| Contact form and request data | Responding to information and contact requests, forwarding the request to the relevant department and managing the communication process. | Subparagraph (c) of Article 5(2) of the Personal Data Protection Law (KVKK) for the requested pre-contractual steps; subparagraph (f) where its conditions are met. |
| Technical access and transaction security data | Ensuring the operation and security of the website, identifying and resolving technical issues, and preventing unauthorized access. | Subparagraphs (a), (ç) and (f) of Article 5(2) of the Personal Data Protection Law (KVKK), provided that they are applicable to the relevant processing activity. |
| Cookie data | Operation and security of the website for strictly necessary cookies; only predetermined purposes for which the legal conditions have been met for optional cookies. | The applicable processing condition under the Personal Data Protection Law (KVKK) is determined according to the type of cookie and its purpose of use. If non-essential analytics or advertising cookies are used, their legal conditions and the necessary preference/consent mechanisms are assessed separately. |
Method of collecting personal data
Your personal data may be obtained by automated or non-automated means through website visits, contact forms and online channels, cookies and technical access records.
Recipients and purposes of transfer
- IT, software, hosting and technical support service providers for the operation, hosting and security of the website and the resolution of technical issues, to the extent necessary.
- Authorized public institutions and organizations within the scope of statutory obligations or duly submitted requests.
- Legal advisers where necessary for legal disputes or the protection of rights.
The review of the Company's current processes was based on the information that the Company does not transfer personal data abroad. Website hosting services, analytics/advertising cookies, plugins and other third-party services must be checked before publication. If a transfer abroad is identified, the notice and legal processes must be updated accordingly.