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Information Security Policy


PRIVACY POLICY


As Manas Enerji Yönetimi A.Ş., we are highly committed to the protection of personal data. Ensuring the security of the personal information of every individual who shares their data with us is our top priority. In this regard, we implement all necessary administrative and technical security measures meticulously within our organization. Therefore, we are pleased to assure you that your personal data is safe with Manas Enerji Yönetimi A.Ş. We will respect all your rights regarding personal data protected by the Constitution of the Republic of Turkey and relevant legal regulations. With this awareness, we are committed to adhering to the universal principles of “transparency” and “accountability” in the field of personal data security, and we are pleased to share our corporate Privacy Policy with you. You can always contact us for your comments, suggestions, or complaints. Rest assured that we will carefully evaluate all your requests regarding the protection of your personal data. We will continue to protect your data with the same attention and care as we do in all the services we offer. Sincerely,
MANAS ENERJİ A.Ş.



PURPOSE OF OUR PRIVACY POLICY


As Manas Enerji Yönetimi A.Ş., personal data obtained due to the nature of our operations have always been kept confidential and have not been shared with third parties for purposes other than those intended. The protection of personal data has been one of our company’s most important principles. Even before the enactment of legal regulations, our company adopted the confidentiality of personal information as a primary principle and acted accordingly. Furthermore, as Manas Enerji Yönetimi A.Ş., we are determined to comply with all the obligations introduced by the Personal Data Protection Law and are committed to fully fulfilling these responsibilities.



PRIVACY PRINCIPLE


Data belonging to employees or other individuals within Manas Enerji Yönetimi A.Ş. is subject to confidentiality. No individual, unless in compliance with the contract or legal regulations, can use, copy, reproduce, transmit, or assess such data for purposes other than work-related purposes. Our company ensures compliance with the privacy standards and conditions. The commitments made in this policy apply to the information shared on this website. However, the privacy principles, ethical standards, and terms of use of websites that are linked to or visited from this site are the responsibility of those websites, and our company is not liable for any material or moral damages that may occur on those sites.



BASIC RULES ON PROCESSING PERSONAL DATA



  • Compliance with the Law and Good Faith Principles: Manas Enerji Yönetimi A.Ş. carefully reviews the legal sources of the data it obtains or receives from other institutions and ensures that these data are obtained in accordance with legal requirements and the principles of good faith.

  • Accuracy and Timeliness When Necessary: Manas Enerji Yönetimi A.Ş. takes necessary steps to ensure that all data it holds is accurate and does not contain erroneous information. If there is a change in personal information, this data will be updated if it is communicated to us.

  • Processing for Specific, Explicit, and Legitimate Purposes: Manas Enerji Yönetimi A.Ş. processes personal data only for specific and legitimate purposes with the user’s consent obtained during the provision of the service. Data will not be processed, used, or shared for purposes beyond these.

  • Processing in Accordance with the Purpose, Limited and Proportionate: Manas Enerji Yönetimi A.Ş. uses personal data only in a manner that is relevant to and necessary for the processing purpose. Unnecessary data processing is avoided.

  • Retention for Necessary Duration: Manas Enerji Yönetimi A.Ş. retains data only for as long as required by relevant legislation, contracts, and obligations under commercial and tax law. When these periods expire, the data will be deleted or anonymized in accordance with the Data Deletion Directive.



COLLECTED INFORMATION AND METHODS OF COLLECTION


Unless otherwise stated on our website, only non-identifiable data (analytical data) or data we are required to collect by legal requirements are collected. Therefore, you can visit our website without sharing any personal data outside the specified scope. However, there may be situations where you voluntarily share personally identifiable data (e.g., your name, phone number, email address) when you contact us through the contact form on our official website (www.manas.com.tr), submit your resume, or contact us in other ways. In these cases, your personal data will be processed and used by us.



PURPOSES OF DATA USAGE


The collected data is processed by Manas Enerji for the following purposes, and retained as long as the relevant legal periods allow:



  • Planning and execution of corporate sustainability activities.

  • Ensuring the legal and commercial security of Manas Enerji and individuals in business relationships with Manas Enerji.

  • Carrying out activities to determine and implement Manas Enerji’s strategies.



RETENTION PERIOD OF PERSONAL DATA


As Manas Enerji Yönetimi A.Ş., we take all necessary measures to securely store your personal data and retain them only for the periods specified by legal obligations. This process is carried out in accordance with the Personal Data Protection Law No. 6698 (KVKK), the Turkish Code of Obligations (TBK), the Tax Procedure Law (VUK), and other relevant legislation. Personal data are retained for as long as required by processing purposes and legal provisions, and are then deleted or anonymized when no longer needed.



  1. Legal Requirements:


The retention period of your personal data is primarily determined by legal requirements. Various laws and regulations require the retention of certain personal data for specific periods. Manas Enerji Yönetimi acts in accordance with the following laws and regulations, among others:



  • Personal Data Protection Law No. 6698 (KVKK): Personal data processed under this law are retained in accordance with the principles and conditions outlined in Articles 4, 5, and 6. Retention periods for personal data are in compliance with Article 7 of the KVKK, which mandates the deletion, destruction, or anonymization of data once the processing purpose has ended.

  • Turkish Code of Obligations: Relevant data are retained during the duration of contractual obligations and for the statute of limitations following the conclusion of the contract.

  • Tax Procedure Law: Financial records, invoices, and other documents obtained under tax legislation are retained for at least 5 years as required by Article 253 of the VUK.

  • Labor Law and Social Security Legislation: Employment and social security data are retained in accordance with labor law and the Social Insurance and General Health Insurance Law, and may continue to be retained after the end of employment for legal compliance.



  1. Retention for Business Purposes: Personal data are retained as long as required for business processes. When a business relationship, service, or product supply ends, or when the processing purpose no longer exists, the relevant data are either deleted, destroyed, or anonymized.



COOKIES AND OTHER TECHNOLOGIES


We use session and persistent cookies on our website depending on their duration of use. Session cookies are used to ensure session continuity and are automatically deleted when you close your browser. Persistent cookies are not deleted when you close your browser and are retained until their expiration date. After this period, cookies are automatically deleted.



SECURITY OF TRANSACTIONS POLICY


At Manas Enerji Yönetimi A.Ş., the security of transactions is of paramount importance in all the services we offer. Transaction security is crucial to ensuring the security of both our customers' and employees' information. We have taken all necessary technical and administrative measures to minimize security vulnerabilities and protect data from unauthorized access. Our company guarantees the protection of data by using secure protocols during data transfer, processing, and storage.



INFORMATION SECURITY MANAGEMENT SYSTEM (ISMS) POLICY


The aim of our ISMS Policy is to:



  1. Protect the information assets of MANAS ENERJİ YÖNETİMİ SANAYİ VE TİCARET ANONİM ŞİRKETİ against all kinds of internal or external threats, whether intentional or unintentional.

  2. Maintain the continuity of the three fundamental elements of the Information Security Management System in all activities carried out.

  3. Address not only electronically stored data but also written, printed, spoken, and other forms of information.

  4. Raise awareness by providing Information Security Management training to all personnel.



DATA SUBJECT RIGHTS UNDER KVKK (Article 11)



  • The right to learn whether personal data is processed.

  • The right to request information if personal data has been processed.

  • The right to learn the purpose of processing personal data and whether they are used in accordance with their purpose.

  • The right to know the third parties to whom personal data are transferred, both domestically and abroad.