CCTV Information Notice

1. Identity of the Data Controller

Under Turkish Law No. 6698 on the Protection of Personal Data (the "KVKK"), the data controller is as follows:

Company name: San Metal A.Ş. ("San Metal", the "Company")
Address: Pelitli Mahallesi, Sanayi Caddesi No: 1, 41400 Gebze, Kocaeli, TÜRKİYE
Telephone: +90 262 751 09 69
Email: info@sanmetal.com.tr

This notice has been prepared to inform data subjects — in particular our employees, visitors and contractor personnel — about the personal data processed through the closed-circuit television (CCTV) systems on our Company premises.

2. Purposes of Processing Personal Data

Video recordings obtained through the closed-circuit television systems on our Company premises are processed for the following purposes:

Ensuring workplace and facility security
Preventing theft, sabotage and unauthorised access
Fulfilling occupational health and safety obligations
Fulfilling legal obligations and audit processes
Supporting emergency and crisis management
Information security and internal audit activities
Providing records as evidence in incident investigations

3. Method of Collection and Legal Grounds

Video recordings are collected automatically on a 24/7 basis through closed-circuit television systems positioned strategically across the Company premises. Appropriate signage and notices are displayed in areas covered by cameras to inform data subjects.

This processing activity is carried out on the basis of the following KVKK provisions:

KVKK Art. 5/2-(ç): Being necessary for the data controller to fulfil its legal obligations.
KVKK Art. 5/2-(e): Being necessary for the establishment, exercise or protection of a right.
KVKK Art. 5/2-(f): Being necessary for the legitimate interests of the data controller, provided it does not harm the data subject's fundamental rights and freedoms.

Camera systems are used only in common areas serving a security purpose; they are not installed in areas where they could infringe privacy (changing rooms, rest areas, toilets, etc.).

4. Transfer of Personal Data

Under Articles 8 and 9 of the KVKK, video recordings may be transferred to the following parties, limited strictly to the purpose of processing:

Authorised public institutions and organisations upon request, in particular courts, public prosecutors' offices and police units
Private security companies providing services on the Company's behalf (with limited access)
Law firms consulted for the conduct of legal proceedings

As a rule, no transfers abroad take place. Where a transfer is unavoidable, it is carried out with the security measures required by the KVKK in place.

5. Retention Period and Destruction of Personal Data

Camera recordings are retained for a maximum of 30 days in line with the purpose of processing. At the end of this period the recordings are automatically deleted or destroyed by being overwritten. Recordings required for an incident investigation or legal proceedings are kept in a separate, secure environment for as long as that process requires.

6. Rights of the Data Subject

Under Article 11 of the KVKK, you have the following rights as a data subject:

To learn whether your personal data is being processed
To request information if it has been processed
To learn the purpose of processing and whether the data is used in accordance with that purpose
To know the third parties, in Türkiye or abroad, to whom the data has been transferred
To request the correction of data processed incompletely or inaccurately
To request deletion, destruction or anonymisation
To object to an adverse outcome arising from analysis carried out by automated systems
To claim compensation for damage suffered as a result of unlawful processing

7. How to Apply

To exercise the rights set out above, you may apply to our Company via the Data Subject Application Form using one of the channels below:

By sending a written application bearing a wet signature to the Company address
By emailing info@sanmetal.com.tr from the email address registered in our system
By any other method provided for in the KVKK legislation

Depending on their nature, your applications will be concluded under Article 13 of the KVKK within 30 days at the latest and communicated to you in writing or electronically. Information may be requested to verify the identity of the applicant.

8. Effective Date and Updates

This CCTV Information Notice takes effect on the date it is published on our website. It may be updated in line with legislative changes or changes to the camera system infrastructure. The current version is always published on this page.