CCTV Surveillance Systems Clarification Text

Pursuant to the Procedures and Principles of the Law on the Protection of Personal Data No. 6698 (KVKK)

Identity of the Data Controller

This Clarification Text has been prepared by SOSE (hereinafter referred to as “SOSE”) in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) to inform you regarding personal data collected through CCTV surveillance systems used for security purposes.

SOSE processes your personal data in accordance with the following principles:

• In compliance with the law and principles of honesty,
• By storing personal data accurately and, where necessary, up to date,
• For specific, explicit, and legitimate purposes,
• For as long as necessary in accordance with applicable legislation.

Personal Data Processed

Purposes of Processing Personal Data

Personal data collected through CCTV surveillance systems used in SOSE stores or facilities are processed within the scope of Article 4 of the KVKK for the following purposes:

• Ensuring the physical security of premises,
• Protecting the safety of employees, customers, and visitors,
• Preventing security risks such as theft, fraud, and deception,
• Managing occupational health and safety processes,
• Providing necessary evidence for resolving legal disputes that may arise due to security incidents,
• Responding to requests from authorized public institutions.

The placement and recording duration of security cameras are determined solely to the extent required to fulfill the above-mentioned security purposes.

Legal Basis for Processing Personal Data

SOSE processes personal data obtained through CCTV systems on the following legal grounds:

• KVKK Article 5(2)(a): Processing is expressly permitted by law,
• KVKK Article 5(2)(ç): Processing is necessary for the data controller to fulfill a legal obligation,
• KVKK Article 5(2)(e): Processing is necessary for the establishment, exercise, or protection of a right,
• KVKK Article 5(2)(f): Processing is necessary for the legitimate interests of the data controller.

Transfer of Personal Data to Third Parties

SOSE may share CCTV footage with authorized persons or institutions under the following circumstances:

• Responding to lawful requests from authorized public institutions and organizations,
• Fulfilling legal obligations,
• Upon request of judicial or administrative authorities.

Your personal data is not shared with third parties located domestically or abroad. However, should such a transfer be required in the future, you will be duly informed in accordance with applicable legal procedures.

Your Rights Under the Law

Pursuant to Article 11 of the KVKK, you may contact SOSE to exercise the following rights:

• Learn whether your personal data has been processed,
• Request information if your data has been processed,
• Learn the purpose of processing and whether your data is being used in accordance with that purpose,
• Learn the third parties to whom your data has been transferred,
• Request correction of incomplete or incorrect data,
• Request deletion or destruction of your personal data if the reasons for processing no longer exist,
• Object to results arising to your detriment from the exclusive analysis of your personal data via automated systems,
• Request compensation if you suffer damage due to unlawful processing of your personal data.

How to Apply

You may submit your requests regarding your rights by using the “Application Form to the Data Controller” available at www.soseonline.com or through the contact details below:

E-mail: [email protected]
Registered Electronic Mail (KEP): [email protected]

Your application will be concluded free of charge within 30 days at the latest. If your request is denied, a reasoned response will be provided to you in writing or electronically.