Turkish Radio- Television Corporation

HUMANITARIAN FILM FESTIVAL WEBSITE

CONFIDENTIALITY POLICY AND INFORMATION DISCLOSURE TEXT PURSUANT TO PERSONAL DATA PROTECTION LAW

The purpose of this confidentiality policy and information disclosure text is to explain in detail which personal data of yours Turkish Radio Television Corporation (“TRT”) processes and for which purposes it processes them.

Your privacy is important to us. We protect all your personal data that you have submitted to us in line with the general principles of the data protection law, including especially Personal Data Protection Law No. 6698 (“PDPL”), General Data Protection Regulation (“GDPR”) and general principles of these regulations.

Which Personal Data Do We Collect?

When you register with TRT Services;
Category of Personal Data that are Processed	Category Detail
User Data	These are the personal data provided by you or collected by us for your subscription to TRT and use of/ benefiting from TRT Services. Your name, surname, e-mail address, phone number, and profile pictures may be collected depending on the subscription method. Profile pictures, email addresses, and phone numbers of users who register through the FilmFreeway website can be collected. Official ID number information may also be collected in certain countries for invoicing and tax compliance purposes. The exact types of personal data collected depend on the type of TRT Network Application that you subscribe to and the account creation method. If you use a third-party service to create an account and permit such third party service to share your data with us, we will collect your personal data from this third party service.

Through Your Use of TRT Services; (Information regarding you and your service use, your interactions with us and our advertisements, and your computers or other devices (smart televisions, mobile devices, set-top modems and other media flow devices) that you use to access our service, is collected.)
Category of Personal Data that are Processed		Category Detail
Usage Data	Technical Usage Data	We can use online identifiers such as URL information, cookie data and IP address, unique device ID numbers; information regarding the type of devices you use such as device model, network connection type (for instance, wireless, 3G, LTE, Bluetooth), network access point name and SSID, service provider, network and device performance, browser type, browser version, language, digital right management activating information, operating system, screen resolution, time zone and TRT Network application version; device features (such as device ID) or other unique identifiers of the devices on your wireless connection network which can connect to TRT Network (for instance, smart speakers, smart TVs, connected devices), device and software features (such as type and configuration), connection information, page viewing statistics, application resource (for instance, application URLs), browser and standard web server directory details, and third party map applications and/or your device’s location service to verify your address.
	Data Regarding Actions on Application	Searches made and search history (activity history, including date and time of your requests)
		Comments and suggestions you made.

How Do We Collect Your Personal Data?

We collect your personal data automatically on our website and mobile applications:

• when you use our services and websites,
• when you submit information to us via forms and other methods.

We can also collect such data via third parties (the applications through the FilmFreeway website).

Information Provided by Third Parties

Third Parties	Information Provided
Technical service partners	We work with technical service partners who provide certain data to us, such as matching IP addresses with imprecise location data (for instance, city, country), in order to enable us to provide TRT services, content and features.
Advertisers and other partners	We can collect certain data regarding you, such as cookie ID, mobile device ID, e-mail address and inferences regarding your interests and preferences, from certain advertisers and advertisement partners, to offer advertisements, organize campaigns and send notifications that interest you more, and to measure their effectiveness.
Analytical service provider partners	We can collect data from our analytical service provider partners in order to assist us in getting to know our users visiting and using our websites and applications in more detail, to understand the expectations of our users, to contribute to the development of our content in line with the demands of our users, and to take the correct steps regarding promotion and advertisement campaigns.
FilmFreeway Website	The contact information of participants applying to the Festival, including their full name, email address, phone number, and address, along with the details of the production they wish to submit to the competition, are provided to us.

Our Purposes of Data Processing and Legal Ground of Processing

We process your personal data in accordance with the general principles under Article 4 of the PDPL and Article 5 of the GDPR and in line with the data processing terms under the PDPL and GDPR.

Personal Data that are Processed	Our Purpose of Processing	Legal Ground
User Data, Usage Data	To provide and manage TRT Services (such as websites, applications, social media accounts, etc.), to produce statistical and scientific data and improve our products and services accordingly, to increase satisfaction regarding our products and services, and to customize user experience accordingly	Where it is necessary to process the personal data of parties of a contract, for the execution or performance of the contract Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed Existence of explicit consent
User Data, Usage Data	To understand, detect and resolve problems, and to solve problems regarding the TRT Service.	Where it is necessary to process the personal data of parties of a contract, for the execution or performance of the contract Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed
User Data, Usage Data	To evaluate and develop new features, technologies and improvements regarding TRT Services.	Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed
User Data, Usage Data	To communicate through any means of communication as part of in-house services and developments, and service programs and activities, for marketing, promotion and advertisement purposes.	Existence of explicit consent
User Data, Usage Data	To satisfy legal obligations and requests of law enforcement authorities.	Where data processing is absolutely necessary for compliance with a legal obligation which the data controller is subject to
User Data, Usage Data	To satisfy contractual obligations under the agreements made with third parties (for instance, license agreements) and to take proper actions regarding their reporting.	Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed
User Data, Usage Data	To file legal claims, to satisfy such claims or to defend against such claims.	Where it is mandatory to process data for securing, exercising or protecting a right,
User Data, Usage DataContest, Survey and Lottery/Raffle Data	To make business planning; to archive, analyze, report and make projections based on data in order to prevent data losses.	Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed
User Data, Usage Data, Contest and Survey Data	To receive requests to participate in organizations such as trainings and seminars.	Where it is necessary to process the personal data of parties of a contract, for the execution or performance of the contract Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed Where it is mandatory to process data for securing, exercising or protecting a right

Transfer of Personal Data

We transfer the personal data that we process to relevant suppliers in order to carry out the business processes and to authorized public authorities and institutions in order to satisfy our legal obligations.

Storage and Destruction of Personal Data

TRT keeps personal data in line with and in proportionate to the purpose of their processing. All technical and administrative measures stipulated under the PDPL and GDPR are taken to ensure the security of the personal data that are stored.

When their purpose and/or reason of processing ceases to exist, the personal data are stored until the end of the storage duration prescribed by the applicable legislation, by taking into consideration also our judicial and legal rights. When the purpose and reason of processing of personal data ceases to exist, personal data shall be destroyed once the statute of limitations required to ensure satisfaction of our obligations arising from the laws expires.

Important Matters Regarding Children

TRT shows utmost care regarding the protection of the personal data of children. Taking into consideration the actual difficulty to monitor children on the internet, the internet use by children should be supervised by their parents/guardians, and explicit consent should be obtained from parents/guardians where explicit consent is required for the processing of data.

Rights of the Data Subject (Relevant Person)

Everyone has the following rights pursuant to Article 11 of PDPL:

1. To learn whether or not their personal data have been processed,
2. To request information on the procedure, if their personal data have been processed,
3. To learn the purpose of processing of the personal data and whether or not such data are used in accordance with their purpose,
4. To obtain information about the identity of third parties to whom their personal data have been transferred domestically or abroad,
5. If personal data have been processed incompletely or inaccurately, to request correction of the same, and to request that the third parties to whom personal data are transferred be also informed about the transaction executed in this regard,
6. In the case where, although they have been processed pursuant to the provisions of PDPL and other relevant laws, the reasons requiring them to be processed have ceased to exist; to request that their personal data be deleted or destroyed and to request that the third parties to whom their personal data are transferred be also informed of the procedure carried out in this context,
7. To object to the emergence of an outcome which is to the detriment of the relevant person as a result of the analyzing of the processed data exclusively through automated systems,
8. To request indemnification for damages in the case that damages are sustained as a result of unlawful processing of personal data.

You can submit your requests under Article 11 of the PDPL, “regulating the rights of the data subjects”, to us in accordance with the Communiqué on Principles and Procedures for Applications to the Data Controller. To exercise your rights mentioned above, you may submit your request, including your explanations regarding the right you wish to exercise, in writing, or deliver it in person together with your identification information to the address ‘Türkiye Radyo Televizyon Kurumu- TRT Genel Müdürlüğü Turan Güneş Bulvarı TRT Sitesi 06550 Oran’, or send it via our institution’s email address “kvkk@trt.net.tr”, or through our registered electronic mail address(KEP) “filmfestival@trtworld.com”, or by using other methods specified under the PDPL. Requests will be evaluated and decided upon free of charge as soon as possible and in any case within thirty (30) days at the latest. In the case that the evaluation and decision procedure requires an additional cost, the fee specified in the tariff designated by the Personal Data Protection Board will be taken as a basis.

Your Rights within the scope of GDPR

As an individual, you have certain rights regarding our processing of your personal data, including a right to lodge a complaint with the relevant supervisory authority.

Under GDPR, you have rights, including:

• Your right of access – You have the right to ask us for copies of your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances (where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground). You also have the right to object where we are processing your personal information for direct marketing purposes.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the information you gave us to another organization, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Identity of the Data Controller

Title                            : Türkiye Radyo Televizyon Kurumu (Turkish Radio Television Corporation)

Website                      : www.trt.net.tr

Phone Number          : 444 0 878

E-mail Address         : kvkk@trt.net.tr

Address                      : TRT Sitesi Turan Güneş Bulvarı 06550 Or-An Ankara