Anadolu Efes Sports Club Personal Data Protection and Processing Policy

1. PURPOSE AND SCOPE

Anadolu Efes Sports Club ("Anadolu Efes" or "the Club") strives to comply with all applicable legislation regarding the processing and protection of personal data.

The Personal Data Protection and Processing Policy ("Policy") outlines the principles adopted by Anadolu Efes in conducting personal data processing activities.

The Policy aims to ensure transparency in the Club's operations and aligns with Law No. 6698 on the Protection of Personal Data ("KVKK"). It defines the key principles for compliance with KVKK and explains the Club's data processing practices.

This Policy applies to natural persons whose personal data is processed by Anadolu Efes, whether through automated or non-automated means as part of a data recording system. However, the protection of employee personal data is separately regulated in the "Anadolu Efes Sports Club Employee Personal Data Protection and Processing Policy."

2. POLICY PRINCIPLES

2.1 General Principles

The Policy is publicly available on the Anadolu Efes Sports Club website (www.anadoluefessk.org).
Any updates to the Policy due to legal changes will be published in an easily accessible manner.
In case of conflict between applicable laws and this Policy, legal provisions shall prevail.

2.2 Covered Individual Groups

The Policy applies to the following data subject groups whose personal data is processed by Anadolu Efes:

Job Applicants
Individuals evaluated for employment but not yet under contract with Anadolu Efes.
Business Partners’ Representatives & Employees
Real persons associated with organizations in a commercial relationship with Anadolu Efes (e.g., authorized representatives, shareholders, employees).
Visitors of Anadolu Efes
Natural persons visiting Anadolu Efes facilities or official websites.
Other Natural Persons
Any individuals not covered under the Employee Personal Data Protection Policy.

3. INFORMING DATA SUBJECTS

Anadolu Efes ensures compliance with Article 10 of the KVKK by informing data subjects during data collection. The disclosure texts provided include:

Club’s official title
Purpose of processing personal data
Recipients and purposes of data transfers (domestic/abroad)
Method and legal basis of data collection
Rights of data subjects, including:

Right to learn whether personal data is processed
Right to request information if processed
Right to know the purpose and whether data is used accordingly
Right to identify third parties (domestic/international) to whom data is transferred
Right to request correction of incomplete/incorrect data and notification to third parties
Right to request deletion/destruction of data under legal conditions and notification to third parties
Right to object to automated profiling leading to unfavorable outcomes
Right to claim compensation for damages due to unlawful processing

4. PROCESSING REQUESTS FROM DATA SUBJECTS

Data subjects may submit written requests regarding their personal data by:

Providing identity verification documents and
Completing the application form available at:
www.anadoluefessk.org/pub/aesk-veri-basvuru-formu.pdf

As the data controller, Anadolu Efes processes such requests in compliance with Article 13 of the KVKK, ensuring resolution within 30 days based on the nature of the request.

Security Verification:

Anadolu Efes may request additional information to confirm the applicant’s identity.
The Club may also ask clarifying questions to properly address the request.

Grounds for Rejection:
Requests may be denied (with justification) if they:

Risk violating others’ rights/freedoms,
Require disproportionate effort, or
Concern publicly available information.

4.1. Rights of Data Subjects (Under KVKK Article 11)

Data subjects may request:

Confirmation of whether their personal data is processed.
Details on processing activities (if applicable).
Purpose of processing and whether data is used accordingly.
Third parties (domestic/international) to whom data is transferred.
Correction of incomplete/incorrect data (with notification to third parties).
Deletion, destruction, or anonymization (if legal grounds for processing no longer exist).
Objection to automated profiling resulting in adverse effects.
Compensation for damages due to unlawful processing.

4.2. Exemptions Under KVKK Article 28

Data subject rights do not apply in cases involving:

National defense, security, public order, or economic security.
Artistic, historical, literary, or scientific purposes (if no privacy violation occurs).
Official statistics (anonymized data for research/planning).
Judicial/investigative proceedings by authorized public bodies.

Additional exemptions (except for compensation claims):

Processing necessary for crime prevention/investigation.
Processing publicly disclosed data by the data subject.
Processing by regulatory bodies for audits/discipline.
Processing for protecting state economic/financial interests.

5. ENSURING CONFIDENTIALITY OF PERSONAL DATA

Anadolu Efes implements technical and administrative measures to prevent unlawful access, disclosure, or breaches:

(1) Administrative Measures

Employee training on data protection laws.
Contractual clauses ensuring third-party compliance in data transfers.
Regular audits of data processing activities.
Internal policies aligning with KVKK requirements.

(2) Technical Measures

Up-to-date security technologies (e.g., encryption, access controls).
Expert consultations for technical safeguards.
Restricted access (only authorized personnel).
Secure software/systems (firewalls, intrusion detection).

(3) Audit Activities

Periodic reviews of security measures.
Reporting findings to relevant departments.
Continuous improvement of data protection practices.

(4) Breach Response

Immediate notification to the KVK Board and affected data subjects in case of a breach.

6. DATA PROTECTION RESPONSIBLE UNIT

The "Anadolu Efes KVK Committee" oversees compliance, including:

Drafting and enforcing data protection policies.
Monitoring compliance with KVKK.
Risk assessment and mitigation strategies.
Training staff and stakeholders.
Handling data subject requests.
Liaising with regulatory authorities.

7. PURPOSES OF PROCESSING & DATA CATEGORIES

7.1. Personal Data Categories Processed

Anadolu Efes processes (automatically/non-automatically) the following data groups:

Identity/contact details (e.g., name, email, phone).
Professional information (e.g., job title, employer).
Financial data (e.g., payment details for transactions).
Visitor records (e.g., CCTV footage, website logs).
Special categories (if legally justified, e.g., health data for player management).

Purpose: Data is processed for contract fulfillment, legal obligations, Club operations, and legitimate interests (e.g., marketing with consent).

7.2. Purposes of Personal Data Processing

Personal data is processed by Anadolu Efes in compliance with Articles 5 and 6 of the KVKK and for the following purposes (may vary per data subject):

Planning and Execution of Product/Service Marketing Processes
Promotional campaigns, fan engagement, and sponsorship activities.
Planning and Execution of Business Activities
Team management, player contracts, and operational workflows.
Market Research for Sales & Marketing of Products/Services
Fan surveys, ticket sales optimization, and merchandise development.

7.3. Categories of Recipients

Anadolu Efes may share personal data (in line with KVKK Articles 8 & 9) with:

Companies within the Anadolu Group
For cross-functional business operations (e.g., joint promotions).
Suppliers & Vendors
Service providers (e.g., ticketing platforms, merchandise partners).
Subsidiaries & Affiliates
Shared resources for basketball operations (e.g., youth academies).
Business Partners
Sponsors, broadcasters, and event organizers.
Authorized Public Institutions & Private Entities
Legal/regulatory compliance (e.g., tax authorities, sports federations).
Other Third Parties (if KVKK conditions are met)
Data processors (e.g., cloud storage providers under confidentiality agreements).

Legal Basis: Transfers occur only with explicit consent or under legal obligations/legitimate interests (e.g., contract fulfillment).

LEGAL NOTICE and PRIVACY

The owner of this website is ANADOLU EFES SPORTS CLUB (“Anadolu Efes”), and users who visit our site shall be deemed to have accepted the following conditions, without being limited to those stated herein.

All information, designs, trademarks, logos, tables, comments and recommendations, as well as audio, visual, and written information and documents (“Content”) contained on the website www.anadoluefessk.com.tr, and all links provided herein, are presented to the user for general informational purposes.

Anadolu Efes reserves the right and authority to modify, correct, partially or completely remove the information contained on this site at any time and in any manner, without prior notice, and to carry out such actions solely on its own discretion.

Some statements used on this site may have been prepared as forward-looking statements and may therefore involve certain risks and uncertainties. Due to various reasons, actual results and developments may differ materially from those stated or implied in such expressions.

Users may only use the Content for informational purposes. The Content available herein may not be copied, distributed, rented, loaned, reproduced, sublicensed, modified, transmitted, published, stored for future use, or used in any way for commercial purposes without the prior written consent of Anadolu Efes. Access to this site is free and anonymous.

Any alteration of any information or document contained on this site in any manner shall result in legal and criminal liability.

Anadolu Efes shall not, under any circumstances, accept responsibility for any damages and/or losses arising or to arise from reliance on the information published on this site, from actions taken based on such information, or from inability to access the site. The materials published on this site do not constitute any commitment of any kind to any person and/or organization. Anadolu Efes does not guarantee the suitability of the Content on this site for any specific purpose. Any and all decisions made in light of the information on this site are the sole responsibility of the visitor.

Links from this site to third-party websites may take the user outside of the Anadolu Efes web network. Anadolu Efes assumes no responsibility for the content, accuracy, or functionality of such linked sites. These links are provided in good faith. Anadolu Efes cannot be held responsible for any subsequent changes that may occur in the content of linked sites. Anadolu Efes and any third parties involved in the creation, production, or transmission of this site cannot be held liable for any direct, indirect, incidental, consequential damages, losses, or harm, or for any legal or criminal liability that may arise from access to or use of this site.

Anadolu Efes shall not, under any circumstances, bear responsibility due to non-updating of the information on the site, delays in updates, possible errors or omissions, or any changes. Furthermore, Anadolu Efes shall not be held liable for any damage that may occur to computer hardware or any infection by malicious software to computer systems due to access to, use of, or downloading of any audio, visual, or written information and documents from this site.

Any comments, suggestions, ideas, graphics, and other information communicated via this site may be used by Anadolu Efes for commercial or non-commercial purposes without any payment to the sender or any other person. Anadolu Efes is not obligated to keep such comments, suggestions, ideas, graphics, and information confidential.

The copyright of the Content contained on this site belongs to Anadolu Efes. It may not be used without the written permission of Anadolu Efes.

Anadolu Efes declares that, with due regard to matters concerning the confidentiality of private life, it shall exercise the necessary care and diligence in protecting personal data pursuant to Law No. 6698 on the Protection of Personal Data (“KVKK”) and general privacy practices.

In the event of disputes arising from the use of the site and the Content herein, the Turkish version of the Legal Notice shall prevail, and in such case, Anadolu Efes reserves all legal rights. Prior to accessing the site, it shall be assumed that the above terms have been read and accepted, and in the event of any dispute, claim, or demand, it is acknowledged, declared, and undertaken by all persons and organizations accessing the site that the terms set forth herein and all computer records belonging to Anadolu Efes shall constitute exclusive evidence and may be submitted by Anadolu Efes to the competent Courts and Enforcement Offices.