ELC Strategy Confidentiality Text

Personal data is any type of information about a real person whose identity is certain or identifiable. ELC Strategy processes personal data for the purposes in this clarification text, and the legal grounds for which data is processed with regard to these purposes as well as the way of collecting, transferring, processing such data are also defined by this clarification text.  

Processing personal data

ELC Strategy requests people and/or its clients to share only the personal data required for the purposes explained below and agreed by the clients. 

In cases where ELC Strategy must process personal data to provide professional service, the clients must meet all legal requirements if they share personal data about their employees, contractors, clients, and other people with ELC Strategy including but not limited to informing relevant people of the anticipated disclosure of the information and the purpose and scope of the process of information processing handled by ELC Strategy and getting their consent. The clients can guide the relevant people for drawing on this statement.

ELC Strategy processes the relevant personal data for the purposes below:

  1. Administration, management, and development of the activities and services

ELC Strategy processes the personal data for carrying out its activities and professional services as well as performing activities with its business partners such as Kyriba, SWIFT, and TreasuryExpress (including but not limited to those different parties that are required for conducting business), and those stated below:

  • In line with the purpose of providing offered services through relevant business units, performance of consultancy services carried out by ELC Strategy;
  • Management, planning and performance of relations with customers, planning and/or monitoring client satisfaction processes, monitoring client demands and/or complaints;
  • Developing activities and services (identifying client needs and improvements for service delivery and having information about the opportunity of relation with benefit for a client or ELC Strategy);
  • Analyzing and evaluating the power of interaction with the people with whom we do business 
  • Planning and performance of market research activities for sales and marketing and/or promotion of business activities and services;
  • Ensuring that the data is accurate and up to date;
  • Using and updating IT technologies (Includes also providing treasury management, internal financing reporting, information technologies (IT) services, and using storage, hosting, maintenance, support, cloud and/or centrally distributed server system);
  • Carrying out processes and operations conducted for identifying and implementing commercial and business strategies, communication, market research and social responsibility activities, purchase operations (demand, offer, evaluation, order, budgeting, agreement);
  • Informing authorized people and/or organizations about the regulations;
  • Hosting events;
  • Managing website, systems and applications;
  • Monitoring financial and/or accounting and legal procedures.
  1. Providing information on itself and service groups

Unless stated otherwise by the client, ELC Strategy uses client contact information that it considers to be relevant for itself and its services (E.g.: sectoral updates and foresight, other services related to events and event invitations).

ELC Strategy does not market and/or, for any other purpose, disclose the personal data in its systems for third parties except its Business partners (Kyriba, SWIFT, etc.) to market their products and services without the permission of the relevant people.

  1. Safety, quality and risk management activities

ELC Strategy has safety measures in place to protect its own and its clients’ information (including personal data). These include identifying, investigating and resolving safety threats.  Personal data can be processed as part of the safety monitoring, and automatic scanning, etc. can be carried out for identifying malicious e-mails. Services provided to clients for enhancing the service quality are monitored in a way that includes also the processing of the personal data kept in the relevant client file. 

Such data is processed per each legal reason below:

  • being projected by relevant laws,
  • legal obligation
  • legitimate interest,

Provided that network and information safety is ensured, risks are managed and quality of services is checked and fundamental rights and liberties of the relevant person are not damaged, personal data must be processed where explicitly projected by relevant laws or when data processing is required for establishing, using or protecting a right, for protecting the legitimate interests of ELC Strategy.

Support is taken from other institutions and organizations if needed for a project while providing services in line with the agreement with the client.

Cause of action

This personal data is automatically processed in the electronic environment based on the legal ground that “it must be required for the legitimate interest of the data supervisor provided that fundamental rights and liberties of the relevant person are not damaged” as stated in article 5 of the Law 6698 on Personal Data Protection and shared with the express consent of the relevant people.