PROTECTION AND PROCESSING OF PERSONAL DATA POLICY

1. OBJECTIVE

KURDMAX MEDIA GROUP (Kurdmax TV, Kurdmax Show, Kurdmax Music and Kurdmax Pepule referred as Kurdmax Media Group); Our audience, our readers, members, customers, visitors and employees, the Republic of Iraq of the personal data of natural persons, including employees nominated Constitution and the parties of the country on human rights and international conventions to 72658 numbered Law on the Protection of Personal Data ( "CMC Iraq") in accordance with the relevant legislation, especially Our priority is to ensure that the persons whose data are processed and whose data are processed are used effectively.
Therefore, but not limited to; We carry out the procedures for processing, storing, and transmitting data regarding all personal data we have obtained during our activities, according to our Kurdmax Media Group Personal Data Protection and Processing Policy ("Policy").
Protection of personal data and the observance of the fundamental rights and freedoms of natural persons whose personal data are processed are the basic principles of our policy regarding the processing of personal data. For this reason, we continue all our activities in which personal data are processed by protecting the privacy of private life, the privacy of communication, freedom of thought and belief, and the right to use effective remedies.
In order to protect personal data, we take all administrative and technical protection measures required by the quality of the relevant data in accordance with the legislation and current technology.
This Policy describes the methods we follow to process, store, transfer and delete or anonymize personal data shared during our commercial or social responsibility and similar activities within the framework of the principles mentioned in CMC.


2. SCOPE

All personal data processed by the Kurdmax Media Group, including our audience, readers, members, customers, business contacts, business partners, employees, candidates, consumers, potential customers, third parties, are covered by this Policy. Our policy is applied in the activities for processing all personal data managed by Show Group and has been handled and prepared by considering CMC Iraq and other relevant legislation on personal data and international standards in this field.


3. DEFINITIONS AND ABBREVIATIONS 



 In this section, special terms and phrases, concepts, abbreviations and so on. is briefly explained.

3.1 Kurdmax Media Group or Company: (Kurdmax TV, Kurdmax Show, Kurdmax Music and Kurdmax Pepule)

• 3.2 Open Consent: Consent to a specific subject, based on information and free will, without any hesitation, limited only to that transaction.

• 3.3 Anonymization: It is to make personal data unrelated to an identified or identifiable natural person by any means, even by matching with other data.

• 3.4 Employee: Company Personnel.

• 3.5 Holding: Edicoo Group 

• 3.6 Personal Data Owner (Relevant Person): The real person whose personal data is processed.

• 3.7 Personal Data: It is any information related to a real person whose identity can be determined or determined.

• 3.8 Special Qualified Personal Data: Persons' race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, disguise and outfit, association, foundation or union membership, health, sexual life, criminal conviction, and security measures. related data and biometric and genetic data.

• 3.9 Processing of Personal Data: Acquisition, recording, storage, storage, modification, reorganization, disclosure, transfer, acquisition, acquisition of personal data in a fully or partially automated manner or non-automated provided that it is part of any data recording system. is any operation performed on data such as its classification or inhibition of its use.

• 3.10 Data Processor: A real or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller.

• 3.11 Data Officer: Real or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

• 3.12 CMC Board: It is the Personal Data Protection Board. 

• 3.13 CMC Authority: It is the Personal Data Protection Authority.

• 3.14 CMC: It is the Law on the Protection of Personal Data No. 72658, published in the Official paper dated March 7, 2004 and numbered 29677.

• 3.15 Policy: Kurdmax Media Group Policy of Protection and Processing of Personal Data.


4. LEGAL OBLIGATIONS


In accordance with CMC Iraq Law, the legal obligations within the scope of protection and processing of personal data as data controller are listed below:

4.1. Our obligation to lighting While collecting personal data as data controller;

• For what purpose your personal data will be processed,
• Information about our identity, identity of our representative, if any,
• To whom and for what purpose your personal data can be transferred,
• Our method of collecting data and its legal reason, o We have an obligation to enlighten the Person concerned regarding the rights arising from the Law. 
• As "Company", we make sure that this policy, which is open to the public, is clear, understandable and easily accessible.

4.2. Our obligation to ensure data security As the data controller, we take the administrative and technical measures stipulated in the legislation in order to ensure the security of the personal data available to us. Data security obligations
and measures are detailed in sections 9 and 10 of this Policy.


5. CLASSIFICATION OF PERSONAL DATA



5.1. Personal data

Personal data; is any information related to a real person who can be identified or identified.
Protection of personal data is only related to natural persons, and information belonging to legal persons, which does not contain information about real persons, is excluded from personal data protection. For this reason, this Policy does not apply to the data of legal persons.

5.2. Special personal data

People's race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, disguise and outfit, association, foundation or union membership, health, sexual life, criminal conviction and data related to security measures and biometric and genetic data are personal data of a special nature.

5.3. Personal data categories

We collect the following data within the scope of our visual and written communication / broadcasting services and employment purposes:
1. Identity information
2. Contact information
3. Data of family members
4. Personal data
5. Children's data
6. Other data


Data Category
ID
information


Explanation


  It is the data related to the identification of the person.

From where to collect
  Identity information; We collect from Employee, Employee candidates, customers, program guests and exhibitors, people using the website and mobile applications, visitors and business contacts.

Content
  Name-surname, T.C. These are data such as identification number, photograph, photocopy.

The purpose of collecting data
 For the purposes of invoice issuance, product delivery or service and advertising and marketing purposes; In the context of the applications made to the programs and competitions published by the Show Group and     the evaluation of the said applications and where the content of the related program or competition requires; Among the people who use these platforms to increase the number of visitors and improve the service   provided within the scope of the website and mobile application; in order to ensure security at the entrance and exit of the building; We collect personal data from business contacts as part of the performance of the   service provided, such as product delivery, and in accordance with our legal obligations.
 We are obliged to record employee identification information in accordance with labor and social security legislation.
 To evaluate the identity information of our candidates, job applications; We collect the data of people with whom we have a supplier, subcontractor and similar business relationship in order to fulfill our commercial       requirements and obligations, and if any, our contractual obligations.



Data Category
Contact
information

Explanation


It is personal data that enables communication with the person. 



From where to collect


  Contact information; We collect from employees, employee candidates, customers, program guests and program participants, people using the website and        mobile applications, visitors and business contacts.


Content


Home and work address are data such as mobile phone number, home phone number, postal address, e-mail address and IP address.

The purpose of collecting data

Providing communication from our customers, business contacts, program guests and participants within the scope of our services and commercial activities in the media sector; In order to ensure security at the entrance and exit of the building from the visitors; We collect personal data from people using the website and mobile applications within the scope of our legal obligations. We are obliged to record the contact information of our employees in accordance with the labor and social security legislation. To communicate the results of job applications, contact information of our candidates; We collect the data of suppliers, subcontractors and people with whom we have a similar business relationship in order to fulfill our commercial requirements and liabilities, and if any, our contractual obligations. To evaluate the identity information of our employee candidates for job applications; We collect the data of people with whom we have a supplier, subcontractor and similar business relationship in order to fulfill our commercial requirements and obligations, and if any, our contractual obligations. 




Data Category
Data for Family Members


Explanation


   It is the personal data of the family members of the person concerned.


From where to collect

 

We collect data from family members from employees, program guests and program participants.


Content


 Family members name-surname, T.C. Identification number, photograph, marital status information, home and work address, mobile phone number, fax number, home phone number, postal and e-mail     address.


The purpose of

collecting data


  We are obliged to record the family members' information of our employees in accordance with the labor and social security legislation.


Data Category


 Personal Data


Explanation

 

It is the necessary information for maintaining the business relationship without any problems.


From where to collect

 

Personal data; we collect from our employees and candidates.


ContentIdentity information, contact information, financial information, gender information, social insurance number, blood group, document showing family status, residence, IP records, bank account information, residence document, testimonial / service / employment document, criminal record from previous workplace Information such as CV, military status information, disability information, tax exemption for disabled people, insurance data, housing information and rental information, foreign language information, education status, professional information, previous address and signature.


The purpose of collecting data


Data of employees and candidates; We collect the service contract we make with them, in accordance with the legislation we are subject to and our legitimate interests.



Data Category
Children's data


Explanation


It is personal data of people under the age of 18.


From where to collect


As part of participating in programs and competitions published on Show TV, it is collected from individuals who are under 18 years of age.


Content


Data such as name-surname, phone number, age and school information.
In addition, the talents of the child participant, the agency to which he / she is registered, the data about whether he had previous broadcasting experience and the video recording are also collected within the scope of the evaluation of the suitability of the participant. 



The purpose of collecting data


It meets in order to evaluate the applications made to the programs and competitions and to contact the participant.


Data Category

 Other Data


Explanation


  Other data collected within the scope of our commercial activities.


From where to collect


  This data; We collect from employees, employee candidates, customers, program guests and listeners, program participants, people using the website and mobile applications, visitors and business contacts.


Content


  Identity information, contact information, financial information and CCTV (closed circuit camera recording images) recordings, voice recordings, facial recognition systems records, magnetic card and turnstile records,    identity and contact information and financial information belonging to the staff of our business connections, financial information, within the scope of the event and organization organized The data collected are     data collected in the scope of application to programs and competitions, such as data collected in complaints and company communication processes.


The purpose of collecting data


  In order to ensure building security, to control the entrance and exit of employees, to evaluate the appropriateness of applications to programs and competitions, to organize the flow of programs and competitions, to   organize events and organizations, to carry out marketing and promotional activities, to fulfill our commercial requirements and obligations and if any, our obligations in contracts. we collect the data of the people we   are with.



5.3.1 Legal reason for the collection of personal data

Within the scope of our personal data, our services in the media sector and the employment we provide; we operate due to legal reasons arising from our obligations in the relevant legislation, contractual relationships and legitimate interests.


 6. PROCESSING OF PERSONAL DATA


6.1. Our principles for processing personal data We process personal data in accordance with the principles below.

6.1.1. Processing in accordance with law and honesty rules We process personal data in accordance with integrity rules, transparent and within the framework of our lighting obligation.

6.1.2. Keeping personal data accurate and up-to-date when necessary We take the necessary measures in our data processing procedures to ensure that the processed data is accurate and up to date. We also allow the Personal Data Owner to contact us to update their data and correct any errors in their processed data, if any.

6.1.3. Processing for specific, clear and legitimate purposes As "the Company", we process personal data within the legitimate objectives determined to continue our activities within the scope of the legislation and the ordinary course of business life.

6.1.4. Personal data should be linked, limited and measured for the purpose for which they are processed
We process personal data in an open, precise, connected, limited and measured manner.
We avoid the processing of personal data that is not relevant or needed to be processed. For this reason, we do not process private personal data unless we have a legal requirement, or we obtain explicit consent when we need to process it.

6.1.5. Retention of personal data as stipulated by legal regulations and during our commercial legitimate interests
Many regulations in the legislation require that personal data be stored for a certain period of time. For this reason, we keep the personal data we process for the period specified in the relevant legislation or required for the purposes of processing the personal data.
In the event that the retention period stipulated in the legislation expires or the purpose of processing disappears, we delete, destroy or anonymize the personal data. Our principles and procedures regarding retention periods of this Policy 9.1. It is detailed in.

6.2. Our purposes for processing personal data
As "Company", we process personal data for purposes similar to those listed below, but not limited to:
• Conducting our publishing activities,
• Providing support services to customers under the contract and within the framework of service standards,
• Shaping and updating the services to be given to our customers by determining their preferences and needs within this scope,
• Fulfilling our legal obligations as required or required by legal regulations,
• Implementing the instructions and procedures within the "Company",
• Improvement management and planning,
• Training of employees,
• Supervision of employees,
Organizing events and organizations,
Ensuring security,
• Creation and management of visitor records,
• Management of the website and mobile applications,
• Measuring reader and audience satisfaction,
• Market researches and statistical studies,
Surveys, contests, promotions and sponsorships,
• Evaluation of job applications,
• Managing program productions,
• Production,
• Ensuring liaison with the people who have a business relationship with the "Company",
• Marketing,
• Compliance management,
• Vendor / supplier management,
• Advertising,
Legal reporting,
• Planning and executing risk management and quality improvement studies,
Billing it.

6.3. Processing of special quality personal data
Special personal data are processed by us by taking administrative and technical measures stipulated in the laws and stipulated by the CMC Iraq Board, and if there is a clear consent or when required by the legislation.
For the purpose of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, special personal data related to health and sexual life, without seeking explicit consent by persons or authorized institutions and organizations under the obligation to keep secrets processed.

6.4. Processing of personal data collected through cookies on our website
We use cookies to improve the functioning and usage of our website and we try to make the time you spend on our website more efficient and enjoyable. In addition, we make use of some cookies to remember the choices you make on our website, thereby providing you with an improved and personalized experience.
We can collect your personal data, process, transfer and store the data we collect through cookies on our website.
For detailed information about the cookies we use on our website, you can review our "Cookie Policy".

6.5. Processing of personal data collected on our website
Via contact forms on our website;
Name, surname and
• With electronic mail information
Within the scope of application to the competitions and programs published within Show TV, it also belongs to the applicants through the application forms on our website;
Name, surname,
• Place of birth,
• Date of birth,
• Contact information and
• Regarding the concept of the program in which the application is made, information about a number of characteristics of the applicant is collected.

6.6. Processing of personal data for human resources and employment purposes
CV, diploma, etc. that you shared with us during the applications you will make as an employee candidate. We process, store and transfer your personal data contained in other documents for the purpose of evaluating a job application. Processing, transfer and storage of personal data that you share as an employee candidate is within the scope of this Policy.
Personal data of the Employee; Apart from this Policy, Edicoo Group, processed and stored within the framework of the Human Resources Regulation.
Personal data of employee candidates:
• To evaluate the suitability of the candidate for the open position,
• To confirm the accuracy of the information and documents provided by the candidate employee or to conduct research about the candidate employee,
• To communicate with the candidate who is working in connection with his application,
• To meet legal obligations or demands of authorized institutions or organizations; and
• It can be collected for the purpose of developing our Human Resources Policy and with the following tools and methods:
• Application form provided in written or electronic form,
• Employee candidates can be sent to the "Kurdmax Media Group" with electronic mail, mail, etc. CVs sent by methods,
Employment or consultancy companies,
• Universities,
• Interviews,
• Controls and investigations carried out to confirm the accuracy of the information transmitted by the candidate for employment,
• Recruitment tests.

6.7. Processing of your personal data for security purposes
We collect, process and store your personal data to ensure the security of our building and electronic systems. In this context;
Camera images,
• License plate information, name-surname in building entrances and exits,
• Visitor entry-exit (name-surname, ID Iraq) information is collected. Camera image recordings are deleted within 45 days.

6.8. Processing of personal data within the scope of suggestions, requests and complaints management
In order to improve our services, personal data are collected and processed through forms on our website within the scope of suggestions, requests and complaints.
• Name and surname,
Electronic mail,
• The content of the message is collected.
If you participate as a spectator or guest within the scope of the programs made by "Show Group" or made by third parties,
Depending on the format and content of the program, we may process your personal data mentioned below to evaluate your suitability:
• Name and surname,
• Your birthplace,
• Your date of birth,
• Photo
• Your contact information,
• Your marital status,
• Height and weight
where you originally came from,
the city where you live,
• Your profession and where you work
To the schools he graduated from,
• Where is your spouse's hometown,
• Spouse's profession,
• Your parents' profession,
How you met your spouse,
Whether you have a child or not,
• Your child's name and age,
• How many square meters your house is,
• Your room number in the house,
• Decoration of the house,
• Whether you care about customs and customs,
Whether there is a dowry to be exhibited,
• Objective ideas about yourself,
• Whether you have participated in a television program before,
• Your favorite books and movies,
• Your foreign language knowledge,
• whether you go abroad and which countries you see,
• Your social media accounts,
Whether you have a block,
• Whether you will participate in the program alone,
• Whether you have a travel disability
People who have not completed the age of 18 with your information such as:
that his age,
that the school
Capabilities that,
• Whether he was previously in a television program,
• Information about whether an agency it is registered with.
In case of participation as a guest or audience, your personal data is communicated and processed within our legitimate interests and stored for the periods stipulated by the legislation. Personal data of persons under the age of 18 are processed as part of the consent of the parent or legal representative. Collected data of people participating in trial shots and not evaluated as competitors are stored for 6 (six) months.

6.9. Processing of personal data through open consent
Due to the legislation, personal data cannot be processed without the explicit consent of the person concerned. Explicit consent is defined in the law as "consent on a particular subject, based on information and disclosed with free will."

6.10. Exceptions where explicit consent is not sought in the processing of personal data
In exceptional cases listed below, we may process personal data without express consent:

1. Clearly prescribed by law
Personal data of the relevant Person may be processed in accordance with the law, if clearly prescribed by law.

2. Failure to obtain explicit consent of the person concerned due to actual impossibility
Personal data may be processed without explicit consent if the person who is unable to disclose his consent due to de facto impossibility or whose consent is not legally valid is required to protect his or someone else's life or body integrity.

3. Is directly related to the establishment or performance of the contract
It is possible to process personal data if it is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract.

4. It is compulsory for the "Kurdmax Media Group" to fulfill its legal obligation
As the "Kurdmax Media Group", the data controller will be able to process the data required to fulfill its legal obligation, even without the express consent of the Relevant Person.

5. The personal data owner is publicized by himself
Personal data that has been made public by the Contact Person, in other words, disclosed to the public in any way, can be processed without explicit consent.

6. Data processing is mandatory for the establishment, use or protection of a right
In the event that data processing is mandatory for the establishment, use or protection of a right, personal data can be processed without explicit consent.

7. Data processing is mandatory for the legitimate interests of the “Kurdmax Media Group”
In the event that data processing is mandatory for the legitimate interests of the "Show Group", provided that it does not harm the fundamental rights and freedoms of the Relevant Person, personal data may be processed without seeking explicit consent. For example; the employer has a legitimate interest in controlling the entry and exit times of the Employee. For these reasons, the employer
No explicit consent of the Employee is required in this context, provided that the practices performed by the company are moderate.
Exceptional situations in which special personal data can be processed without the express consent of the Relevant Person are set out in Article 7.3 of this Policy.



Data Category


ID information


Explanation


  It is the data related to the identification of the person.


From where to collect


  Identity information; We collect from Employee, Employee candidates, customers, program guests and exhibitors, people using the website and mobile applications, visitors and business contacts.


Content

 

Name-surname, ID Iraq These are data such as identification number, photograph, photocopy.


The purpose of collecting data


  For the purposes of invoice issuance, product delivery or service and advertising and marketing purposes; In the context of the applications made to the programs and competitions published by the Show Group and the    evaluation of the said applications and when the content of the related program or competition requires; Among the people who use these platforms to increase the number of visitors and improve the service provided      within the scope of the website and mobile application; in order to ensure security at the entrance and exit of the building; We collect personal data from business contacts as part of the performance of the service             provided, such as product delivery, and in accordance with our legal obligations.

  We are obliged to record employee identity information in accordance with labor and social security legislation.

  To evaluate the identity information of our employee candidates for job applications; We collect the data of people with whom we have a supplier, subcontractor and similar business relationship in order to fulfill our       commercial requirements and obligations, and if any, our contractual obligations.




Data Category
  Contact information


Explanation

 

                   It is personal data that enables communication with the person.


From where to collect


                 Contact information; We collect from employees, employee candidates, customers, program guests and program participants, people using the website and mobile applications, visitors and business contacts.


Content

 

                  Home and work address are data such as mobile phone number, home phone number, postal address, e-mail address and IP address.


The purpose of collecting data

 

   Providing communication from our customers, business contacts, program guests and participants within the scope of our services and commercial activities in the media sector; In order to ensure security at the            entrance and exit of the building from the visitors; We collect personal data from people using the website and mobile applications within the scope of our legal obligations.

   We are obliged to record the contact information of our employees in accordance with the labor and social security legislation.

   To communicate the results of job applications, contact information of our candidates; We collect the data of suppliers, subcontractors and people with whom we have a similar business relationship in order to fulfill       our commercial requirements and liabilities, and if any, our contractual obligations.

   To evaluate the identity information of our employee candidates for job applications; We collect the data of people with whom we have a supplier, subcontractor and similar business relationship in order to fulfill our      commercial requirements and obligations, and if any, our contractual obligations.




Data Category
Data for Family Members


Explanation


  It is the personal data of the family members of the person concerned.


From where to collect


  We collect data from family members from employees, program guests and program participants.


Content


  Family members name-surname, Iraq Identification number, photograph, marital status information, home and work address, mobile phone number, fax number, home phone number, postal and e-mail address.


The purpose of collecting data


  We are obliged to record the family members' information of our employees in accordance with the labor and social security legislation.





Data Category

Personal Data


Explanation

 

It is the necessary information for maintaining the business relationship without any problems.


From where to collect

  Personal data; we collect from our employees and candidates. 



Content


  Identity information, contact information, financial information, gender information, social insurance number, blood group, document showing family status, residence, IP records, bank account information, residence    document, testimonial / service / employment document, criminal record from previous workplace Information such as CV, military status information, disability information, tax exemption for disabled people,     insurance data, housing information and rental information, foreign language information, education status, professional information, previous address and signature.


The purpose of collecting data


  Data of employees and candidates; We collect the service contract we make with them, in accordance with the legislation we are subject to and our legitimate interests.




Data Category
Children's data


Explanation


  It is personal data of people under the age of 18.


From where to collect


  As part of participating in programs and competitions published on Show TV, it is collected from individuals who are under 18 years of age.


Content


  Data such as name-surname, phone number, age and school information.Data such as name-surname, phone number, age and school information.

  In addition, the talents of the child participant, the agency to which he / she is registered, the data about whether he had previous broadcasting experience and the video recording are also collected within the    scope of the evaluation of the suitability of the participant.


The purpose of collecting data

  It meets in order to evaluate the applications made to the programs and competitions and to contact the participant.



Data of children Data Category
Other Data


Explanation


  Other data collected within the scope of our commercial activities.


From where to collect

  This data; We collect from employees, employee candidates, customers, program guests and listeners, program participants, people using the website and mobile applications, visitors and business contacts.


Content


  Identity information, contact information, financial information and CCTV (closed circuit camera recording images) recordings, voice recordings, facial recognition systems records, magnetic card and turnstile           records, identity and contact information and financial information belonging to the staff of our business connections, financial information, within the scope of the event and organization organized The data     collected are data collected in the scope of application to programs and competitions, such as data collected in complaints and company communication processes.


The purpose of collecting data


  In order to ensure building safety, to control the entrance and exit of employees, to evaluate the appropriateness of applications to programs and competitions, to organize the flow of programs and competitions, to    organize events and organizations, to carry out marketing and promotional activities, to fulfill our commercial requirements and obligations and if any, our obligations in contracts. we collect the data of the people     we are with.




7. TRANSFER OF PERSONAL DATA  


•7.1. Transfer of personal data to the country As the “Kurdmax Media Group”, we act in accordance with the decisions and arrangements made by the CMC Board for the transfer of personal data.
Without prejudice to the exceptions in the legislation, personal data and special data are not transferred to other real persons or legal entities without the express consent of the Person concerned.
In exceptional cases stipulated by CMC and other legislation, the data may be transferred to the administrative or judicial institution or institution authorized in accordance with the limits and in accordance with the limits, without the express consent of the Relevant Person.
In addition, with exceptional cases stipulated by the legislation;

7.11. of that Policy. In the cases described in the article,
o 7.3 of the Policy on special personal data. In the cases listed in the article,
o With the taking of the measures stipulated by the CMC Board and the relevant legislation, special personal data regarding the health and sexual life of the Person concerned can only be protected from public health, preventive medicine, medical diagnosis, treatment and care services, health care and financing planning and For the purpose of management, it can be transferred to the persons under obligation to keep secrets or to authorized institutions and organizations without explicit consent.

7.2. Transfer of personal data abroad
As a rule, personal data is not transferred abroad without the express consent of the Contact Person. However, 7.3 of this Policy. and 7.11. In cases where one of the exceptions in the articles exists, third parties abroad can only:
o Being in countries with sufficient protection announced by the CMC Board;
if it take place in countries where there is adequate protection in Iraq and said the presence of adequate protection and permission to commit in writing the CMC Iraq Board responsible for data in foreign countries;
Personal data can be transferred abroad without explicit consent.

7.3. Institutions and organizations to which personal data are transferred The personal data are not limited to; that our suppliers, o Our business partners and business contacts, o The Group “Company”, o Legally authorized public institutions and organizations, o Private legal persons, can be transferred according to the principles and rules described above



Contact Category
Explanation
Transfer Purpose


Business partner


Within the scope of the activities of "Show Group", it is possible to organize events, receive services, etc. means the parties with which it has established a business partnership, such as production companies.


In order to realize the planned activity within the scope of business partnership

SuppliersIt refers to the parties that provide services to the “Show Group” in return for the contract in accordance with the Company's needs and instructions.In order to fulfill the service to be provided from the supplier
AuthorizedRefers to the "Kurdmax Media Group" officials.For the purpose of planning and executing the Company's activities
Legally Authorized Public Institutions and OrganizationsIt refers to public institutions and organizations authorized to receive information and documents from "Show Group" within the scope of the relevant legal regulations.For the purposes stipulated by the said legal regulation
Legally Authorized Private Legal PersonsIt refers to private law persons authorized to receive information and documents from the “Show Group” within the scope of the relevant legal regulations.For the purposes stipulated by the said legal regulation
Group "Kurdmax Media Group" means the companies within the Holding.In order to realize the planned activity within the scope of existing relations with the Group Companies


•7.4. Measures we take regarding the transfer of personal data in accordance with law

7.4.1. Technical measures Not limited to those listed to protect personal data;
Carries out in-house technical organization to process and store personal data in accordance with the legislation, 
Creates the technical infrastructure to ensure the security of the databases where your personal data will be stored,
It monitors the processes of the technical infrastructure created and conducts inspections,
 Determines the procedures for reporting the technical measures we take and audit processes,
It periodically updates and renews the technical measures,
Risky situations are re-examined and necessary technological solutions are produced,
 We use virus protection systems,
firewalls and similar software or hardware security products and install security systems suitable for technological developments, We employ experts who are experts in technical issues.

7.4.2. Administrative measures
Not limited to those listed to protect your personal data; 
Creating policies and procedures for accessing personal data, including the company and its affiliates within the "Show Group".
Inform and educate our employees on the lawful protection and processing of personal data,
We record the measures to be taken in cases of unlawful processing of personal data by our employees in the contracts we make with our employees and / or the Policies we create, We oversee the personal data processing activities of the data processors or partners of the data processors we work with. 


8. STORAGE OF PERSONAL DATA


•8.1. Storing personal data for the period required by the relevant legislation or for the purpose for which they are processed
We retain personal data for the period required by the purpose of processing personal data, provided that the retention periods stipulated in the legislation are reserved.
In cases where we process personal data for more than one purpose, the data is deleted, destroyed or anonymized and stored in the event that there is no obstacle in the legislation for the data to be eliminated or upon the request of the Contact Person. Legislation and CMC Board decisions are complied with in terms of annihilation, deletion or anonymization.

•8.2. Measures we take regarding the storage of personal data

8.2.1. Technical measures 
Creates technical infrastructures and related control mechanisms for erasing, destroying and anonymizing personal data,
Takes necessary measures for the safe storage of personal data,
Employs Employees with technical expertise,
Creates business continuity and emergency plans against possible risks and develops systems for their implementation,
We establish security systems in accordance with the technological developments regarding the storage areas of personal data.

8.2.2. Administrative measures
 Creates awareness by informing the Employee about the technical and administrative risks related to the storage of personal data,
In the case of cooperation with third parties for the storage of personal data, contracts with companies to which personal data are transferred; We include provisions for taking necessary security measures in order to protect the personal data transferred and to keep it safe and secure.


9. SECURITY OF PERSONAL DATA


9.1. Our obligations regarding the security of personal data Personal data;
• To prevent illegal processing,
• To prevent illegal access,
• We take administrative and technical measures according to technological possibilities and implementation costs to ensure that it is stored in accordance with the law. 

9.2. Measures we take to prevent illegal processing of personal data
• Performing and having the necessary inspections done within our company,
• Training and informing our employees about the processing of personal data in accordance with the law,
• The activities carried out by our company are evaluated in detail in all business units, and as a result of this evaluation, we process personal data in relation to the commercial activities carried out by the relevant units,
• In cases of cooperation with third parties for the processing of personal data, in contracts with companies that process personal data; personal
Includes provisions regarding the necessary security measures of the data processors,
• In the event that personal data is unlawfully disclosed or there is a data leak, we inform the CMC Board about the situation and take the necessary measures and take the necessary measures.

•9.2.1. Technical and administrative measures taken to prevent illegal access to personal data To prevent illegal access of personal data; 
 Employs Employees with technical expertise,
It periodically updates and renews the technical measures,
Creates access authorization procedures within our company,
Determines the procedures for reporting the technical measures we take and audit processes,
Creates the data recording systems used in our company in accordance with the legislation and periodically audits them,
Creates emergency aid plans against possible risks and develops systems for their implementation,
Training and informing our employees on access to personal data and authorization,
In agreements with companies that provide access to personal data in cases of cooperation with third parties for activities such as processing and storing personal data; Includes provisions for taking necessary security measures of people who access personal data,
We are establishing security systems within the technological advances to prevent illegal access to personal data.

9.2.2. Measures we take in case of unlawful disclosure of personal data
We take administrative and technical measures to prevent illegal disclosure of personal data and update them in accordance with our relevant procedures. If we find that the personal data have been disclosed as unauthorized, we create systems and infrastructures to report this situation to the Person and CMC Board.
In case of an illegal disclosure despite all administrative and technical measures taken, this situation may be announced on the website of the CMC Board or by any other method, if deemed necessary by the CMC Board.


10. RIGHTS OF THE PERSONAL DATA OWNER (RELATED PERSON)


As part of our lighting obligation, we inform the Personal Data Owner and establish systems and infrastructures for this information. We make the technical and administrative arrangements necessary for the Personal Data Owner to exercise his rights regarding your personal data.
Personal Data Owner on personal data;
• To learn whether personal data is processed,
• Requesting information about this if personal data has been processed,
• Learning the purpose of processing personal data and whether it is used in accordance with its purpose,
• To know the third parties to whom personal data are transferred domestically or abroad,
• Requesting correction of personal data if it is incomplete or incorrectly processed, • Request the deletion or destruction of personal data in case the reasons requiring the processing of personal data disappear,
• Requesting the above-mentioned correction, deletion or destruction to third parties to whom personal data are transferred,
• To object to the emergence of a negative result by analyzing the processed data exclusively through automated systems,
• If the personal data is damaged due to the illegal processing of the data, it has the right to demand the removal of the damage.

10.1. Exercise of rights regarding personal data If a separate method is determined by the CMC Board, the person concerned requests for personal data is determined by this method or Kurdmax Application Form by Bahrka Road Edicoo Buliding Erbil/ Iraq, with a signed and wet signature or with a secure electronic signature to our registered e-mail address Kurdmaxtv@kurdmaxmedia.com In the application containing the explanations about the right to be made and requested by the concerned person to exercise the above-mentioned rights; If the requested issue is clear and understandable, the requested issue is related to the applicant's person or if someone else is acting on behalf of someone else, it should be specially authorized and documented in this regard, also the application should include the identity and address information, and documents proving the identity of the application should be added. These requests will be made individually and the requests made by unauthorized third parties regarding personal data will not be evaluated.

10.2. Evaluation of the application

10.2.1. Application response time Requests related to personal data are finalized as soon as possible and in any case not later than 30 (thirty) days free of charge or if the conditions in the tariff to be published by the CMC Board are met. Additional information and documents may be requested during the application or while the application is being evaluated.

10.2.2. Our right to reject the application Applications related to personal data;
• Processing personal data for purposes such as research, planning and statistics by anonymizing with official statistics,
• Processing of personal data for art, history, literature or scientific purposes or within the scope of freedom of expression, provided that it does not violate privacy or personal rights of private life or constitute a crime,
•Processing of personal data publicized by Personal Data Owner,
•The application is not based on a justified reason,
• The application contains a request contrary to the relevant legislation,
• Failure to comply with the application procedure is rejected by justification in their case.

10.3. Procedure for the evaluation of the application
In order for the response period specified in article 11.2.1 of this Policy to begin, you must send the requests made in written and wet signature or via CMC Iraq Board of Electronic Signature or other methods determined by the CMC Board with the authentication of information and documents. 
If the request is accepted, the relevant transaction is applied and notified in writing or electronically. In case of rejection of the request, the applicant is notified in writing or electronically by explaining its justification. 

10.4. Right to complain to the Personal Data Protection Board
In cases where the application is rejected, the answer we give is insufficient or there is no response in time; The applicant has the right to complain to the CMC Board within 30 (thirty) days from the date of receipt and in any case 60 (sixty) days from the date of application. 

11. PUBLICATION AND STORAGE OF POLICY 


This Policy is stored in two different media: printed paper and electronic media.

12. VALIDITY


This Policy is deemed to have come into force after it has been published on the Company website.