379 PERSONAL DATA PROTECTION to the business’s own privacy practices, and the business may designate a number of employees, or even other vendors, to process and respond to the message. As well, some businesses will be able to choose WhatsApp’s parent company, Facebook, to securely store messages and respond to customers. In this case, data transfer is performed. Evaluation of the Change in Privacy Policy within the Framework of Personal Data Protection Legislation While processing personal data, it is obligatory for data controllers to comply with the principles of lawfulness and fairness, being accurate and kept up to date where necessary, being processed for specified, explicit and legitimate purposes, being relevant, limited and proportionate to the purposes for which they are processed, being stored for the period laid down by relevant legislation, or the period required for the purpose for which the personal data are processed. Apart from this, in accordance with Article 5 and Article 8 of the PDPL, it is only possible to process and transfer the general personal data domestically, with the existence of the legal grounds that are regulated numerus clausus, or - if they are not applicable in the concrete case - with the existence of the explicit consent of the data subject. Accordingly, personal data can be processed and transferred domestically without seeking the explicit consent of the data subject, only in cases where one of the following conditions are met: i. It is expressly provided for under the law; ii. It is necessary for the protection of life or physical integrity of the person himself/herself or of any other person, who is unable to explain his/her consent due to the physical disability or whose consent is not deemed legally valid; iii. Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract; iv. It is necessary for compliance with a legal obligation to which the data controller is subject;
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