This is a convenience translation. The Turkish version is legally binding.
Protection of Personal Data
Legal Notice
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Personal Data Protection Law — Disclosure Statement
As İMZAPOS BİLGİ VE YAZILIM TEKNOLOJİLERİ A.Ş. (the "Company"), we pay the utmost attention to the security of your personal data. With this awareness, as a Company we attach great importance to processing and safeguarding, in accordance with Law No. 6698 on the Protection of Personal Data (the "PDP Law"), all kinds of personal data belonging to all natural persons connected with the Company, including those who benefit from our products and services. Aware of this responsibility, we process your personal data in our capacity as "Data Controller" as defined in the PDP Law, as explained below and within the limits set by the legislation.
Collection, Processing and Purposes of Processing of Personal Data
Your personal data may vary depending on the services provided by our Company. Your data may be collected verbally, in writing or electronically, by automated or non-automated methods, through Group Companies and their units, the website, social media, mobile applications and similar means. Your personal data may be processed for as long as you benefit from the products and services offered by our Company and its Group Companies.
In addition, your personal data may be processed when you use our call centers or our website in order to use the services of the Company or our Group Companies, when you visit our Company offices or our website, and when you attend training sessions, seminars or events organized by our Company.
The personal data collected will be processed for the reasons set out below, within the limits of the personal-data processing conditions and purposes specified in Articles 5 and 6 of the PDP Law:
Carrying out, by our business units, the work necessary to enable you to benefit from the products and services offered by our Company and our Group Companies,
Customizing and recommending these to you according to your preferences, usage habits and needs, by our Company and our Group Companies,
Ensuring the legal and commercial security of our Company, our Group Companies and the persons in a business relationship with our Company,
Administrative operations for communication carried out by our Company, ensuring the physical security and supervision of the Company's locations,
Conducting our Company's and Group Companies' customer-evaluation/complaint-management processes, reputation-research processes, legal-compliance processes, audits and similar processes,
Determining and implementing our Company's commercial and business strategies,
Conducting our Company's human-resources policies.
To Whom and For What Purpose Processed Personal Data May Be Transferred
The personal data collected may be transferred, for the reasons set out in Article 1 of this text, to Group Companies, our business partners, our suppliers, Company officials, our shareholders, and legally authorized public institutions and private persons, within the framework of the personal-data processing conditions and purposes specified in Articles 8 and 9 of the PDP Law.
Method and Legal Grounds of Personal Data Collection
Your personal data is obtained through any verbal, written or electronic medium, in line with the reasons stated above, so that the products and services offered by our Company can be provided within the defined legal framework and so that our Company can fully and accurately fulfill its contractual and statutory obligations. Personal data collected on this legal basis may also be processed and transferred for the reasons stated in items (1) and (2) of this text, within the scope of the personal-data processing conditions and purposes specified in Articles 5 and 6 of the PDP Law.
Rights of the Personal Data Owner Listed in Article 11 of the PDP Law
As personal-data owners, if you submit your requests regarding your rights to our Company by the methods set out below in this Information Text, our Company will conclude the request free of charge within thirty days at the latest, depending on the nature of the request. However, if the Personal Data Protection Board stipulates a fee, the fee in the tariff determined by our Company will be charged. In this context, personal-data owners have the right to:
Learn whether personal data is being processed,
Request information if personal data has been processed,
Learn the purpose of processing personal data and whether it is used in accordance with its purpose,
Know the third parties to whom personal data is transferred domestically or abroad,
Request the correction of personal data if it has been processed incompletely or incorrectly, and request that the transaction carried out in this context be notified to the third parties to whom the personal data has been transferred,
Request the deletion or destruction of personal data if the reasons requiring its processing cease to exist, even though it has been processed in accordance with the PDP Law and other relevant legal provisions, and request that the transaction carried out in this context be notified to the third parties to whom the personal data has been transferred,
Object to a result arising against the person themselves through the analysis of the processed data exclusively by automated systems,
Request the compensation of the damage in the event of loss due to unlawful processing of personal data.
Cases Not Requiring Consent
Pursuant to Article 5, paragraph 2 of Law No. 6698 on the Protection of Personal Data, in the cases set out below the Company has the right to process personal data without obtaining the explicit consent of the person:
Being expressly provided for by laws; being necessary to process the personal data of the parties to a contract, provided that it is directly related to the establishment or performance of the contract,
Being mandatory for the Company, as data controller, to fulfill its legal obligation,
Being made public by the data owner themselves,
Being mandatory for the establishment, exercise or protection of a right,
Being mandatory for the legitimate interests of the Company, as data controller, provided that it does not harm the fundamental rights and freedoms of the data owner.
The Personal Data Owner's Right to Apply
Pursuant to Article 13, paragraph 1 of the PDP Law, to exercise the rights stated above, your request — containing the information necessary to establish your identity and your explanations regarding the right you wish to exercise among those listed in Article 11 of the PDP Law — should be submitted by filling in the form at www.imzapos.com; a signed copy of the form should be delivered by post or in person to Ağaoğlu My Newwork Barbaros, Ihlamur Bv No: 3, Floor: 15, 34746 Ataşehir/İstanbul, or the form should be scanned and sent by e-mail to
[email protected].