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PDPA Document

We attach importance to the protection of your personal data. In accordance with the Law on the Protection of Personal Data (‘PDPA’), the processing and processing of data obtained in connection with your use of the “Company Website”, including but not limited to, collection, storage, transfer. We would like to inform you about the purpose of the processing.

Data Custodian domain ………………………………………………….. A.Ş.
(Company). As the data controller, the company is responsible for determining the
purposes and means of processing personal data, establishing and managing the
data recording system.
We attach importance to the protection of your personal data. In accordance with the
Law on the Protection of Personal Data (‘PDPA’), the processing and processing of
data obtained in connection with your use of the “Company Website”, including but
not limited to, collection, storage, transfer. We would like to inform you about the
purpose of the processing.

Processing and Transfer of Personal Data

The COMPANY requests some personal data from the users during the membership
phase of its customers using the Company Website or while using the Company
Website. Personal data is any information that makes a person specific or
identifiable. Such information may be, for example, your name, address, e-mail
address or telephone number. Information collected through the use of cookies that
do not directly allow you to be identified, such as how you use the Company
Website, can also be considered personal data if they are based on an identity
assigned to the user and are therefore collected, stored and evaluated individually.
Non-personal data is information that can only be aggregated, qualified as big data,
summarized, collected, evaluated and not associated with a real person by
anonymizing it.

Your personal data is collected by our company due to the nature of the business by
filling in the information in the demo request form, contact form, e-bulletin form,
support system, call centre and membership form to the Relevant Person. Our
Company records and uses the IP address of its members in order to identify
system-related problems and quickly resolve any problems or disputes that may
arise regarding the service provided. IP addresses can also be used to identify users
in a general way and to gather comprehensive demographic information.

Our company may use the requested information for direct marketing purposes by
itself or by the people it cooperates with, even outside the purposes and scope
determined by the Membership Agreement. Personal information can also be used
to contact the user when necessary. Information requested by our company or
information provided by the user or information about transactions made on the
Company Website; It can also be used in various statistical evaluations, database
creation and market research, without disclosing the identity of our members, outside

the scope and purposes determined by the “Membership Agreement” by our
company and its collaborators.

During some periods, our company may send notifications such as campaign
information, information about new packages, promotional offers to its customers
and members. Our members can make all kinds of choices about whether or not to
receive such information while becoming a member, then this selection can be
changed from the administration panel after logging in, or they can make a
notification with the link in the information message they receive.

Purposes of Processing Personal Data

Our company processes Personal Data for certain, clear and legitimate purposes. In
this context, Personal Data may be processed for the purposes listed below.
 Providing and changing the services provided on the website,
 Customizing the offered products and services in accordance with the
demands; updating, developing due to customer needs, legal and technical
 Making user definitions for the systems specific to the products and services
 Announcing new or existing products, services and campaigns, executing
sales and marketing activities,
 Conducting market research,
 Creating statistics and analysing usage,
 Payment of product, service and service fees, collection, selection of
collection method,
 Fulfilling the obligation to inform pursuant to the Law No. 6563 on the
Regulation of Electronic Commerce and other relevant legislation,
 To forward the advertisements of the company website and the products and
services suitable for the purpose of processing the data to the Related
Person, to provide information about the products, services, promotions and
 To provide solutions to the problems encountered during the use of the

 Improving the visit, usage, switching between pages and purchasing
experiences on the website, providing better quality service,
 Providing contact/communication,
 Execution of commercial relations with cooperated companies, suppliers,
resellers and service providers,
 Reporting within the framework of cooperation,
 Developing the company’s commercial strategies and making plans,
 Contacting the company for satisfaction measurement surveys,
 Registration of participants in events/trainings/competitions organized by the
company, arrangement of certificates/participation certificates, determination
of award/gift holders and delivery of awards/gifts,
 Management of judicial/administrative processes, responding to requests from
public institutions,
 Fulfilment of legal obligations depending on legal regulations, resolution of
legal disputes,
 Managing investor relations,
 Providing the results arising from this legal transaction in case of merger,
division, transfer of all or part of the company with another company,
 Introducing Company employees, Real Person Customers and Relevant
Persons in social media posts,
 Conducting job interviews, evaluating job applications,
 Establishment, execution and termination of the employment
 Making the company employees benefit from the basic and fringe benefits
arising from the employment contracts, evaluating their performance and
 opening user accounts for employees,
 In case of participation in an organization on behalf of the company, the
registration of the participant,

 Participation of employees in trainings and creation of certificate records,
 Ensuring the security of the Company Website and Applications,
 Usage analysis of the Website,
 Creation of personal data inventory,
 Evaluating and responding to all questions, requests, suggestions, complaints
and applications submitted in writing, verbally or electronically, including those
related to personal data.
 The performance of the contract is transferred to the systems in the country or
in other countries, especially the European Union countries (for more detailed
information, you can apply in writing to our Company) for the purposes of data
security, compliance with our Company’s policies and other purposes.

Method and Legal Reason for Personal Data Collection

Data about current and potential Company Website users are collected partially or
completely automatically or non-automatically, for contractual or other reasons
determined within the framework of the legislation, as a requirement of our business.

Personal Data Processed Without Explicit Consent

According to PDPA; We may process the personal information made public by you
publicly without your consent and share it with third parties in this context.
If there are provisions in the legislation that make it lawful to process your personal
data without express consent, we may process it without your explicit consent and
share it with third parties in this context.
We may process your personal data without express consent, if it is necessary to
fulfil our legal obligation, including information that needs to be disclosed pursuant to
applicable laws or regulations or a court decision, administrative order.
If data processing is necessary for the establishment, exercise or protection of a
right, we may process your personal data without your explicit consent.

Data Transferred to Third Parties

Without prejudice to our rights in PDPA, your personal data can be sent to the
Company employees, Company officials, legal, financial and tax consultants,
auditors, in the scope of commercial activities on the Company Website, in the cloud
located abroad, especially in the United States and European countries, to carry out
data processing. Companies, IBM Softlayer Data Center, Amazon Web Services, Inc

(AWS), collaborating consultants and contracted organizations, educational
institutions, advertising and marketing agencies that the Company works with, and
real or legal entities in order to present advertisements that may be of interest to the
Relevant Person by anonymisation. We can share with people. You give explicit
consent to the Data Controller regarding this sharing.

Network Server Data Logging

When you log into the Company Website, your web browser is technically set to
automatically transfer the following data (data log) to our internet server, then saves
the following information in the data log records even without your consent.
 Login Date
 Login Time
 URL of the application website
 Received files
 Amount of data transmitted
 Browser Type and Version
 Operating System
 IP address
 Domain name of your internet access provider
This information is the information required for technical purposes in order to deliver
the content requested by you correctly, and its collection is an inevitable aspect of
the use of websites. The data log is analyzed for statistical purposes only and then
deleted to improve our website and the underlying technology.
The data log is stored separately from other data collected as part of your use of the
Company Website.


Like many other websites, we also make use of “cookies”. Cookies are small text
files delivered to your hard drive by a web page server. In this way, we automatically
obtain certain data such as the IP address, the browser used, the operating system
on your computer and your internet connection. The aforementioned technical
communication file facilitates the use of the Internet by storing the status and
preferences about the site. The technical communication file is not designed to
retrieve data or any other personal information from the main memory or your e-mail.
Please note that, cookies cannot be used to run programs or send viruses to your

To get to know you on different Services, to have information about your interests on
and outside of our Services, to improve your experience, to increase security, to
measure the use and effectiveness of our Services, to obtain statistical information
about how many people visit the site for what purpose and how long they stay on the
site, and is specially designed for users. We use cookies and similar technologies to
help dynamically generate advertisements and content from user pages. To offer
different discounts and campaigns, to make advertisements and promotions, to
make the Company Website personalized for you, to provide a personalized experience, to monitor your navigation on the Company Website and

your transactions in your membership account through cookies, to use various
methods on the Company Website or We may analyse your personal data collected
on third sites and mobile applications together.

In any case, the data we collect cannot be shared with third parties without your
consent. Of course, you can always view our website without cookies. Internet
browsers are always set up to accept cookies. You can control cookies and stop
their use at any time through browser settings and other tools. Please use your
browser’s help function to learn how to change these settings. Please note that
certain features of our website may not work if you stop the use of cookies.

Use of Social Plugins in the Context of Social Media

The company is a social network operated by Facebook Inc., Palo Alto, CA, USA,
Facebook, YouTube LLC, 901 Cherry Ave. YouTube video platform operated by San
Bruno, CA 94066 USA, social network Twitter operated by Twitter Inc, 1355 Market
Street, Suite 900, San Francisco, CA 94103 USA, Arbitration Opt-out 1601 Willow
Rd. The social network Instagram operated by Menlo Park, CA 94025 USA uses
social plugins (plugins) from social networks.

If you visit a page on our website that contains such plug-ins, they are initially
ineffective. Plugins cannot take effect unless you click the specified button. By
activating the plugins, you connect with these social networks and give them consent
for data transfer. If you are logged in to these social networks, social networks may
associate this visit with your account in the relevant social network. If you press the
corresponding button, the corresponding information is directly transmitted by your
browser to the relevant social network and stored there.

For the scope and purpose of data collection, further processing and use of data by
the relevant social networks, and the settings you can make to protect your rights
and privacy, please refer to the Data Protection notices of the relevant social
networks. If you do not want these social networks to collect data about you through
our website, you must log out of the relevant social networks before visiting our

Your Rights Regarding Your Personal Data

In accordance with the legislation regarding your processed personal data; to learn
whether personal data is processed, to request information if personal data has been
processed, to learn the purpose of processing personal data and whether they are
used in accordance with its purpose, to know the third parties in the country or
abroad to whom personal data is transferred, in case of incomplete or incorrect
processing of personal data, requesting the correction of personal data, requesting
the deletion or destruction of personal data, requesting notification of the processes
regarding the correction of personal data in case of incomplete or incorrect
processing and/or the deletion or destruction of personal data to the third parties to
whom the personal data has been transferred, analyzing the processed data
exclusively through automated systems You have the right to object to the
emergence of a result against the person by means of this method, and to demand
the compensation of the damage in case of loss due to the unlawful processing of
personal data.

Use of Rights, Application and Communication

You can send your requests regarding your rights mentioned above within the scope
of the PDPA to the Company in writing in person or in accordance with the legislation
(for example, through a notary public) provided that your identity is verified.

Data Security

The Company has taken technical and administrative measures to the extent
possible regarding data security within the scope of KVKK. Information on the
measures taken is detailed under the Personal Data Protection, Storage, Processing
and Disposal Policy.

Data of Minors

Personal data of minors should not be sent without the consent of their parents or

Linking to Other Websites

The Company Website contains links to other websites. We have no influence on
whether the operators of these sites act in accordance with data protection
provisions. The company is not responsible for the content of the sites to which it
links (and the content of other sites to which those sites link) and does not have the
authority to interfere with the contents of the sites to which it links.

Changes in the Data Privacy Statement and the Policy on the Protection and
Processing of Personal Data This “Clarification Text on the Data Privacy Statement
and the Policy on the Protection and Processing of Personal Data” in order to
announce changes in our data protection-related services, for example, in the
provision of new services and the applicable legal requirements. shall be changed as

User Access

No one will have access to your account unless invited by you. Only in case of a
technical or system failure, authorized Company personnel can access your data for
support purposes.

Data Sharing

Data transfer is not shared with our business partners without your consent and
without adequate security.

Data Back-up

Daily backups of your data are made against possible technical problems.

Interventions to Security Violations

Despite our best efforts, no method of transmission and no method of electronic
storage is fully secure on the Internet. We cannot guarantee absolute safety.
However, if the Company becomes aware of a security breach, we will alert affected

users so that they can take appropriate protective steps. Our violation reporting
procedures are consistent with our obligations under regulatory regulations and any
industry rules or standards we comply with. Notification procedures include providing
e-mail notifications or posting notices if a violation occurs on our website.

Your Responsibilities

Keeping your data safe also depends on you keeping your account secure by using
sufficiently complex passwords and storing them securely. You should make sure
that the computer, tablet or phone on which you use the company service has
sufficient security.

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