KVKK Clarification Text

PERSONAL DATA PROTECTION AND PROCESSING POLICY

(CLARIFICATION TEXT)

ZEYNEP IGDELIOGLU Consultancy Services Ltd. Co. respects your privacy and attaches importance to your data security. In this context, this text has been prepared to inform and clarify you within the scope of the Personal Data Protection Law No. 6698 (“Law”, “KVKK”) and other relevant legislation.

Information

Personal Data Protection Law No. 6698 was accepted on March 24, 2016 and entered into force by being published in the Official Gazette on April 7, 2016. However, according to Article 32 of the Law titled Entry into Force, Articles 8, 9, 11, 13, 14, 15, 16, 17, and 18 of this Law entered into force as of October 7, 2016.

The Law was adopted to regulate the obligations and the procedures and principles to be followed by natural and legal persons processing personal data, and to protect the fundamental rights and freedoms of individuals, especially the privacy of private life, in the processing of personal data. With this text, visitors are informed and clarified by ZEYNEP IGDELIOGLU, and the “Protection of Personal Data and Personal Data Sharing Permission” is presented for the information and review of visitors.

ZEYNEP IGDELIOGLU accepts, declares, and undertakes that it will not sell, rent, or in any way make available to third parties your name, email address, work and home address, telephone number, and other personal data submitted by visitors through the forms on this site.

Processing of Your Personal Data

Processing of your personal data means any operation performed on data such as obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, classifying, or preventing the use of your personal data by fully or partially automated means or by non-automated means provided that it is part of any data recording system.

Data Controller and Representative

In accordance with the Law, your personal data may be processed within the scope explained in this text by ZEYNEP IGDELIOGLU as the data controller. ZEYNEP IGDELIOGLU is responsible for establishing and managing the data recording system by determining the purposes and means of processing personal data registered in the database.

Reasons for Processing Your Data

Your personal data is processed by our company in accordance with Articles 5 and 6 of the Law for purposes including, but not limited to, carrying out the necessary operational activities within the company to ensure that the products and services offered by our company can be presented to you, carrying out the necessary studies with the relevant business unit and business partners to recommend products and services suitable for your consumption and purchase motivation to our customers, ensuring human resources management by our Company to guarantee the rights of real persons, taking the necessary steps for the commercial decisions of our Company to be made, implemented, and realized, ensuring the legal security of real persons with whom we establish business relationships and of our Company arising from these relationships.

Your Personal Data may be processed by ZEYNEP IGDELIOGLU in its capacity as Data Controller in the following cases without seeking your explicit consent:

a) It is clearly prescribed in the laws;

b) It is mandatory for the protection of the life or physical integrity of the person or another person who is unable to express their consent due to actual impossibility or whose consent is not granted legal validity.

c) Provided that it is directly related to the execution of a contract, it is necessary to process the personal data of the parties to the contract.

d) It is mandatory for us to fulfill our legal obligations as the data controller;

e) It has been made public by the data subject themselves.

f) Data processing is mandatory for the establishment, exercise, or protection of a right

g) Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject, and can be used for the purposes we will state below.

Your personal data may be processed for the following purposes;

• Communicating with you and others as part of the business.

• Sending you important information about changes to our terms of service, changes to our electronic services, and other administrative information.

• Providing quality, training, and safety improvement (for example, regarding recorded or monitored phone calls made to our contact numbers)

• Managing our infrastructure and commercial operations and complying with internal policies and procedures, including those connected with audit, finance, and accounting; billing and collections; IT systems; data and website hosting; business continuity and records, document, and print management.

• Determining and defending legal rights; protecting our operations or the operations of our business partners, our rights, privacy, safety, or property and/or those of you or others, and implementing available remedies or limiting our damages.

• Personalizing your experience with electronic services by presenting you with custom information and advertisements.

To Whom and for What Purpose the Processed Personal Data Can Be Transferred

Your collected personal data may be transferred to our business partners, suppliers, 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 KVKK Law for the purposes of ensuring the legal and commercial security of our Company and the persons in business relations with our Company; carrying out the necessary work by our business units to benefit you from the products and services offered by our Company; customizing and recommending the products and services offered by our Company according to your tastes, usage habits, and needs; determining and implementing our Company's commercial and business strategies; and ensuring the execution of our Company's human resources policies.

Method and Legal Reason of Personal Data Collection

Your personal data is collected by our Company through different channels and based on different legal reasons to carry out our commercial activities. Your personal data collected for this legal reason can also be processed and transferred for the purposes specified in articles (b) and (c) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK Law.

Rights of the Personal Data Owner Enumerated in Article 11 of the KVKK Law

As personal data owners, if you submit your requests regarding your rights to our Company through the methods regulated below in this Clarification Text, our Company will finalize the request free of charge as soon as possible and within thirty days at the latest according to the nature of the request. However, if a fee is foreseen by the Personal Data Protection Board, 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 processed,

• Request information if personal data has been processed,

• Learn the purpose of processing personal data and whether they are used in accordance with their purpose,

• Know the third parties to whom personal data is transferred domestically or abroad,

• Request correction of personal data if they are processed incompletely or incorrectly and request notification of the transaction made within this scope to third parties to whom personal data is transferred,

• Request deletion or destruction of personal data in the event that the reasons requiring its processing disappear, despite having been processed in accordance with the provisions of the KVKK and other relevant laws, and request notification of the transaction made within this scope to third parties to whom personal data is transferred,

• Object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,

• Request compensation for the damage in case of damage due to unlawful processing of personal data.

In accordance with the 1st paragraph of Article 13 of the KVKK Law, you can submit your request to exercise your above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application to our Company in writing in accordance with the KVKK Law. In this framework, the channels and procedures through which you will submit your application in writing within the scope of Article 11 of the KVKK Law are explained below.

To exercise your above-mentioned rights, you can fill out the contact form on our website and send it to us, or send it with a wet signature to Harbiye mah. Abdi İpekçi cad. Bostan sk. 15/5 Şişli / İstanbul, or send it to our email address office@zeynepigdelioglu.com with your identification information and explanations regarding the right you request to exercise from the rights specified in Article 11 of the KVKK Law.