Web Confidentiality

INFORTE PRIVACY AND PERSONAL DATA PROTECTION POLICY

1. PURPOSE AND SCOPE

This Privacy and Personal Data Protection Terms (“Terms”) sets out the principles, which are accepted by Inforte Bilişim A.Ş. (shall be referred to as “Company” or “Data Controller”) with respect to the protection of personal data, determines the personal data processing principles with respect to the processing of personal data of Visitor, Customer, Potential Customer, Supplier, Supplier Employee, Potential Employee, and Online Visitor and 3rd Person (“Data Subject Groups”) and aims to inform such Data Subject Groups according to Personal Data Protection Law numbered 6698 (“Law numbered 6698”).

2. PRINCIPLES OF PROCESSING PERSONAL DATA

We, the Company, as the Data Controller, process your personal data under the below principles.

2.1 Processing in accordance with Law and Rule of Fairness
The principles brought with legal regulations and the general trust and fairness rule are complied with in respect of processing your personal data. According to this principle, while we, as the Data Controller try to reach our personal data processing purposes, we take into consideration your interest and reasonable expectations, do not abuse our rights and act in compliance with the principle of transparency in respect of our actions.

2.2 Ensuring that the Personal Data Are Correct and, When Necessary, Up to Date
In line with this principle, which emphasizes the importance of the accuracy and up-to-date of your personal data, periodical controls, and updating are made to ensure that the personal data, which is processed, is accurate and up-to-date, and in this respect necessary measures are taken by taking into consideration your legitimate interests. To this effect, systems, which are aimed to check the accuracy of the personal data and to make the necessary corrections, are established within the Company. Furthermore, the accuracy of the resources, from which the personal data are collected, is checked and requests, which arise due to inaccuracy of personal data, are taken into consideration. Therefore, this principle is applied in harmony with your right to request correction of the personal data, to which you are entitled under the Law numbered 6698.

2.3 Being Processed for Specified, Explicit, and Legitimate Purposes
Your personal data are processed based on explicit, specified, and legitimate data processing purposes. In this respect, we ensure that our personal data processing activities are clearly comprehensible by the data subject and we determine and explicitly set forth the purposes of the personal data processing activities in clauses 5 and 7 of this Terms.

2.4 Being Relevant, Limited and Proportioned to the Purposes for Which They Are Processed
Your personal data are processed in a manner, which is proportioned, relevant and limited to the envisioned processing purpose(s) and the processing of personal data, which are not relevant to achieving the(se) purpose(s) or are not needed, is avoided. Again, under this principle, personal data are not collected or processed for purposes, which do not exist and are deemed to occur later.
2.5 Being Stored for the Period Set Forth by the Legislation or the Period Required for the Purpose for Which They are Processed  
Your personal data are stored only for the period, which is set forth by the relevant legislation or is required for the purpose for which they are processed. For this, we, as the Data Controller, take and apply the organizational and technical measures. In this respect, we firstly determine whether a period of time is foreseen by the relevant legislation for the storing of personal data and if a period is determined, we comply with such period of time and if a period of time is not determined, the personal data are stored for the period, which is required for the purpose, for which they are processed. In the event of expiry of the period or that the reasons for processing cease to exist, if there is not any legal basis, which allows for data to be processed for a longer period of time, your personal data is erased, destructed, or anonymized according to the personal data protection legislation.

3. CONDITIONS FOR PROCESSING PERSONAL DATA

Your personal data may be processed by the Company under the conditions set forth below.

3.1 Being Expressly Provided for In the Laws
The fundamental rule is that the personal data cannot be processed without the explicit consent of the data subject, but according to this exception, your personal data may be processed in the event the processing of personal data is explicitly provided for in the laws.

3.2 Explicit Consent of the Data Subject Cannot Be Taken Due to Actual Impossibility
Your personal data may be processed to protect the life of the data subject or any other person if the data subject is unable to express his/her consent due to an actual impossibility or the data subject’s consent is cannot be deemed valid. In this respect, it is foreseen that in cases, where the consent cannot be expressed or is not valid, on the condition that it is mandatory to protect the life or bodily integrity of persons, personal data may be processed.

3.3 Being Directly Related to the Establishment or Performance of a Contract
On the condition that it is directly related to the establishment or performance of a contract, your personal data may be processed if the processing of the personal data of the parties to the contract is required. Based on this condition, in the event the personal data of the parties are processed for the performance of the obligations under a valid contract, explicit consent shall not be required.

3.4 Performance by the Company of its Legal Obligation
If the processing is mandatory to fulfill the legal obligations as a Data Controller, your personal data may be processed.

3.5 Personal Data Is Made Public
If your personal data is made public by yourself; in other words, if they are disclosed to the public by you, they may be processed. In such a case, it is deemed that the legal interest, which is required to be protected, is deemed to cease to exist.

3.6 Data Processing Is Mandatory for Establishment, Exercise or Protection of A Right
Your personal data may be processed if data processing is mandatory for establishment, exercise or protection of a right.

3.7 Processing Based on Legitimate Interests
If data processing is required for the legitimate interests of the Company, your personal data may be processed. In this respect, the Company may process personal data for the purposes such as promotion of employees, raise in the salaries of the employees or regulating the social benefits of the employees on the condition that the fundamental rights and freedoms of the employee are not violated. On the other hand, even in such cases, the fundamental principles with respect to the protection of personal data shall be complied with and the balance of interests of the data subject shall be respected.

3.8 Processing Based on Explicit Consent
Although the main rule is that the personal data is processed based on explicit consent, in the event the other conditions outlined in this clause exist, the explicit consent of the data subject is not sought. Otherwise, it will be an abuse of rights. In this respect, your personal data is processed based on explicit consent if they are not processed based on one of the conditions, which are outlined in this Terms.

4. CATEGORIZATION OF PERSONAL DATA

5. PURPOSES OF PROCESSING PERSONAL DATA

Personal data may be processed in the Company in accordance with the personal data processing conditions, which are outlined in articles 5 and 6 of the Law numbered 6698, based on the group of the data subject.

5.1 CUSTOMER
The personal data of the Customers may be processed under the conditions for processing personal data, which are set forth in article 5 of the Law numbered 6698, for the purposes of our relevant business units carrying out the necessary works and conducting relevant business processes and planning and execution of the activities for maintaining the business continuity by the relevant business units in order to realize the commercial activities, which are carried out by the company; carrying out the necessary business processes in order to have the data subjects benefit from the products and services, which are provided by the company; planning and execution of its operational activities, which are required in order to ensure that the operations of the company are carried out in accordance with the company procedures and the relevant legislation; conduct of audit activities; planning and execution of market research activities for the sale and marketing of the products and services and; provision of the legal, technical and commercial-business security of the company and the persons, which are in business relationship with the company; carrying out financial and accounting works, planning and execution of the operation processes of the company; pursuing contract processes and legal claims; pursuing customer requests and/or complaints; planning and execution of purchase, sale processes of products and/or services; planning and execution of the after sales support services activities and operation processes; planning and execution of transfer processes; planning and execution of corporate communication activities; management of events and activities; planning and execution of logistics activities; provision of the security of company premises and facilities; planning of information security; establishing and management of and audit and execution of information technologies infrastructure.

5.2 POTENTIAL EMPLOYEE
The personal data of the Potential Employee may be processed under the conditions for the processing of personal data, which are outlined in article 5 of the Law numbered 6698, to carry out the processes of procurement of personnel, planning, and execution of human resources processes, fulfilling the obligations arising from the legislation.

5.3 POTENTIAL CUSTOMER

The personal data of the Potential Customers may be processed under the conditions for processing of personal data, which are set forth in article 5 of the Law numbered 6698, for the purposes of planning and execution of the activities, which are necessary for suggesting and promoting the products and services, which are provided by the company, to the data subject by customizing such products and services as per the liking, habit of use and needs; carrying out the necessary works, which are necessary to realize the commercial activities, which are carried out by the company, and conducting the business processes related thereto; carrying out the works, which are necessary in order to benefit from the products and services, which are provided by the company, and the related business processes, planning and execution of activities, which are required for suggesting and promoting the products and services, which are provided by the company, by customizing thereof; planning and execution of processes for management of customer relations.

5.4 VISITOR

The personal data of the Visitors may be processed, under the conditions for the processing of personal data, which are outlined in article 5 of the Law numbered 6698, provision of security of buildings and facility premises and/or facilities; creating and following up visitor logs; provision of security of its fixtures and/or its resources; provision of technical and commercial-occupational security; provision of security of company operations; provision of information, which arises from the legislation to authorized institutions and organizations.

5.5 REPRESENTATIVES / EMPLOYEES OF SUPPLIERS / BUSINESS PARTNERS

Personal data of Representatives / Employees of the Suppliers / Business Partners may be processed under the conditions for processing personal data set forth in article 5 of the Law numbered 6698 for the purposes of conducting the necessary work carried out by our relevant business units for realizing the commercial activities carried out by the company and the conduct of the business processes in relation to this, the management of the relationships with the business partners and/or suppliers, the planning and execution of the communication activities with the business partners and/or suppliers, the planning and execution of our company’s commercial and/or business strategies, the provision of the security of the company’s operations, for the provision of the legal, technical and commercial-occupational security of our company and the relevant persons, who are in a business relationship with our company, the conduct of agreement processes, the conduct of finance and accounting processes, the conduct of purchase of goods/services, the provision of the security of the data controller’s operations and providing information to authorized persons, institutions, establishments.

5.6 ONLINE VISITOR

Personal data of Online Visitors may be processed under the conditions for processing personal data outlined in article 5 of the Law numbered 6698 for the conduct of marketing analysis works, the conduct of advertisements/campaigns/promotions’ processes, the conduct of communication activities, the conduct of product and services development works, carrying out legal obligations.

5.7 3^rd PERSON

Personal data of 3^rd Person may be processed under the conditions for processing personal data set forth in article 5 of the Law numbered 6698 for the purposes of the conduct of personnel procurement processes, the conduct of the business and operational processes for allowing the use of the services provided by the company, following up on legal works and the performance of agreements.

6. TRANSFER OF PERSONAL DATA

Your personal data may be transferred within the scope of principles and purposes set forth in clauses 3 and 5 of this Confidentiality and Personal Data Protection Terms under the conditions for, and for the purposes of, processing personal data set forth in articles 8 and 9 of the Law numbered 6698 in a limited capacity to our business partners, suppliers, legally authorized public authorities and legal entities in the country or abroad.

7. METHOD AND LEGAL BASIS OF COLLECTION OF PERSONAL DATA

Depending on the Data Subject Group, your personal data transferred electronically to the Company are processed as follows.

7.1 CUSTOMER

Personal data of the Customers are processed on the legal bases that “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”, “it is necessary for compliance with a legal obligation to which the data controller is subject” and “processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject” set forth in article 5 of the Law numbered 6698 or by obtaining explicit consent, in physical or electronic media, by automated or semi-automated means or by non-automated means as part of a data recording system through written or verbal data transfer tools by way of being received either directly from the person or third persons.

7.2 POTENTIAL CUSTOMER

Personal data of the Potential Customers are processed on the legal bases of “personal data have been made public by the data subject himself/herself”, “processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject”, set forth in article 5 of the Law numbered 6698 or by receiving explicit consent, in physical or electronic media, by automated or semi-automated means or by non-automated means as part of a data recording system through written or verbal data transfer tools by way of being received either directly from the person or third persons.

7.3 POTENTIAL EMPLOYEE

Personal data of the Potential Employee are processed on the legal bases of “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” in terms of the employment agreement which may be established, and “processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject”, set forth in article 5 of the Law numbered 6698 or by obtaining explicit consent by filling out an application form in electronic medium, by filling out a physical form by automated or semi-automated means or by non-automated means as part of a data recording system through written or verbal data transfer tools by way of being received either directly from the person or third persons.

7.4 VISITOR

Personal data of the Visitors are processed on the legal bases that “it is necessary for compliance with a legal obligation to which the data controller is subject”, “data processing is necessary for the establishment, exercise or protection of any right” and “processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject” set forth in article 5 of the Law numbered 6698, by automated or semi-automated means or by non-automated means as part of a data recording system by way of recording visuals via security cameras located in various locations in our service building and via other information obtained from you during your entries.

7.5 REPRESENTATIVES / EMPLOYEES OF SUPPLIERS / BUSINESS PARTNERS

Personal data of Representatives / Employees of the Suppliers / Business Partners are processed on the legal bases that “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”, “it is necessary for compliance with a legal obligation to which the data controller is subject” and “processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject” set forth in article 5 of the Law numbered 6698 or by receiving explicit consent in physical or electronic media, by automated or semi-automated means or by non-automated means as dart of a data recording system through written or verbal data transfer tools as part of the data recording system by way of being received either directly from the person or third persons.

7.6 ONLINE VISITOR

Personal data of Online Visitors are processed on the legal bases of “processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject” and “it is necessary for compliance with a legal obligation to which the data controller is subject” set forth in article 5 of the Law numbered 6698 by automated means.

7.7 3^rd PERSON

Personal data of Third Persons are processed on the legal bases of “it is necessary for compliance with a legal obligation to which the data controller is subject” and “Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject” set forth in article 5 of the Law numbered 6698 by automated or semi-automated means or by non-automated means as part of a data recording system in physical or electronic media through written or verbal data transfer tools by way of being received either directly from the person or third persons.

8. SECURITY OF PERSONAL DATA

The Company takes reasonable measures to prevent unauthorized access risks, data losses by accident, deliberate deletion of data or data from being damaged for the purpose of ensuring the security of the personal data and prevention of unlawful processing thereof.

All reasonably required technical and physical measures are taken to prevent persons other than those who are authorized to access personal data from accessing personal data. In this context, especially the authorization system is set up in a way which makes it impossible for persons and systems to access more personal data than it is necessary.

The Company carries out the required audits and has such audits carried out in its institutions and establishments for the purpose of execution of  the provisions of the Law numbered 6698.

9. UNDERTAKINGS TO THIRD PARTY PERSONAL DATA

The Data Subject Group accepts and consent that personal data in relation to 3^rd Persons transferred by the Data Subject Group may be processed by the Company. The relevant Person Group also undertakes that it has informed as required in line with the Law numbered 6698 in relation to the transferred persons and information and that it has obtained the consents. Otherwise, the relevant Person Group shall be liable for the damages arising.

10. PROCEDURES AND PRINCIPLES FOR APPLICATION

As data subject, you may make a submission in relation to your requests regarding your rights in article 11 of the Law numbered 6698, in line with the procedures and principles in the Data Subject Application Form , by filling out the relevant form and sending it a message to our REM address infortebilisim@hs01.kep.tr or with your e-mail address registered in your system sent to kvkk@inforte.com.tr or with a message sent with a secure e-signature, by a written application bearing signature made in person or via notary to our address Kozyatağı Mh. Değirmen Sk. No:16/12 Kadıköy, Istanbul. The Company will conclude the application made by you as soon as possible depending on the nature of the request and at the latest within thirty days free of charge. However, in case the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be charged by the Company.

In this context, as the data subject, you have the following rights;

• To learn whether your personal data is processed or not,
• To demand for information as to if your personal data have been processed,
• To learn the purpose of processing of your personal data and whether these personal data are used in compliance with such purpose,
• To know the third persons to whom personal data were transferred in the country or abroad,
• To request the rectification of the incomplete or inaccurate data, if any,
• To request the erasure or destruction of your personal data ,
• To request the notification to third persons to which personal data were transferred,
• To object to the occurrence of a result against himself/herself by analyzing  of the data processed solely through automated systems,
• To claim compensation for the damage arising from the unlawful processing of your personal data.

DOWNLOAD THE DATA SUBJECT APPLICATION FORM