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Data Protection Policies

“WISERA TECHNOLOGY AND INFORMATION SERVICES INC.”

PERSONAL DATA PROCESSING CLARIFICATION TEXT

 

1.  What is personal data, and who processes it?

According to Article 3 of the Personal Data Protection Law No. 6698, personal data refers to any information related to an identified or identifiable real person. WISERA TECHNOLOGY AND IT SERVICES JOINT STOCK COMPANY (“Company”), as the “data controller” pursuant to the Personal Data Protection Law No. 6698, will record, store, update, process, disclose, and transfer your personal data in accordance with the law.

2.  For what purposes can your personal data be processed?

Your personal data, which is collected as specified below;

Identity Information:

  • Clearly stipulated by laws (Article 5/2-a)
  • It is necessary for the data controller to fulfill its legal obligation (Article 5/2-ç)
  • It is necessary for the performance of a contract directly related to the data subject (Article 5/2-c)

Communication Information:

  • It is necessary for the performance of a contract directly related to the data subject (Article 5/2-c)
  • Clearly stipulated by laws (Article 5/2-a)
  • It is necessary for the data controller to fulfill its legal obligation (Article 5/2-ç)

Financial Information:

  • It is necessary for the performance of a contract directly related to the data subject (Article 5/2-c)
  • Clearly stipulated by laws (Article 5/2-a)
  • It is necessary for the data controller to fulfill its legal obligation (Article 5/2-ç)

Physical Security Information:

  • It is necessary for the performance of a contract directly related to the data subject (Article 5/2-c)
  • Clearly stipulated by laws (Article 5/2-a)
  • It is necessary for the data controller to fulfill its legal obligation (Article 5/2-ç)
  • It is necessary to establish, use, or protect a right (Article 5/2-d)
  • It is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed (Article 5/f)

Legal Transaction Information:

  • It is necessary for the data controller to fulfill its legal obligation (Article 5/2-ç)

Special Categories of Personal Data:

With the explicit consent of the data subject (Article 5/1) in accordance with the conditions for processing personal data:

  • Through our website www.ccngroup.com.tr and other websites to be established in the future, either electronically or non-electronically,
  • automatically or non-automatically (cookies typically collect anonymous data),
  • Through various social media channels operated on behalf of the Company (“Social Media”), either electronically or non-electronically, automatically or non-automatically,
  • Through the call centers managed by the Company (“Call Center”), either electronically or non-electronically, both verbally and electronically,
  • Through emails, text messages, or multimedia messages sent by the Company, or through the sales and marketing network the Company manages,
  • Through contracts, correspondence, and user devices, both verbally, electronically, and in writing,
  • Through physical means such as obtaining business cards from visitors or through other means by employees engaged in sales and marketing activities,
  • Through the communication channels mentioned above, the personal data of visitors, whether electronically or non-electronically,
  •  Through other communication tools such as online sales platforms, distributors, solution partners, etc.

The personal data collected through these methods will be processed for the following purposes and within the scope mentioned below.

  • In accordance with Article 5.2 and Article 6.3 of the Personal Data Protection Law:

Generally, we process your personal data based on your explicit consent. However, in exceptional cases permitted by the Personal Data Protection Law, your personal data may be processed without your explicit consent. These include:

  • Fulfilling our legal obligations (tax regulations, consumer protection law, obligations under the Turkish Commercial Code, etc.)
  • In case you are unable to give consent due to physical impossibility (Article 5/2-d)
  • For the performance of a contract (Article 5/2-c)
  • To handle questions and complaints, provide responses, and in case of potential disputes (Article 5/2-ç)
  • To protect fundamental rights and freedoms, with respect to our legitimate interests, such as cost reduction, resource efficiency, and improving customer service quality (Article 5/f)
  • Also, personal data shared publicly by you through social media or the internet can be processed under the conditions stipulated by the Law, without requiring explicit consent. Such data may include, but are not limited to, personal data shared through social media or website channels.

Your personal data may be processed in the following cases with your explicit consent, as per Article 5.1 of the Personal Data Protection Law:

  • Communication, advertising, marketing, product/service offers, notifications, promotions, and sales activities
  • Creation of marketing archives and future collaboration opportunities

Who can your personal data be transferred to, and for what purpose?

Your collected personal data may be transferred to:

  • To fulfill the legal obligations of the Company
  • To carry out operational activities by our business units
  • To manage human resources policies and ensure the correct operation of commercial strategies
  • To ensure the legal, commercial, and physical safety of the Company and its stakeholders
  • To fulfill official institution requests
  • To resolve your service requests and improve service delivery
  • To ensure product/service optimization based on your needs and demands

How and on what legal basis is your personal data collected?

  • Personal data is collected for the purposes outlined in this Policy using various methods such as online communication, contracts, and emails. Data is processed according to legal obligations, contracts, and other lawful reasons outlined by the applicable law.

Conditions for Personal Data Transfer

The Company may transfer personal data to third parties following proper confidentiality measures and in compliance with the law. Transfers can occur based on:

  • Your explicit consent,
  • Clear provisions in law permitting the transfer,
  • Legal obligations,
  • Publicly disclosed personal data,
  • Legitimate interests of the Company.

How long are your personal data retained?

The personal data you share will be processed and stored in accordance with applicable laws and regulations, particularly the Personal Data Protection Law No. 6698, until the purposes mentioned are fulfilled or as long as required by law.

What are your rights under the Personal Data Protection Law?

You have the right to:

  • Learn whether your personal data is being processed,
  • Request information about how your personal data is being processed,
  • Request the correction of incorrect or incomplete data,
  • Request the deletion or destruction of your personal data,
  • Object to decisions made solely on automated processing, including profiling,
  • Request compensation for damages caused by the unlawful processing of your personal data.

How to exercise your rights?

You can exercise your rights by sending a written request to the address ÖMER AVNİ MAH. İNEBOLU SK. İŞ HANI NO: 1 A BEYOĞLU/İSTANBUL or using electronic means such as KEP (secure e-mail), electronic signature, or the email address previously provided to the Company. Requests will be responded to within 30 days, free of charge (except for cases where additional fees may apply based on the document volume).