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Law on the Protection of Personal Data

As a company, we would like to inform and enlighten you regarding our personal data processing activities in accordance with Article 10 of Law No. 6698 on the Protection of Personal Data.

1. Identity of the Data Controller

Pursuant to Law No. 6698 on the Protection of Personal Data, your personal data may be processed, recorded, stored, classified, updated, and disclosed/transferred to third parties where permitted by legislation and/or within the limits of the purposes for which they are processed, in accordance with the law and the principles of honesty, by Fineo Digital Transformation Inc., located at Yenişehir Mah., Kardeşler Cad. No:7/2/124, Merkez/Sivas, as the data controller.

2. Purpose of Processing Personal Data

Our company processes personal data within the scope of the personal data processing conditions and purposes specified in Article 5, Paragraph 2, and Article 6, Paragraph 3 of Law No. 6698. These purposes and conditions include:

  • The explicit stipulation of personal data processing activities in the applicable laws;

  • The necessity of processing your personal data for the establishment or execution of a contract to which you are a party;

  • The necessity of processing your personal data for our company to fulfill its legal obligations;

  • The condition that your personal data has been made public by you, allowing our company to process them within the scope of your intended disclosure;

  • The necessity of processing your personal data for the establishment, exercise, or protection of the rights of our company, you, or third parties;

  • The necessity of processing your personal data for the legitimate interests of our company, provided that it does not infringe on your fundamental rights and freedoms;

  • The necessity of processing personal data to protect the life or physical integrity of another person when the data subject is unable to express consent due to actual impossibility or legal invalidity.

In cases where these conditions are not met, our company will seek the explicit consent of personal data subjects before processing their personal data.

Within the framework of the conditions mentioned above, our company may process personal data for, but not limited to, the following purposes:

For the execution of commercial activities carried out by our company and the necessary work conducted by our business units, including:

  • Planning and execution of business activities and business continuity efforts;

  • Monitoring of finance and/or accounting processes;

  • Providing necessary information to authorized institutions as required by legislation;

  • Planning corporate communication and activities;

  • Planning and execution of production and/or operational processes;

  • Planning and execution of access authorizations for business partners and/or suppliers.

For enabling individuals to benefit from the products and services provided by our company, including:

  • Planning and execution of customer relationship management processes;

  • Tracking customer requests and/or complaints;

  • Planning and execution of marketing processes for products and/or services;

  • Planning and execution of after-sales support services;

Conducting necessary studies to customize and recommend products and services according to the preferences, usage habits, and needs of personal data subjects.

For determining and implementing the commercial and business strategies of our company in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

To prevent unlawful processing and unauthorized access to personal data and to ensure their secure storage, all necessary technical and administrative measures are taken.

3. To Whom and for What Purpose Personal Data May Be Transferred

Within the scope of the purposes explained above, your processed personal data may be transferred, in compliance with the fundamental principles stipulated by the Personal Data Protection Law (KVKK) and within the conditions specified in Articles 8 and 9, to:

  • Public legal entities and authorities authorized to receive personal data,

  • Our subsidiaries,

  • Companies operating as intermediaries/agents,

  • Third parties providing services for our core business activities such as information systems and software services,

  • Domestic institutions and organizations with which we cooperate,

  • Our business partners,

  • Independent audit firms.

4. Method and Legal Basis for Collecting Personal Data

Your personal data is collected by our company through various channels such as customer representatives, relevant websites, electronic platforms, and/or call centers. Your data is processed and transferred under the scope of the Tax Procedure Law General Communiqué No. 397, the Electronic Ledger General Communiqué (No. 1 and No. 2), and the Registered Electronic Mail (KEP), E-Invoice, and E-Ledger regulations, as well as within the conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

5.⁠ ⁠Rights of Data Subjects

As personal data subjects, if you submit your requests regarding your rights to our company using the methods specified below, our company will conclude the request free of charge within a maximum of 30 (thirty) days, depending on the nature of the request. However, if the process incurs an additional cost, a fee may be charged according to the tariff determined by the Personal Data Protection Board.

Within this scope, personal data subjects have the right to:

  • Learn whether their personal data is being processed,

  • Request information if their personal data has been processed,

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

  • Know the third parties to whom their personal data has been transferred domestically or abroad,

  • Request correction of personal data if it is incomplete or incorrect, and request that the correction be notified to third parties to whom the data has been transferred,

  • Request the deletion or destruction of personal data if the reasons for processing no longer exist, even if the data was processed in compliance with the law, and request that third parties to whom the data has been transferred be informed of this,

  • Object to any outcome that is against the data subject resulting from the analysis of processed data solely through automated systems,

Demand compensation if they suffer damage due to the unlawful processing of personal data.

6.⁠ ⁠Application Methods

You may submit your request in writing to the address below with identity verification documents:

Fineo Digital Transformation Inc. Yenişehir Mah., Kardeşler Cad. No:7/2/124, Merkez/Sivas

Alternatively, you can send your request via notary or by filling out the Data Subject Information Request Form and sending it to us via email at fineo@fineo.com.tr.