CLOUD SYSTEMS SERVICE DISTANCE SUBSCRIPTION AGREEMENT

This “INTERNET SERVICE PROVIDER AND SUBSCRIPTION AGREEMENT” (“Agreement”) has been concluded between on the one hand by DT İletişim Hizmetleri A.Ş (“Service Provider”) located at Fatih Mahallesi Çavuşbaşı Cumhuriyet Caddesi No: 391 Beykoz / Istanbul and on the other hand ………… resident at ……………………………………………………………………………………………. … (“Subscriber or Customer ”) under the following conditions.

By accepting this contract, the SUBSCRIBER accepts in advance that if the subject of the contract approves the order, it will be under the obligation to pay the price of the order and the additional fees specified, if any, such as shipping fee and tax, and that it has been informed about it.

1. THE SUBJECT OF THE CONTRACT

This Agreement regulates the mutual rights and obligations of the Service Provider for the provision of Cloud Systems (“Service”) to be provided to the Subscriber on a continuous 24-hour basis, and for the Subscriber to pay the price of the service provided under the terms of the Agreement. This Agreement regulates the rights and obligations of the parties in accordance with the provisions of the Law No. 6502 on the Protection of the Consumer and the Regulation on Distance Contracts, regarding the sale and delivery of the product, the qualifications and sales price of which are specified below, that the subscriber orders electronically through the website of the Service Provider.

The prices listed and announced on the site are the sales price. The announced prices and promises are valid until they are updated and changed. The prices announced for a limited period are valid until the end of the specified period.

2. DESCRIPTION OF THE SERVICE TO BE PROVIDED

   2.1 As part of the service, the Service Provider will provide CLOUD SYSTEMS over the Internet access and system infrastructure to be provided under the Internet Service Provider license authorized by the Republic of Turkey Ministry of Transport, Information Technologies and Communications Authority. In addition, the Service Provider will allow the use of this service by Subscriber users within the capacities on the Annex-1 Subscription form.The service is in beta version and can be migrated by the Service Provider after the customer is informed.

   2.2 The basic features of the service are published on the website of the Service Provider. If the campaign is organized by the service provider, you can review the basic features of the relevant product during the campaign. Valid until the date of the campaign.

   2.3 The prices listed and announced on the website are sales prices. Advertised prices and promises are valid until updated and changed. Prices announced for a period of time are valid until the end of the specified period.

   2.4 Based on the service capacities provided under the Annex-1 Subscription form, the bandwidth and system infrastructure corresponding to the leased capacities will be available for data traffic continuously

   2.5The Service will be deemed unavailable in the following cases:

2.5.1 The Subscriber's or user's inability to use the Service for a reason not caused by its own infrastructure,

2.5.2 When the connection between the entire system infrastructure and routers of the Service Provider and the main line of the national / international partner suppliers is broken,

2.5.3 In case the delay between the Service Provider's own system infrastructure and router and the access points of national/international partner suppliers exceeds the values given in the service quality parameters for round trip.

   2.6 Based on annual average availability, the following cases will not be considered interruptions of service:

2.6.1 Scheduled maintenance reported at least 24 hours in advance

2.6.2 Failure of subscriber equipment or application

2.6.3 Non-Contractual use of the service by the Subscriber

2.6.4 Error in leased line connection locally

2.6.5 All Subscriber errors, including errors arising from misuse/integration of the service by the Subscriber

2.6.6 Force majeure situations

3. SERVICE LEVEL CRITERIA OBJECTIVES

   3.1 Priority Levels and Response Times

3.1.1 Service response times and availability rates for the services provided within the scope of Data Center Managed Services provided by the Service Provider are defined in Table-1. Service level exclusions have also been determined

TABLE-1

  3.2 Availability

The Service Provider aims to provide the monthly availability rates in Table-2 for the virtual server, network infrastructure, access infrastructure and storage services in the Data Center environment, which are listed in the Customer inventory within the scope of Data Center Managed Services, regardless of the situations arising from the network environment

TABLE-2

4. MUTUAL RIGHTS AND OBLIGATIONS OF THE PARTIES

   4.1 The Service Provider agrees to provide the service described above on a 24/7 basis. If the Service Provider fails to meet the quality of service (annual availability, repair time) determined in this Agreement, it will be liable to pay a penalty (or prepare a crediting invoice) to the Subscriber under subsequent terms and conditions. The subscriber will not have the right to terminate the contract due to insufficiency as long as the annual availability rate of the service remains above 99.5%. The Service Provider shall not be liable to pay any penalty or credit to the Subscriber as long as the Subscriber delays its payment obligations. If 99.5% accessibility cannot be achieved within the contract period, due to the following situations;

4.1.1 Force majeure situations,

4.1.2 Service Provider shall not be responsible for the interruptions caused by the problems caused by the Subscriber.

4.1.3 DT will provide the Service specified in this Agreement and its annexes to the Customer within the scope of this Agreement, the related annexes and the relevant legislation.

4.1.4 By signing this Agreement, the parties accept, declare and undertake that they will not gain titles and statuses such as representatives, agencies, commercial representatives, partners of each other.

4.1.5 The Customer does not request anything from DT due to the temporary or permanent suspension or the inability to provide the Services at all or as required of DT's activities due to the reasons beyond its control or natural disasters, legal obstructions, including but not limited to those listed here, general problems that prevent the provision of comprehensive Services in telecommunication and energy infrastructures, data transfer and connection problems, computer, equipment and hardware used by the customer does not work well or the security problems caused by its users. In this context, DT will not be held responsible in any way for service interruptions that are not caused by DT and which are not clearly DT's fault, and for damages caused by cyber attacks by third parties.

4.1.6 In the event that whether due to this Agreement or not, programs such as accounting or ERP programs that the Customer is using and/or the companies that these programs belong to prevent DT from fulfilling its obligations in this Agreement and or cause similar situations to prevent communication, DT assumes no liability to the Customer or these companies.

4.1.7 DT does not accept any responsibility for delays caused by the Customer and for failures, delays and similar situations preventing communication.

4.1.8 Although DT has taken all kinds of measures and precautions, it may narrow the scope of the services provided or stop it completely in cases where there are justifiable reasons that require it to act otherwise in accordance with national or international laws, communiqués, circulars and principles published by the competent authorities. The Customer accepts, declares and undertakes in advance that he/she will not request recourse to DT in any way for the damages and losses he may suffer due to these reasons.

4.1.9 The customer must constantly keep his/her REM address, other e-mail addresses and other contact information provided to DT up to date and it is obliged to follow up the informative e-mails, announcements and notifications to be made via DT's website from the registered e-mail address or to the Customer's account on the Platform.

4.1.10 The Customer accepts, declares and undertakes that all legal sanctions arising from the transactions to be made with the user names and passwords of the Authorized Users will belong to him, and that DT will not accept any responsibility for the transactions to be made through these persons.

4.1.11 In the event that the authorization granted to Authorized Users is withdrawn by the Customer or any employee uses the Platform without authorization, he/she is obliged to immediately notify DT of this issue. Upon request, DT will define the removal of the authority of the person concerned on the system and will prevent their access to the system. The existing authorization will remain valid until the Customer notifies DT of the withdrawal of the authorization or the change of authorizations on the current Authorized Users. Customer accepts, declares and undertakes that all responsibility belongs to him/her for the transactions to be made within the framework of this Agreement by using the Customer's "password" and "authorized user information" due to the Customer's late notification of authorization changes, bankruptcy, liquidation or termination of his commercial activities for any reason and DT will not have any responsibility.

4.1.12 During the contract period, the Customer may purchase and start using new Service Packs through the responsible person or Authorized Users authorized in the contract and additional protocols. The Customer gives consent in advance to these purchases made by the Authorized Person. The provisions of this Agreement will continue to be applied for each new service package to be purchased. The right to use the software to be submitted to the Customer to receive the Cloud Computing Services belongs exclusively to DT. The customer accepts, declares and undertakes that the software offered by DT within the scope of the service will not be used by other institutions and / or organizations.

4.1.13 The Customer agrees that he/she only shall benefit from the service to be provided to him/her within the scope of this Agreement and its annexes, he/she accepts, declares and undertakes that he/she cannot use or transfer to his/her subsidiaries, the companies affiliated to the parent company and other persons, institutions and organizations, except for the real persons authorized by it before its own legal entity, that it cannot rent or sell to anyone else, otherwise all responsibility will belong to he/she and that DT has the right to stop all services provided and/or terminate the Agreement if this situation is determined.

4.1.14 The Customer accepts, declares and undertakes not to engage in illegal activities, not to violate the laws and provisions of the Republic of Turkey, the titles and decisions of official authorities while receiving the services subject to this Agreement.

4.1.15 The customer accepts, declares and undertakes that if he/she does not comply with the commitments set forth in the above articles, he/she will be responsible for all kinds of responsibility, that he/she will indemnify any damages incurred by DT, within this scope, DT has the right to cease the service and/or terminate the Agreement.

4.1.16 The Parties ensure that all reasonable measures will be taken to prevent or reduce or minimize the loss or damage that the Parties may suffer due to any event, situation, fact or event that may cause damage.

4.1.17 DT will notify the Customer 30 (thirty) days in advance of changes in the provision of the service, including price changes and pricing for the Customer, in accordance with the changes in market conditions.

5. PAYMENT

   5.1 5.1 The subscriber shall pay the installation commissioning fee and service fee to the Service Provider in return for the service provided, the fee specified in the order form.

   5.2 The Service Provider will issue an invoice for the monthly service fee for the relevant month on the 5th day of each month upon the entry into force of the Agreement and for the service overage fees of the previous month according to the scope specified in the Annex-1 Subscription form. (The Service Provider will bill the initial monthly service fee on a partial month account basis on the 5th day of the month following the provisioned connection delivery). The Subscriber shall pay the fee specified in the invoice within 30 days following the invoice date by transferring it to the bank account number of the Service Provider. Otherwise, legal interest will be applied and accrued until the date of payment. In case of non-payment by the Subscriber for 2 (two) consecutive months, the Service Provider has the right to interrupt the service from the 3rd day following the last payment date.

   5.3 Objections to be made by the Subscriber to the Invoice shall not stop the payment. In case of overpayment from the Subscriber, this payment will be deducted from the next month's invoice or returned to the Subscriber within 30 days.

   5.4 Since the stamp tax arising from this contract will be paid equally by the parties, half of the stamp tax arising from the service received by the customer is reflected on the first invoice for once.

6. TERM AND TERMINATION OF THE AGREEMENT

   6.1 This Agreement is the subscriber's statement, "I have read and approved the User Agreement and Privacy Conditions." It enters into force upon acceptance and/or use of the Application in electronic environment by ticking the box. The duration of the contract is limited to the period specified in the package or service content, and the subscriptions other than the Pay as you go model will be deemed to be automatically renewed for the same period with the same conditions, unless one of the parties terminates the contract 15 days before the end of the contract.

   6.2 The contract is according to the subscriber's preference; Payment as you go (Pay as you go model) or monthly (VPC, VPS, S3). In the pay-as-you-go model, per-unit pricing is applied according to the amount of usage. By linking to the price list, payment is made as here, 1 month is used. The months used are priced according to the amount of usage. Prices may vary according to the month of use, as it is linked. Prices can be displayed on the same link on a monthly basis (VPC or VPS).

   6.3 If the obligations assumed by this Agreement are not fulfilled, the Party whose rights have been violated has the right to terminate the Agreement by sending a written Notice of Termination. The Notice of Termination must be based on a just cause and must be served on the other party. The Service Provider reserves the right to terminate the Agreement immediately and without notice in case of non-payment by the Subscriber. In such a case, all debts that have arisen or will arise according to the records of the Service Provider will be paid by the Subscriber.

   6.4 If the subscriber requests the cancellation of the service at the end of the commitment period, he is obliged to notify the Service Provider in writing of this request. The Contract will be terminated within fifteen (15) days after the cancellation request is notified to the Service Provider in writing. However, the Service Provider will send an invoice to the Subscriber in order to collect the payments that have arisen until the moment of termination.

   6.5 Subscriber, the duration of this contract is 24 (twenty-four) months and the subscriber has committed not to terminate the contract during this period. If the subscriber terminates the contract within the commitment period, he irrevocably accepts and pays the payment of the remaining period and the installation activation fees as a penalty for breaking the commitment. This penal clause has been freely agreed between the parties and its exorbitance cannot be claimed.

7. PRIVACY

   7.1 Both Parties, without prejudice to the applicable laws, regulations and legislative provisions of the Republic of Turkey, to the implementation of this Agreement, regardless of the other Party's service, production, performance, financial situation and similar issues. It will retain any contractual or technical information. It will be kept confidential. They declare and undertake that they will not disclose, directly or indirectly, partially or completely, to third parties or organizations.

   7.2 The parties shall not use, distribute, transfer to third parties in any way the private information communicated to them, and shall take the necessary measures to ensure that their own employees comply with this confidentiality obligation.

   7.3 Private information means any product, technology, procedure, program, financial information and targets, data, know-how, design, software, customer list, tariffs and similar information communicated by the Parties to each other in written and/or verbal and/or electronic format encompasses all. The parties will keep the private information confidential and will take all kinds of security measures to prevent the said information from being used by unauthorized persons

   7.4 In the event that any of the Parties violate the provision of this article, the compensation for the damage to be incurred is essential. Even if this Agreement is terminated for any reason, the obligations in this article will be evaluated by the Parties indefinitely, without being subject to any time period, in accordance with the provisions of this article.

8. FORCE MAJEURE

   8.1 Delays in the fulfillment of any obligations under the terms of this Agreement due to force majeure, lockout, fire, war and similar reasons, including natural disasters, earthquakes, bad weather conditions, riots and turmoil that may occur after the conclusion of this Agreement In the event of such obligations, the due date for the fulfillment of such obligations shall be extended by mutual agreement as appropriate.

   8.2 DT cannot be held responsible for the disruptions arising from product supply and product establishment, due to the fact that the software in the Customer does not meet the needs. In case this situation exceeds 30 (thirty) days, the Parties reserve the right to terminate the Agreement by giving written notice to the other party.

9. SLA PENALTY CONDITIONS

   9.1 Penalty Payment to be applied in cases where the Service Provider cannot meet the rates specified in the SLA will be as follows on a monthly basis. The penalty to be paid cannot exceed 25 percent of the contract term/monthly invoice amount. Penalty payments Within 15 days after Service Provider reporting, a credit of 2 times the interrupted service fee is defined.

10. GENERAL PROVISIONS

   10.1 Transfer and Assignment: DT may transfer and/or assign this Agreement to an affiliate, its successors in connection with a merger, acquisition or consolidation, or its purchaser in connection with the sale of all or substantial assets. The Customer cannot transfer and/or assign this Agreement or any of its rights or obligations under this Agreement without the prior written consent of DT.

   10.2 If any term of this Agreement is invalid or unenforceable, it will not render the entirety of this Agreement invalid or unenforceable

   10.3 This Agreement shall not be interpreted as a waiver of this right or authority if one of the Parties is late in using any right or power arising from the Agreement or neglecting to use it.

   10.4 In disputes arising from the implementation or interpretation of this Agreement, its annexes or amendments, the Laws of the Republic of Turkey shall apply. Istanbul Anatolian Courts and Enforcement Offices are authorized to resolve disputes arising from them.

   10.5 The address specified by the parties in the Order Form or all warnings and notifications regarding this Agreement are made to the e-mail address that the User has entered during activation or has somehow notified DT İletişim Hizmetleri A.Ş. The user cannot claim that the notification made to this address was received by unauthorized persons. Notifications made to this e-mail address will result in legally valid notification. The parties accept that even if the notifications made to this address are returned, it will have the same result as the legally valid notification.

   10.6 Final Evidence Agreement: In case of disagreement; All kinds of official records and books kept by the parties and electronic records kept by the Data Centers of the Software constitute definitive evidence.

   10.7 The other party accepts, declares and undertakes that it has read the preliminary information about the basic characteristics, sales price, payment method and delivery of the product subject to the contract on the website, has been informed and has given the necessary confirmation in electronic environment. environment. As a result of the Subscriber's confirmation of the Preliminary Information electronically, he accepts that he has acquired the address and basic features to be given to the Subscriber by the Service Provider before the distance sales contract is established. It accepts, declares and undertakes that it has obtained the price, payment and delivery information of the ordered products, including taxes, accurately and completely.

   10.8 During the service period of the service, 99% of the service will be charged, 99% during the service period of the service, and 2 times the service price from the part that will benefit from the service provider's service. the service covered by the service is within the scope of the subscriber's ongoing service, according to the credit or after-service pricing to be deducted from the growth plan for the purchase of new service on the site to be performed from the service period to be determined or for anything else of this type.

   10.9 Although the Service Provider has the right to perform some or all of the service through intermediary services by using third party subcontractors, provided that it does not mean the transfer of the obligations in the Agreement, it will be fully responsible for the fulfillment of its obligations to the Subscriber.

   10.10 The Subscriber agrees to make the payments to be made pursuant to Article 4 of the Agreement in return for the Service provided, on time and in full.

   10.11 The Service Provider has the right to make changes in the service fee only to the detriment of the Subscriber due to changes in tax rates, and this change must be notified to the Subscriber at least 1 month in advance

   10.12 Service Provider shall notify the Subscriber in advance of any maintenance, repair and/or modifications to be made in the technical infrastructure. The liability of the Service Provider regarding the damages incurred by the Subscriber due to the failures that may occur in or related to this Agreement will be limited to the maximum monthly service fee.

   10.13 Service Provider in writing of their requests such as address change, transfer, title change, IP number, domain name change and user ID change.

   10.14 Service Provider will not disclose the information of the Subscriber or the meaningful or meaningless whole or part of the packages passing over the line used, or the personal communication or data of the Subscriber employees to third parties.

   10.15 If the Service Provider is not at fault, it is not responsible for force majeure events, network maintenance and repair works of the infrastructure provider, operational failures of the infrastructure provider, fraudulent blocking of lines, legal regulations. It is not responsible for the partial, complete, temporary or permanent suspension of the service provided, especially for the reasons arising from this Agreement.

   10.16 The Service Provider is only responsible for the maintenance of its own equipment and infrastructures.

   10.17 Service Provider for this service are housed in data centers where physical security measures are taken and comply with information security criteria. The Service has the right to change the data center, make the necessary changes in hardware, security, accommodation and other infrastructure if it deems necessary.

   10.18 The Service Provider may supply a different product with equal quality and price by informing the subscriber and obtaining his explicit approval before the contractual performance obligation expires.

   10.19 The Subscriber accepts, declares and undertakes that he/she will confirm this Agreement electronically for the delivery of the product subject to the Contract, and that the Service Provider's obligation to deliver the product subject to the contract shall expire in case the contractual product price is not paid and/or canceled in the bank records for any reason.

   10.20 In case the contract product price is not paid to the Service Provider by the relevant bank or financial institution as a result of the unfair use of the Subscriber's credit card by unauthorized persons after the delivery of the service as specified by the Subscriber or the Subscriber, the Subscriber may, within 3 days, It accepts, declares and undertakes that it will return it to the Service Provider .

   10.21 The Service Provider accepts, declares and undertakes that it will notify the Subscriber of the situation if the product subject to the contract cannot be delivered within the period due to force majeure situations such as the occurrence of circumstances that are beyond the will of the parties, unpredictable and prevent and / or delay the fulfillment of the debts of the parties. also reserves the right to request from the Service Provider to cancel the order, replace the product subject to the contract with its precedent, if any, and/or delay the delivery period until the obstacle is removed. In case of cancellation of the order by the Subscriber, the amount of the product is paid to the Subscriber in cash and in full within 14 days in the payments made by the Subscriber. In payments made by the Subscriber by credit card, the product amount is returned to the relevant bank within 14 days after the order is canceled by the Subscriber. The Subscriber agrees that the average period for the bank to reflect the amount refunded to the credit card to the Subscriber's account may take 2 to 3 weeks. It accepts, declares and undertakes that it cannot hold.

   10.22 The Service Provider , through letter, e-mail, SMS, telephone call and other means, through the address, e-mail address, fixed and mobile phone lines and other contact information specified by the Subscriber in the registration form on the site or updated by him later, communication, marketing, has the right to reach the Subscriber for notification and other purposes. By accepting this agreement, the Subscriber accepts and declares that the Service Provider may engage in the above-mentioned communication activities.

   10.23 In case the subscriber and the credit card holder used during the order are not the same person, or if a security vulnerability is detected regarding the credit card used in the order before the product is delivered to the Subscriber, the Service Provider shall provide the identity and contact information of the credit card holder of the credit card used in the order for the previous month. It may request from the Subscriber to present the statement or a letter from the bank of the card holder stating that the credit card belongs to him. The order will be frozen until the Subscriber provides the information/documents subject to the request, and if the aforementioned requests are not met within 24 hours, the Service Provider has the right to cancel the order.

   10.24 The Subscriber declares and accepts that the personal and other information provided by the Service Provider when subscribing to the website is correct, and that he will immediately indemnify any damages he may suffer due to the inaccuracy of this information, in cash and in full, from the moment the Service Provider first notifies other party.

   10.25 The Subscriber agrees and undertakes in advance to comply with the provisions of the legal legislation and not to violate them while using the website of the Service Provider. Otherwise, all legal and penal liabilities that may arise will bind the Subscriber completely and exclusively.

   10.26 On the website of the Service Provider , links to other websites and/or other content that are not under the control of the Service Provider and/or owned and/or operated by other third parties may be provided. These links are provided for the purpose of facilitating navigation to the Subscriber and do not support any website or the person operating that site and do not constitute any guarantee for the information contained in the linked website.

   10.27 The member who violates one or more of the articles listed in this agreement will be personally and criminally liable for this violation, and the Service Provider will be excluded from the legal and penal consequences of these violations. Moreover; In the event that the event is referred to the legal field due to this violation, the Service Provider reserves the right to claim compensation against the member for non-compliance with the membership agreement.

11. OTHER PROVISIONS

   11.1 In order for the SLA to be valid, the Service Addendum and the payments for the Service provided under this SLA must be made on due date and in full. The service level service will be deemed invalid when the Customer has overdue debts exceeding fifteen (15) days past due date. .

   11.2 All Service Level calculations and determinations will be based on Vodafone Net records and data. A monthly request and call report will be generated by Vodafone Net within the scope of this SLA.

   11.3 Any deduction that is not covered by Article 3 of this SLA, that is not Force Majeure and that has not been explained in writing to the Customer will be used in the calculation of the service commitment within the scope of the SLA, except in cases where it is stated in the Service Attachment that Vodafone Net is not responsible.

12. ENFORCEMENT

   12.1 The Subscriber shall be deemed to have accepted all the terms of this contract when he/she makes the payment for the order placed on the Site. The Service Provider is obliged to make the necessary software arrangements to obtain confirmation that this contract has been read and accepted by the Subscriber before the order is fulfilled.

APPENDIX-1 SUBSCRIPTION FORM

Subscription Reference No: DTI2020……..

Subscriber Name :

Billing Address :

Payment department number :

Phone Number :

Contact Person :

Contact Authorized E-Mail :

Contact Authorized Phone :

PRIVACY TERMS

Accessing this website or using any information on this website means that you accept the following terms.

Entering this website, the site or the information and other data on the site, programs, etc. DT İLETİŞİM HİZMETLERİ A.Ş is not responsible for any direct or indirect damages that may arise due to breach of contract, tortious act, or other reasons due to the use of the product. DT İLETİŞİM HİZMETLERİ A.Ş. as a result of breach of contract, tort, negligence or other reasons; does not accept any responsibility for interruption of the transaction, error, negligence, interruption.

It reserves the right not to require a prepared warning from you on the site, to reorganize the site, to request any product, product, or completion of the site available on this site and site extension. Versions begin to be published on the site. By using the site or logging into the site, this choice is deemed to be accepted. It applies to other web pages given these terms.

DT ILETİŞİM HİZMETLERİ A.Ş. as a result of breach of contract, tort, negligence or other reasons; does not accept any responsibility for interruption of the transaction, error, negligence, interruption, deletion, loss, delay of the transaction or communication, computer virus, communication error, theft, destruction or unauthorized entry, modification or use of the records.

This website may contain links or references to other websites that are not under the control of DT İLETİŞİM HİZMETLERİ A.Ş. and who is not responsible for the content of these sites or any other links they contain.

DT ILETİŞİM HİZMETLERİ A.Ş., the general appearance and design of this website and all information, pictures, logos, icons, demonstrative, written, electronic, graphic or machine-readable technical data, computer software, applied sales system, business method and is the owner or licensee of all materials ("Materials") and related intellectual and industrial property rights, including the business model, and are under legal protection. any Material on the Website; It cannot be changed, copied, reproduced, translated into another language, republished, uploaded to another computer, posted, transmitted, presented or distributed, including code and software, without prior permission and without reference. The whole or part of the website cannot be used on another website without permission. On the contrary, actions require legal and criminal responsibility. All other rights of DT ILETİŞİM HİZMETLERİ A.Ş. which are not expressly stated here are reserved.

DT İLETİŞİM HİZMETLERİ A.Ş reserves the right to update the content of this legal warning page whenever it wishes and advises its users to visit the legal warning page every time they enter the site.

Privacy and Cookie Usage Policy

DT İLETİŞİM HİZMETLERİ A.Ş. ,  We use internet cookies to provide a better usage experience to our visitors by observing the privacy and protection of personal data of the visitors of the website ('Website'). This Cookie Usage Policy ('Policy') explains to all our website visitors and users which type of cookies are used and under what conditions. Membership transactions and order-based lighting texts are available on our website.

This Policy is implemented regardless of what technologies, methods and how you connect to the Website. Therefore, we recommend that you read this Policy carefully and make a copy for future reference.

I. What is a cookie and for what purposes is it used?

Cookies are small data storage files saved on your computer, mobile phones, tablets or other mobile devices that you access by websites. This file stores information about your Web Site navigation. Thus, the devices you access will remember this data when you use the Website again. Therefore, cookies are necessary and important for you to use the Website effectively and more easily. Cookies are also used on the Website and third party websites so that we can offer you more suitable services, products or offers.

What are the main purposes of using cookies?

The need for some technical data for the more effective use of the Website, the collection of information about the Company's preferences and habits of browsing and using your Website, the need of your personal data such as your IP address in order for the Company to fulfill its legal and contractual obligations, especially those arising from the Law No. 5651 on Regulating Broadcasts Made on the Internet and Combating Crimes Committed Through These Broadcasts, and the Regulation on the Procedures and Principles Regarding the Regulation of Broadcasts Made on the Internet

II. What Type of Data Do We Process With Cookies?

Cookies, depending on their types, generally collect data regarding your browsing and usage preferences on the device you access the Website. This data includes all information about the pages you access, the products you view, and your navigation on the Website.

III. Which Types of Cookies Do We Use In Which Ways?

We use different types of cookies on the Website. These are cookies, function cookies, analysis/performance cookies and targeting/advertising cookies that are required to make the Website work.

Types of Cookies in Terms of Use

Compulsory Cookies

These cookies are absolutely necessary for the Website to function properly. These cookies are needed to manage the system and prevent fraudulent transactions, and if they are blocked, the Website will not be able to work.

Function Cookies

These cookies are used to give you a more advanced and easier user experience. For example, it fulfills the functions of remembering your previous preferences and enabling you to easily access some of the content on the Website. You can prevent the use of these cookies as detailed below.

Analysis and Performance Cookies

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Targeting and Advertising Cookies

These cookies are used to identify and serve you content that may be of interest to you, including advertising content. You can prevent the use of these cookies as detailed below. However, blocking these cookies will not completely block the advertising content, but instead of ads that may be of interest to you, ads with general content will be served.

Types of Cookies in Terms of Storage Period

Persistent Cookies

These are cookies that persist on a person's computer until a certain date or until they are deleted by the user. These cookies are mostly used to measure users' site movements and preferences.

Session Cookies

These cookies are used to log the user's visit and do not collect data from the user. The cookie is deleted when the user closes the web page he visited or remains inactive for a certain period of time. Target and tracking cookies are used on the Website to help third parties provide services, especially advertising services, and to increase the effectiveness of these services. These cookies can remember the web pages and sites you visit and collect personal data, especially the IP address of the user device. The Website is used by both first party and third parties to collect information, remember your interests and demographic data, and serve you targeted ads, improve ads, determine the number of visits and ad impressions, other uses of advertising services, and the ratio between those ad impressions and interactions with the ad services. uses party cookies. Website; It benefits from social plugins that provide links to social networks such as Facebook, LinkedIn, Instagram. When you visit the Website and use these plugins, the Website connects directly to the server of the selected social network. Then the content offered by the plug-in is transmitted directly from the social networks to your web browser and added to the website you are visiting. Thus, the relevant social network can access and process your data and combine it with the data of your account in the relevant social network.

Please note that we have no influence or control over the scope of data that social networks process via plugins. Please carefully review the personal data processing policies published by the relevant social networks for more information on the purpose, methods and duration of the social networks' processing of your personal data.

IV. How can you prevent the use of cookies?

The use of cookies allows the Website to serve better, but you can prevent the use of cookies if you wish. However, please note that in this case, the site may not function fully and you may not be able to benefit from all its features. To prevent the use of cookies, you need to change the settings of your internet browser. These changes vary depending on the device and internet browser you are using.

For detailed information about the cookie management functions of your browser, please click on the relevant link below and get information from your browser's website.

The Company uses cookies within the scope of the Clarification Text in addition to the Policy, and reserves the right to change the terms of use regarding cookies and the Cookie Policy.

Personal Data Sharing and Communication Permission

By signing the Personal Data Sharing and Communication Permission , your personal data that you have consented to be shared with us and to send all kinds of electronic communications and other communication messages in order to provide you with various advantages and to provide advertising, promotion, sales, marketing, information, promotion, campaign notification, membership transactions, survey and customer satisfaction surveys that are suitable for you personally and services within this scope you consent to the collection, recording, processing, storage, use and transfer/sharing to the following third parties for the same purposes by DT İletişim Hizmetleri A.Ş. and DT's other business partners, authorized dealers and services. The third parties to whom you have consented to the transfer/sharing of your personal data are as follows:

• Companies that provide research, promotion and consultancy services that process data on behalf of DT

This information will only be shared with third parties with whom we have a contractual relationship, who have the same legal and technical responsibilities as us in terms of data protection and security, and who comply with the provisions of the relevant legislation, only in case of need and to the necessary extent, in order to provide you with the services to be provided to you in a flawless manner, to deliver your possible shipments in a healthy way, to deliver our notifications by phone, sms and / or e-mail in a timely manner.

In accordance with Article 11 of the Law on the Protection of Personal Data No. 6698 ("KVKK"), you have the right to request to learn whether your personal data is a) processed, b) to request information if it is processed, c) to learn whether it is used in accordance with the purpose and purpose of processing, ç) to know the 3rd persons to whom it is transferred domestically / abroad, d) to request correction if it is processed incompletely / incorrectly e) to request that it be deleted / destroyed within the framework of the conditions stipulated in Article 7 of the Law on the Protection of Personal Data No. 6698, f) to request that the 3rd parties to whom you are transferred are notified of the transactions carried out in accordance with subparagraphs (d) and (e) above, g) to object to the occurrence of a result against you due to their analysis exclusively by automated systems, ğ) to request the compensation of the damage if you suffer damage due to unlawful processing.

In accordance with Article 11/d of the Personal Data Protection Law No. 6698, you can send and e-mail to contact@dt.net.tr/dtcloudnow.com in order to update / correct your records regarding your personal data, from your e-mail address registered in our company, in order to exercise your other rights under Article 11, you can send an e-mail to contact@dt.net.tr/dtcloudnow.com address with an e-mail signed with your own secure electronic signature, or you can sign a file in the format "word or pdf." addressed to our company and send it to the same e-mail address by signing it with a secure e-signature, or you can apply to the registered e-mail address available on the web page of our company with a secure electronic signature from your registered e-mail address or you can apply to our company address to the attention of the Financial Affairs and Human Resources department with a petition bearing your wet signature.

Personal Data Protection and Processing Notice

DT İletişim Hizmetleri A.Ş. Data Protection Clarification Text

Entrance

DT İletişim Hizmetleri A.Ş. ("DT”, or " Company") attaches great importance to the legal processing of the personal data of its customers and this Data Protection Clarification Text ("Clarification Text”) is the data protection disclosure text that reaches our company by any means and/or purchases products and services. or similar processing, in order to process the personal data of our customers in a transparent manner, has been prepared in accordance with Article 10 of the Personal Data Protection Law No. 6698 ("Law") and the European Union General Data Protection Regulation ("GDPR").

In this context, the Clarification Text provides information about the third parties with whom your data is shared, your rights and the methods by which you can contact us, especially which of your personal data we process as DT as data controller and for what purposes these data are processed.

If you are a customer subject to GDPR, we kindly ask you to visit for detailed information.

How Do We Obtain Your Personal Data? What is the Legal Basis for the Processing of Your Personal Data?

Your personal data; web, social media, customer conversations, SMS channels, business intelligence, contracted merchants, business / program partners and the agencies authorized to sell DT products and services and sales channels through them; if you request to receive services through these channels in verbal, written or electronic form by fully and partially automatic and non-automatic means, the website located at ……..com.tr ( "Website"); software and applications (" Application ") provided through computers or other smart devices; Social media accounts managed by persons authorized to provide services on behalf of DT, instant messaging applications that mediate the service provided by DT such as WhatsApp Business, Telegram, Facebook Messenger, WeChat, BiP, and all other digital channels to be referred to are obtained through "Digital Media" . In accordance with the Law, your personal data can only be processed if there is at least one of the conditions stipulated in the Law. We, as DT, regardless of the purpose for which we process your personal data in accordance with the provisions of national and international legislation, especially the basic principles in Article 4 of the Law and based on the personal data processing conditions listed within the scope of Articles 5 and 6 of the Law. In this context as DT İLETİŞİM HİZMETLERİ A.Ş. we process the personal data of our customers within the scope of our legitimate interests, provided that i) it is explicitly stipulated by law, ii) it is directly related to the establishment or performance of a contract iii) the obligations to which we are subject in accordance with the applicable national and international legislation and iv) it does not have a negative result on the fundamental rights and freedoms of our customers.

In addition to personal data processing requirements, in some cases we may request your express consent to process your personal data. In such cases, your personal data will be processed limited to the scope of the express consent you have given with your free will. You have the opportunity to withdraw your express consent at any time.

What Personal Data Do We Process?

The general information regarding your personal data processed by DT is as follows.

• Identity and Contact Information: Your personal data such as name, surname, identification number, passport information etc. and personal data such as e-mail address, telephone number, mobile phone number, social media contact information, address etc. that you have provided when creating an account, while receiving product and services.
• Your evaluations and requests: Evaluation information we have provided from you on our services
• Your payment information: Credit/debit card information, bank account information, IBAN information, balance information, credit balance and other financial information
• Marketing Information: Reports and evaluations showing the habits and tastes of the person associated with our customers and to be used for marketing purposes, targeting information, cookie records, information derived through data enrichment activities, information and evaluations obtained as a result of personal surveys, satisfaction surveys, campaigns and direct marketing studies.

For What Purposes Do We Process Your Personal Data?

DT processes your personal data for the following purposes.

• Contact: To inform you, about our  usual activities such as contacting our customers by SMS, e-mail or telephone in order to share confirmation information about your purchase of products, services, to convey payment or other information to you, (we would like to remind you that, Messages sent only for the above purposes or to provide similar service information may be sent to you by DT, even if you do not give consent to receive messages, they are not subject to approval pursuant to Article 6 of the Regulation on Commercial Communication and Commercial Electronic Messages)
• Evaluation of Your Requests and Opinions: Receiving and evaluating the opinions, complaints and evaluations of our customers about our services through written/online forms and surveys.
• Legal Obligations: Ensuring compliance with the national and international legislation to which DT is subject and fulfilling the obligations arising from the relevant legislation,
• Service Customizations: Suggesting and promoting the offered programs, services and products to the people concerned, and performing activities to customize them according to the usage habits and needs of the relevant people.
•  

To Whom and For What Purposes Do We Transfer Your Personal Data?

In some cases, we may transfer your personal data processed by us to third parties at home or abroad within the framework of the provisions of national and international legislation, especially Articles 8 and 9 of the Law.

The third parties to whom we may transfer your data are categorically as follows:

• Our business partners at home and abroad;
• Our group companies, e.g.  Some of the services offered by DT are carried out through our affiliates, and your personal data may be shared with our relevant group companies in this context.
• Our Suppliers; eg. As DT,  we receive technical support from software companies, security companies or companies that provide transportation services, etc.
• Authorized private institutions and organizations and public institutions authorized by national and international legislation; eg. law enforcement officers as part of investigations carried out

Information About Commercial Electronic Messages

In line with the permission you have given in accordance with the Law No. 6563 on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages, your personal data may be processed in order to provide information about our services, to promote our goods and services and to ensure that you are aware of our campaigns. In accordance with the relevant legislation, your commercial electronic message permissions must be recorded in the Message Management System (İYS) and in this context, the contact address (telephone number or e-mail address), permission date, communication channel, recipient type and permission source data will be shared with the İYS. You can visit https://iys.org.tr address to get detailed information about İYS.

What rights do you have as a data owner?

In accordance with Article 11 of the Law, you have many rights in relation to your personal data. In this section we would like to inform you about your rights and the methods of using them. Your rights under Article 11 of the Law are as follows:

• You can learn whether your personal data is processed by us,
• If your personal data has been processed by us, you can request information from us about this,
• Find out for what purposes we process your personal data and whether your personal data is used in accordance with these purposes,
• You can learn about the third parties to whom we transfer your personal data at home or abroad,
• If we have processed your personal data incompletely or incorrectly, you can request their correction and that these corrections are also forwarded to the third parties to whom we have transferred your personal data.
• Although we have processed your personal data in accordance with the Law and other relevant national and international legislation provisions, you may request the deletion or destruction of your personal data if the reasons requiring the processing of your personal data disappear and you may request that the corrections made in this context be forwarded to the third parties to whom we have transferred your personal data.
• In the event that a result arises against you by analyzing the data we process exclusively through automated systems, you can object to this result,
• In case you suffer any damage due to the processing of your personal data contrary to the Law, you can request the compensation of the damage caused by the unlawful data processing.
• If you are a passenger subject to GDPR, we kindly ask you to visit http//……….. for detailed information about your rights.

In order to easily exercise your rights mentioned above and to easily communicate the relevant requests to us, you can contact us via our contact information below. We will respond to you as soon as possible depending on the nature of your application and no later than thirty days. As a rule, applications of data owners are answered free of charge; however, in case of an additional cost, we reserve the right to charge you a fee according to the tariff to be determined by the Personal Data Protection Board.

Our Contact Information

DT İLETİŞİM HİZMETLERİ A.Ş.

Web – dt.net.tr

Tel - 0(850) 333 38 83

Adres - Cavusbasi Cumhuriyet Street No:391 Beykoz, Istanbul, Turkey

DT ILETISIM HIZMETLERI A.Ş. GDPR Privacy Statement

1.      Introduction of the Data Controller and this Privacy Statement

As the data controller, DT İletişim Hizmetleri A.Ş (hereinafter referred to as “DT” or “Company”) pays utmost attention to the legality of the processing of personal data of its customers. To ensure compliance with the European Union General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), we have prepared this Company GDPR Privacy Statement (“Privacy Statement”) on the protection and processing of personal data.

The security of our customers' personal data is at the forefront of our work. For this reason, in order to prevent unlawful access or leakage of personal data and to ensure that personal data of our customers are kept securely, this data is transferred only to reliable business partners and at a minimum level, by taking the necessary security measures in accordance with the legislation in force.

Transparency is one of the key issues in our personal data protection program. In this context, we have prepared this Privacy Statement in order to provide our customers with all necessary information when processing personal data, for example, to comply with our legal obligations and to provide a better customer experience. Detailed information on the types of personal data and the purposes of processing personal data are detailed in section 5 of this Privacy Statement.

Another issue we pay attention to is the right of customers to have control over their personal data. We take measures to ensure that our customers manage their preferences regarding their personal data and that they respect their preferences with the utmost respect. This Privacy Statement also explains your data protection rights, including the right to object to certain processing activities that DT performs.

 In summary, data security, transparency and the right of individuals to have control over their personal data are essential to us in ensuring compliance with GDPR.

This Privacy Statement contains our statements and explanations regarding the processing of personal data regarding other natural persons who communicate with us, excluding our customers and employees, in accordance with the provisions of the GDPR.

This Privacy Statement has been prepared to provide information about which personal data DT processes within the scope of its commercial activities, the purposes of processing, the parties to which personal data is transferred and the purposes of these transfers.

2.      Contact Information

If you have any concerns about how we process your data or if you wish to opt out of direct marketing under applicable law, you can reach:

DT İletişim Hizmetleri A.Ş.

Web site :         dt.net.tr

Phone      :        0(850)333 38 83

Address  :         Cavusbasi Cumhuriyet Street No:391 Beykoz, Istanbul, Turkey

3.      How Do We Collect Your Personal Data?

This section covers the source of information and the channels through which personal data is collected:

• Web, social media, customer conversations, SMS channels, business intelligence, contracted merchants, business/program partners and agencies authorized to sell DT products and services and sales channels through them; verbally, in writing or electronically, in whole or in part, by automated and non-automatic means.
• If you request to receive services through these channels, the website at dt.net.tr (“Website”); software and applications (“Application”) provided through computers or other smart devices; Social media accounts managed by persons authorized to provide services on behalf of DT, instant messaging applications such as WhatsApp Business, Telegram, Facebook Messenger, WeChat, BiP, etc. that mediate the service provided by DT, and all other digital channels to be referred to come together as "Digital Media".

4.      Which Personal Data Do We Collect and Process?

Personal data processed by our company differs according to the nature of the legal relationship established with our Company. In this context, the categories of personal data collected by our Company through all channels, including Digital Media, are as follows:

• Identity and Contact Information: Personal data such as name, surname, official identification number, passport information and contact information (such as e-mail address), telephone and mobile phone number or social media contact information, which you have given us when creating the account,
• Customer Transaction Information (personal data stored in channels such as call centers, credit card statements, purchase, cancellation, inclusive customer instructions and other changes to an individual's instruction or request.)
• Transaction Security Information (website password etc. information given during the use of products and services offered in Digital Media)
• Request/Complaint Management Information (such as information and records collected regarding requests and complaints regarding our products or services, and information contained in reports regarding the conclusion of these requests by our business units).
• Financial Information (credit/debit card information, bank account information, IBAN information, balance information, credit balance information and other financial information.)
• Physical Environment Security Information (Entry/exit logs, visit information, camera records in the physical environments of the company)
• Legal Procedure and Compliance Information (information provided within the scope of information requests and decisions of judicial and administrative authorities.)
• Audit and Inspection Information (Information on all kinds of records and transactions regarding the legal request of the data owner and the exercise of our rights.)
• Marketing Information (such as reports and evaluations attributable to the data owner and containing information indicating preferences, tastes, usage and travel habits used for marketing purposes, targeting information, cookie records, data generated within the scope of data enrichment operations, survey records, satisfaction, surveys, information and evaluations obtained as a result of campaigns and direct marketing activities.)
• Visual Information (photos, camera.)
• Voice Information Call center voice recordings with your explicit consent.

5.      Why Do We Process Your Personal Data and What is the Legal Basis for This Use (Purpose of Processing)?

We process your personal data for the following purposes:

• To fulfill a contract or take steps in connection with a contract we have with you. (According to Article 6/(1) of GDPR, Subparagraph 1(b)) This includes:

• Establishing communication with our customer and customer relationship management

In some cases, we are required to provide our customers with certain information about our flights. For example, we may need to contact you via SMS, email or phone to provide confirmation or payment information regarding the purchase of the product and/or Service. In addition, customers who benefit from the services offered through the Application can also be contacted via in-app notifications.

As necessary to conduct our business and pursue our legitimate interests (in accordance with Article 6/(1) GDPR, Subparagraph 1(f)), in particular:

• Requests and Evaluations:  Your personal data may be processed in order to take necessary actions in order to respond to the questions, requests or complaints of our customers through Digital Media or other written and verbal channels. The opinions of our customers are of great importance to us. For this reason, we may process personal data when evaluating our customers' responses to questions within the scope of customer satisfaction surveys in order to evaluate the quality of our services.
• Fraud prevention: We monitor the actions of customers in accordance with applicable laws to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime.
• Establishment of information technology infrastructure, execution and supervision of information security processes and operations: Personal data about you may be processed for the purposes of ensuring compliance with internal policies and procedures regarding information security, management, improvement and optimization of information technology systems. Ensuring the availability and reliability of these infrastructures and systems through backups and testing, improving the products and services provided, including statistical analysis and research of systems and programs related to ticketing and travel operations.
• Execution of financial and accounting transactions: Personal data about you may be processed for the purposes of complying with information obligations including identification and verification, preventing fraudulent transactions, receiving payments and reimbursement when deemed necessary.
• Service Customization: Presenting, recommending and promoting programs, services and products to the relevant people and performing activities to customize them according to their usage habits and needs.
• Usage Information: Your usage habits on our website and applications can be tracked in order to provide better service to our customers and to customize our services for you. In addition, information such as IP address, device model, etc. regarding the devices you view on our site or use our applications may be processed just for the purpose of providing services. Where required by law, marketing and advertising activities through targeting and profiling are only performed with your consent.

For purposes required by law (in accordance with Article 6/(1) GDPR, Subparagraph 1(c)) (legal obligations):

• Ensuring compliance with national and international legislation to which DT is subject and fulfilling the obligations arising from the relevant legislation. In response to requests from government or law enforcement agencies conducting an investigation.
• In such cases, it may be necessary to comply with business or tax retention requirements or to meet security-related requirements.
• When you have given us your consent (in accordance with Article 6/(1) of GDPR, Subparagraph 1(a)):
• Marketing activities: Where required by law, we will send you direct marketing related to our related products and services or other products and services provided by us, our affiliates and carefully selected partners, with your consent.
• Cookies: We place cookies and use similar technologies in accordance with our Cookie Notice and the information provided to you when these technologies are used. For more information see “Use of Cookies”

Revoking consent or otherwise objecting to direct marketing:

Wherever we rely on your consent, you will always be able to withdraw this consent, although we have other legal grounds to process your data for other purposes such as those set out above. You have an absolute right to opt out of direct marketing or profiling that we carry out for direct marketing at any time. You can do this by following the instructions in the communication, where this is an electronic message, or by contacting us using the information provided below.

6.      To Whom, Why and Where Do We Transfer Your Personal Data?

The recipients to whom we may transfer your data can be categorically listed as follows:

• Our business partners located in Turkey or abroad
• Group companies: Some of the services offered by DT are carried out by our affiliates, and in this context, your personal data may be shared with our related affiliates.
• Suppliers: Your personal data will also be shared with service providers, especially website hosting, software, maintenance, call centers.
• If the business is sold or integrated into another business, certain pieces of your information may be disclosed to our advisors and prospective purchasing advisors and passed on to the new owners of the business.

We will only transfer your personal data outside the EEA if appropriate security measures ensure that an appropriate level of protection is in place.

Further information on such transfers or copies of these measures can be obtained through the contact details above.

Third Party Websites: Our website may contain links to third party websites, microsites, plug-ins and applications. Please note that clicking or activating these links may allow third parties to collect or share data about the following. We do not control these third-party websites and are not responsible for their privacy statements. Therefore, please read the privacy statement of third parties whenever you use these links or microsites or leave our website. 

7.      How long will you keep my data?

DT is subject to legal obligations regarding data retention periods under Turkish law, European Law and national laws of a country (eg. USA, Germany, Italy, Spain, Switzerland etc.) depending on the country you live in or which law is applicable. As DT, as a global company, has locations in different countries and relevant laws have changed since then, retention periods may vary from country to country.

Your personal data will be deleted as soon as it is no longer necessary for the stated purposes. However, we may sometimes continue to store data until the retention periods and deadlines set by the legislative or supervisory authorities, depending on the periods specified by the Turkish Commercial Code, the Tax Code, the Turkish Code of Obligations and other applicable European legislation. After that, the relevant data is routinely deleted or anonymized.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and shortly thereafter (to allow us to fulfill your requests). We also keep a record of your request that we not send you direct marketing or process your data so that we can respect your request in the future.

8.    . Principles regarding personal data privacy

Principles regarding personal data privacy Our company acts in accordance with the following principles in all data processing activities. “Legality, fairness and transparency”, “purpose limitation”, “data minimization”, “accuracy”, “storage limitation”, “integrity and confidentiality” and “accountability”.

9.      Use of cookies

As DT, we use technologies such as cookies, pixels, GIFs (“Cookies”) to improve your user experience while using our websites and applications. The use of these technologies complies with the Law and other relevant regulations to which we are subject.

10.      Use of Digital Platforms

Your personal data may be processed during your use of the Digital Platforms in order to manage and operate the Website, to perform activities to optimize and improve the user experience of the Website and the Application, to identify and support the ways in which the Website is used. Improve the use of location-based tools to manage your online accounts and inform you about services available near you.

If you want to benefit from the products and services offered, your personal data will be processed only to enable you to benefit from these products and services.

11.      What Are Your Rights as Data Owners?

You have the following rights under GDPR

• Right to withdraw consent (Art. 7 GDPR) Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR) (Madde 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right of objection (Art. 21 GDPR)

Under GDPR or national law, your request may be limited to those rights if, for example, fulfilling your request would expose personal data about another person, it would violate a third party's rights (including our rights). Relevant exemptions are included in GDPR or applicable national laws. We will notify you of relevant exemptions that we rely on when responding to any request you make.

12.      Right to object to the processing of personal data (Art. 21 GDPR)

As mentioned above, you have the right to object to the processing of your personal data based on Article 6 (1) (e) or (f) of the GDPR, including profiling, at any time, on grounds relating to your particular situation.

We will no longer process personal data unless we demonstrate compelling legitimate grounds for processing that override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

Where personal data is processed for direct marketing purposes, you have the right at any time to object to the processing of your personal data for such marketing, including profiling, to the extent that it relates to such direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

In the context of the use of information society services and despite Directive 2002/58/EC, you can exercise your right to object by automated means using technical specifications.

13.      Data security

• We take all appropriate technical and organizational measures to protect your personal data and reduce the risks associated with unauthorized access, accidental data loss, deliberate deletion or damage to personal data.

In this direction, our company;

• Ensures data security by using other software and hardware, including virus and other malware protection systems, firewalls and intrusion prevention systems,
• Access to personal data within our Company is carried out in a controlled process in accordance with the nature of the data and on the basis of what needs to be known precisely,
• Provides necessary audits for the implementation of GDPR provisions in accordance with Article 32 of the GDPR,
• To ensure the legality of data processing activities through internal policies and procedures,
• Implements stricter measures for access to special categories of personal data,
• In case of external access to personal data due to outsourced service procurement, our Company undertakes to comply with the GDPR provisions of the relevant third party,
• Takes necessary actions to inform all employees, especially those with access to personal data, about their duties and responsibilities under GDPR.

14.      Changes to this Privacy Statement

We reserve the right to make changes to this Privacy Statement to provide accurate and up-to-date information on practices and regulations regarding the protection of personal data. In the event of a significant change in the Privacy Statement, data owners will be informed by appropriate means.