Privacy Policy.

OUR PERSONAL DATA PROCESSING AND PROTECTION POLICY AND DISCLOSURE TEXT

With this policy, Dataguess Teknoloji Sanayi ve Ticaret Anonim Şirketi (Dataguess

will be referred to as); customers, visitors and real persons, including staff,

that our country is a party to the Constitution of the Republic of Turkey, human rights

international agreements and the relevant law, especially the Law on the Protection of Personal Data No. 6698.

processing in accordance with the legislation and effectively exercising the rights of the persons whose data are processed.

basic principles regarding the use and protection of

In this direction, Dataguess, regarding all personal data of natural persons whose data is processed; give your data

KVKK, other relevant legislation and transactions regarding the processing, storage and transfer of

According to Dataguess Personal Data Processing and Protection Policy (Policy)

carries out.

Dataguess, in accordance with the relevant legislation and technology for the protection of personal data

takes the administrative and technical protection measures required by its nature.

Natural persons whose personal data are processed within the scope of the law, by examining the text below,

Personal data that may be processed by the Company in the capacity of data controller and the purposes of their processing,

groups of recipients to which it can be transferred, the method of collection, its deletion or anonymisation, and

learn about the rights of individuals.

1 SCOPE

Protection of personal data is only about real persons; legal persons and real persons

Data that does not contain information on the subject is not within the scope of the Policy. staff, visitors, customers,

potential customers, suppliers, website visitors and other personal data processed

All personal data obtained and processed during Dataguess activities of natural persons

It is covered by the Policy.

2 DEFINITIONS

express consent; consent on a specific subject, based on information and expressed with free will,

make anonymous; Personal data cannot be identified in any way, even by matching with other data.

making it impossible to be associated with a specific or identifiable natural person,

Related person; the real person whose personal data is processed,

Personal data; Any information relating to an identified or identifiable natural person,

Data processor; Processing personal data on behalf of the data controller based on the authority granted by him

natural or legal person,

data recording system; the registration system in which personal data is processed and structured according to certain criteria,

Data controller; data recording system, which determines the purposes and means of processing personal data.

the natural or legal person responsible for the establishment and management of

KVKK; Personal Data Protection Law No. 6698,

Policy; Dataguess's Personal Data Processing and Protection Policy

Registered Electronic Mail (REM); The sender and receiver identities are known, the shipping time

and secure electronic content that cannot be changed, legally valid in case of conflict.

refers to the postal service.

3 PRINCIPLES ON THE PROCESSING OF PERSONAL DATA

Dataguess complies with the general principles stipulated in the legislation, the Constitution and the KVKK in the processing of personal data.

acts in accordance with the principles listed below in the processing of personal data.

a) Compliance with the law and the rules of honesty: Dataguess, personal data processing activities

acts in accordance with the law and the rules of honesty; in the processing of personal data

only as much personal data as necessary, applying the principles of proportionality and necessity.

operates at a level suitable for processing purposes.

b) Being accurate and up-to-date when necessary: Dataguess ensures that the personal data they process is accurate and up-to-date.

takes the necessary measures to keep it up to date.

c) Processing for specific, clear and legitimate purposes: Dataguess processes personal data in a specific, clear and legal manner.

operates for the right reasons. Dataguess determines the purpose for which personal data will be processed and

It provides these purposes to the information of the data owners before the personal data is processed. Legitimate and

does not process unlawful personal data.

d) Being connected, limited and proportional to the purpose for which they are processed: Dataguess, not related to the purpose of processing

or avoids the processing of unnecessary personal data.

e) Preservation for the period required by the relevant legislation or for the purpose for which they are processed:

Dataguess, limited only to the periods stipulated by the laws or the purpose for which they are processed.

preserves.

4 PURPOSE OF PROCESSING PERSONAL DATA

Dataguess, within the personal data processing conditions specified in Articles 5 and 6 of the KVKK,

datas; In Article 5 of the KVKK; It is clearly stipulated in the laws, that the data controller is legal

obligation to fulfill its obligations, the conclusion or performance of a contract.

the processing of personal data belonging to the parties to the contract, provided that it is directly related

provided that it is necessary and does not harm your fundamental rights and freedoms,

The fact that data processing is mandatory for their interests operates within the scope of legal reasons.

a) Processing of data for business relationship: expressly stipulated in the Laws in Article 5 of the KVKK,

it is mandatory for the data controller to fulfill its legal obligations,

provided that it is directly related to the establishment or performance of the contract.

The necessity of processing the personal data of the parties may harm your fundamental rights and freedoms.

Data processing is mandatory for the legitimate interests of the data controller, provided that

Personal data of the personnel are collected and processed in line with legal reasons.

Establishment, arrangement, performance of employment contracts with personnel, human resources process

planning, documenting the entry and exit of work, fulfillment of legal obligations, paper

information and information that will form the basis of the work and transactions to be carried out on the Internet or in the electronic environment.

preparation of documents, reporting and examinations deemed legally required.

personal data within the scope of the purposes of ensuring order and security in the workplace

is processed.

Information given by the personnel (identity information, name, surname, TR identity number, gender,

especially the date of birth, contact data, e-mail address, address and telephone information, signed

signatures and similar information in documents) that are not automatic in employment contracts and personnel files.

It is collected and processed by the method and the automated method on computers; in the workplace

data within the scope of fingerprint reading system for security reasons and for the detection of entrances and exits.

The records and information are partially collected in line with the collection of

are collected and processed by fully automated methods.

The person to whom personal data can be transferred to the extent permitted by legislation and required by business processes and 

organizations, public legal entities and judicial bodies. The personal data in question are legal

For the purpose of resolving disputes or upon request, judicial authorities or the relevant law enforcement

be transferred to the forces. In addition, personal data, social security insurance coverage

due to legal obligations, due to legal obligations, due to transactions such as

may be shared with public institutions and other organizations.

b) Customer, prospective customers, representatives of legal entities that are customers, officials and liaison

personal data of the persons to be established, suppliers and visitors, website visitors

Processing: Your personal data is clearly stipulated in the Laws specified in Article 5 of the KVKK, data

It is mandatory for the responsible person to fulfill his legal obligations,

personal data of the parties to the contract, provided that it is directly related to the establishment or performance of the contract.

data processing is necessary, provided that it does not harm your fundamental rights and freedoms.

Legal reasons for data processing mandatory for the legitimate interests of the controller

within the scope of company activities, customers, prospective customers, legal entities with customers

representatives, officials and contact persons of persons, suppliers, our visitors

in terms of the establishment, arrangement, performance of contracts within the scope of commercial activities, legal

limited to the purposes of fulfilling obligations, on paper or

information and documents that will be the basis for the work and transactions to be carried out in the electronic environment.

issuing invoices, preparing and presenting price offers,

Personal data is processed within the scope of the purposes of ensuring order and security.

Personal data within the personal data processing conditions specified in Articles 5 and 6 of the KVKK; web

visit the website, visit the company headquarters, shares in telephone, e-mail correspondence, personal

sending the data electronically with the request for proposal, delivery in hard copy by post,

including personal information in the proposal text and also transferring information by the relevant persons; Moreover

In case of entering into a commercial or legal relationship with Dataguess, identity information (name,

contact data (e-mail), especially surname, TR ID number, gender, date of birth

address, address and telephone information, IP address), signature and other information in the signature circular

Partly or fully automated by Dataguess within the scope of Dataguess' field of activity.

methods are collected and processed.

Personal data processed by Dataguess can be used to fulfill legal responsibilities and

In order to ensure the performance of the contract, the requested product and / or service can be provided,

In order to be able to give product and / or price offers, the work processes and business processes allowed by the legislation

with real and legal persons, business partners, working together within the scope of the activity required,

suppliers, public institutions and organizations authorized to request this data, judicial bodies.

can be shared.

c) Data Processing in terms of Workplace Safety:

Legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person.

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

the fundamental rights and freedoms of the person concerned, based on the legal reasons that the processing is compulsory.

Provided that it does not harm Dataguess, it is safe to enter and exit the workplace and that the employees

uses the fingerprint reading system to detect the entrance and exit to the workplace.

The system is in the form of placing on the turnstile after entering the first entrance door of the workplace.

was created. Fingerprint records are collected and processed automatically. Workplace

If the records kept for the purpose of ensuring the safety of the workplace are violated or

where there is doubt about security, the right and legitimate interests, if necessary.

may be shared with judicial bodies in order to be protected; judicial authorities or relevant law enforcement authorities.

can be transferred.

5 CLASSIFICATION OF PERSONAL DATA

5.1. Personal data

Personal data; Any information relating to an identified or identifiable natural person. Personal

Data cannot be processed without the express consent of the person concerned.

However, in the presence of one of the following conditions, personal data without seeking the explicit consent of the person concerned

it is possible to process the data; Except for these cases, personal data without express consent

It doesn't seem possible to process:

a) It is clearly stipulated in the laws,

b) Those who are unable to express their consent due to actual impossibility or

the life or bodily integrity of the unrecognized person himself or another

necessary to protect

c) Provided that it is directly related to the establishment or performance of a contract,

It is necessary to process the personal data of the parties,

d) It is mandatory for the data controller to fulfill its legal obligation,

e) The person concerned has been made public by himself,

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

g) Provided that the fundamental rights and freedoms of the data subject are not harmed, the data controller's legitimate

The necessity of data processing for their interests.

5.2. Special categories of personal data

People's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs

attire, association, foundation or union membership, health, sexual life, criminal conviction and

Data on security measures and biometric and genetic data are special personal data.

6 DATAGUESS OBLIGATIONS

6.1. Obligation to Inform the Personal Data Owner

Dataguess determines the persons whose data will be processed during the acquisition of personal data, how their data will be processed.

clarifies how it will be handled. In the lighting text

a) Identity of the data controller and its representative, if any,

b) For what purpose the personal data will be processed,

c) To whom and for what purpose the processed personal data can be transferred,

d) Method and legal reason for collecting personal data,

e) The rights of the person concerned in Article 11 of the Law must be included.

6.2. Obligation to ensure data security

Dataguess takes administrative and technical measures to prevent the unlawful disclosure of personal data.

and updates its measures. Detecting unauthorized disclosure of personal data

to notify the Related Person and the Personal Data Protection Board.

form infrastructures.

To prevent unlawful processing and access of data by Dataguess,

Technological, administrative and technical measures are taken to ensure that

dataguess,

- Trains and supervises its personnel about the legal processing of personal data,

- Processes personal data limited to its commercial activities,

- In case of unlawful disclosure/data leakage of personal data,

It takes measures to notify the Conservation Board of the situation.

To prevent unlawful access to personal data;

- Establishing security systems,

- Taking technical measures, updating and renewing,

- Creating and auditing data recording systems in accordance with the legislation,

- It detects possible risks and develops systems against them.

7 EXPRESS CONSENT

Data about a specific subject, based on information and free will

Written or verbal consent, expressing the will for processing, is express consent. explicit consent data

can be withdrawn at any time by the owner.

Explicit consent, by having the explicit consent form signed by the data owner or by the contract to be made with the data owner or

can be obtained in electronic form by including these necessary elements.

8 RIGHTS OF PERSONAL DATA OWNERS AND ANSWERING APPLICATIONS

Personal data owners may apply in writing or by other methods to be determined by the Board.

and they can use their rights in the KVKK regarding their own data. In this context,

Dataguess is required to fulfill its obligations under Article 13 of the KVKK.

take administrative and technical measures.

Within the scope of KVKK, personal data owners have the following rights:

• Learning whether personal data is processed or not,

• If personal data has been processed, requesting information about it,

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

• Knowing the third parties to whom personal data is transferred in the country or abroad,

• Requesting correction of personal data in case of incomplete or incorrect processing,

• Although it has been processed in accordance with the provisions of the KVKK and other relevant laws,

requesting that it be deleted or destroyed in the event that the reasons requiring it disappear,

• In case of correction, deletion or destruction of personal data, these processes

requesting notification to third parties to which it has been transferred,

• By analyzing the processed data exclusively through automated systems,

to object to the emergence of a result against him,

• In case of damage due to unlawful processing of personal data,

You have the right to request removal.

Only requests of personal data owners sent to Dataguess in writing are processed.

According to the nature of the request, the relevant request is made as soon as possible and within 30 (thirty) days at the latest.

must be answered. Rejection of the application, insufficient response to the application, or

in case of not responding in time; 30 from the date the applicant learns the answer

(thirty) days and in any case within 60 (sixty) days from the date of application.

He has the right to lodge a complaint with the Protection Board.

9 EVALUATION PROCEDURE OF APPLICATION OF PERSONAL DATA OWNERS

In order to start the response period specified in article 8 of the Policy,

your requests, in writing and with wet signature, to Zümrütevler Mah. Nazmi İlker Sokak, No:3 Maltepe, Istanbul

address, by hand or via a notary public or other methods determined by the Personal Data Protection Board, together with the information and documents proving the identity of the applicant. If the request is accepted, the relevant process is applied and a notification is made in written or electronic form. In case of rejection of the request, the applicant is notified in writing or electronically by explaining the reason.

10 STORAGE OF PERSONAL DATA

Dataguess does not process personal data, except for the periods stipulated by the legislation.

It is stored for as long as its purpose requires.

The purposes of processing personal data are explained in 4 articles; are kept for the same purposes.

Although it has been processed in accordance with the provisions of the KVKK and other relevant laws,

In case of disappearance of the reasons requiring personal data, ex officio or upon the request of the person concerned

deleted, destroyed or anonymized by the data controller. Deletion of personal data,

Provisions in other laws regarding the destruction or anonymization are reserved.

Technical infrastructure systems are established and used by Dataguess; destroy, delete or

the provisions of the legislation and the decisions of the Personal Data Protection Board regarding anonymization.

is complied with.

11 DATA SHARING TERMS

In order for personal data to be shared, one of the following conditions must be met:

a) The explicit consent of the data subject has been obtained,

b) It is clearly stipulated in the laws,

c) Those who are unable to express their consent due to actual impossibility or

the life or bodily integrity of the unrecognized person himself or another

necessary to protect

d) Provided that it is directly related to the establishment or performance of a contract,

It is necessary to process the personal data of the parties,

e) It is mandatory for the data controller to fulfill its legal obligation,

f) The person concerned has been made public by himself,

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

h) Provided that it does not harm the fundamental rights and freedoms of the data subject, the legitimate

The necessity of data processing for their interests.

Dataguess personal data, expressly stipulated in the Laws,

obligation to fulfill its obligations, the conclusion or performance of a contract.

the processing of personal data belonging to the parties to the contract, provided that it is directly related

provided that it is necessary and does not harm your fundamental rights and freedoms,

It may be transferred based on legal reasons that data processing is mandatory for their interests. This

to act in accordance with the law, to fulfill legal obligations, to

It is legitimate, provided that it is established or performed and does not harm fundamental rights and freedoms.

to ensure their interests, to fulfill the requirements of employment contracts, to comply with legal obligations.

to perform the reporting and examinations deemed legally required,

declaration of invoices, giving price offers, fulfillment of tax obligations

limited and proportionate to the purposes of ensuring order and security in the workplace.

can be transmitted somehow. For these purposes, personal data,

• To our business partners,

• Public institutions and organizations,

• Legally authorized private legal persons,

• To our suppliers

• In case of need/demand, with judicial authorities, law enforcement officers, judicial bodies.

is shared.

Dataguess takes technical measures, including but not limited to:

• Internal technical measures for the processing and storage of personal data in accordance with the legislation

to create a technical infrastructure that will ensure security,

• Periodically updates and renews the technical measures,

• It makes virus protection systems, firewall and similar security applications.

Dataguess takes administrative measures, including but not limited to:

• Establishing personal data access policy and procedures within the company,

• Employees to process, store and protect personal data in accordance with the law.

informing and educating about

• It determines the measures to be taken in case of unlawful processing of personal data.

12 UPDATE

Dataguess, at least once a year, when necessary and when required by legislative changes.

review and update this Policy for the next time.