Protection of Personal Data

Illuminating Text on Protection and Processing of Personal Data

ePati Siber Güvenlik Teknolojileri San. Ve Tic. A.Ş. Informs about the protection and processing of personal data. ePati Siber Güvenlik Teknolojileri San. Ve Tic. A.Ş. (Protection of Personal Data No. 6698) concerning the use of personal data obtained from and / or obtained from the use of (Portal) by the web site at ePati.com, which is managed by the Company (hereinafter referred to as “ePati” for short) the fulfillment of the obligation to be informed by Article 10 of the Law on the Protection of Personal Data. It also informs Users in a transparent manner with regard to the purposes of collecting personal data collected by ePati or the Positive actions of Users and their entry into the Portal in connection with the use of the Portal by Users, for purposes of processing, legal reasons and rights.

ePati takes the highest possible level of security measures to ensure that personal data is collected, stored and shared in accordance with law to protect its privacy and to protect its privacy in order to better serve its users in the Internet domain. In order to accomplish this purpose, the personal data of the users are processed in the scope and conditions explained below.

ePati may update and amend this Disclosure Statement at any time by publishing it on the Portal. Updates and changes made by ePati will be effective from the date of publication on the Portal.

a) Data Responsible

In accordance with the Law on the Protection of Personal Data, your personal data is; will be collected and processed by ePati as the data responsibility as described below.

b) Personal Data Collected

ePati collects various static (static) and dynamic (variable) data from users with the following methods. The data collected by ePati depends on the services and features used by the Users.

Under this heading, the following data are processed in the scope of the Services provided by ePati and are considered as personal data in accordance with the Law on the Protection of Personal Data. Unless expressly stated otherwise, the terms “personal data” and “personal data of special interest” under the terms and conditions of this Notice contain the following information:

Name and Contact Information: Name, surname, mobile phone, home phone, business phone, address, e-mail address, billing information, TC identity number (national identity number), identity photocopy and other similar documents.
Authentication Information: User’s membership information, passwords used to authenticate and provide account access, User Name, contact information, user numbers,
Demographic data: Date of birth, age, gender, marital status, educational background, occupation, interests, preferred language.

Uses and Favorites: Reasons for calling ePati or Call Centers, including but not limited to data collected from your devices via various software and technological tools, voice recordings, date and time data of the product used, content read through the portal, labels, categories , The last login date to the portal, visited internet sites, the number of pages viewed, the length of the visit and the number of completions, the search terms entered, categories of news articles visited, errors during service use and similar problems.
Position Data: Includes data about the precise or approximate location of users. The location data extracted from the IP address and the port address by the GPS data is used when the user is using mobile applications of ePati and wants to search for content around his / her location and if the user permits it.

Payments: Subscriber invoice and payment information (name, surname, billing address, TC identity number, tax identification number), receipt sent to the member and payment receipts from the members, payment number, invoice number, invoice amount, invoice such as the date of slaughter.

Content Data: Similar data such as membership information, notification description, solution description, satisfaction, notification reason, customer note, subscription renewal date, error content indicated during use of the service, intermediate information status, intermediate information, search reason.

Survey Answers: The answers given by ePati to periodic surveys organized within the Portal

Where are Personal Data Stored and Processed?

Your personal data we obtain may be stored at home or abroad in another country where ePati or its affiliates, subsidiaries or cooperating service providers are located, and may be processed in accordance with and for the purposes of this Information.

Your personal data collected under this Notice will be processed within the scope of the legislation in force in the country where the provisions and data contained therein are stored and processed and within the prescribed security measures.

c) For which purpose Personal Data will be processed

Your personal data will be processed in accordance with the purposes set forth in this Notice and the Membership Agreement in accordance with the Policies and Procedures set forth in the Law on the Protection of Personal Data No. 6698 and for the purposes set out below:

Name and Communication Information: It is used for internal evaluation, communication, user registration, acquisition of potential subscriber information, development of after sales processes, business development, collection, promotion, analysis, complaint management, subscriber satisfaction processes, inspection, control, optimization, customer verification, marketing, sales, advertising, after-sales services, detection and prevention of fraudulent activity;
Authentication Information: User registration, problem / error notification, control, development and execution of operational activities, development of post-subscriber processes, business development, collection, internal evaluation, customer portfolio management, measurement of service quality, communication, optimization, , audit, customer verification, fraud detection and prevention;

Demographic Data: Promotion, internal evaluation, analysis, communication, development of after-sales processes, business development, collection, usage data and interests, frequent users, marketing, sales, advertising, control and control, risk management, sales development, communication, complaints management processes, execution and development of operational activities, registration, problem / error notification; business development, collection, internal evaluation, after-sales services, quality of service;

Uses and Favorites: User registration, problem / error notification, control, execution and development of operational activities, development of after sales services and after sales processes, business development, collection, in-house evaluation, online behavioral advertising and marketing, subscriber portfolio management, measurement and improvement of service quality, communication, optimization, control, risk management and control, promotion, analysis, determination of interests, scoring, profiling, marketing, sales, advertising, communication, complaint management, error notification;

Location data: Use of portal functions related to condominium or location, supervision and control, risk management;

Payment Certificates: Providers of invoicing processes, accounting, post-sale processes development, business development, collection, internal evaluation, scoring, profiling, customer relationship management, after-sales services, communication, marketing, control, processes carried out with;

Content: Business development, optimization, customer relationship management, audit, control, development of operational activities, business development, promotion, internal evaluation, subscriber management, analysis, scoring, profiling, post-sale processes development, services, communication, measurement of quality of service, development, execution of complaints management processes;

Survey Responses: Information requested from Users who responded to periodical surveys organized by ES ePati Portal within the Portal, the use of ePati and Portal functions and the use of the Portal by real and / or legal persons cooperating with ePati to fulfill these functions direct marketing, making statistical analysis, improving processes and creating databases for these Users by third parties and legal entities that have cooperated within the scope of all the above mentioned processing activities in accordance with their objectives;

rights, rights and obligations arising from contracts made by ePati with partners / customers / suppliers for the realization of legal and commercial obligations within the framework of contracts executed or activities carried out with third parties or legal entities that are in business relationship with ePati and legal arrangements to fulfill legal, commercial and legal evaluation processes, to conduct legal and commercial risk analysis, to execute the legal harmonization process, to execute financial affairs, to fulfill legal requirements, to fulfill the decisions of the authorized institutions, institutions and authorities, to respond to the requests, will be processed in accordance with the personal data processing requirements and purposes set forth in Articles 6 and 6.

Personal Data Retention

ePati and personal data obtained shall retain such information for the period required for the purpose for which they are performing in order to be able to use the Service in the best way possible to fulfill the obligations arising from the nature of the Membership Agreement and the conditions set forth in this Membership Agreement.
In addition, ePati may retain personal data for the duration of the statute of limitations set out in the applicable legislation, limited to the conduct of administrative or judicial proceedings under dispute in the event of any dispute arising from the Membership Agreement.

d) Who and what purpose of processing personal data can be transferred

ePati, the personal data of the User and the new data obtained by using this personal data, or personal information entered by the Users with their positive movements in the Portal primarily to perform the Services, to improve the user experience (including improvement and personalization), to ensure the safety of the Users , outsourcing service providers, cargo companies, law firms, law enforcement agencies, law enforcement agencies, law enforcement agencies, law enforcement agencies, law enforcement agencies, law enforcement agencies, software companies, agencies, consultancy companies, companies in the printing sector, banks, research institutions, call centers, complaints management and security assurance may be able to share with third parties and legal entities, including media representatives, and with the competent institutions, organizations, authorities, administrative and judicial bodies within the scope of legal obligations.

In addition, the User’s Name and Contact Information may be shared with payment entities pursuant to the framework agreement to be approved at the time of payment, and for verification of identity pursuant to the Regulation on the Prevention of Terror Financing and the Prevention of Terrorist Financing, published in the Official Gazette No. 26751 of 9 January 2008.

Your personal data obtained through the cookies placed on the device may be shared with the third parties for the purposes and purposes specified in this Notice.

ePati may transmit to third parties in the country as well as abroad as well as limited and proportionally for these purposes within the above categories and purposes.

d) Method of Collecting Personal Data and Legal Cause

ePati collects your personal data to work more effectively and provide you with the best experience. Your data is collected using the following methods:

Data You Have Directly Applied to ePati: refers to personal data provided by ePati Users in their own initiative for the performance of the Service and prior to or during the use of the Portal. This personal data includes all personal data provided directly by Users in the context of ePati positive actions. For example, name-surname, contact information, identity information, answers to the questionnaires, demographic data, and content information fall into this category.

Time-of-Use Data: The ePati provides personal data on the usage habits of users received through specific software or technological tools during the service provided by ePati. For example, location and frequency of use, as well as interest and usage data, are included in such data.
ePati can associate the behavior of the site with a cookie found on the browser and define the remarketing lists based on the metrics such as the number of pages viewed, the number of visits and the number of completions of the target, even if the visitor arrives on site to enable online behavioral marketing.

Your personal data collected through these methods can be processed and transferred to the purposes stated in this Information within the scope of the personal data processing conditions and purposes stated in Articles 5 and 6 of Law No. 6698.
Legal basis for collecting personal data;

• Membership Agreement, Terms of Use and based on them, the performance of the contract, establishment and protection of the right
• Legal regulations regulating e-commerce activities, financial and tax issues, consumer protection and other issues
• It is based on the legitimate interest in ePati’s activities related to the Portal, especially the prevention of fraud and the accumulation of the data necessary to carry out its services.

e) Measures and Commitments Regarding Data Security

ePati is committed to safeguarding personal data. Technical and administrative measures are taken using various methods and security technologies to ensure the appropriate level of security in order to prevent unauthorized processing and access of personal data and guard personal data.

ePati shall not disclose any personal data obtained to others in contradiction to the provisions of this Information and Protection of Personal Data Act No. 6698, and shall not use it except for the purpose of processing. ePati expressly warrants that outsourcing suppliers will perform the necessary warning and audit activities in order to comply with the commitments under this Article in the case of sharing personal data of users with outsourcing service providers in accordance with this Disclosure.

In case of linking to other applications via the portal, ePati does not bear any responsibility for the privacy policies and contents of the linked applications.

The User undertakes to update the information on this Information to the full, correct and up-to-date information and to update them immediately at ePati.com. If the User has not provided up-to-date information, ePati will not have any responsibility.

**f) The rights of the personal data holder mentioned in Article 11 of Law no.

As personal data owners, if you submit your requests for your rights to ePati through the means described below, ePati will conclude the request as soon as possible and within thirty days at the latest, free of charge. No response will be charged in ten pages. For each page above ten pages, 1 Turkish Lira processing fee will be charged. If the application is submitted in a recording medium such as a CD or flash memory, the fee will not exceed the cost of the recording medium which may be claimed by ePati.

This includes personal data owners;

• To learn whether personal data is processed,
• Requesting information about personal data if it has been processed,
• To learn the purpose of processing personal data and whether they are used appropriately for their purpose,
• Knowing the third parties to which the personal data are transferred in or out of the country,
• Requesting correction of personal data if it is incomplete or incorrectly processed, and requesting that the process performed in this context be notified to the third party to whom personal data is transferred,
• Requesting the deletion or cancellation of personal data in the event that the reasons for the processing have been processed in spite of being processed in accordance with the provisions of Law No. 6698 and other relevant laws and requesting that the process carried out within this scope be notified to the third parties,
• Objecting to the appearance of a result against the person himself by analyzing the processed data exclusively through automated systems,
• It has the right to claim damages in case of loss of personal data due to the processing of personal data in contravention of blood.

Your request for the use of your above mentioned rights is in Turkish; you can send your identity to Mersin Üniversitesi Çiftlikköy Kampüsü Teknopark İdari Binası Kat:4 No: 411 33343 Yenişehir / MERSİN with your identifying documents or you can forward it to bilgi@ePati.com.tr as your data responsibility.

ePati reserves the right to verify your identity before responding.

Your application;

1. Your name, surname and if your application is signed,
2. For the citizens of the Republic of Turkey T.C. your identity number, your foreign nationality, your passport number or, if applicable, your identity number,
3. The address of your place of residence or place of business,
4. If provided, your notifying e-mail address, telephone and fax number,
5. Your request,

it is compulsory to find the information and documents related to the subject should be added to the application.