INFORMATION NOTICE REGARDING THE PROCESSING OF PERSONAL DATA

This information notice has been prepared by Pdı.Net İnternet Bilgisayar Hizmetleri, acting as the data controller (hereinafter referred to as the “Data Controller” or the “Company”), in order to fulfill its obligation to inform under Article 10 of the Personal Data Protection Law No. 6698 (“Law”).

Pursuant to the provisions of the Personal Data Protection Law No. 6698, the personal data specified below, which are intended to be transferred by real persons whose data will be processed, shall be recorded in the Company’s database.

A-IDENTITY OF THE DATA CONTROLLER

TITLE	Pdı.Net İnternet Bilgisayar Hizmetleri San.Tic.Ltd.Şti
ADDRESS	Maslak Mah. Büyükdere Cad. Spring Giz Plaza Floor:5 Sarıyer, Istanbul
PHONE	0212 286 69 50
FAX	0212 286 69 80
E-MAIL	pdi@pdi.com.tr

B-PERSONAL DATA PROCESSED

Personal Data is defined in the Law as “any information relating to an identified or identifiable natural person.” Personal Data collected and/or processed within the scope of activities carried out by Pdı.Net İnternet Bilgisayar Hizmetleri includes the name, surname, signatures, passport-size photographs, Turkish Republic identity numbers, information on Turkish Republic identity cards/identity register information, passport information for foreign nationals, address information, telephone numbers and similar information of our customers, board of trustees and board of directors, personnel, subcontractors from whom services are received, suppliers and their employees; bank and bank account information, bank payment information, bank payment receipts, photographs used on the website, health data relating to health status that the Company is required to obtain under applicable legislation, contact information (address, mobile phone, telephone, fax and e-mail address), audio and/or video recording security cameras, and Turkish Republic identity number information collected when entering institutions.

C-GENERAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA

Personal data are processed by our Company, which acts as the data controller, within the framework of the principles regulated under Article 4 of the Personal Data Protection Law No. 6698 and listed below:

• Being processed for specific, explicit and legitimate purposes and, where necessary, being up to date,
• Being processed lawfully and fairly,
• Being relevant, limited and proportionate to the purposes for which they are processed,
• Being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed

D-PURPOSES OF PROCESSING DATA

Pursuant to Articles 5 and 6 of the Personal Data Protection Law, personal data that will be collected or have been processed to date must be processed for the purposes set out in the legal regulations and for the purposes listed below or similar purposes:

a. Customers:

Necessary information such as name-surname, Turkish Republic identity number, passport number for foreign nationals, contact information, photograph and bank account information is obtained and recorded for the purpose of concluding contracts with customers where necessary.

b. Camera Data:

Audio and/or video recordings are obtained through security cameras for the purposes of ensuring the security of institutions and customers, controlling entries and exits to buildings and facilities, increasing personnel efficiency and determining working conditions, proving the employment relationship, proving possible judicial incidents through camera footage, and reducing congestion during entry-exit hours.

c. Visitor Data:

For security purposes, the name-surname, Turkish Republic identity/passport number/driver’s license number, entry-exit times and information on whom they will meet are obtained and recorded for visitors coming to our institution.

d. Company Personnel Data:

Data are obtained for the purposes of evaluating job applicants, inviting them to interviews, creating personnel files, fulfilling other legal obligations determined by the Labor Law No. 4857, the Social Insurance and General Health Insurance Law No. 5510, the Turkish Code of Obligations No. 6098, the Turkish Commercial Code No. 6102 and other legislation, proving the Company’s employment relationship with the relevant personnel, and effectively exercising its rights of claim and defense in a possible judicial process.

e. Data Obtained Within the Scope of Service and/or Commercial Business Relationships:

Within the scope of the Company’s commercial business relationships with third parties, such as the purchase of goods and services, leasing, etc., necessary professional information such as name-surname, Turkish Republic identity number, passport number, signature circulars, contact information, title/business department, qualification certificate, professional chamber information, and financial information such as account number of the parties, their representatives, personnel and relevant persons are obtained for the purpose of proving contracts and securing services mutually.

E-COLLECTION, PROCESSING AND TRANSFER OF PERSONAL DATA

Your personal data may be collected verbally, in writing or electronically, by automatic and non-automatic means, through all workplaces and all affiliated business units of our institution, our website, social media accounts, integration systems, parties from whom our institution receives services that are complementary to or an extension of its activities, contracted institutions, business partners, suppliers and similar means, including but not limited to these.

The Company may share your personal data with employees, financial advisors, subcontractors/suppliers from whom it procures services and goods, companies that prepare, process and store the Company’s software, and legally authorized public institutions, and may also transfer certain statistical information abroad by anonymizing it. Confidentiality agreements are concluded with real and legal persons for all transferred and shared data, and the utmost care is taken when working with software companies in terms of data security.

Your personal data that are required to be retained under legislation such as the Labor Law, Tax Law, etc. shall be stored by the Company for an appropriate period.

Pursuant to Article 5 of the KVKK, in the following cases, the Company may process your personal data specified above and obtained in accordance with the law without seeking your explicit consent:

• Where it is expressly provided for by laws,
• Where it is mandatory for the protection of the life or physical integrity of yourself or another person, in cases where you, as the data subject, are unable to express your consent due to actual impossibility or where your consent is not legally valid,
• Where the processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract you have concluded with companies/organizations affiliated with Pdı.Net İnternet Bilgisayar Hizmetleri,
• Where it is mandatory for the Company to fulfill a legal obligation,
• Where your personal data have been made public by you,
• Where data processing is mandatory for the establishment, exercise or protection of a right, and
• Where data processing is mandatory for the legitimate interests of the Company, provided that it does not harm your fundamental rights and freedoms.

F-RIGHTS OF PERSONS WHOSE DATA ARE PROCESSED

Pursuant to Article 11 of Law No. 6698;

“Everyone has the right to apply to the data controller and, with respect to themselves, to;

1. Learn whether personal data are being processed,
2. Request information if personal data have been processed,
3. Learn the purpose of processing personal data and whether they are used in accordance with their purpose,
4. Know the third parties to whom personal data are transferred domestically or abroad,
5. Request correction of personal data if they have been processed incompletely or incorrectly,
6. Request deletion or destruction of personal data within the framework of the conditions set forth in Article 7,
7. Request notification of the transactions carried out pursuant to subparagraphs (d) and (e) to third parties to whom personal data have been transferred,
8. Object to the occurrence of a result against the person themselves by analyzing the processed data exclusively through automated systems,
9. Request compensation for damages in case of suffering damage due to unlawful processing of personal data,

rights.”

Pdı.Net İnternet Bilgisayar Hizmetleri shall conclude your request free of charge as soon as possible according to the nature of the request and, in any case, within 30 (thirty) days at the latest.

You may submit your requests containing your explanations regarding the rights you wish to exercise among the rights specified in Article 11 of the Personal Data Protection Law, together with the necessary documents identifying your identity, by written and signed petition, delivered in person to Maslak, Büyükdere Cad. Meydan Sok. Spring Giz Plaza 30/A, 34398 Sarıyer/Istanbul, or sent via notary public or registered mail with return receipt.