İnform Elektronik Sanayi ve Ticaret A.Ş.

Clarification Text Regarding Processing of Personal Data

As İnform Elektronik Sanayi ve Ticaret A.Ş., we pay great importance on confidentiality and security of your personal data.

Within this scope, processing and storing all types of personal data in accordance with The Law on Protection of Personal Data ("LPPD") of all persons related to İnform Elektronik Sanayi ve Ticaret A.Ş. including our business contacts and our customers having benefit from our products and services, are amongst our priorities. With the title of "Data Officer" we carry as per LPPD and awareness of our responsibility, we would like to inform you as stated below about the purpose of processing your personal data, data collection method and reasons, your rights about processing your personal data and application principles and procedures that are methods of using those rights.

a. What is Personal Data? Which personal data of yours we collect?
Personal Data refers all types of information ("Personal Information") such as primarily personal information of your identity (name, surname, TRIN etc.), address and telephone information, vehicle and plate information, personal status information, IP address, bank account information those can be regarded with you and your data related with race, ethnic origin, political opinion, philosophic belief, religion, sect or other beliefs, appearance, association, foundation or union membership, health, sexual life, penal conviction and security measures if it is a Private Personal Data as a special type and sensitive personal information ("Private Personal Data") such as your biometric and genetic data. Explanations those are made for your Personal Date on that page, cover your Private Personal Data.

Within this scope, as İnform Elektronik Sanayi ve Ticaret A.Ş., we collect Personal Data belonging to our customers, business contacts, employees, employee candidates, platforms (our internet / mobile sites and applications), users, visitors, subcontractors and authorized persons and employees of the institutions those we have similar business relation in accordance with LPPD when it is required. We can detail Personal Data we collect as stated below:

Identity Data: It is data regarding identity of a person such as name, surname, TRIN, identity card photocopy those we collect from our customers, business contacts, employees, employee candidates, platforms (our internet / mobile sites and applications), users, visitors, subcontractors and authorities and employees of institutions those we have similar business relation

Communication Data: It is data ensuring to establish a communication system with a person such as telephone number, address, e-mail address and IP address those we collect from our customers, business contacts, employees, employee candidates, platforms (our internet / mobile sites and applications), users, visitors, subcontractors and authorities and employees of institutions those we have similar business relation.

Data Regarding Family Members: It is data regarding family members and relatives of a person that we collect from authorized persons and employees of the institutions those we have similar business relations, from subcontractors, employees and employee candidates with the purpose of protecting legal and other interests of our company or related person and/or as per required by related regulations.

Financial Data: It is data such as fee, wage information, bank account information that we collect from authorized persons and employees of the institutions those we have similar business relations and from subcontractors, our business contacts, customers, employees and employee candidates based on legal relation that our company established with related person.

Personnel Data: It is all types of personal data that is base for forming personal rights of natural persons those have working relations with our Company that we collect from employees of the institutions those we have similar relation and from our employees, employee candidates, subcontractors.

Physical Place Security Data: It is personal data such as security and camera records taken during remaining time in a place and in entrance of a physical place that we collect from our customers, business contacts, employees, employee candidates, visitors and subcontractors and authorized persons and employees of the institutions those we have similar business relation.

Communication and Complaint Management Data: It is personal data obtained from our customers, business contacts, platforms (our internet / mobile sites and applications), users, visitors, subcontractors and authorized persons and employees of the institutions those we have similar business relation in receiving and assessing processes of all types of complaints and demands from our Company.

Private Personal Data: It is data such as health data, biometric data (sound and video records), religion and association and union that they have membership indicated in article 6 of LPPD, that we collect from our customers, business contacts, employees, employee candidates, visitors, subcontractors and authorized persons and employees of the institutions those we have similar business relation.

Other Data: It is data collected with automated means via processed data, purchasing information, cookies and other means for technical transaction security that we collect from customers, business contacts, employees, employee candidates, platforms (our internet / mobile sites and applications), users and subcontractors and authorized persons and employees of the institutions those we have similar business relation.

b. With which methods and legal reasons we collect / process your personal data?

We collect your Personal Data with below purposes and methods and means those are automated or not automated via other channels those can be added in future, as audial, verbal, written or electronic format.

We collect your Personal Data over our social media accounts operated on behalf of İnform Elektronik Sanayi ve Ticaret A.Ş. on various social media channels, our internet and mobile platforms (our internet / mobile sites and applications), via our call center operated by İnform Elektronik Sanayi ve Ticaret A.Ş., via other communication methods including e-mail, short messages ("SMS") or multi-media messages ("MMS"), via business cards and other documents given by you within the scope of customer visits those we made and submitted commercial offers, printed and electronic forms and Contracts those we signed with your company where you are an authorized person or your personally within the scope of customer visits we made, with various methods those are automated as a part of any data record system or partially automated or wholly automated on condition that it is on verbal, written or electronic environment via various channels including sources such as Trade Registry and via third persons such as İnform Elektronik Sanayi ve Ticaret A.Ş. group companies, business contacts, dealer and sales channel, producer companies or companies those they procure service/product.

We process your Personal Data that we collect in line with above given methods, based on one or more of above mentioned legal reasons:

• Having your explicit consent,
• Having permit for processing provisions of regulations and laws in force in Republic of Turkey,
• In case that you cannot provide your consent due to actual impossibility, being obliged to protect life or body integrity of yourself or another person,
• Need for execution of a contract that is signed by your or your company,
• Need to process your Personal Data with the purpose of performing our legal obligations,
• Making your Personal Data public by yourself,
• Need for protection and using our contractual or legal rights as İnform Elektronik Sanayi ve Ticaret A.Ş.,
• Need for processing your Personal Data for our legitimate interest on condition not to harm your basic rights and freedoms.

As İnform Elektronik Sanayi ve Ticaret A.Ş., we retain all Personal Data by taking all administrative and technical measures required as long as legitimate purposes are not removed in any case and in accordance with the periods those are obligatory in LPPD and other regulations.

c. For what purpose do we process your personal data?

We process your Personal Data we collect based on its nature with general purposes given below:
(1) Performing contract requirements signed by İnform Elektronik Sanayi ve Ticaret A.Ş., supplying provided products and services, performing production, sales, delivery and installation transactions, improving products and services and making required works and assessments to make you have benefit from them, performing after sales maintenance and repair transactions
(2) Performing and tracking obligations sourced from consumer regulations and responding consumer applications
(3) Tracking demands and complaints of related persons such as customer and consumer, assessing and providing support services, managing consumer satisfactions and practicing planning, statistics and satisfaction surveys within this scope
(4) Performing quality assessment and improvement works to ensure sustainability and to provide better and trustable product and services, auditing suppliers, sub-contractors and the persons those we have similar business relation
(5) Performing advertisement and marketing activities for products and services provided by İnform Elektronik Sanayi ve Ticaret A.Ş., making notification about introduction, promotion, campaign, offer, activity and similar subjects and new products and services, operating organizational communication activities
(6) Performing marketing and CRM (Customer Relation Management) works
(7) Organizing organizational communication and other events and calls within this scope and making notification about them, operating market research works
(8) Improving digital platforms we provide for use of our customers, consumers and business contacts and revealing number of users, type, visiting frequency, behaviors, geographical locations of users and similar statistics with the purpose of providing a customized and productive experience for platform users, submitting customized content, campaign and advertisements according to platform users' area of interests and needs (internet and mobile site and applications), using cookies with this purpose
(9) Providing legal and commercial security of the persons who have business relation with İnform Elektronik Sanayi ve Ticaret A.Ş. (planning administrative operations for communication performed by our company, ensuring physical security and audit of locations of the company, business partner/ customer/ supplier (authorized ones or employees) assessment and audit processes, legal compliance process etc.)
(10) Using legal rights, using information related with transaction background as evidence after legal relation is over
(11) Determining and practicing İnform Elektronik Sanayi ve Ticaret A.Ş. commercial, legal and business strategies
(12) Performing İnform Elektronik Sanayi ve Ticaret A.Ş. human resources, accountancy/finance policies
(13) Planning, auditing and performing information security processes
(14) Compliance with domestic and international regulations, providing information demanded by public institutions and organizations, performing reporting obligations.

d. Transferring Personal Data and Processing Personal Data by Third Persons

The company can transfer personal data to a third natural or legal person in accordance with LPPD regulations. In such case, the Company ensures that third persons who received it, follow this Policy. Within this scope, required protective regulations are added to the contracts those are issued with third persons.

• Personal data transfer to third persons located in Turkey; can be made by the Company without need for explicit consent in exceptional cases indicated in article 5.2 and article 6.3 of LPPD or via obtaining explicit consent of related person in other cases (LPPD article 5.1 and article 6.2).
• Personal data transfer to third persons located abroad, can be made by the Company without need for explicit consent in exceptional cases indicated in article 5.2 and article 6.3 of LPPD or via obtaining explicit consent of related person in other cases (LPPD article 5.1 and article 6.2). In addition to that, presence of one of below conditions is required in terms of the country where it will be transferred.
• Having a foreign country where personal data is transferred, within the status of the countries where sufficient protection is provided, by the Board
• In case that a foreign country where transfer will be realized, does not take place in the safe country list of the Board, on condition to obtain permission from the Board by making a written promise regarding that sufficient protection will be provided, by Data Controllers in related country and by the Company

e. Your Rights and Application Procedure
e.1. Your Rights Regarding Your Personal Data
We would like to state that you have below given rights regarding your data be processed in İnform Elektronik Sanayi ve Ticaret A.Ş. and its affiliates:
(1) Learning whether your personal data has been processed,
(2) Knowledge acquisition regarding your Personal Data if it is processed
(3) Learning the purpose of processing personal data and whether or not personal data has been used in accordance with declared purpose
(4) Learning third persons at home and abroad those your data has been transferred, if any and learning which data has been transferred,
(5) Requesting correction of your processed personal data, if such data has been processed incompletely or incorrectly,
(6) Requesting to inform those third persons who received your Personal Data in case that your personal data has been corrected, deleted or demolished,
(7) Requesting to delete or demolish your processed Personal Data in case that the reasons to process your personal data are removed or your personal data is lost its up-to-dateness,
(8) Objecting to a result against you as a result of analyzing your Personal Data via automated systems,
(9) Requesting to compensate your loss in case you face with a loss as a result of unlawful processing your Personal Data.

e.2. Application
You can make your requests regarding your Personal Data by filling application form which its link is given below:
1. By delivering to welcome desk in our company address taking place in identity information of Data Officer or by making notification to the same address via Notary,
2. It can be made via registered electronic mail.

İnform Elektronik Sanayi ve Ticaret A.Ş. will finalize requests those it receives, as soon as possible based on nature of that request and at least within 30 (thirty) days as free of charge. In case of occurrence of a cost due to performing your request, we can demand only fees taking place in the tariff determined by Personal Data Protection Board. ( Please click for application form )

Requests those are directed to İnform Elektronik Sanayi ve Ticaret A.Ş., can be accepted or rejected by explaining its reason and we can deliver those responds to the persons who make requests, in written or on electronic environment. In case that a request is accepted, we, as İnform Elektronik Sanayi ve Ticaret A.Ş., are obliged to perform that requirement immediately.

e.3. Complaint
In case that your requests those are directed to İnform Elektronik Sanayi ve Ticaret A.Ş. and these requests are rejected by İnform Elektronik Sanayi ve Ticaret A.Ş. but you are not satisfied by related respond or you never receive a respond, you can make a complaint to Personal Data Protection Board within 30 days after the end of the period taking 30 (thirty) days in case you do not receive a respond and within 30 (thirty) days from the date when you receive that respond.

f. Data Officer Identity Information
The expression of İnform Elektronik Sanayi ve Ticaret A.Ş. used in this text, has been issued for two İnform Elektronik Sanayi ve Ticaret A.Ş. affiliates that information is given below and those established in Turkey and it has been issued for related persons of data that data officer of below mentioned companies, is responsible to deal with:

İnform Elektronik Sanayi ve Ticaret A.Ş.
General Directorate
Esenşehir Mah. Hale Sk. No:6/1 Ümraniye-İSTANBUL
Tel: +90 (212) 368 28 00
Fax: +90 (216) 621 92 31

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