Clarification Text on the Processing of Personal Data

Commercial Electronic Message

This Clarification Text on the Processing of Personal Data is valid for the data held by the company, which has the status of data controller, for the relevant person group specified in the top right box.

1. WHY ARE WE SENDING THIS TEXT?

As TWISER BİLİŞİM DANIŞMANLIK TİCARET VE EĞİTİM ANONİM ŞİRKETİ (hereinafter referred to as “Data Controller” or “Company”), we provide this “Clarification” text to inform you about the “Data Controller’s Obligation to Inform” (Article 10) and the “Rights of the Data Subject” (Article 11) as stipulated in the Law No. 6698 on the Protection of Personal Data (“KVKK”) and the Communiqué on the Principles and Procedures to be Followed in Fulfillment of the Obligation to Inform, published in the Official Gazette No. 30356 dated 10.03.2018. This text aims to inform you about the purpose of processing your personal data, to whom and for what purposes your processed personal data may be transferred, the method and legal reason for collecting your personal data, and other rights enumerated in Article 11 of the KVKK.

2. WHAT INFORMATION DO WE PROVIDE?

• Which personal data is collected
• The purposes for processing your personal data
• With whom and for what purposes your personal data is shared
• The method and legal reason for collecting your personal data
• Data deletion processes
• Your rights under the KVKK

3. WHAT PERSONAL DATA DO WE PROCESS?

If you consent to receive commercial electronic messages to be informed about announcements and new developments, the following personal data will be processed based on your explicit consent for the purpose of sending commercial electronic messages via email and/or SMS, depending on your choices:

• Identity Information: Name and surname
• Contact Information: Email address, phone number
• Transaction Security: IP address, website entry-exit log records, system log records
• Legal Transaction Data: Records of consent and rejection for receiving commercial electronic messages
• Marketing Data: Contents of commercial electronic messages sent to you, the date, and records of commercial electronic message delivery

4. WITH WHOM AND FOR WHAT PURPOSES DO WE SHARE YOUR PERSONAL DATA?

Your personal data may be shared with our company lawyer, judicial or administrative authorities requesting information, third-party service providers, or public institutions or organizations authorized to request these data as a legal obligation, in cases of legal disputes, investigations, judicial or administrative audits, and other cases, for the purpose of ensuring our legal defense rights and responding to official or legal information and document requests, in accordance with the law and the principles of honesty, accurately and up-to-date, for specific, clear, and legitimate purposes, limited and measured.

5. WHAT IS THE METHOD AND LEGAL BASIS FOR COLLECTING AND PROCESSING YOUR PERSONAL DATA?

We automatically collect your personal data through the form mentioned in section 3 and cookies during your visits to the site, record them digitally in the information system, store them on physical servers and cloud servers, and process them through non-automatic means such as creating databases, making lists, filling out forms, writing petitions, depending on the nature of the work and the nature of the personal data that needs to be processed.

6. WHAT ARE THE PURPOSES AND LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA?

• Identity Information: Your personal data is processed for the purposes of ensuring activities are carried out in compliance with the legislation, following and conducting legal affairs, conducting communication activities, managing business activities/audits, managing customer relationship processes, conducting activities aimed at customer satisfaction, conducting marketing analysis studies, managing advertising/campaign/promotion processes, conducting strategic planning activities, conducting marketing processes for products/services, and providing information to authorized persons, institutions, and organizations.
  • Legal Grounds: Article 5/1 of the Law No. 6698, “Explicit Consent”
• Contact Information: Your personal data is processed for the purposes of ensuring activities are carried out in compliance with the legislation, following and conducting legal affairs, conducting communication activities, managing business activities/audits, managing customer relationship processes, conducting activities aimed at customer satisfaction, conducting marketing analysis studies, managing advertising/campaign/promotion processes, conducting strategic planning activities, conducting marketing processes for products/services, and providing information to authorized persons, institutions, and organizations.
  • Legal Grounds: Article 5/1 of the Law No. 6698, “Explicit Consent”
• Transaction Security: Your personal data is processed for the purposes of conducting marketing analysis studies, following and conducting legal affairs, ensuring activities are carried out in compliance with the legislation, providing information to authorized persons, institutions, and organizations, conducting information security processes, ensuring the security of data controller operations, and managing access authorizations.
  • Legal Grounds: Article 5/2 (a) of the Law No. 6698, “It is expressly provided for by the laws.”
• Legal Transaction Data: Your personal data is processed for the purposes of ensuring activities are carried out in compliance with the legislation, following and conducting legal affairs, managing business activities/audits, and providing information to authorized persons, institutions, and organizations.
  • Legal Grounds: Article 5/2 (a) of the Law No. 6698, “It is expressly provided for by the laws.”
• Marketing Data: Your personal data is processed for the purposes of ensuring activities are carried out in compliance with the legislation, following and conducting legal affairs, conducting communication activities, managing business activities/audits, managing customer relationship processes, conducting activities aimed at customer satisfaction, conducting marketing analysis studies, managing advertising/campaign/promotion processes, conducting strategic planning activities, conducting marketing processes for products/services, and providing information to authorized persons, institutions, and organizations.
  • Legal Grounds: Article 5/1 of the Law No. 6698, “Explicit Consent”

7. YOUR RIGHTS UNDER THE KVKK

By applying to our company, you have the right to: a) Learn whether your personal data is processed, b) Request information if your personal data has been processed, c) Learn the purpose of processing your personal data and whether they are used in accordance with their purpose, ç) Know the third parties to whom your personal data is transferred, domestically or abroad, d) Request correction if your personal data is incompletely or incorrectly processed, e) Request the deletion or destruction of your personal data under the conditions stipulated in Article 7 of the KVKK, f) Request notification of the processes carried out under subparagraphs (d) and (e) to third parties to whom your personal data is transferred, g) Object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems, ğ) Request compensation for damages in case of unlawful processing of personal data.

To use the above-mentioned rights, you can submit your request in Turkish and in writing or through a registered electronic mail (KEP) address, secure electronic signature, mobile signature, or using the electronic mail address previously notified to our Company and registered in our system, in accordance with Article 13, paragraph 1 of the KVKK and the Communiqué on the Principles and Procedures for Application to the Data Controller No. 30356 dated 10.03.2018. In applications, information will only be provided about the applicant, and it will not be possible to obtain information about other family members and third parties. Our company reserves the right to verify your identity before responding to your application.

In your application:

• Your name, surname, and signature if the application is in writing,
• For Turkish citizens, your Turkish ID number; for foreigners, your nationality, passport number, or if any, your ID number,
• Your place of residence or business address for notification,
• Your electronic mail address, telephone, and fax number, if any,
• Your request must be present, and any information and documents related to your request must be attached to the application, if any.

You can submit your written applications with the necessary documents to the address: Dijitalpark Teknopark, Kirazlıdere Mah., Eski Ankara Cad., 4/3/19, Çekmeköy/Istanbul as the data controller.

You can also submit your applications using the electronic mail address previously notified to our Company and registered in our system via info@twiser.com.

You can also submit your applications by signing with a secure electronic signature within the scope of the Electronic Signature Law No. 5070 and through the Registered Electronic Mail (KEP) address to our KEP address. KEP addresses can only receive deliveries from KEP domain addresses.

Depending on the nature of your request, all information and documents necessary to verify your identity must be fully and accurately provided to us. If the requested information and documents are not provided correctly, there may be difficulties in conducting a full and qualified investigation in response to your request. In this case, our company declares that it reserves its legal rights. Therefore, your application must be submitted with all the requested information and documents for verification purposes, according to the nature of your request.

8. MEASURES FOR PROTECTING YOUR PERSONAL DATA

The protection of personal data is an important issue for our company. Our company takes necessary technical and administrative measures to protect personal data against unauthorized access or loss, misuse, disclosure, alteration, or destruction. Our company undertakes to keep your personal data confidential, to take all necessary technical and administrative measures to ensure confidentiality and security, and to show due care.

Despite our company taking necessary information security measures, in case personal data is damaged or falls into the hands of unauthorized third parties as a result of attacks on the website and the system, our company will immediately notify you and the Personal Data Protection Board of this situation.

9. KEEPING YOUR PERSONAL DATA ACCURATE AND UP-TO-DATE

Individuals who share their personal data with our company acknowledge that keeping this information accurate and up-to-date is important in terms of both the rights they have under the Law No. 6698 on the Protection of Personal Data and the relevant other legislation, and they accept and declare that all responsibility arising from providing incorrect information will be borne by them.

You can notify us of any changes and/or updates related to your shared personal data through the notification address specified below by physical mail or via info@twiser.com.

10. DELETION, DESTRUCTION, OR ANONYMIZATION OF YOUR PERSONAL DATA

Personal data processed for the purposes specified in this Clarification Text will be deleted, destroyed, or anonymized when the purpose requiring their processing ends and when the legally prescribed retention periods have passed, in accordance with our Company’s Personal Data Retention and Disposal Policy, either ex officio or upon your request.

11. IDENTITY OF THE DATA CONTROLLER

TWISER BİLİŞİM DANIŞMANLIK TİCARET VE EĞİTİM ANONİM ŞİRKETİ

• Mersis No: 0859120516700001
• Address: Dijitalpark Teknopark, Kirazlıdere Mah., Eski Ankara Cad., 4/3/19, Çekmeköy/Istanbul
• KEP Address: twiser@hs02.kep.tr

For more information, you can contact us via info@twiser.com.