INTERNET SITE CLARIFICATION TEXT

SYBERCODE INFORMATION TECHNOLOGIES INC.

CLARIFICATION TEXT UNDER THE PROTECTION OF PERSONAL DATA LAW NO.6698

    Identify of the Data Controller

As SYBERCODE INFORMATION TECHNOLOGIES INC. (hereinafter referred as “Company”), we inform you that we are processing your personal data as a data controller under the Personal Data Protection Law No.6698 (hereinafter referred as “KVKK”) and other related legislation.

Processed Personal Data

In accordance with the KVKK and other related legislation, your personal data (Name-Surname, Telephone number and e-mail address) will be processed within the scope of the purposes and legal reasons specified in this Clarification Text.

Processing Purpose of Your Personal Data

Your personal data is collected with the purpose of;

• Making the necessary work by our business units to benefit you from the products and services offered by our company.
• Recommending the products and services offered by our company to you, planning and / or performing of market research activities for the sales and marketing of products and services.
• Informing our customers who benefit from our products and services, about sector developments and managing these processes.

They will be processed within the legal grounds which are “a) It is expressly provided for by the laws”, “c) Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract“, ”ç) It is necessary for compliance with a legal obligation to which the data controller is subject“, “e) Data processing is necessary for the establishment, exercise or protection of any right“ specified in Article 5 (2) of the KVKK.

To Whom and For What Purpose the Processed Personal Data Can Be Transferred

Your personal data processed by our company are not transferred to any institution, real persons or private law legal entities. If required or requested, your personal data can be shared with the relevant public institutions and organizations in order to fulfill legal obligations in accordance with the relevant legislation without considering the explicit consent of the relevant person in accordance with Article 8 (2) (a) of the KVKK.

Transfer Abroad

Based on the legal grounds specified in Article 5 (2) of the KVKK, your processed personal data are transferred to

• Foreign countries (“Foreign Country with Sufficient Protection”) declared as having adequate protection by the Personal Data Protection Council (hereinafter referred to as the “Council”)
• Foreign countries where data controllers who are in Turkey and relevant countries guaranteed adequate protection in writing and provided that it is limited to the foreign country and / or countries where the Council has permission in terms of the relevant transfer (“Foreign Country Where the Data Controller Guarantees Sufficient Protection”)

without obtaining the explicit consent of the relevant person in line with the international transfer conditions in article 9 (2) of the KVKK, due to the fact that the sales and marketing activities of the Company’s products and services are carried out through online software systems whose databases are located abroad.

The transfer of your processed personal data within the scope of the purposes described above will be carried out in accordance with the decisions taken by the Council and the relevant regulations, especially the KVKK and other related legislation, with the necessary care and taking all necessary security measures by our Company.

Management and Legal Reason of Personal Data Collection

Your personal data is obtained by methods of as automatic or non-automatic filling out a contact form, sending an e-mail message and visiting the website, in order to fulfill the purposes specified in paragraph (c) of this text and based on the legal reasons specified in Article 5 (2) of the KVKK.

Your Rights Mentioned in Article No.11 of the KVKK

Within the scope of Article 11 of the KVKK, you have rights as a data owner, and you can make your requests regarding these rights, in accordance with the Article 11 and paragraph 1 of Article 13 of the KVKK and the Citation on Application Procedures and Principles to the Data Controller. Your request might be preferably by filling in all the information specified in the Relevant Person Application Form on our website,

• Coming to our Company at Küçükbakkalköy Mah. Kayışdağı Cad. Çelik Plaza No: 137/1 B-Blok K: 4 D: 4 in person,
• By registered mail or through a notary public, in writing, in order to determine your identity and not to inform the wrong people,
• By sending an e-mail to our address by using the e-mail address (if any) previously notified to our Company and registered in our systems.
• or by other methods to be determined by the Council in the future.

     Retention Period of Personal Data

The Company deletes, destroys, annihilates or anonymizes the personal data when the purpose of processing personal data is removed and/or the mandatory retention periods specified in the Laws and other relevant legislation expired.

 Changes and Updates

This Clarification Text has been prepared within the scope of the Personal Data Protection Law No.6698 and other relevant legislation. Necessary changes can be made in the aforementioned clarification text in line with the changes in the relevant legal legislation and / or the Company’s personal data processing purposes and policies.