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Disclosure Text

Disclosure Text




SUPPORTIVE SERVICE ELECTRONICS ELECTRIC COMPUTER TECHNOLOGY AND INDUSTRY TRADE LTD. ŞTİ. ("SUPPORITIVE / COMPANY") DATA PROCESSING INFORMATION TEXT

This Information Text is prepared in order to inform the data subjects ("data subjects") about the protection and processing of personal data of our company, which is the data controller Supportive Service Electronic Electric Computer Technology and Industry Trade Ltd. Şti. ("SUPPORTIVE / COMPANY") in accordance with the Constitution, Law No. 6698 on Protection of Personal Data ("Law") and relevant legislation, in line with the importance attached to personal data owned by the Company, including through the website www.supportive-service.com our employees, our customers, potential customers, our dealers, our suppliers, our job applicants, the Company shareholders, our visitors, the employees of the institutions we cooperate with, and third parties (collectively "data subjects") and to demonstrate the Company's approach to the protection and processing of personal data of third parties and to inform the data subjects accordingly.

1. Data Controller

Your personal data are processed by the data controller SUPPORTIVE SERVICE ELECTRONIC ELECTRIC COMPUTER TECHNOLOGY AND INDUSTRY TRADE LTD. ŞTİ. ("SUPPORTIVE / COMPANY") located at the address "Yeşilce Mah. Barbaros Cad. Gerçek İş Merkezi No:69 Kağıthane / İstanbul / TURKEY" in accordance with the requirements of current technology.

2. Principles Regarding Personal Data

a. Processing of Personal Data

Our company, in accordance with Article 20 of the Constitution and Article 4 of the Law on the Protection of Personal Data, processes personal data:

  • In accordance with the law and honesty,
  • Accurately and, if necessary, up-to-date,
  • For specific, clear, and legitimate purposes,
  • Relevant to the purpose for which they are processed,
  • In a limited and measured manner,
  • By keeping it for the period stipulated by the laws or for the period required by the purpose of processing personal data,

Our company processes the aforementioned personal data based on one or more of the conditions specified in Article 5 of the Law on the Protection of Personal Data.

Our company, in accordance with Article 20 of the Constitution and Article 10 of the Law on the Protection of Personal Data, fulfills its obligation to inform by informing who the processed personal data can be transferred to and for what purpose, the method and legal reason for collecting personal data, and the rights of the data subject.

b. Purpose of Processing Personal Data

Personal data are processed within the scope of the purposes specified in Article 5 of the Law at our company. The purposes of processing personal data may be updated in line with our Company policies and obligations arising from legislation, and relevant updates will be announced;

• The processing of personal data by our Company is expressly provided for in the Laws in relation to the relevant activity of our Company,
• The processing of personal data by our Company is directly related and necessary for the establishment, mediation, or performance of a contract,
• The processing of personal data is mandatory for our Company to fulfill its legal obligations,
• Limited processing of personal data by our Company for the purpose of making them public,
• The processing of personal data by our Company is mandatory for the establishment, exercise, or protection of our Company's or data subjects' or third parties' rights,
• Processing personal data for the legitimate interests of our Company, provided that it does not harm the fundamental rights and freedoms of data subjects,
• Processing personal data is mandatory for the protection of the life or physical integrity of the data subject or another person, and in this case, the data subject is unable to express consent due to physical impossibility or legal invalidity
Article 6 of the Law identifies certain personal data as "special categories" that may pose a risk of causing individuals' hardship or discrimination when processed unlawfully. These data include: race, ethnicity, political opinion, philosophical belief, religion, sect, or other beliefs, appearance, membership in associations, foundations or unions, health, sexual life, criminal conviction, and security measures-related data, as well as biometric and genetic data. Special category personal data are processed by our Company under the following conditions, provided that adequate measures determined by the Personal Data Protection Board (Board) are taken:
• Special category personal data other than the data subject's health and sexual life are processed in cases provided by laws,
• Special category personal data regarding the data subject's health and sexual life are processed only by persons or authorized institutions and organizations under confidentiality obligations for the purpose of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, or by persons or authorized institutions and organizations.
If the above-mentioned data processing conditions are not met, explicit consent is obtained from the data subject by our Company for data processing. Under the conditions specified above by our company, personal data are processed for the following purposes: • Ensuring the implementation of our company's human resources policies, including the execution of HR operations in compliance with company HR policies, recruitment of personnel suitable for vacant positions, conducting application and evaluation processes, fulfilling obligations within the framework of occupational health and safety, and taking necessary precautions. • Ensuring the fulfillment of legal and commercial obligations with individuals and legal entities in relation to our company and its business relationships, including administrative operations related to communication, service-oriented operations, and production-oriented operations. • Ensuring the physical security and supervision of all company premises (factories, warehouses, vehicles, administrative buildings). • Planning and execution of information security processes and management of information technology infrastructure. • Evaluation processes for dealers/customers/suppliers/business partners (authorized persons, employees, or partners), legal and commercial risk analyses, legal compliance process, and execution of financial and fiscal affairs. • Planning and execution of access permissions for employees to information, monitoring and supervision of employees' business activities. • Customizing products, works, and services provided or created by our company according to the preferences, usage habits, and needs of our customers for recommendation purposes, including individual and/or integrated advertising, promotion, and marketing activities, as well as sales or post-service operations. • Determination and implementation of our company's commercial, social, and business strategies, including communication, campaigns, promotion, advertising, participation in fairs, market research, and social responsibility activities, procurement operations (demand, offer, evaluation, order, budgeting, contract), internal system and application management operations, and management of legal operations.

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3. Places Where Processed Personal Data is Transferred and Purpose of Transfer

The personal data collected by the company will be transferred to individuals and institutions domestically/abroad that provide data storage services, database service providers, and, upon request in accordance with the relevant legislation, to Judicial Authorities, other official institutions and organizations, relevant business partners, and legally authorized private individuals, limited to the purpose requested by private legal persons. Your personal data may be shared with these institutions in compliance with the relevant legislation so that they can perform their duties, and it is stated that these institutions do not have the right to use this data for any other purpose. Your personal data obtained and processed in accordance with the relevant legislation may be transferred to the physical archives and/or information systems of the Company and kept both digitally and physically.

4. Method and Legal Reason for Personal Data Collection

Your personal data is collected for the purposes stated above; to provide, procure, produce, market, develop, and conduct our commercial activities. In this process, your personal data collected for the purpose of conducting commercial activities are collected through our employees, business partners, dealers, and representatives, or through public databases within the scope of the relevant legislation. Your personal data collected on this legal basis may also be processed and transferred for the purposes specified in clauses (2.b) and (3) of this Information Note, within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

5. Data Storage and Deletion

Our company keeps the personal data it processes for the periods specified by the legislation, and if there is no period specified in the legislation; personal data are kept for the period required by the Company's practices and commercial life, which necessitates processing within the framework of the services offered by the Company while processing the data, and after this period, only for the periods required for possible legal disputes to constitute evidence. After the expiration of the specified periods, the personal data are deleted, destroyed, or anonymized. Detailed information on the storage and destruction of personal data can be found in the "POLICY on the Processing, Storage, and Destruction of Personal Data" of SUPPORTIVE SERVIS ELEKTRONIK ELEKTRIK BILGISAYAR TEKNOLOJI VE SANAYI TICARET LTD. STI.

6. Data Security

The Company fully complies with all technical and administrative security controls required by information security standards and procedures in order to protect your personal data. These security measures are provided at a level appropriate to the possible risk, taking into account technological and economic capabilities. The Company conducts or has audits conducted within itself to ensure the implementation of the provisions of the Law. Maximum attention and care are given to issues related to the preservation and security of personal data. Detailed information on the preservation and security of personal data can be found in the "POLICY on the Processing, Storage, and Destruction of Personal Data" of SUPPORTIVE SERVIS ELEKTRONIK ELEKTRIK BILGISAYAR TEKNOLOJI VE SANAYI TICARET LTD. STI. In addition, • Employment of knowledgeable personnel in establishing and operating systems compliant with the principles of personal data processing and relevant legislation, • Providing training for personnel to inform them about personal data protection legislation and compliance with company practice rules in personnel contracts, • Using backup programs compliant with the legislation to securely store personal data, • In case a service covering personal data processing processes is procured as an external resource, including provisions in contracts with external resource companies regarding the protection of personal data and ensuring compliance with these measures in their organizations.

7. Your Rights Regarding Personal Data Protection

According to Article 20 of the Constitution, everyone has the right to be informed about personal data concerning them, and according to Article 11 of the Law on the Protection of Personal Data (KVKK), among the rights of the data subject is the right to request information. In this context, our Company provides the necessary information to the data subject if a request for information is made; with this Declaration, our Company informs the data subject about how the right to request information will be exercised and how requests for information will be evaluated. In accordance with Article 11 of the Law, you have the right to apply to our Company and request your personal data to: a) learn whether it is processed or not, b) request information if it has been processed, c) learn the purpose of processing and whether it is used appropriately, d) learn the third parties to whom it has been transferred domestically / abroad, e) request correction if it is incomplete / incorrect, f) request deletion / destruction, g) request notification of the operations carried out pursuant to subparagraphs (e) and (f) to third parties to whom personal data has been transferred, h) object to the occurrence of a result against you due to the analysis of the data exclusively by automatic systems, ı) request restriction of processing, i) request data in a structured, commonly used and machine-readable format, and j) demand compensation in case of damage due to unlawful processing. According to Article 28 of the KVKK, the following cases are excluded from the scope of the KVKK; therefore, data subjects cannot assert their rights regarding these issues: The following cases are excluded from the scope of the KVKK, except for the right to request compensation for damages:

Customer Information: Information obtained and generated about the person who is clearly or identifiably a real person, either partially or entirely processed automatically or non-automatically as part of our commercial activities and the operations conducted by our business units regarding the person who is the representative, agent, or employee of the customer.

Customer Transaction Information: Information about the person who is clearly or identifiably a real person and contained within the data recording system, including records related to the use of our products and services, as well as instructions and requests necessary for the customer to use the products and services.

Transaction Security Information: Personal data processed within the data recording system for the purpose of ensuring the fulfillment of technical, administrative, legal, and commercial obligations while conducting our commercial activities.

Risk Management Information: Personal data processed within the data recording system through methods used in commercial, technical, and administrative fields, in accordance with generally accepted legal, commercial customs, and principles of integrity, to manage our commercial, technical, and administrative risks.

Financial Information: Personal data, including information about the authorized or employee of the customer, processed partially or entirely automatically or non-automatically as part of the data recording system, showing all financial outcomes, documents, and records related to the customer.

Employee Candidate Information: Personal data processed partially or entirely automatically or non-automatically as part of the data recording system about individuals who have applied to become employees of our Company, evaluated as employee candidates in accordance with commercial customs and principles of integrity, or individuals who are in a working relationship with our Company.

Legal Action and Compliance Information: Personal data processed partially or entirely automatically or non-automatically as part of the data recording system for the purposes of determining, pursuing, and fulfilling our legal rights and obligations, as well as compliance with our Company's policies.

Marketing Information: Personal data processed partially or entirely automatically or non-automatically as part of the data recording system, for the purpose of marketing our products and services customized according to the customer's usage habits, preferences, and needs, including personal data of the customer, employee, or representative, and the reports, documents, financial information, and evaluations created as a result of this processing.

Data Subject Categories

Customer Employee/Representative/Agent: Employees and representatives of our customers who have used or are using the products and services offered by our Company.

Potential Customer Employee/Representative: Employees and representatives of legal entities who have expressed interest in or have the potential to be interested in our products and services, evaluated in accordance with commercial customs and principles of integrity.

Visitor: Individuals who have entered our physical premises for various purposes or visited our websites.

Third Party: Individuals associated with the aforementioned parties in order to ensure the security of commercial transactions or to protect the rights and interests of these individuals (e.g., Guarantor, Companion, Family Members, and relatives).

Employee Candidate: Individuals who have applied to our Company through any means (digital, job placement offices, in person, etc.) or have made their resumes and relevant information available for review by our Company.

Shareholder: Real individuals who are shareholders of our Company.

Chairman/Authorized Person of the Board of Directors of the Company: Members of the Board of Directors authorized to represent our Company and other authorized individuals in various units.

Employees, Shareholders, Representatives, and Authorized Persons of Institutions We Cooperate With: Real individuals, including employees, shareholders, representatives, and authorized persons of institutions with which our Company has any kind of business relationship (such as business partners, clients, suppliers, etc., without limitation).