WITHIN THE SCOPE OF THE LAW ON THE PROTECTION OF PERSONAL DATA

GENERAL INFORMATION AND DISCLOSURE TEXT

This information and disclosure text has been prepared by Pusula Customer Experience İletişim A.Ş. for the purpose of informing and enlightening data subjects during the collection, acquisition, storage, sharing, and protection of confidentiality of personal data in accordance with Law No. 6698 on the Protection of Personal Data and other related legislation.

In this context, in order to fulfill our obligation of disclosure pursuant to Article 10 of the said Law, this information text is presented to your knowledge and review regarding the conditions and purposes to be explained below and the data to be processed lawfully.

Definition of Data Controller:

As defined in Article 3 of Law No. 6698, the data controller is described as “the natural or legal person who determines the purposes and means of processing personal data, and who is responsible for the establishment and management of the data recording system.”

Within this scope, Pusula Customer Experience İletişim A.Ş., as the Data Controller regarding the processing of personal data, is responsible, and the fulfillment of the obligation of information and disclosure is ensured with this disclosure text.

Legal Basis and Reasons for Processing Personal Data:

In case personal data explicitly defined in the Law on the Protection of Personal Data No. 6698 is obtained, such data will be processed within the scope of Articles 5 and 6 of the relevant Law. In this context, your personal data will be processed based on the following legal grounds, and in cases other than the specified legal grounds, your explicit consent will be requested for the processing of your personal data.

These legal purposes required by the Law are as follows;

• To provide information when requested by authorized public institutions and organizations, especially upon the request of courts and authorized public officials,
• To fulfill legal obligations and to exercise rights arising from current legislation,
• To fulfill obligations arising from the establishment, performance, and conclusion of a contract,
• To process personal data by our Company in cases where it is mandatory for the establishment, exercise, or protection of the rights of our Company, you, or third parties,
• Provided that the fundamental rights and freedoms of individuals are protected, the necessity of processing data for the legitimate interests of our Company (conducting satisfaction evaluation activities for existing customers, organization and event management, execution of financial-accounting transactions, auditing processes, occupational health and safety activities, fulfilling the obligation of notification to courts and other authorized public institutions, etc.),
• In cases of actual impossibility, where the person concerned cannot declare consent or where consent is not legally valid, the necessity of processing data for the protection of the life or physical integrity of the person himself/herself or of another person,
• If the personal data has already been made public by the data subject,
• Where it is mandatory to process the data for the establishment, exercise, or protection of a right,

Personal Data falling outside the above-mentioned purposes will be processed by obtaining the explicit consent of the data subject. Personal data may be collected by our Company lawfully through different platforms (manual means, oral/written statements, electronic channels, forms on the website, or by entering information such as name, surname, business or private e-mail address, or through pages accessed by username and password, visits and use of the website, activities and events carried out within our Company).

Personal Data acquired by our Company may be obtained, stored, updated, and processed as long as the above-mentioned conditions are met and/or explicit consent is available.

Collection of Personal Data and Purpose of Processing

Personal Data obtained by us through our website or by other means mentioned above will be processed by us, depending on its nature, for the following purposes:

• To enable our business units to carry out necessary planning, evaluation, and work to benefit our customers from the products and services we offer as Pusula Customer Experience İletişim A.Ş.;
• To carry out advertising and marketing activities related to the services we provide, to carry out corporate communication activities, and to provide information on similar matters,
• To conduct Marketing and Customer Relationship Management activities;
• To organize corporate communication, events, campaigns, and invitations within this scope and to provide information about them, to conduct market research activities;
• To improve and personalize the digital platforms we offer to our customers, and to use cookies for this purpose if necessary;
• To follow up, evaluate, and manage requests, suggestions, and complaints received from relevant persons, and to conduct evaluations and planning in every field within this scope;
• To ensure the sustainability of all activities carried out within the scope of the services provided by Pusula Customer Experience İletişim A.Ş., to make improvements, and to supervise the individuals and companies with whom we have contractual relationships;
• To ensure the legal and commercial security of individuals with whom Pusula Customer Experience İletişim A.Ş. is in an employment-service relationship,
• To plan and implement occupational health and safety processes;
• To use the said information for the exercise of legal rights, and to use transaction history information as evidence in case of disputes after the termination of the existing legal relationship with the relevant person/institution;
• To carry out planning, reporting, visitor/customer statistics, and similar analyses within its activities and/or to comply with domestic legislation, to provide information requested by public institutions and organizations, and to fulfill reporting obligations.
• To confirm the identity information of persons who carry out transactions through the website/mobile applications or on whose behalf transactions are carried out, and to record the necessary addresses and other required contact information,
• To ensure the security of the website established by Pusula Customer Experience İletişim A.Ş. and other electronic systems and physical environments

The rights of natural/legal persons whose personal data is processed pursuant to Article 11 of the KVKK are as follows;

• To learn whether personal data is processed or not,
• If personal data has been processed, to request information regarding this,
• To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
• To know the third parties to whom personal data is transferred domestically or abroad,
• To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data has been transferred,
• To request the deletion or destruction of personal data in case the reasons requiring its processing disappear, despite being processed in accordance with the KVKK and other relevant laws, and to request that the transaction carried out within this scope be notified to third parties to whom personal data has been transferred,
• To object to the emergence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
• To request compensation in case of damage due to unlawful processing of personal data.

For the exercise of the rights specified above, distinctive identity/registration information, the right intended to be exercised, and related explanations must be submitted as a written request in accordance with Article 11 of the KVKK Law No. 6698, by sending a registered return receipt letter to the head office address of Pusula Customer Experience İletişim A.Ş.: “Meşrutiyet Mahallesi Atatürk Bulvarı Gama İş Merkezi Kızılay Çankaya/ANKARA”. Applications will be processed accordingly.

Evaluation of Data Subject’s Requests

Pursuant to Article 13, Paragraph 1 of the KVKK Law No. 6698, the requests regarding the exercise of the rights specified above will be concluded free of charge as soon as possible (However, if the process incurs an additional cost, a fee will be charged according to the tariff determined by the Board) after being communicated to our Company in writing or through other methods determined by the Personal Data Protection Board, and feedback will be provided via the contact information you shared with us.

Links to Third-Party Websites

Our Company’s Website may contain links to third-party websites. Our Company accepts no responsibility for the privacy policies of these sites and does not in any way guarantee whether the data protection practices of these websites comply with the relevant legislation and regulations in force.