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Online Visitor Clarification Text Regarding the Processing of Personal Data

As Boss Yönetişim Hizmetleri Anonim Şirketi (“Company”), we attach the utmost importance to the security of your personal data. With this awareness, we place great emphasis on ensuring that personal data of a general and special nature is processed, retained, and deleted in compliance with the Law on the Protection of Personal Data No. 6698 (“Law” or “KVKK”), the secondary legislation enacted and to be enacted pursuant to the Law (regulations, communiqués, circulars), and the binding decisions adopted and to be adopted by the Personal Data Protection Board. With full awareness of this responsibility, acting in the capacity of “Data Controller” as defined under the Law, we process your personal data relating to your visit in the manner explained below and within the limits prescribed by the applicable legislation.

1. Information Regarding the Data Controller

Pursuant to the Law, Boss Yönetişim Hizmetleri Anonim Şirketi, registered with the Istanbul Trade Registry Directorate under tax identification number 1800379183, and domiciled at “Esentepe Mahallesi Büyükdere Cad. Astoria Sit. No: 127 B/8 Şişli/İstanbul”, is the Data Controller.

2. Categories and Types of Personal Data Processed

Category	Personal Data
Identity Information	Name, Surname
Contact Information	Phone Number, Email Address
Professional Information	Your Company

3. Methods of Collecting Personal Data and the Activities Through Which It Is Collected

As the Company, we collect your personal data through automated means and/or through non-automated methods, provided that such data forms part of an automated data recording system.

Data Category	Activity Through Which It Is Collected
Identity Information	Contact Form on the Website
Contact Information	Contact Form on the Website
Professional Information	Contact Form on the Website

4. Purposes and Legal Grounds for the Processing of Personal Data

As the Company, your personal data is processed in accordance with the purposes and legal grounds set out below, within the limits prescribed under the Law, in a lawful and fair manner, and in a way that is at all times relevant, limited, and proportionate to such purposes.

Data	Purposes of Processing	Legal Grounds
Identity Information	Responding to your complaints, suggestions, or any kind of requests; Enabling communication with you; Providing information regarding the Company’s products and services; Providing information about the Company’s products and services, Carrying out risk management processes; Receiving and evaluating suggestions aimed at improving business processes.	Article 5/2 (c) and (f) of the Law; (c) Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract; (f) Processing of personal data is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed
Contact Information
Professional Information	Providing information regarding the Company’s products and services; Receiving and evaluating suggestions aimed at improving business processes.

5. Transfer of Personal Data

Transferee Parties	Purposes of Transfer	Legal Grounds
Authorized internal departments of the Company and, where necessary, other group companies	Carrying out customer relationship management processes and activities aimed at customer satisfaction; Responding to requests and complaints; Providing information to authorized persons, institutions, and organizations; Ensuring the security of the data controller’s operations.	With reference to Article 8/2 (a) of the Law: Transfer of personal data is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed; Transfer of personal data is mandatory for the data controller to fulfill its legal obligations.
Authorized public institutions and organizations, where deemed necessary
Foreign-based platforms (Typeform, Mailchimp)	Enabling communication with you regarding the form you have submitted and sending communications to you via email and other methods for which you have provided consent.	With reference to Articles 9/4 (c) and 9/6 (a) of the Law: 4(c) The existence of a standard contractual clause announced by the Board, covering matters such as data categories, purposes of data transfer, recipients and recipient groups, technical and administrative measures to be taken by the data recipient, and additional safeguards for special categories of personal data; (6)(a) The data subject’s explicit consent to the transfer, provided that the data subject has been informed of potential risks.

6. Rights of the Data Subject

any time, by applying to the Company, you may exercise the following rights arising from Article 11 of the Law:

To learn whether your personal data is processed;
To request information if your personal data has been processed;
To learn the purpose of processing your personal data and whether such data is used in accordance with its purpose;
To know the third parties to whom your personal data is transferred domestically or abroad;
To request correction of your personal data if it is incomplete or inaccurately processed;
To request deletion or destruction of your personal data within the framework of the conditions set forth in Article 7 of the Law;
To request notification of the transactions carried out pursuant to subparagraphs (d) and (e) of Article 11 of the Law to third parties to whom your personal data has been transferred;
To object to the occurrence of a result against you arising from the analysis of your processed data exclusively through automated systems;
To request compensation for damages in the event that you suffer damage due to the unlawful processing of your personal data.

You may submit your requests regarding your rights and the implementation of the Law by completing the application form available at www.bordromat.com or obtainable from us, or by submitting your request together with the minimum required elements specified below:

By sending your application via email to [email protected] using your registered electronic mail (KEP) address assigned in your name;
By completing the application form with a wet signature and submitting it via a notary public, registered mail with return receipt, or personal application to “Esentepe Mahallesi Büyükdere Cad. Astoria Sit. No: 127 B/8 Şişli/İstanbul”;
By sending an email to [email protected] using the email address previously notified by you to the Company and recorded in the Company’s systems.

If responses to such requests are provided in writing, the Company shall respond free of charge for up to ten pages and may charge a processing fee of 1 Turkish Lira for each page exceeding ten pages. If the response is provided on a recording medium such as a CD or flash drive, the fee that may be requested by the Company shall not exceed the cost of the recording medium.

In the application to be submitted by you as the data subject in order to exercise your rights listed above, the subject of your request must be clear and understandable and must relate to you personally. If you are acting on behalf of another person, you must submit a notarized special power of attorney authorizing you to do so.

Pursuant to the Communiqué on the Principles and Procedures for Application to the Data Controller, applications must include your name and surname, signature, Turkish Republic identification number, residential or workplace address, email address, telephone and fax number, and details of the subject matter of the request. Applications that do not include these elements shall be rejected by the Company and/or directed to valid application channels.

The Company reserves the right to make amendments to this clarification text at any time due to reasons arising from the Law, secondary legislation, and decisions of the Board. Any amendments made to the clarification text and the updated version shall become effective as of the date on which they are notified to you.