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Online Visitor Clarification Text on the Processing Personal Data

Data Controller: Boss Yönetişim Hizmetleri A.Ş.

Address: Astoria Towers Büyükdere Cad. No: 127 B Kule Kat: 8 34394 Şişli, İstanbul, Türkiye

Boss Yönetişim Hizmetleri A.Ş. ("Company") prepared this Clarification Text as the data controller to inform you, our valuable online visitors, about your personal data that we process in accordance with the Turkish Personal Data Protection Law (hereinafter referred to as "KVKK") and the relevant legislation.

1. Your Personal Data Processed and the Scope of the Processing

Personal data is any data that identifies you or makes you identifiable. For example, your name, surname, eye color, phone number or bank account information are considered personal data. On the other hand, processing your personal data refers to all kinds of processes such as obtaining, amending, registering, storing, retaining, deleting, disclosing, and transferring your data. We have provided the following information about the personal data we process:

ID Data

Contact Data

Personnel Data

Customer Transaction Information

Transaction Security Information

2. Our Retention Period for Storing Your Personal Data

We store your personal data for a period of time stipulated in the relevant legislation or for the periods of time required by the processing purposes. We will delete, destruct, or anonymize your data ex officio or upon your request, if legal reasons requiring data processing disappear.

3. Your Rights Regarding Your Personal Data

Data subject refers to the natural persons whose personal data are processed. As a data subject, you, our valuable online Visitors, have the following rights regarding your personal data processed under KVKK:

• To learn whether your personal data are being processed,
• To request information if your personal data are processed,
• To learn the purpose of processing your personal data and whether this data is used for the intended purposes,
• To know the third parties to whom this personal data is transferred domestically or abroad,
• To request the rectification of the incomplete or inaccurate data, if there are any,
• To request the deletion or destruction of this personal data under the conditions set forth in KVKK,
• To request notification to the third parties that the personal data have been transferred to about the rectification of incomplete or inaccurate data and the deletion or destruction of personal data upon your request,
• To object to the issues that have arisen due to the analysis of your data exclusively through automated systems and are to the detriment of you,
• To request compensation for the damage arising from the unlawful processing personal data.

4. Methods to Follow to Exercise Your Rights

You can share your application and requests regarding your personal data with Boss Yönetişim Hizmetleri A.Ş. via Data Subject Application Form,

• By sending it with your wet signature and a copy of your identity card to Astoria Towers Büyükdere Cad. No: 127 B Kule Kat: 8 34394 Şişli, İstanbul, Türkiye,
• By sending an e-mail to [email protected],
• By applying in person with a valid identity document to Astoria Towers Büyükdere Cad. No: 127 B Kule Kat: 8 34394 Şişli, İstanbul, Türkiye

You, as a data subject, should include your name and surname, your signature if the application is in written form, your Turkish ID Number if you are a Turkish citizen, your nationality and passport number (or if you have an ID number) if you are foreigner, place of residence or business address for notifications, your e-mail address and fax number if you have one, and lastly, the subject of the request in your application with respect to legal requirements regarding the applications to data controllers. In addition, you should add documents and information confirming your identity to your application.

In order for us to operate the process in the most effective way for you, you should clearly and understandably indicate in your request which right you want to use and the details of the transaction you request.

We would like to emphasize that the request should concern the data subject itself. If the application is made on behalf of someone else, the person making the request should rely on a specially documented authorization for the requested transaction (power of attorney). Unauthorized applications will not be evaluated.

5. Evaluation of Your Application

By evaluating your applications, we respond to you as soon as possible and within 30 days of receipt as of the date of your application.

Privacy Policy

CottGroup^® companies' network ("CottGroup^®") includes independent companies with separate legal entities that provide various sections of this website and other websites in the CottGroup^® member network; and this Policy applies separately for each CottGroup^® member company.

Informasoft^® website you visited is affiliated with Boss Yönetişim Hizmetleri A.Ş., one of the CottGroup^® member network companies.

Thank you for visiting our website and reading our privacy and security statement.

Basic Information About Our Approach to Data Security and Privacy

Company has dedicated itself to ensuring the security of your personal data on all of its information systems. For Company, privacy and security matters form the basis of the relation between us and our customers. Company understands your concern about your confidentiality and security and place utmost importance on that matter.

Information that you will be disclosing when using this website may also be controlled by other firms in order to enable us to secure the control, inspection and security of the said data at the utmost level. Each independent firm shall be legally liable for any data controlled and inspected by it.

This Privacy Statement is applicable to all data processed by Company, including Personal Data collected or transmitted via website, our software and self-service applications, mobile applications or social media accounts and other online or offline channels.

Protection of Personal Data

Company acts in the capacity of a data controller and data processor in line with the Turkish Personal Data Protection Law (KVKK) no. 6698 and provisions of any other legislation applicable to the protection of personal data. Accordingly, personal data shall be processed only by Company personnel authorized to implement any privacy and security policy as well as services falling within the scope of duty of Company's management office and the personnel named in the privacy and security authorization matrices, and those natural/legal persons authorized by Company for such purpose by fulfilling the condition of informing the data subjects. For details, please click the Personal Data Protection and Processing Policy.

Electronic Messages:

Subject to communication consents provided by you during your communication with us regarding electronic messages (e-mail) and through any other Company channel, you will be deemed to have accepted to receive e-mail messages through your contact details, for the promotion of services offered by Company and its business partners, information on new products and services, announcements on issues regarding legislation, and other matters that may be of interest for you. In this respect, you may contact Company to request that messages are no longer sent to you through one or more than one communication channel.

Log Data, Cookies and Web Beacons

Cookies are program bits that are usually in the form of text files that may be embedded in laptops, desktop PCs and mobile devices, which collect various data.

Cookies may be used to collect the following data:

• Internet Protocol (IP) address
• Domain name of the computer that you use for connecting to the website
• Date and time of your connection and the time you spend on the website
• Link of the page over which you connect our web site or the address of another Company website
• Information about your computer, your browser's, your operating system, Java support, flash version, your screen definition and connection speed and similar data
• Details of the page on the computer that is used for connection when a request is made from our web site
• Volume of the data in bytes, transferred on our website
• Contents of traceable cookies
• Company websites use temporary session cookies to render your online activities secure and to enhance the website performance;
• Areas such as Login time, Username and User ID that are necessary for our software and self-service applications ("Applications");
• Details of the URL over which the User has transmitted his last request through the Applications
• Your browser's language

Please click Cookie Policy for details.

Purpose of Using Your Data

We may use your personal data which we record during your visits to our website, via automated or non-automated means, or which you may disclose to us in communication forms, e-mails or via other electronic transactions, primarily for the purpose of satisfying your requests and subsequently for ensuring improvement of the services offered to you. Overall purposes of use of such data may be listed as follows:

• To contact you
• To enable your access to the website or self-service options, by performing operations regarding your online account, including but not limited to the provision of a username and password
• To answer questions received from you
• To provide information about legislative changes and other important matters
• To ensure the administration of our website
• To improve our service quality

Please do not disclose such data that you would not want us to collect for the purposes above. Please remember that unless you provide such data, we will be unable to contact you, and that your certain data may still be collected by means of cookies during your visit to this website.

Data Security

Company places utmost importance on the security of your data. We take measures conforming to sector standards to prevent unauthorized collection and use of your data. Exchange of information on the İnternet is not generally secure. Therefore, we recommend you exercise due care by user when exchanging information through our websites and online systems. If you do not take relevant measures, Company cannot guarantee you about security of your information and communication on the website or capture them by third parties.

When your information arrives at Company, it is protected in accordance with our security and privacy standards.

Your data are stored for the purposes set out above and only for the durations required by the needs of our business process or as prescribed by law.

Data Transfer

We may transfer the personal information we collect on you, to other countries different from the country we collect the data, as we use their services of the internet service providers, hosting companies, e-mail providers, domain providers (for example: Microsoft 365). Data protection laws and regulations applied in these countries may differ from the laws applicable in Turkey.

Hereby, we will protect your information in accordance with the applicable law as described in this Privacy Policy while transferring to other countries.

Protection for Children's Online Activities

We support parents willing to supervise and control online activities of their children. In no event do we ask children on purpose to share their personal data. If we come to know that a person whose personal data are collected by us is younger than 13 years old, we may use such data to try to promptly inform his/her parents. This rule shall be applicable for age 16 under the European Union General Data Protection Regulation (GDPR).

Designing New Processes in Line With Privacy Rules

Company takes the most appropriate technological and organizational measures to ensure confidentiality when developing new systems and applies necessary developments for the processing of personal data in line with their intended purposes (Privacy by design).

Should you have any queries about this Privacy Policy, please click the link.

Company website: https://www.cottgroup.com