Clarification Text for the Customers of Aktivido Information Technologies Inc.

As Aktivido Bilgi Teknolojileri Anonim Şirketi ('Our Company' or 'Aktivido'), we show maximum sensitivity to the processing and protection of personal data of our customers in accordance with the Personal Data Protection Law No.6698 and its secondary regulations ('KVKK Legislation').

This Disclosure Text for Customers ('Clarification Text') has been prepared in order to fulfill the disclosure obligation arising from the KVKK legislation as a data controller within the scope of personal data processing activities carried out by our company for its customers.

1. Your Personal Data Processed by Our Company

Your identity information (name, surname), contact information (e-mail, phone), if necessary legal information (correspondence with judicial authorities and lawsuit / execution file information), transaction security information (device information, operating system IP address information , log records), your customer transaction information (customer ID information), your visual and / or audio records (selfie / selfie image, online / offline audio or non-audio video image through digital applications), your marketing information and other information in accordance with the KVKK legislation. is being processed.

2. Purposes and Methods of Processing Your Personal Data

Our company fulfills your personal data stated above and its obligations arising from the laws; To be able to manage your accounts / make your orders / payment / purchase-sale transactions within the scope of the establishment and execution of the contract, to present the products and services of our company, to provide general information about these products and services, to carry out customer acquisition, customer satisfaction and / or customer acquisition studies, to increase our service quality, To be able to perform customer relations management or communication processes, to evaluate your complaints or requests, to provide confirmation and approval of your transactions, to offer you services within the scope of commercial activities; Carrying out Company operations and policies while observing your fundamental rights and freedoms, detecting and auditing suspicious transactions, terrorist financing and money laundering activities, Conducting criminal attempts such as fraud, theft, money laundering, financing of terrorism targeting the assets / personal information of the Company and / or its customers. and / or preventing fraudulent / unauthorized transactions, determining whether the searched suspicious persons and existing or potential customers are the same persons and / or reporting suspicious transactions; to be able to follow fraud / fraud processes; To carry out internal audit / internal control / investigation audits ex officio or upon complaint; to share information about legislation with authorized persons and organizations; conducting compliance processes; to comply with information obligations; to fulfill the information and document retention obligations arising from the legal legislation; To fulfill the legal and commercial obligations of our Company arising from the contract within the framework of contracts made with third real or legal persons who are in business relations with our company or activities carried out together; to investigate, prevent and report violations of the contract and the law to the competent authorities; In order to communicate with you, it is processed in written, automatic or non-automatic methods in accordance with the KVKK legislation in a limited and measured manner in electronic and / or physical media in connection with the purposes of sharing with service providers and business partners we have contracted with and conducting marketing activities.

In addition to the aforementioned, our Company will process your personal data in order to inform you about the campaigns and promotions that you may be interested in, if you give your express consent.

In addition to the aforementioned, if you give your explicit consent, your personal data will be transferred abroad due to the systems and infrastructures used by our Company.

Our company undertakes that it will not process your personal data without your explicit consent, except for the above purposes.

3. Method of Collection of Your Personal Data and Legal Reasons for Processing

Your personal data obtained through internet site, mobile or digital applications, customer interviews made by phone / mobile / internet channel, written and digital applications made to our Company, electronic, verbal or physical means in accordance with the KVKK legislation, in accordance with your explicit consent or concluding the contract; the establishment of your contractual rights; exercise and protection of these rights by you; The Company's fulfillment of its obligations arising from the relevant legal regulations, for the purpose of ensuring the legal, technical and commercial-business security of the Company and the relevant persons in business relations with the Company or acting in accordance with the legitimate interests of the Company provided that it does not harm your fundamental rights and freedoms. It is processed within the scope of legal reasons.

4. Sharing Your Personal Data with Third Parties

Third parties with whom we share your personal data are obliged to process and protect your personal data as bound and limited for the purpose of sharing, unless otherwise stipulated in the KVKK legislation, and are under the control of Aktivido within the scope of these activities.

4.1. Our Domestic Shares
Your personal data listed in this Clarification Text, with the relevant banks, investment institutions, private finance institutions, payment systems organizations, card institutions, electronic money institutions, other financial institutions, with the purpose of making payments and / or obtaining services to carry out the activities of our Company, ; With the relevant official institutions, organizations and judicial authorities and relevant audit firms in order to fulfill legal obligations; Call or customer contact centers from which we receive service for the purpose of increasing our service quality, conducting customer satisfaction and / or customer acquisition studies, fulfilling customer relations management or communication processes, evaluating your complaints or requests and ensuring the confirmation and approval of the transactions you have carried out, and at the same time in order to carry out the commercial activities of our Company. our solution partner “iyzi Ödeme ve Elektronik Para Hizmetleri A.Ş.” (iyzico), external service providers and other contracted organizations in accordance with the KVKK legislation.

4.2.Our Shares Abroad
Again, your personal data mentioned above is shared with our foreign-based foreign service providers, with which we work, within the scope of the operation of the infrastructure and systems used by our company and upon your explicit consent.

5. Protection, Storage and Destruction of Your Personal Data

Kişisel verilerinize yetkisiz kişiler tarafından erişilmesini, kişisel verilerinizin hatalı işlenmesini, ifşa edilmesini, hukuka uygun olmayan sebeplerle değiştirilmesini/silinmesini önlemek, korunmasını ve güvenliğini sağlamak amacıyla Şirketimiz KVKK mevzuatı uyarınca gerekli tüm teknik ve idari tedbirleri alır.

Kişisel verileriniz, aramızda sözleşme imzalanmış olmasının söz konusu olduğu hallerde sözleşmenin sona erme tarihinden itibaren 10 yıl süreyle muhafaza edilir. Sözleşmesel ilişki dışında işlenen kişisel verileriniz ise işleme amacının gerekli kıldığı makul süreler boyunca işlenecektir. Bununla birlikte, her halükarda, ilgili işleme süreci kapsamında kişisel verilerinizin muhafazasına ilişkin yasal düzenlemelerle öngörülen saklama sürelerinin bulunması durumunda, söz konusu süreler boyunca verilerinizin silinemeyeceğinin altını çizmek isteriz.

Kişisel verileriniz, ilgili yasal düzenlemede öngörülen veya işlendiği amaç için gerekli olan sürenin sona ermesi halinde veya sizlerin silme taleplerinin olumlu sonuçlanması durumunda, Şirketimizin Kişisel Verilerin Korunması ve Gizliliği Prosedürü ile Kişisel Veri Saklama ve İmha Prosedürleri doğrultusunda KVKK mevzuatına uygun olarak silinir, yok edilir veya anonim hale getirilir.

Aktivido’nun fiziki arşivine ve/veya sunucularına ve/veya diğer sistemlerine yapılan saldırılar sonucunda kişisel verilerinizin zarar görmesi ve/veya üçüncü kişiler tarafından ele geçirilmesi/ifşası durumunda, Şirketimiz sizleri ve KVKK Kurulu'nu söz konusu durumdan haberdar olduktan sonra 72 saat içinde bilgilendirir.

6. Your Right to Information

Within the scope of Article 11 of the KVKK, by applying to our Company, your personal data; (i) learning whether it has been processed; (ii) request information about it if it has been processed, (iii) learn the purpose of processing and whether it has been used appropriately; (iv) to know the third persons to whom it was transferred domestically or abroad, (v) to request correction if it was incomplete or incorrectly processed; (vi) To request their deletion or destruction within the framework of the conditions stipulated in Article 7 of the KVKK; (vii) to request the deletion and destruction of your personal data within the scope of Article 7 of the KVKK and the correction of incomplete or incorrectly processed personal data to third parties to whom personal data are transferred; (viii) to object to the emergence of a result against you because it is analyzed exclusively by automated systems; (ix) If you suffer damage due to unlawful processing, we inform you that you have the right to demand compensation for the damage.

If you want to make an application regarding your personal data within the scope of the KVKK, you can send your applications using one of the channels below,

• By using registered electronic mail (KEP) address, secure electronic signature, mobile signature, or by using your e-mail address previously notified to Aktivido and registered in Aktivido's system, to our Company's [email protected] address or;
• Hamidiye Mahallesi Başak Konutları Gül Sokak No: 16 A2 B-212 Blok D:20 Kağıthane İstanbul adresine kimlik teyidinizin yapılması sağlanarak yazılı olarak bizzat veya noter kanalıyla

In accordance with Article 13 of the KVKK and Article 5 of the Communiqué on Application Procedures and Principles of Application, which was published in the Official Gazette numbered 30356 and dated 10.03.2018.

Our company will finalize the application requests, which are duly, according to the nature of the request and within 30 (thirty) days at the latest. If the transaction requires cost, the tariff determined by the KVKK Board will be applied. Your request will be accepted or rejected by explaining the reason, and our response will be sent to you in writing or electronically.

This Information Text may be updated in order to comply with changing conditions and legal regulations. Updates to be made by our company will be notified to you, the customers.

Explicit Consent Text for International Transfer of Personal Data Belonging to Customers of Aktivido Bilgi Teknolojileri Anonim Şirketi

I have read the Clarification Text for the Customers of Aktivido Bilgi Teknolojileri Anonim Şirketi ("Company" or "Aktivido").

In the context of the Clarification Text;

• Fulfillment of obligations arising from laws; Managing my accounts within the scope of the establishment and execution of the contract; providing my membership to the site; confirmation of my membership; the execution of my orders, payment and trading transactions; Presenting the company's products and services; Providing general information about these products and services; customer acquisition, customer satisfaction and customer acquisition activities; increasing the quality of service; the ability to perform customer relationship management or communication processes; To be able to evaluate my complaints or requests; ensuring confirmation and approval of my transactions; To be able to provide services within the scope of commercial activities to me; sending a monthly newsletter; Maintaining company operations and policies; detecting and auditing suspicious transactions, terrorist financing and money laundering activities; Prevention of fraud, theft, money laundering, terrorism financing and / or fraudulent / unauthorized transactions targeting the assets / personal information of the company and / or its customers; Determining whether the suspicious people searched and existing or potential customers are the same person and / or reporting suspicious transactions; Tracking fraud / fraud processes; Performing internal audit / internal control / investigation audits, either ex officio or upon complaint; Sharing information about legislation with authorized persons and organizations; conducting compliance processes; compliance with information obligations; fulfillment of information and document retention obligations arising from legal legislation; Fulfilling the legal and commercial obligations of our Company arising from the contract within the framework of contracts made with third real or legal persons who are in business relations with our company or activities carried out together; investigating, preventing and reporting violations of the contract and the law to the competent authorities; My identity information (name, surname), transaction security information (device information, operating system, IP address information, log records), customer transaction information (customer ID information), my contact information (e-mail, phone), my financial information (invoice, IBAN), other information, visual and / or audio records (selfie / selfie image, online / offline audio or non-audio video image through digital applications) ;
• Managing my accounts within the scope of the establishment and execution of the contract; the execution of my orders, payment and trading transactions; the ability to perform customer relationship management or communication processes; ensuring confirmation and approval of my transactions; To be able to provide services within the scope of commercial activities to me; Maintaining company operations and policies, detecting and auditing suspicious transactions, terrorist financing and money laundering activities; Prevention of fraud, theft, money laundering, terrorism financing and / or fraudulent / unauthorized transactions targeting the assets / personal information of the company and / or its customers; Determining whether the suspicious people searched and existing or potential customers are the same person and / or reporting suspicious transactions; Tracking fraud / fraud processes; Performing internal audit / internal control / investigation audits, either ex officio or upon complaint; Sharing information about legislation with authorized persons and organizations; conducting compliance processes; compliance with information obligations; fulfillment of information and document retention obligations arising from legal legislation; Fulfilling the legal and commercial obligations of our Company arising from the contract within the framework of contracts made with third real or legal persons who are in business relations with our company or activities carried out together; investigating, preventing and reporting violations of the contract and the law to the competent authorities; My title information for the purpose of sharing it with the service providers and business partners we have contracted with in order to communicate with you and to carry out marketing activities;
• Legal information (correspondence with judicial authorities and lawsuit / execution file information) in order to fulfill the obligations arising from the laws;
• Law No. 5651 on the Distribution of Broadcasts Made on the Internet and the Struggle with the Water Processed Through These Publications (' 5651 numbered Law ') and the obligations arising from its secondary regulations Within the scope of the fulfillment, & nbsp;

I accept that I have freely consented to the processing and transfer of the infrastructure and information systems used by Aktivido in a measured and limited manner related to the aforementioned purposes.