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Information notes on the recording, storage, and sharing of personal data of institution members under the Law on Protection of Personal Data No. 6698 ("PDPL").

WEBSITE VISITOR DATA PRIVACY NOTIFICATION

Vmind Bilgi Teknolojileri A.Ş. ("VMIND") is an organization committed to all applicable legal regulations, corporate codes, business ethics, and ethical standards. The term "VMIND" ("we" or "us" or "our") used in this text refers to all affiliates of VMIND.

VMIND, as the data controller operating the website you visited, is in a contractual relationship with you. Data pertaining to an identified or identifiable natural person is considered personal data and is protected under the Turkish Data Protection Legislation, which includes the Law on Protection of Personal Data No. 6698 ("PDPL"), secondary legislation derived from it, and decisions of the Personal Data Protection Board ("Board").

As VMIND, we commit to processing all personal data related to individuals who visit our website or reach out to us through our website in accordance with Turkish Data Protection Legislation, ensuring the security of this data, and showing respect for it. We provide this data privacy notification to inform you about how we will process individuals' personal data for the execution of the contract and management of customer relations.

LEGAL PROCESSING OF YOUR PERSONAL DATA

Individuals' personal data is processed both due to the establishment or performance of the contract between you and VMIND as a result of your use of the website (1) and in accordance with VMIND's legitimate interests (2). Managing the performance of the contract to which VMIND is a party and evaluating requests and complaints are considered VMIND's legitimate interests.

PURPOSE OF PROCESSING PERSONAL DATA

We process personal data for the following purposes:

1) Conducting Customer Satisfaction Activities,

2) Execution of Contract Processes,

3) Conducting Internal Audit/ Investigation/ Intelligence Activities,

4) Conducting Business Activities/ Auditing,

5) Conducting Marketing Activities,

6) Fulfillment of Legal Notification Obligations.

TYPES OF PERSONAL DATA WE COLLECT

Our company processes the general nature of personal data of individuals during visits and applications made on its website, www.vmind.com.tr, including i) Identity information (Name-Surname), ii) Contact information (Mobile Phone Number, Email Address), iii) website visit information (IP address, cookie records, permission/consent records, browsing records, log information), and iv) other personal data you prefer to convey to us within your message, for the reasons mentioned above.

SOURCES OF PERSONAL DATA

We directly collect the aforementioned personal data from individuals who visit the VMIND website to reach our company.

TO WHOM ARE YOUR PERSONAL DATA TRANSFERRED?

At any time regarding the management of contractual relations with individuals, personal data may be shared with VMIND's business partners, suppliers, and manufacturers, directly or indirectly with domestic/foreign subsidiaries, and service providers who process data on our behalf under a service and privacy agreement. We do not share the personal data we collect with third parties other than our data processors.

Individuals' personal data is securely processed and stored in local and global data processing systems related to finance, contracts, and supplier management, which VMIND utilizes to effectively carry out its activities. Additionally, we may process and transfer the personal data we handle to competent public institutions and organizations in accordance with the procedures and principles prescribed by other legislation, in order to fulfill our legal obligations.

From all individuals whose personal data is processed, it is your company's responsibility to obtain explicit consent for the processing of their data on VMIND's domestic data recording systems, if necessary, in accordance with Turkish Data Protection Legislation, and to inform individuals in accordance with the procedures and principles set out in the Notification on Compliance with the Obligation to Inform Individuals for any data processing activity to be carried out using VMIND systems.

HOW LONG DO WE RETAIN PERSONAL DATA?

We process and retain individuals' personal data for the duration of the contract between your company, where you are an authorized representative/employee, and VMIND. Additionally, following the termination of the contract between VMIND and your company, we continue to retain the personal data of individuals for a period of 10 (ten) years in accordance with the statutory limitation periods specified in the Turkish Code of Obligations No. 6098, based on our legitimate interests (3). However, during the 10 (ten) year retention period after the termination of the contract, we maintain the personal data with restricted authorization, ensuring that only specific individuals can access it.

ENSURING THE SECURITY OF PERSONAL DATA

Ensuring the security of individuals' personal data is our priority. Personal data is securely stored by us or by our carefully selected service providers who act as data processors under a service and privacy agreement. We implement stringent security measures to safeguard personal data against loss, misuse, unauthorized access, or disclosure. We ensure that the technical and administrative measures we take in terms of security meet the requirements specified by Turkish Data Protection Legislation.

INDIVIDUALS' DATA PROTECTION RIGHTS

In accordance with Turkish Data Protection Legislation, individuals have the right to request the following information from VMIND at any time regarding their personal data:

a) To learn whether their personal data is being processed,

b) If their personal data is being processed, to request information regarding this processing,

c) To learn the purpose of processing their personal data and whether they are being used for their intended purpose,

ç) To know the third parties to whom personal data has been transferred domestically or abroad,

d) To request the correction of personal data if it is incomplete or inaccurate,

e) To request the deletion or destruction of personal data,

f) To request that the actions taken under subparagraphs (d) and (e) be communicated to third parties to whom the personal data has been transferred,

g) To object to the occurrence of a result against the individual's interests as a result of the analysis of processed data exclusively through automated systems,

ğ) To request compensation for damages in case of harm due to the unlawful processing of personal data.

IN CASE OF ANY ISSUES

If you are not satisfied with our data processing methods or if you have any questions or concerns, you can contact the Data Protection Officer at any time. (Email: [email protected])

1) It is regulated as one of the conditions that allow the processing of personal data without the explicit consent of the data subject according to Article 5(2)(c) of the Personal Data Protection Law No. 6698.

2) It is regulated as one of the conditions that allow the processing of personal data without the explicit consent of the data subject according to Article 5(2)(f) of the Personal Data Protection Law No. 6698.

3) It is regulated as one of the conditions that allow the processing of personal data without the explicit consent of the data subject according to Article 5(2)(f) of the Personal Data Protection Law No. 6698.