INFORMATION NOTE UNDER PERSONAL DATA PROTECTION LAW

INFORMATION NOTE UNDER PERSONAL DATA PROTECTION LAW

We as the Smartpulse Teknoloji Anonim Şirketi (the “Company”), are acting as a data controller under the Personal Data Protection Law No. 6698 (the “Law”) which came into effect on 7 April 2016. Therefore, we, as the data controller hereby provide enlightening note as per the Article 10 of the Law in order to set out how we collect and process your personal data.

  1. What type of Personal Data is Processed?

Name, surname, telephone number, postal address, e-mail address, job, position, IP address, bank account details, Turkish ID Number, invoice details, cirriculum vitae and any other information relating to you which you may have provided us.

  1. Method and Legal Basis of Collecting Personal Data

The personal data is collected in order to perform the Company’s commercial activities and carry out the business relationship with our customers, electonically via e-mails, via cookies when the data owners visits the Company’s website or phsically via registration of the personal data by the data owner to the Company’s information data base or submission of the personal data to the Company’s related employees. During the job application process, the personal data is collected by way of online applications forms or e-mails or phsical submission of the cirriculum vitae. The legal ground for collection of the personal data is directly related to the agreement to be executed and performed by and between the data owner and the Company and provision of services by the Company.

The personal data can be processed  within the scope of the data processing conditions and purposes set out in Article 5 and 6 of the Law and the purposes indicated in the Article 3 of this Infırmation Note. The personal data which are processed as per this Information Note will be erased, destroyed or anonimised after the purpose for collection of the data no longer exists or after expiry of the statutory periods indicated in the applicable laws for retaining the personal data.

  1. The Purpose of Processing

The personal data is processed, recorded and transferred in order to perform Company’s comemrcial activities and carry out the commercial relationship with the data owner, to render the services or sell the Company products and perform related processes, to determine the Company’s business strategy, to offer or promote the Company products to data owners as per the needs and habits of the customers, to manage the customer relations, services and the customer satisfaction, to carry out market research in relation to the services and products of the Company, to manage the Company’s performance assesment, to issue invoice by the Company, to transfer and receive payment in consideration for the services provided, to keep the job application data base, to update the Company’s personal data records, to manage the job application processes, to hire the new employees for the Company and formation of the cirriculum vitae data base, to follow up the data security procedures.

  1. Where do we transfer the Personal Data?

For the puposes indicated herein, the personal data may be transferred, where necessary, to the Company’s affliates, services providers who support the Company’s services, Company’s legal, financial, tax and operational consultants, auditors, data base storage infrastructure service providers, cloud service providers, to the banks to receive and make the payments.

  1. Rights of the Data Owner as per the Law

As per the Article 11 of the Law, the data owners can apply the data controller i) to learn whether their personal data are processed or not, ii) to request information if their personal data are processed, iii) to learn the purpose of data processing and whether the data is used for intended purposes, iv) to know the third parties to whom their personal data is transferred within the country and abroad, v) to request the correction of the incomplete or inaccurate data vi) to request the deletion or destruction of the personal data as per the Article 7 of the Law, vii) to request notification of the operations carried out in compliance with subparagraphs (v) and (vi) to third parties to whom their personal data have been transferred, viii) to object to the processing the data by automatic means, which may lead to an unfavourable consequence for the data owner ix) to request compensation for the damage arising from the unlawful processing of personal data.

For any queries:

Smartpulse Teknoloji Anonim Şirketi

Adres: Sultan Selim Mah., Libadiye Sok., No: 3, Kat: 3, Kağıthane, İstanbul  Türkiye

Contact e-mail: [email protected]