REGARDING THE PROCESSING OF YOUR PERSONAL DATA

CUSTOMER DISCLOSURE TEXT

Dear Customers,

This disclosure text has been prepared by Compro Bilişim Teknolojileri A.Ş., acting as the data controller, within the framework of Article 10 of the Law No. 6698 on the Protection of Personal Data (“KVKK”) and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform. It aims to inform you, our real person customers and/or the authorized persons and employees of our legal entity customers, regarding the purposes of processing your personal data, the legal reasons, the methods of collection, to whom it can be transferred, and your rights under the KVKK.

1. What Personal Data Do We Process?

Data Categories	Examples of Data Types Processed in This Category
Identity Data	Your name, surname, signature
Contact Data	Your phone number, open address, e-mail address
Legal Transaction Data	Information in correspondence with judicial authorities, information in the case file
Customer Transaction Data	Your invoice, bill, check information, order information, request information
Physical Location Security Data	Your security camera recordings
Financial Data	Your bank account information, credit/risk information
Marketing Data	Your shopping history information, survey and cookie records
Transaction Security	Your system access information

2. For What Purposes Do We Process Your Personal Data?

Your Personal Data mentioned above;

• To be able to offer you our products and services,
• To be able to carry out communication activities with you,
• To be able to carry out after-sales support services for goods/services to you,
• To be able to carry out customer relations and satisfaction management processes and customer satisfaction activities,
• To be able to follow up on your requests and/or complaints,
• To be able to carry out risk management processes,
• To be able to carry out our logistics activities,
• To be able to carry out contract processes,
• To be able to carry out the necessary work by our relevant business units for the realization of the commercial activities carried out and to carry out the related business processes,
• To be able to plan and implement commercial and/or business strategies, to carry out financial and accounting affairs,
• To be able to ensure the safety of our company and the physical location security and to provide the administrative and technical measures related to these,
• To be able to carry out marketing analysis studies of our products/services,
• To be able to carry out advertising, campaign, promotion processes related to our products/services, to be able to send commercial electronic messages,
• To be able to verify your identity information and documents when necessary; to be able to carry out the necessary procedures to prevent abuse, loss and fraud,

• To be able to preserve your information that must be kept in accordance with the relevant legislation; to perform the copying and backup of information to prevent data loss; to ensure the consistency control of your information; to take the necessary technical and administrative measures for the security of your information,
• To be able to fulfill our legal obligations required or mandated by regulatory and supervisory institutions and legal regulations, to carry out legal follow-ups and legal processes,

will be obtained, processed, recorded, stored, maintained, and classified for the purposes mentioned above.

3. To Whom and For What Purposes Do We Transfer Your Personal Data?

In matters related to public safety and in legal disputes that may arise, to be able to provide information to prosecutor’s offices, courts and relevant public officials upon request and as required by legislation; and, when necessary, to authorized public institutions and organizations within the scope of the purposes stated above, to the law firms we have contracted for the follow-up of legal processes, to financial advisors for the creation of our company’s financial balance sheets, to banks for the performance of goods/services contracts, to company partners for the management of our company and for the confirmation of our compliance with company rules and policies, to cargo companies for the purpose of sending documents and products, to audit firms for the auditing of our business activities, and to companies from which we receive accounting support in order to carry out accounting work. Based on your explicit consent, your identity and contact information may be transferred to a travel agency for the purpose of providing international accommodation and transportation services; your identity and contact information may be transferred to our international solution partners for the purpose of preparing an invitation letter.

4. What are the Methods of Collecting Your Personal Data and the Legal Reasons for Them?

Your personal data mentioned above are processed based on the legal grounds stated in Articles 5 and 6 of Law No. 6698: (i) being explicitly stipulated in the laws, (ii) being mandatory for the data controller to fulfill its legal obligation, (iii) being necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract, (iv) being mandatory for the legitimate interest of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned, and (v) your identity and contact data will be processed based on your explicit consent for the purposes of advertising, conducting campaigns, promotions, and sending commercial electronic messages to you.

Within the scope of the purposes stated in this Disclosure Text and in accordance with the General Principles stated in Article 4 of the Law below;

1. a) To be in compliance with the law and the rules of honesty,
2. b) Provided that it is accurate and up-to-date when necessary,
3. c) With specific, clear and legitimate purposes,
4. d) Related, limited and proportionate to the purposes for which they are processed,
5. e) To be stored for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed, by automatic means or by non-automatic means provided that they are part of any data recording system (e-mail, paper, forms, telephone, etc.) and may be transferred to the places mentioned above when necessary.

5. What are Your Rights Regarding the Processing of Personal Data and How Can You Access These Rights?

Article 20 of the Constitution states that everyone has the right to be informed about their personal data. Article 11 of the KVKK lists the rights of the personal data owner within the scope of the law.

You can submit your requests regarding your rights under the KVKK to COMPRO in writing or by using a registered electronic mail (KEP) address, secure electronic signature, mobile signature, or the electronic mail address previously notified to the data controller by the person concerned and registered in the data controller’s system, in accordance with Article 5 of the “Communiqué on the Procedures and Principles of Application to the Data Controller”.

Data Controller : Compro Bilişim Teknolojileri A.Ş.

Address : İçerenköy Mahallesi Çayır Cad. Partaş Plaza No:1 Kat:10

Ataşehir / İstanbul

Mail : kvkk@compro.com.tr