CORPORATE GENERAL DISCLOSURE TEXT REGARDING THE PROCESSING OF PERSONAL DATA

As Compro Bilişim Teknolojileri A.Ş. (“COMPRO”), we have prepared this disclosure text to inform you, our Visitors, Online Visitors, Customers, Potential Customers, Supplier Employees, and Supplier Representatives, regarding the processing, storage, and transfer of your personal data within the framework of activities arising from the Law No. 6698 on the Protection of Personal Data (“KVKK”) and related legislation and legal regulations.

  • What Categories of Your Personal Data Do We Process and For What Purposes Do We Process Them?

Your personal information may be processed by COMPRO in accordance with Article 4.2 of the KVKK;

(i) Compliance with the law and rules of integrity,

(ii) Being accurate and up-to-date when necessary,

(iii) Processing for specific, explicit, and legitimate purposes,

(iv) Being relevant, limited, and proportionate to the purposes for which they are processed,

(v) Retention for the period stipulated in the relevant legislation or necessary for the purposes for which they are processed,

in accordance with these principles, within the scope of our business relationships established and continuing with our business partners (it is possible for a person to fall into multiple categories), for the purposes specified below.

 

  1. Our Visitors

Physical location security information of our visitors (e.g., camera recordings);

  1. Will be processed for the purposes of ensuring physical location security.
  1. Our Online Visitors

Transaction security information of our online visitors using our website (e.g., your IP address information), marketing information (e.g., shopping history information, cookie records), and (if you provide us with this information*) identity information, contact information (e.g., your e-mail address);

  1. Compliance with legislation,
  2. Execution of information security processes,
  3. Monitoring requests/complaints,
  4. Execution of communication activities,
  5. Providing information to authorized persons, institutions, and organizations,
  6. Will be processed to enable your access to our website via the internet.
  1. Our Customers

Identity information, contact information, customer transaction information (e.g., order information), transaction security information, physical location security information, financial information (e.g., balance sheet information), legal transaction information, marketing information (e.g., shopping history information) of our real person customers or the representatives and/or employees of our legal entity customers;

  1. Compliance with legislation,
  2. Execution of financial and accounting affairs,
  3. Execution/supervision of business activities,
  4. Execution of logistics activities,
  5. Execution of after-sales support services for goods/services,
  6. Execution of sales processes for goods/services,
  7. Execution of marketing analysis studies,
  8. Execution of contract processes,
  9. Providing information to authorized persons, institutions, and organizations,
  10. Ensuring physical location security,
  11. Resolution of legal disputes,
  12. Execution of storage and archiving activities,
  • Execution of risk management processes,
  1. Execution of advertising/campaign/promotion processes, ability to send commercial electronic messages,
  2. Execution of company/product/service loyalty processes,
  3. Will be processed for the purposes of conducting communication activities.
  4. Our Potential Customers

Identity information, contact information, customer transaction information, physical location security information, marketing information of our real person customers or the representatives and/or employees of our legal entity customers;

  1. Management of sales processes for goods/services,
  2. Execution of contract processes,
  3. Ensuring physical location security,
  4. Execution of advertising/campaign/promotion processes, ability to send commercial electronic messages,
  5. Will be processed for the purposes of conducting marketing analysis studies.
  1. Our Supplier Employee

Identity information, contact information, physical location security information of our supplier employee,

  1. Execution of communication activities,
  2. Execution/supervision of business activities,
  3. Ensuring physical location security,
  4. Execution of supply chain management processes,
  5. Execution of logistics activities,
  6. Compliance with legislation,
  7. Will be processed for the purposes of conducting occupational health/safety activities.
  1. Our Supplier Representative

Identity information, contact information, physical location security information, customer transaction information, financial information, marketing information, legal transaction information of our real person suppliers or the representatives of our legal entity suppliers;

  1. Execution/supervision of business activities,
  2. Execution of purchasing processes for goods/services,
  3. Execution of financial and accounting affairs,
  4. Execution of contract processes,
  5. Execution of investment processes,
  6. Ensuring physical location security,
  7. Will be processed for the purposes of tracking and executing legal affairs.
  • What are the Methods of Collecting Your Personal Data?

Your personal data specified above in categories are collected through physical means such as order forms, contracts, visitor forms, or through information systems and electronic devices (e.g., telecommunications infrastructure, computers, and telephones), third parties (e.g., KKB and Findeks), our website, and other documents declared by the data subject, by automatic or non-automatic means.

  • What is the Legal Basis for Collecting Your Personal Data?

Your personal data is processed by COMPRO in line with the realization of the purposes described above, based on the legal grounds specified in Article 5 of the KVKK;

(i) Explicitly stipulated in the laws,

(ii) 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,

(iii) Being mandatory for the data controller to fulfill its legal obligation,

(iv) Data processing being mandatory for the establishment, use, or protection of a right,

(v) Data processing being mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

(vi) The identity and contact data of our Customers and Potential Customers will be processed based on their explicit consent for the purposes of advertising, conducting campaigns, promotions, and sending commercial electronic messages.

  • Do We Transfer Your Personal Data to a Third Party?
  1. a) Personal data of our Visitors may be shared with law enforcement and judicial authorities in case of a request for the resolution of legal disputes and as required by the relevant legislation.
  1. b) Personal data of our online visitors may be shared with judicial authorities and authorized public institutions and organizations in case of a request for the resolution of legal disputes and as required by the relevant legislation.
  2. c) Personal data of our Customers is transferred to authorized public institutions and organizations to the extent required by legal regulations, for the purposes of conducting activities in accordance with legislation, tracking and executing legal affairs, and providing information to authorized persons, institutions, and organizations; to our company partners, IT company, suppliers, cargo companies, audit firms, banks, and our financial advisor to the extent necessary for the proper performance of our services, for the purposes of conducting/supervising business activities, executing risk management processes, and to the companies from which we receive accounting support. In addition, this personal data may be transferred to the law firm we receive services from and to judicial authorities in order to be used as evidence in legal disputes that may arise in the future. 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.
  1. d) Personal data of our potential customers may be transferred to the law firm we receive services from and to judicial authorities in order to be used as evidence in legal disputes that may arise in the future.
  1. e) Personal data of our supplier employee is transferred to authorized public institutions and organizations to the extent required by legal regulations, for the purposes of conducting activities in accordance with legislation, tracking and executing legal affairs, providing information to authorized persons, institutions, and organizations, and conducting/supervising business activities; to the extent necessary for the proper performance of the service, to company partners, IT company, suppliers, cargo companies, banks, and our financial advisor. In addition, this personal data may be transferred to the law firm we receive services from and to judicial authorities in order to be used as evidence in legal disputes that may arise in the future.
  1. Personal data of our supplier representative is transferred to authorized public institutions and organizations to the extent required by legal regulations, for the purposes of conducting activities in accordance with legislation, tracking and executing legal affairs, providing information to authorized persons, institutions, and organizations, and conducting/supervising business activities; to the extent necessary for the proper performance of the service, to company partners, IT company, suppliers, cargo companies, banks, and our financial advisor. In addition, this personal data may be transferred to the law firm we receive services from and to judicial authorities in order to be used as evidence in legal disputes that may arise in the future.
  • Do We Transfer Your Personal Data Abroad?

As COMPRO, we do not transfer your personal data abroad.

  • How Can You Exercise Your Rights Regarding Your Personal Data?

You can submit your requests within the scope of Article 11 of the KVKK, which regulates the rights of data subjects, to COMPRO via the https://www.compro.com.tr/ address, using the “Data Subject Application Form” prepared to provide you with convenience in accordance with 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