SUPPLIER DISCLOSURE TEXT REGARDING THE PROCESSING OF PERSONAL DATA

Dear Supplier,

p.com

This disclosure text has been prepared by Compro Bilişim Teknolojileri A.Ş., acting as the data controller, in accordance with 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 suppliers and/or the authorized persons and employees of our legal entity suppliers, 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, corporate e-mail address

Legal Transaction Data

Your information in correspondence with judicial authorities, your information in the case file

Customer Transaction Data

Your invoice and order information

Physical Location Security Data

Your security camera recordings

Financial Data

Your bank account information

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

Your Personal Data mentioned above;

  • To conduct communication activities with the company of which you are an executive or employee,
  • To carry out the processes of purchasing/selling goods/services with the company of which you are an executive or employee,
  • To carry out financial and accounting affairs,
  • To ensure the safety and physical location security of our company and to provide administrative and technical measures related to them,
  • To manage supply chain processes,
  • To manage logistics activities,
  • To verify your identity information and documents when necessary; to carry out the necessary procedures to prevent abuse, loss and fraud,
  • 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 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 processed, recorded, stored, maintained, and classified for the purposes mentioned above.

  1. 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 our company partners for the confirmation of our compliance with company rules and policies, to audit firms for the auditing of our business activities, to cargo companies for the purpose of sending documents and products, and to companies from which we receive accounting support in order to carry out accounting work.

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

Your personal data mentioned above are processed in accordance with the General Principles stated in Article 4 of the Law, within the scope of the purposes stated in this Clarification Text, with the legal reasons that it is (i) explicitly stipulated in the laws (ii) obligatory for the data controller to fulfill its legal obligation (iii) provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract (iv) it is obligatory for the legitimate interest of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned, 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.
  1. 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 Bilişim Teknolojileri A.Ş. 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