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LPPD Information

This information notice has been prepared in accordance with Article 10 of the Law No. 6698 on the Protection of Personal Data (“Law”) within the scope of VegaGrup Yazılım ve Bilişim Teknolojileri A.Ş. acting as the data controller, to inform individuals (“Data Subjects”) about the collection, processing, storage, protection, and destruction of their personal data, as well as their rights and how to exercise them.

Data Controller: VEGAGRUP YAZILIM VE BİLİŞİM TEKNOLOJİLERİ TİCARET ANONİM ŞİRKETİ Address: Universiteler Neighbourhood, 1596 Street, no :8 İnner gate no : 19 Cankaya /ANKARA Tel: +90 (850) 346 94 94 Website: www.vegayazilim.com.tr

  1. For what purposes do we process your personal data?

As the data controller, we may process your personal data for the following purposes:

• Negotiation, conclusion, and execution of contracts,
• Provision of products and services,
• Customization of offered products and services according to requests; updating, developing, and enhancing products and services due to customer needs, legal and technical developments,
• User identifications in systems specific to the offered products and services,
• Provision of call center and remote support services, call monitoring and tracking,
• Announcements of new or existing products, services, and campaigns, conduct of sales and marketing activities, • Conducting market research,
• Creating statistics and analyzing usage,
• Payment and collection of product, service, and service fees, selection of collection methods,
• Establishment of contact/communication,
• Conducting commercial relationships with cooperation companies, suppliers, resellers, and service providers,
• Reporting within the scope of cooperation,
• Evaluation of reseller partnership applications,
• Development of the company’s commercial strategies and plans,
• Contacting for satisfaction surveys by VegaGrup Yazılım,
• Providing discounts for purchases made from affiliated websites and institutions,
• Creating participant records for events/training organized by VegaGrup Yazılım, issuing certificates/participation documents, determining prize/gift recipients, and delivering prizes/gifts,
• Management of judicial/administrative processes, response to requests from public institutions and authorities, fulfillment of legal obligations, resolution of legal disputes,
• Conducting investor relations,
• Ensuring the consequences of mergers, divisions, or transfers of all or part of the company,
• Presentation of VegaGrup Yazılım employees, Individual Authorized Resellers/Customers, and Authorized Reseller/Customer Stakeholders in social media posts,
• Conducting job interviews, evaluating job applications,
• Establishment, execution, and termination of business relationships/contracts,
• Utilization of the main and ancillary rights arising from VegaGrup Yazılım employee contracts, evaluation of their performance and work,
• Opening user accounts for employees, issuing company ID and meal cards,
• Arrangement of transportation for company employees, tracking of company pool vehicles,
• Creation of participant records in case of participation in an organization on behalf of the company,
• Participation in trainings by employees and creation of certificate records,
• Creation and tracking of visitor records,
• Ensuring internal and environmental security of the company and the security of the Website and Applications,
• Usage analysis of the Website.

  1. To whom and for what purposes do we transfer your processed personal data?

Your personal data may be transferred to the following third parties within the scope of the purposes stated in paragraph 1 and in compliance with the provisions of the Law and other applicable legislation on personal data:

• Consultants
• Audit firms
• Service providers
• Cooperation companies (Solution Partners and Resellers)
• Customers
• Shareholders
• Suppliers
• Technopark management (Managing company)
• Banks and financial institutions
• Judicial authorities and public authorities
• Resellers
• Central Registry Agency, Public Disclosure Platform, Borsa Istanbul A.Ş., Custodians, Capital Markets Board

  1. What are our methods of collecting personal data and what are the legal grounds for our collection?

We can collect and process your personal data in accordance with the Law, regulations of this Policy, and other applicable legislation, in writing, verbally, electronically, through visual/audio recordings, or physically by being face-to-face with you.

Our data collection process can take place through: i) digital channels or software belonging to third parties including Websites, mobile applications, e-mails, recruitment portals; ii) forms, contracts, applications, call centers, remote support, sales and marketing units, cookies on Websites, business cards, phones; or iii) face-to-face meetings with Data Subjects.

  1. What are your rights as a data subject?

In accordance with Article 11 of the Law, as a data subject, you have the right to:

• Learn whether your data is being processed,
• Request information if your data has been processed,
• Learn the purpose of processing your data and whether it is used appropriately for that purpose,
• Know the third parties to whom your data is transferred, domestically or internationally,
• Request correction of incomplete or incorrect data and notification of these corrections to third parties to whom the data has been transferred,
• Request deletion or destruction of your data in case the reasons requiring processing cease to exist, and notification of these actions to third parties to whom the data has been transferred,
• Object to the occurrence of a result against you due to the analysis of processed data solely by automatic systems,
• Request compensation in case of damages due to unlawful processing of data.

However, according to Article 28/2 of the Law on Protection of Personal Data, except for the right to request compensation in case of damages, you cannot exercise the rights listed above in the following cases:

• If processing of personal data is necessary for the prevention of crime or for conducting investigations regarding crimes.
• If the relevant person has already made their personal data public.
• If processing of personal data is necessary for the discharge of duties or for the exercise of authorities conferred by law to public institutions and organizations, professional associations with public institution status for regulatory, inspection, disciplinary, or enforcement purposes.
• If processing of personal data is necessary for the protection of the State’s economic and financial interests regarding budget, taxation, and financial matters.

If you wish to exercise your rights, you can fill out the form that you can obtain by clicking the button on the left and send the signed form to our address at “Üniversiteler Mah. 1596.Cadde Hacettepe Teknokent 5.Arge Binası Kat:5 No:19, 06800 Çankaya/Ankara” via notary public or deliver it personally or through a proxy to the same address.

It is mandatory to provide identity documents, supporting documents if any, supporting documents for your request, and a special power of attorney containing the specific authority if you wish to exercise your rights through your representative.

Requests submitted with the form will be responded to free of charge within the shortest time possible and no later than thirty days, depending on the nature of the request. However, in case there is an additional cost, a fee may be charged according to the tariff determined by the Board.

If your request contains incomplete or incorrect information, is not clearly stated, or if supporting documents are not provided or not adequately provided, or if a power of attorney is not attached in the case of requests made through representatives, we may have difficulty in fulfilling your requests and there may be delays in the investigation process. Therefore, it is important to adhere to these rules when exercising your rights. Our company will not be responsible for delays caused by incorrect, unlawful, or malicious applications. Our company reserves its legal rights in cases of incorrect, unlawful, or malicious applications.

LPPD Application Form