PRIVACY POLICY
PERSONAL DATA PROTECTION CLARIFICATION TEXT
As CTech Information Technologies Industry and Trade Joint Stock Company (“CTECH” or the “Company”), we attach great importance and sensitivity to the protection of your personal data. With this awareness, in our capacity as the “Data Controller” as defined in the Law on the Protection of Personal Data No. 6698 (“KVKK”), we process all kinds of personal data belonging to all individuals we are associated with in accordance with the KVKK, carefully and diligently, within the purposes and methods explained below, and within the limits set, complying with destruction requirements and retention periods.
Definitions
Within the scope of this Clarification Text on the Protection of Personal Data, the following terms shall mean:
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Personal Data: Any data relating to an identified or identifiable natural person (such as Name, Surname, Turkish ID Number, Email Address, Phone Number, and similar data),
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Sensitive Personal Data: Any data that, if learned, may cause discrimination or victimization and must be protected more strictly than other personal data (such as race, ethnic origin, biometric data, and similar),
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Processing of Personal Data: Any operation performed on personal data such as collection, recording, storage, alteration, sharing with third parties, and transfer abroad by automatic or non-automatic means as part of a data recording system,
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KVKK: The Law on the Protection of Personal Data No. 6698, published in the Official Gazette on April 7, 2016,
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Regulation: The Regulation on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform, published in the Official Gazette dated March 10, 2018, No. 30356,
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Authority: The Personal Data Protection Authority,
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CTech or Company: CTech Information Technologies Industry and Trade Joint Stock Company,
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Data Processor: A natural or legal person who processes personal data on behalf of the data controller based on its authorization,
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Data Controller: The person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system,
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Data Subject: The natural person whose personal data is processed,
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Contact Person: The person responsible for communication with the Authority and data subjects,
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Country: The country in which CTech is established and operates, in this case, Turkey,
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Website: The internet site of CTech with the domain name “https://ctech.com.tr/”, all intellectual property rights of which belong to CTech,
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IP Address: A number assigned to every device connected to the Internet used to identify the device’s location, also known as the Internet Protocol address.
Data Controller and Contact Person
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Data Controller: CTech Information Technologies Industry and Trade Joint Stock Company
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Address: Teknopark Sanayi Mah. Teknopark Bulvarı A Blok, Kat:2, Kurtköy, 34912 Pendik/İstanbul
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Contact Person: Onur HÜNERLİ
3. Processed Data, Purposes of Processing, and Collection Methods
The personal and sensitive personal data of you, our valued stakeholders, are collected in the following categories and by the methods mentioned below, and are processed by our Company for the purposes stated below.
3.1. OUR CUSTOMERS
From our customers who have entered into agreements and/or contracts with CTech to purchase products and/or services, the personal data listed below are collected by the methods and for the purposes mentioned below.
3.1.1. Identity Information
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Processed Personal Data: Name – Surname, Turkish ID Number
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Purposes of Processing:
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Compliance with legal obligations
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Conducting finance and accounting processes
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Legal follow-up and procedures
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Conducting communication activities
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Managing and auditing business activities
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Managing product/service sales processes
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Providing post-sales support services
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Managing customer relations
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Archiving and storage
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Managing contract processes
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Providing information to authorized persons, institutions, and organizations
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Collection Methods: Website contact forms, other communication forms, meetings, phone calls, billing information, quotation requests, contracts, and events.
3.1.2. Contact Information
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Processed Personal Data: Email Address, Billing & Delivery Addresses, Communication Address, Mobile Phone Number
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Purposes of Processing: (same as above)
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Collection Methods: (same as above)
3.1.3. Legal Transaction Information
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Processed Personal Data: Information in litigation/enforcement files in case of dispute, information in correspondence with judicial and administrative authorities
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Purposes of Processing:
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Compliance with legal obligations
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Legal follow-up and procedures
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Conducting communication activities
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Providing information to authorized persons, institutions, and organizations
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Archiving and storage
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Collection Methods: Through official documents and correspondence received from judicial and administrative authorities.
3.1.4. Physical Space Security
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Processed Personal Data: Camera recordings
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Purposes of Processing: Ensuring physical space security
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Collection Methods: Via cameras located at our Company premises visited by customers.
3.1.5. Financial Information
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Processed Personal Data: Credit Card Details, Bank Account / IBAN Numbers, Tax Identification Number
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Purposes of Processing:
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Compliance with legal obligations
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Conducting finance and accounting processes
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Providing post-sales support services
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Managing product/service sales processes
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Managing customer relations
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Providing information to authorized persons, institutions, and organizations
Methods of Collecting Personal Data:
The personal data mentioned above are collected through printed and electronic forms, emails, and telephone calls.
3.2. WEBSITE VISITORS
From visitors accessing the website, the personal data listed below are collected for the purposes and by the methods specified below.
3.2.1. Transaction Security
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Processed Personal Data: IP Address
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Purposes of Processing: Conducting information security processes; executing and auditing business activities; providing information to authorized individuals, institutions, and organizations
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Collection Methods: The personal data mentioned above are collected through the website.
3.3. EMPLOYEES / INTERNS / SHAREHOLDERS
Detailed information about the personal data of employees, interns, and shareholders within CTech is shared in a way that only they can access, and they are informed in detail about this.
3.4. JOB APPLICANTS
These are candidates who have applied to work at CTech or who have been identified by CTech through various channels or platforms.
3.4.1. Identity Information
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Processed Personal Data: Name – Surname, Turkish ID Number, Gender, Nationality
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Purposes of Processing: Managing job application processes; conducting communication activities; planning human resources processes
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Collection Methods: Collected via resumes sent by email to our company, through private employment agencies (İŞKUR, Kariyer.net, etc.), other platforms (LinkedIn, etc.), and personal declarations.
3.4.2. Contact Information
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Processed Personal Data: Email Address, Contact Address, Mobile Phone Number
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Purposes of Processing: (same as above)
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Collection Methods: (same as above)
3.4.3. Employment Information
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Processed Personal Data: Resume details, military service status, reference information, social security premium days, language scores, personality analysis indicators
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Purposes of Processing: (same as above)
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Collection Methods: Collected via resumes, private employment agencies (İŞKUR, Kariyer.net), online platforms (LinkedIn, company website), references, and intermediary organizations providing language score or personality analysis.
3.4.4. Physical Space Security
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Processed Personal Data: Camera recordings
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Purposes of Processing: Ensuring the security of physical premises
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Collection Methods: Recorded through security cameras located at company premises.
3.4.5. Professional Experience Information
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Processed Personal Data: Educational background and details, work history and details, diploma information, foreign language proficiency, computer skills, position/title information
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Purposes of Processing: (same as above)
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Collection Methods: (same as 3.4.3)
3.5. SUPPLIER REPRESENTATIVE
Personal data from representatives of suppliers who provide goods/services to CTech under agreement or contract are processed as follows:
3.5.1. Identity Information
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Processed Personal Data: Name – Surname, Signature Circulars, Signature, ID Copy
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Purposes of Processing:
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Compliance with legal regulations
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Conducting finance and accounting processes
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Managing communication activities
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Managing purchasing and logistics processes
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Executing contract processes
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Tracking requests/complaints
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Providing information to authorized individuals, institutions, and organizations
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Collection Methods: Collected through contracts, forms, order and request-related emails, invoices, and documents related to procurement processes.
3.5.2. Contact Information
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Processed Personal Data: Email Address, Contact Address, Mobile Phone Number
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Purposes of Processing: (same as above)
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Collection Methods: (same as above)
3.5.3. Physical Space Security
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Processed Personal Data: Camera recordings
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Purposes of Processing: Ensuring physical space security
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Collection Methods: Collected through security cameras at the company premises.
3.5.4. Financial Information
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Processed Personal Data: Invoice Information, Bank Account Information, Current Account Information
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Purposes of Processing:
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Compliance with legal regulations
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Conducting finance and accounting operations
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Managing supply chain processes
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Providing information to authorized individuals, institutions, and organizations
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Collection Methods: (same as 3.5.1)
3.6. SUPPLIER EMPLOYEE
Personal data of employees of suppliers providing goods/services to CTech are collected as follows:
3.6.1. Identity Information
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Processed Personal Data: Name – Surname, Signature, ID Copy
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Purposes of Processing: (same as 3.5.1)
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Collection Methods: (same as 3.5.1)
3.6.2. Contact Information
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Processed Personal Data: Email Address, Contact Address, Mobile Phone Number
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Purposes of Processing: (same as 3.5.2)
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Collection Methods: (same as 3.5.2)
Methods of Collecting Personal Data
The personal data mentioned above are collected through contracts, forms, request/order and related email correspondences, invoices, and procurement-related documents.
3.6.3. Physical Premises Security
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Processed Personal Data: Camera footage
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Purpose of Processing: Ensuring the security of physical premises
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Collection Method: The aforementioned personal data are collected through security cameras located at our company premises.
3.7. VISITORS
This refers to individuals visiting CTech’s premises for various reasons.
3.7.1. Physical Premises Security
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Processed Personal Data: Camera footage
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Purpose of Processing: Ensuring the security of physical premises
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Collection Method: The aforementioned personal data are collected through security cameras at the company premises.
Clarification Under KVKK
As the Data Controller, we would like to inform you within the scope of the Law on the Protection of Personal Data (KVKK). Pursuant to Article 4 of the KVKK, your personal and sensitive personal data, processed for the purposes and via the methods described above, will be:
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Processed lawfully and in good faith,
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Accurate and, where necessary, up to date,
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For specific, explicit, and legitimate purposes,
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Relevant, limited, and proportionate to the purposes for which they are processed,
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Retained for the period stipulated in relevant legislation or required for the purposes for which they are processed.
Transfer of Personal Data
Your personal data may be transferred, in line with the above-mentioned purposes and in full compliance with KVKK and all applicable legislation, to:
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Our shareholders,
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Our business partners,
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Our suppliers,
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Regulatory and supervisory authorities or official public institutions and organizations, as required by the applicable legislation and the purpose of company activities.
Retention and Deletion of Personal Data
Our company retains personal data for the periods specified in the relevant legislation or, where no period is stipulated, in accordance with company procedures and policies, in line with the services provided and industry practices. When the storage period expires, the data are deleted or destroyed using methods defined in our procedures and policies.
Your Rights as the Data Subject
According to Article 11 of KVKK, you have the right to:
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Learn whether your personal data are processed,
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Request information regarding the processing,
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Learn the purpose of processing and whether it is being used in accordance with that purpose,
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Know the third parties to whom your personal data are transferred domestically or abroad,
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Request correction if your data are incomplete or incorrectly processed,
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Request deletion or destruction of your data under applicable laws,
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Request notification to third parties to whom the data were transferred in case of correction or deletion,
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Object to a result that is to your detriment, arising from the analysis of personal data exclusively through automated systems,
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Request compensation for damages in case of unlawful data processing.
Exercising Your Rights
To exercise your rights, you may submit the Data Subject Application Form:
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In person or via postal mail or through a notary, to the address “Teknopark Sanayi Mah. Teknopark Bulvarı A Blok, Kat:2, Kurtköy, 34912 Pendik/İstanbul” with a wet signature and relevant documents,
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By sending a scanned version of the signed form to “ctech@hs01.kep.tr” from your registered email address that is on file with CTech.
To ensure that your application is processed, it must include:
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A clear and understandable request,
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Content related to your personal data,
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Proof of authorization if acting on behalf of someone else,
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Identification and address details,
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A copy of a document verifying your identity.
Application Evaluation Process
Your request will be concluded free of charge within the shortest time possible, and at the latest within 30 (thirty) days from the date of receipt by the Company. However, if the process incurs a cost, a fee may be charged according to the tariff set by the Board.
If your application is denied, not answered within the time period, or found insufficient, you may file a complaint to the Board within 30 days of being notified of the response, or in any case within 60 days from the application date.
Exceptions to Consent Requirement
Article 5 of KVKK regulates cases where your personal data may be processed without your explicit consent. Article 28 outlines exceptions to the application of the Law.
Enforcement and Publication
This Clarification Text came into effect on 20/09/2020 and is published on the CTech Website at: https://ctech.com.tr/
Should any part or the entirety of the Clarification Text require updates due to changing conditions or legislation, the effective date will be revised and re-announced.
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