PROTECTION AND PROCESSING OF PERSONAL DATA POLICY

1. AIM

As www.istinyetech.com; The personal data of real persons, including our members, customers, visitors, suppliers and employees, are processed and processed in accordance with the relevant legislation, especially the Constitution of the Republic of Turkey, the International Conventions on human rights to which our country is a party, and the Personal Data Protection Law No. 6698 (“KVKK”). It is our priority to ensure that the rights of the relevant persons are effectively exercised.

For this reason, but not limited to the following; The processing, storage and transfer of data regarding our employees, suppliers, customers, visitors, members, stores, users visiting our website and mobile applications, in short, all personal data we obtain during our activities, are subject to www.istinyetech.com Personal Data Protection and Processing Policy (“ Policy”).

Protection of personal data and respect for the fundamental rights and freedoms of natural persons whose personal data are collected are the basic principles of our policy regarding the processing of personal data. For this reason, we continue all our activities in which personal data is processed by taking into account the rights to protect the privacy of private life, confidentiality of personal information, confidentiality of communications, freedom of thought and belief, and the use of effective legal remedies.

For the purpose of protecting personal data, we take all administrative and technical protection measures required by the nature of the data in accordance with the legislation and current technology.

This Policy explains the methods we follow for the processing, storage, transfer and deletion or anonymization of personal data shared during our commercial, promotion-marketing or social responsibility and similar activities, within the framework of the principles mentioned in the Personal Data Protection Law.

• SCOPE

All personal data processed by the Company, including our visitors, business contacts, business partners, employees, suppliers, members and third parties, are within the scope of this Policy.
Our policy is applied in activities related to the processing of all personal data owned or managed by the Company, and has been handled and prepared by taking into consideration the KVKK and other relevant legislation regarding personal data and international standards in this field.

• DEFINITION AND ABBREVIATIONS

In this section, special terms and expressions, concepts, abbreviations, etc. used in the Policy. is explained briefly.

• www.istinyetech.com: (Hereinafter referred to as “İstinye Technology”) service.
• Explicit Consent: Consent regarding a specific subject, based on information and free will, given in a clear manner that leaves no room for hesitation, and limited only to that transaction.
• Anonymization: Making personal data impossible to attribute to an identified or identifiable natural person in any way, even by matching it with other data.
• Employee: Company Personnel.
• Personal Data Owner (Relevant Person): The real person whose personal data is processed.
• Personal Data: Any information regarding an identified or identifiable natural person.
• Special Personal Data: Persons' race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, health information, fingerprints, appearance and clothing, association, foundation or union membership, health, sexual life, criminal record. data regarding his conviction and security measures, as well as biometric and genetic data.
• Processing of Personal Data: Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. or any action performed on the data, such as preventing its use.
• Data Processor: Real or legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller.
• Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.
• KVK Board: Personal Data Protection Board.
• KVK Authority: Personal Data Protection Authority.
• KVKK: Personal Data Protection Law published in the Official Gazette No. 29677 dated April 7, 2016.
• Policy: istinyetech.com Personal Data Protection and Processing Policy.
• (Membership System): Company and Company digital platforms membership system.
• ROLES AND RESPONSIBILITIES

4.1. Board of Directors
The Board of Directors is responsible for the top oversight of the determination and operation of notification, review and sanction mechanisms in case of non-compliance with the Policy, rules and regulations.

Personal Data Protection and Processing Policy has been approved by the Board of Directors.

It is the authorized approval mechanism to ensure that the policy is created, implemented and updated when necessary.

4.2 Audit Unit
The Audit Unit is responsible for taking the necessary measures for the compliance of the outsourced companies with the Policy, together with the employees involved, and examining the issues in order to examine the issues that are contrary to the Policy.

4.3 Information Systems Commission

The Information Systems Commission is responsible for the preparation, development, implementation and updating of this Policy. It evaluates this Policy in terms of its currentness and development needs when necessary. It is the responsibility of the Information Systems Commission Manager to publish the prepared document on the institution portal.

• LEGAL OBLIGATIONS

In accordance with KVKK, as a data controller, the legal obligations within the scope of protection and processing of personal data are listed below:

5.1. Our obligation to enlighten

While collecting personal data as the data controller;

• For what purpose your personal data will be processed
• Our identity, information about the identity of our representative, if any
• To whom and for what purpose your processed personal data may be transferred
• Our method of collecting data and its legal basis
• We have the obligation to inform the Relevant Person regarding the rights arising from the law.

As a company, we take care to ensure that this Policy, which is open to the public, is clear, understandable and easily accessible.

5.2. Our obligation to ensure data security

As the data controller, we take the administrative and technical measures stipulated in the legislation to ensure the security of the personal data we are responsible for. Obligations regarding data security and measures taken are detailed in sections 9 and 10 of this Policy.

TERMS OF USE, GENERAL CONDITIONS AND LIABILITY

These terms regulate the rules of use of the site. Please read the following terms of use before using the www.istinyetech.com website. All Users who use the www.istinyetech.com site in any way will be deemed to have agreed to comply with the terms on this page.

www.istinyetech.com is an İstinye Technology service. The term "User" used in this text refers to any real or legal person who uses the site in any way, with or without logging in.

The terms of use on this page may be changed unilaterally by İstinye Teknoloji at any time, provided that the changes are clearly stated on this page, and these changes become effective immediately upon the posting of the amended agreement on the site. When users use www.istinyetech.com services in any way, they will be deemed to have unconditionally accepted the terms published on this page. By agreeing to review the agreement periodically to be informed of these changes, your continued access or use of the site will mean that you have definitively accepted the changed terms of use.

You may not modify or adapt the www.istinyetech.com Service or modify another website in a way that gives the false impression that it is associated with the www.istinyetech.com Service or İstinye Technology.

www.istinyetech.com stores users' personal information only to fulfill certain services, to provide content and advertisements on the site according to users' requests and to inform them about new services. www.istinyetech.com users have the opportunity to change their personal information while browsing the website. This information can only be changed by the user.

Features of www.istinyetech.com users such as sections visited and areas clicked during their navigation on the site are automatically recorded. These data are used only to determine the viewing and following rates of sections and different areas. In cases where the technology called "cookie" is used, which determines where or how the pages are visited, statistical data is collected in the same way to determine the viewing and clicking rates of different areas of the site; It is not a personalized application. The aim of this technology is to make the content of the sections that users visit more frequently more easily accessible to the user from the first visit to the site. In order to improve the quality of the content provided to users and to provide direct access to some services, data regarding geographical location information can be recorded and used if the user gives consent.

www.istinyetech.com does not undertake to provide uninterrupted or certain service to the users of the website. Likewise, it does not make any suggestions or recommendations to the user that the operation and administration of the website will be error-free and uninterrupted, that faults, defects and defects will be corrected, that the website is clean from harmful elements and viruses, and no assurance or guarantee is given to the user in these matters. The information in these Terms of Use is presented for the sole purpose of informing the user; It does not constitute advice on legal, medical, financial, investment, tax, accounting or other similar matters. Any action you take by relying on the information published on www.istinyetech.com is entirely your responsibility.

The information in these Terms of Use is presented for the sole purpose of informing the user; It does not constitute advice on legal, medical, financial, investment, tax, accounting or other similar matters. Any action you take by relying on the information published on www.istinyetech.com is entirely your responsibility.

İstinye Teknoloji, on www.istinyetech.com, any information that creates or encourages a criminal situation, is threatening, contains insults and profanity, is defamatory, pornographic, disturbing or immoral, or discriminates against gender or race. reserves the right to change the material and content, refuse to publish or remove it from publication, and freeze and terminate the memberships of users who engage in such actions.

This site provides links and pointers to websites managed by third parties, and content on third-party sites is used. The information, products and services on third party sites are not operated or controlled in any way. Additionally, this does not mean that the accuracy and reliability of the content of third party websites is approved. Therefore, no responsibility is accepted for the information or ideas contained on third party websites. Again, it should never be inferred that the accuracy and reliability of the web contents of the links provided by third parties to the site are approved by us.

Users are obliged not to violate the legal rights of third parties in any way when using any content or communication system of www.istinyetech.com. İstinye Teknoloji does not accept any legal or criminal liability regarding such violations, and any legal and criminal liability that may arise from such violations belongs exclusively to the User.

İstinye Teknoloji, under any circumstances, is liable for any direct and/or indirect material and/or moral, negative and/or positive damages arising from access to this www.istinyetech.com website and the direct or indirect use of the information on the site and/or portal services. Board members, managers, group companies, subsidiaries, employees, and persons who prepared the information and/or portal services on this site cannot be held responsible.

You may not create an account on the www.istinyetech.com Service through unauthorized means, including, but not limited to, by using any automated device, code, bot, spider, bug or scraper.

You must not attempt to restrict any other user from using or enjoying the www.istinyetech.com Service, and you must not encourage or facilitate any violation of these Terms of Use or other www.istinyetech.com terms.

Any behavior or action that aims to render the site inoperable, slow it down significantly, or damage software and hardware systems is prohibited. Making a large number of inquiries or membership registrations using automatic programs or sending a large number of requests or information to the site by automatic methods are also included in this prohibition. İstinye Teknoloji has the right to block access to the site and initiate legal action against Users who are found to be engaging in such activities.

www.istinyetech.com website users shall not transmit to the website any content, software or any other material that contains a virus or other harmful element.

Violation of these Terms of Use may result in termination of your www.istinyetech.com membership, at İstinye Teknoloji's sole discretion. You acknowledge that the Content you share on the www.istinyetech.com Service is not and cannot be the responsibility of İstinye Teknoloji, and that the risks you may encounter while using the www.istinyetech.com Service are entirely your responsibility. If you violate the spirit or text of these Terms of Use in any way or expose İstinye Teknoloji to a risk or other possible legal sanction, we may partially or completely stop providing the www.istinyetech.com Service to you.

İstinye Technology, www.istinyetech.com does not accept liability for any damages that may occur as a result of the use of users' personal information within the framework of the above conditions.

In e-mail communications, if the message is not encrypted, the security of the message cannot be guaranteed and www.istinyetech.com users are responsible for the security of the e-mails to be sent.

You are responsible for any actions that occur through your membership and you agree that you will not sell, transfer, delegate or allow the use of your membership, username or other membership rights. Except for individuals or businesses that are expressly authorized to create accounts on behalf of their employers or clients, www.istinyetech.com prohibits the creation of, and you agree that you will not, create an account for anyone other than yourself. You also represent that all information you provide or have provided to www.istinyetech.com upon registration and at all other times will be true, accurate, current and complete and you agree to update your information as necessary to maintain its truth and accuracy.

You agree not to solicit, collect or use login information from other www.istinyetech.com users.

You may not use the www.istinyetech.com Service for any illegal or unauthorized purpose. You agree to comply with all applicable laws, ordinances and regulations, including but not limited to copyright laws, when using the www.istinyetech.com Service and Your Content (defined below).

Your behavior and all data, texts, files, information, usernames, images, graphics, photographs, profiles, audio and video clips, sounds, Musical works, original works, applications, links and other content and materials (collectively referred to as “Content”) are your sole responsibility. www.istinyetech.com users can publish their opinions regarding the contents of the site in 'comments'. The responsibility for the opinions expressed by the users belongs to the user, the responsibility cannot be directed to İstinye Teknoloji.

Users of the www.istinyetech.com website acknowledge that they have obtained the necessary permissions from the persons who own the personal rights in question regarding the personal information and information and/or content regarding the private life of individuals contained in the content, and that they do not violate anyone else's personal rights, privacy rights or publicity rights or contents and information protected by all kinds of intellectual and industrial property rights, including other property rights; They accept and undertake that they will not use the website without obtaining prior written permission from the owner or rights holder.

www.istinyetech.com website users; any illegal, threatening, disturbing, violent, terroristic, insulting, profane or slanderous, humiliating, vulgar, pornographic, disturbing, threatening, harassing or insulting, or contrary to morality, social order, persons and/or institutions They will not transmit content to the www.istinyetech.com website that may harm their private life, personality and other rights, and will not upload/publish messages or content that may disturb members in any way in public areas or private message areas. Publishing these contents on www.istinyetech.com does not mean that the service provider İstinye Teknoloji assumes any responsibilities that may arise for content that is unlawful or violates the rights of third parties.

www.istinyetech.com website users will avoid any behavior that may lead to unfair competition in the commercial sense, take advantage of commercial reputation, and will not copy the existing content on the website in any way.

If users provide inaccurate and up-to-date information to the www.istinyetech.com website or if the accuracy and up-to-dateness of the information is suspected, İstinye Teknoloji reserves the right to suspend or terminate the services.

www.istinyetech.com website users will not prevent any other user from using the website or using it as they wish. The use of comment areas as an advertising medium for other websites or commercial goods and services is prohibited.

We reserve the right to deny anyone access to the www.istinyetech.com Service at any time and for any reason.

We reserve the right to change and/or revoke the right to use any username for any reason.

We may remove, edit, block and/or monitor Content or accounts containing Content that we determine in our sole discretion violates these Terms of Use, but we have no obligation to do so.

Users have the right to terminate their membership at any stage. If the account is closed by either the User or İstinye Teknoloji, all licenses and other rights granted to you in these Terms of Use terminate immediately.

The terms of use on this page may be changed unilaterally by www.istinyetech.com and İstinye Teknoloji at any time, provided that the changes are clearly stated on this page, and these changes become effective immediately upon the posting of the amended agreement on the site. When users use www.istinyetech.com services in any way, they will be deemed to have unconditionally accepted the terms published on this page. By agreeing to review the agreement periodically to be informed of these changes, your continued access or use of the site will mean that you have definitively accepted the changed terms of use.

INTELLECTUAL AND INDUSTRIAL PROPERTY

www.istinyetech.com website users will avoid any behavior that may lead to unfair competition in the commercial sense, take advantage of commercial reputation, and will not copy the existing content on the website in any way.

All materials in the site, including code and software, are protected in accordance with the legal legislation regarding Intellectual and Industrial Property Rights.

www.istinyetech.com users shall be subject to processing of all kinds of text, photographs, videos, software, information, visual, audio materials and other applications including but not limited to these and/or processing and/or sound recordings and/or any created material that they upload to the website. All property rights on all kinds of compositions and versions and/or all determinations obtained from them and/or related to them (hereinafter referred to as "Content") and reproduction and dissemination arising from ownership of the work and the Law on Intellectual and Artistic Works No. 5846 financial rights in the form of representation, financial rights in the form of representation and/or related rights arising from being a performer and/or producer, determining the form, time and place of presentation to the public and making any changes in the work and design, rights arising from the trademark, registration of designs and application to products and all other intellectual and industrial rights, personal rights of image/sound/content owners, in any media/platform/product/material/organization determined by İstinye Teknoloji. (including radio, TV, internet, cinema, direct marketing activities, press conferences, written and visual media, electronic or digital media such as wap, kiosk, mobile phone, telephone switchboard and IVR music, telephone ring tones, etc.) Added All kinds of services, media, satellite services within the scope of Valuable Services (Cell broadcasting, WAP/GPRS, mobile music, mobile video, playback, Mobile TV, Videostreaming and all other song download services and/or new generation mobile technologies that will develop after this date). cable, other digital, wired and wireless devices, including but not limited to those mentioned above, and transferable to others, without any time and medium restrictions, for use in Turkey and around the world, without demanding any fee, He accepts, declares and agrees that he/she consents to it being published and/or displayed/monitored by third parties to be determined by the company without the need for permission, and to the contents in question and the system records related to these contents (uploading the contents to the system, extracting them, etc.) to be recorded/processed by İstinye Technology and shared with infrastructure providing companies. commits.

www.istinyetech.com website users, all property rights on the content in question and on any element constituting Intellectual and Industrial Rights contained in the content, in the form of reproduction, dissemination, processing, transmission to the public by means of sign, sound and/or image transmission. It is the full and sole owner of the financial and related rights arising from being a producer and/or performer, as well as the personal rights of the image/sound/content owners, and that it is the full and sole owner of the rights arising from sub-employees, relevant work or rights owners, or the professional associations to which they are affiliated, pursuant to Articles 48 and 52 of FSEK. In accordance with the health conditions regulated in the articles and in writing, unlimitedly and indefinitely, in Turkey and all over the world, in all kinds of products/platforms/materials/organizations/mediums, etc., including those listed above. They accept and undertake that they have taken over the works in a way that can be transferred to third parties, that they have received permission, that they are the right holders, that they are responsible for all the fees that must be paid to the Professional Associations due to the works, that these rights are under their own responsibility, and that they have the ability and legal authority to transfer these rights, They accept and undertake that no third party has any restriction, financial, moral or commercial right under any name or name, directly or indirectly, on these rights.

The laws of the Republic of Türkiye apply to these Terms of Use. If any provision of this agreement shall be deemed illegal, invalid or otherwise legally unenforceable for any reason, that provision may be severed from this agreement. However, this does not affect the validity and legal applicability of the remaining articles.

Istanbul Courts and Enforcement Offices are authorized to resolve disputes that may arise from the application of the provisions and legal relations written above.

INFORMATION AND CONSENT REGARDING THE PROCESSING OF PERSONAL DATA

In accordance with the "Personal Data Protection Law" No. 6698 published in the Official Gazette No. 7 April 2016, İstinye Teknoloji has adopted a number of basic rules as the "Data Controller" in order to protect the confidentiality of all personal data of www.istinyetech.com users.

Protection of Personal Data In accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), any information that helps to identify or identify a natural person is within the scope of personal data. Your personal data at www.istinyetech.com will be recorded, stored, preserved, stored, updated and recorded in our systems by our Company, as the Data Controller, in accordance with the information storage, reporting and information obligations stipulated by the relevant legal regulations and legal authorities, for the reasons, purposes and methods explained below. It may be disclosed/transferred to third parties, classified and processed in the ways listed in KVKK, in cases permitted by the legislation and within legal limits. www.istinyetech.com aims to protect the user's justified trust in the institution by acting in accordance with these basic rules. For this reason, we kindly request you to obtain information about the legal issues listed below.

Lighting Obligation: As the "Data Controller", our Company is obliged to act in accordance with the Personal Data Protection Law. As the data controller; It will store your personal data and sensitive personal data, but will be able to share it with third parties residing at home and abroad, in cases permitted by the legislation, and will be able to classify it and process it as specified in the Law.

Personal Data Collection Method: Your personal data; It may be collected by İstinye Teknoloji in written or electronic form. While preserving your data, we declare and undertake that we will comply with the relevant Laws and the rule of honesty, as stated in the 2nd Paragraph of Article 4 of the Law, and that we will keep your data accurate and updated when necessary. In order to avoid any doubt, the obligation to keep up to date specified in paragraph 2-b of Article 4 of the Law will be limited to the extent to which the company notifies the personal or private personal data of www.istinyetech.com users. İstinye Technology is obliged to take all necessary technical and administrative measures to ensure the appropriate level of security in order to prevent the unlawful processing of personal data, to prevent unlawful access to data, and to ensure the preservation of personal data.

Purposes and Legal Reasons for Processing Personal Data: İstinye Teknoloji saves some of your personal information to the mobile application in order to provide service to you, the user, in accordance with Article 4 of the Personal Data Protection Law No. 6698 and in any case, provided that it does not go beyond the exceptional cases specified in paragraphs a, c and e of the 2nd paragraph of Article 5. He wants to share it by. İstinye Technology stores users' personal information only to fulfill certain services, to provide content and advertisements on the site according to users' requests and to inform them about new services. www.istinyetech.com users have the opportunity to change their personal information while browsing the website. This information can be changed by İstinye Teknoloji and by the user at any time, if deemed necessary. Features of www.istinyetech.com users such as sections visited and areas clicked during their navigation on the site are automatically recorded. These data are used only to determine the viewing and following rates of sections and different areas. In cases where the technology called "cookie" is used, which determines where or how the pages are visited, statistical data is collected in the same way to determine the viewing and clicking rates of different areas of the application; It is not a personalized application. The aim of this technology is to make the content of the sections that users visit more frequently more easily accessible to the user from the first visit to the site.

İstinye Technology will be able to process information as specified in the Law with persons, institutions and organizations authorized by our laws and those who are allowed to process information within the scope of relevant laws.

Persons/Organizations to which Personal Data Can Be Transferred: İstinye Technology with institutions and organizations permitted by legal legislation; but not limited to all official authorities, customers, solution partners and other third parties with whom İstinye Teknoloji carries out commercial activities under contracts to which it is a party. İstinye Teknoloji has the right to disclose the information of www.istinyetech.com users if required in the following cases: 1. If the user has permission and approval to share their personal information, 2. For use within www.istinyetech.com and İstinye Teknoloji. for the purpose of determining user profiles, 3. In order to develop and provide the products and services that the user requests from www.istinyetech.com and İstinye Technology or to solve problems related to the services and tools offered to you, 4. With whom the user works together while providing products and services to the user ( To be used in the provision of these products and services to companies (with which it cooperates), 5.During legal investigations, if required by court order or legal procedures.

Deletion of Personal Data: Your data maintained within the scope of the law; If the reasons for processing your data disappear, it will be deleted, destroyed or anonymized under the conditions to be determined by the Regulation mentioned in the 3rd paragraph of Article 7 of the Law, in line with your request.

Your Rights Within the Framework of Article 11 of the Law: By applying to www.istinyetech.com; a) learning whether your personal data has been processed, b) requesting information if your personal data has been processed, c) learning the purpose of processing your personal data and whether it is used in accordance with its purpose, d) knowing the third parties to whom your personal data is transferred domestically / abroad, d) missing your personal data / to request correction if it has been processed incorrectly, e) to request the deletion / destruction of your personal data within the framework of the conditions stipulated in Article 7 of the Law, f) to request notification of the transactions made in accordance with paragraphs (d) and (e) above to third parties to whom your personal data has been transferred, g ) you have the right to object to a result against you arising from the analysis of your personal data exclusively by automatic systems, and g) to request compensation for the damage if you suffer damage due to the unlawful processing of your personal data.

www.istinyetech.com may record and use data regarding your geographical location, if you consent, in order to improve the quality of the content provided to you and to provide direct access to some services.

This information letter and consent are part of the use and privacy agreement you have accepted.

Within the framework of these statements, my personal data will be collected, processed, updated, periodically checked, kept and stored in the database by İstinye Technology and www.istinyetech.com in accordance with the Law on the Protection of Personal Data No. 6698 and, if necessary, with the relevant public institutions and organizations. I accept, declare and undertake that I consent to my personal data being shared with third parties, who are our solution partners, and kept by them as a requirement of our business relationship.

PRIVACY POLICY

www.istinyetech.com is an İstinye Technology service.

This text has been prepared to inform you about information security and to explain the rules and responsibilities that must be followed.

You are expected to provide your personal information during your visit to the www.istinyetech.com website. Your personal information shared by you and recorded by us is and will continue to be protected by www.istinyetech.com and İstinye Technology.

Your information such as your name and surname, postal address, date of birth, gender, telephone number and e-mail address are recorded when you provide them to www.istinyetech.com.

www.istinyetech.com has the right to disclose user information if required in the following cases:

1. If the user has permission and approval to share his personal information,
2. 2. In order to determine user profiles for use within www.istinyetech.com and İstinye Teknoloji,
3. 3. In order to develop and provide the products and services requested by the user from www.istinyetech.com and İstinye Teknoloji or to solve problems related to the services and tools offered to you,
4. 4. While offering products and services to the user, to the companies with which it works (collaborates) to be used in the provision of these products and services,
5. 5.During legal investigations, if required by court order or legal procedures.

In order to ensure your information security, you should not share your passwords with anyone.

If the message in question is not encrypted in e-mail communication, the security of the message cannot be guaranteed and you are responsible for the security of the e-mails you send.

We may provide links to other websites that are not operated by İstinye Teknoloji on our website. If you visit any of these websites, you should review that site's privacy and other policies. We would like to point out that İstinye Teknoloji is not responsible for the policies and practices of other companies. It is possible for www.istinyetech.com to change the Terms of Use and Privacy Policies, and we recommend that you check the relevant pages regularly.