Clarification Text

PURE7 SOFTWARE SOFTWARE AND CONSULTANCY SERVICES ANONİM ŞİRKETİ

CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA

AsPure7 Yazılım Bilişim ve Danışmanlık Hizmetleri Anonim Şirketi (‘Pure7’ or ‘Company’), we show great sensitivity and importance to the protection of your personal data. With this awareness, as defined in the Personal Data Protection Law No. 6698 (‘KVKK’), as ‘Data Controller’, we process all kinds of personal data belonging to all persons we are related to, with the purposes and methods described below, within the limits determined, within the limits determined, by complying with the destruction requirements and periods, carefully and carefully, in accordance with the KVKK.

  1. Definitions

The following terms and conditions are defined in this Clarification Text on the Protection of Personal Data;

Personal Data: All kinds of data relating to an identified or identifiable natural person (name, surname, Turkish ID number, e-mail address, telephone number and all other similar data),

Sensitive Personal Data: All kinds of data (race, ethnic origin, biometric data and all other similar data) which, if learned, may cause discrimination or victimisation of the person concerned and which should be protected much more strictly than other personal data,

Processing of Personal Data: Any operation performed on personal data, including obtaining, recording, storing, modifying, sharing with third parties and transferring personal data abroad by automatic or non-automatic means provided that it is a part of any data recording system,

KVKK Law No. 6698 on the Protection of Personal Data, which entered into force after being published in the Official Gazette on 7 April 2016,

Communiqué Communiqué No. 30356 on the Procedures and Principles to be followed in the Fulfilment of the Disclosure Obligation, which entered into force upon publication in the Official Gazette on 10 March 2018,

Institution: Personal Data Protection Authority,

Pure7 or Company: Pure7 Yazılım Bilişim ve Danışmanlık Hizmetleri Anonim Şirketi,

Data Processor: A natural or legal person who processes Personal Data on behalf of the Data Controller based on the authorisation granted 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 the establishment and management of the data recording system,

Data Subjects: The natural person whose Personal Data is processed,

Contact Person: The person who provides communication with the Institution and liaison with the Data Subjects,

Country: The country in which Pure7 is incorporated and operates, in this case Turkey,

Website: Pure7’s website with the domain name “pure7.com.tr”, all industrial property rights of which belong to Pure7,

IP Address: A number assigned to each device connected to the Internet, used to identify the location where the device is connected to the Internet and known as the Internet Protocol address, means.

  1. Data Controller and Contact Person

Data Controller : Pure7 Yazılım Bilişim ve Danışmanlık Hizmetleri Anonim Şirketi

Address : Burhaniye Mahallesi Yunus Emre Sokak No:10 Üsküdar/Istanbul

Contact Person : Ozgur Senol

  1. 3. Processed Data, Data Processing Purposes, Collection Methods

The personal and sensitive personal data of our valued stakeholders, who are the data subject/data subject, in the following categories are collected by the collection methods specified below and processed by our Company for the purposes specified below.

  1. 3. Processed Data, Data Processing Purposes, Collection Methods

The personal and sensitive personal data of our valued stakeholders, who are the data subject/data owner, in the following categories are collected by the collection methods specified below and processed by our Company for the purposes specified below.

3.1. OUR CUSTOMERS

The following personal data are collected from our Customers who purchase products and/or services from Pure7 by reaching an agreement and/or concluding a contract with Pure7 for the following purposes and methods.

3.1.1. Identity Information

Processed Personal Data:

Name – Surname, T.R. Identity Number

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Execution of Financial and Accounting Affairs; Follow-up and Execution of Legal Affairs; Execution of Communication Activities; Execution and Audit of Business Activities; Execution of Goods / Service Sales Processes; Execution of Goods / Service After Sales Support Services; Execution of Customer Relations Management Processes; Execution of Activities for Customer Satisfaction; Execution of Advertisement, Campaign and Promotion Processes; Organisation and Event Management; Execution of Storage and Archive Activities; Execution of Contract Processes; Follow-up of Requests / Complaints; Management of Marketing Processes of Products / Services; Providing Information to Authorised Persons, Institutions and Organizations.

Methods of Collection of Personal Data:

The above-mentioned personal data are collected through the website contact form, other contact forms, interviews, telephone conversations, billing information notifications, offer requests, contracts and events.

3.1.2. Contact Information

Processed Personal Data:

E-Mail Address, Billing & Delivery Addresses, Contact Address, Mobile Phone Number

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Execution of Financial and Accounting Affairs; Follow-up and Execution of Legal Affairs; Execution of Communication Activities; Execution and Audit of Business Activities; Execution of Goods / Service Sales Processes; Execution of Goods / Service After Sales Support Services; Execution of Customer Relations Management Processes; Execution of Activities for Customer Satisfaction; Execution of Advertisement, Campaign and Promotion Processes; Organisation and Event Management; Execution of Storage and Archive Activities; Execution of Contract Processes; Follow-up of Requests / Complaints; Management of Marketing Processes of Products / Services; Providing Information to Authorised Persons, Institutions and Organizations.

Methods of Collection of Personal Data:

The above-mentioned personal data are collected through the website contact form, other contact forms, interviews, telephone conversations, billing information notifications, offer requests, contracts and events.

3.1.3. Legal Transaction Information

Processed Personal Data:

In case of dispute, information in the lawsuit/execution file, information in correspondence with judicial and administrative authorities.

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Follow-up and Execution of Legal Affairs; Execution of Communication Activities; Providing Information to Authorised Persons, Institutions and Organisations; Execution of Storage and Archive Activities.

Methods of Collection of Personal Data:

The personal data mentioned above are collected through official letters from judicial and administrative authorities and other printed / electronic documents.

3.1.4. Customer Transaction Information

Processed Personal Data:

Billing Information, Request Information, Order Information, Customer Comments, Shopping History.

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Execution of Financial and Accounting Affairs; Execution of Communication Activities; Execution and Supervision of Business Activities; Execution of Goods / Services After Sales Support Services; Execution of Goods / Services Sales Processes; Execution of Activities for Customer Satisfaction; Follow-up of Demands / Complaints; Execution of Marketing Processes of Products / Services; Providing Information to Authorised Persons, Institutions and Organisations; Execution of Goods / Services Production and Operation Processes.

Methods of Collecting Personal Data:

The personal data mentioned above are collected through printed/electronic forms, e-mails and other communication channels with our customers.

3.1.5. Physical Space Security

Processed Personal Data:

Camera footage.

Personal Data Processing Purposes:

Ensuring Physical Space Security.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected through the cameras in the workplaces of our Company where our customers are located.

3.1.6. Finance

Processed Personal Data:

Credit Card Information, Bank Account / IBAN Number Information, Tax Identification Number.

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Execution of Finance and Accounting Affairs; Execution of Goods / Service After Sales Support Services; Execution of Goods / Service Sales Processes; Execution of Customer Relationship Management Processes; Providing Information to Authorised Persons, Institutions and Organisations

Methods of Collection of Personal Data:

The above-mentioned personal data are collected through printed and electronic forms, e-mails and telephone conversations.

3.1.7. Marketing

Processed Personal Data:

Information obtained through campaign activities.

Personal Data Processing Purposes:

Organisation and Event Management; Execution of Advertisement, Campaign and Promotion Processes; Management of Marketing Processes of Products/Services.

Methods of Collecting Personal Data:

The personal data mentioned above are collected in writing or electronically.

3.2. OUR PROSPECTIVE CUSTOMERS

The following personal data are collected from our Prospective Customers who have not yet reached an agreement and/or concluded a contract with Pure7, but who are candidates to purchase products and/or services from Pure7, for the following purposes and methods;

3.2.1. Identity Information

Processed Personal Data:

Name – Surname.

Purposes of Processing Personal Data:

Execution of Communication Activities; Execution of Goods / Service Sales Processes; Execution of Customer Relationship Management Processes; Organisation and Event Management; Execution of Advertising, Campaign and Promotion Processes; Management of Marketing Processes of Products / Services.

Methods of Collecting Personal Data:

The personal data mentioned above are collected through the contact form, campaigns and organisations on our website.

3.2.2. Contact Information

Processed Personal Data:

E-Mail Address, Contact Address, Mobile Phone Number.

Personal Data Processing Purposes:

Execution of Communication Activities; Execution of Goods / Service Sales Processes; Execution of Customer Relationship Management Processes; Organisation and Event Management; Execution of Advertising, Campaign and Promotion Processes; Management of Marketing Processes of Products / Services.

Methods of Collecting Personal Data:

The personal data mentioned above are collected through the contact form on our website, campaigns and organisations.

3.2.3. Physical Space Security

Processed Personal Data:

Camera footage.

Personal Data Processing Purposes:

Ensuring Physical Space Security.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected by means of cameras and cameras at the Company’s workplace and other organisations.

3.2.4. Marketing

Processed Personal Data:

Information obtained through campaign activities.

Personal Data Processing Purposes:

Execution of Advertisement, Campaign and Promotion Processes; Management of Marketing Processes of Products / Services.

Methods of Collecting Personal Data:

The personal data mentioned above are collected in writing or electronically.

3.3. WEBSITE VISITORS

The personal data specified below are collected from the visitors who visit the Website for the purposes and methods specified below.

3.3.1. Transaction Security

Processed Personal Data:

IP Address.

Personal Data Processing Purposes:

Execution of Information Security Processes; Execution and Supervision of Business Activities and Providing Information to Authorised Persons, Institutions and Organisations.

Methods of Collection of Personal Data:

The personal data mentioned above are collected through the Website.

3.4 PERSONS COMMUNICATING THROUGH THE WEBSITE

The following personal data are collected from persons who request information about our services and/or products or other issues, make comments, communicate problems, request support and contact Pure7 for other reasons through the Website for the purposes and methods specified below.

3.4.1. Identity Information

Processed Personal Data:

Name – Surname.

Personal Data Processing Purposes:

Execution of Communication Activities; Execution of Goods / Service Sales Processes; Execution of Goods / Service After Sales Support Services; Execution of Customer Relationship Management Processes; Execution of Activities for Customer Satisfaction; Execution of Advertising, Campaign and Promotion Processes; Follow-up of Requests / Complaints; Managing Marketing Processes of Products / Services.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected through the website contact form and offer requests.

3.4.2. Contact Information

Processed Personal Data:

E-Mail Address, Contact Address, Mobile Phone Number

Personal Data Processing Purposes:

Execution of Application Processes of Employee Candidates; Execution of Communication Activities; Planning Human Resources Processes.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected through CVs sent to our Company via e-mail, Private Employment Agencies (İŞKUR, Kariyer.net and others), other channels (Linkedin and others) and your declarations.

3.4.3. Personal Information

Processed Personal Data:

CV Information, Military Service Status, Reference Information.

Personal Data Processing Purposes:

Execution of Application Processes of Employee Candidates; Execution of Communication Activities; Planning Human Resources Processes.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected through CVs sent to our Company via e-mail, Private Employment Agencies (İŞKUR, Kariyer.net etc.), other channels (LinkedIn etc.) and your declarations.

3.4.4. Physical Space Security

Processed Personal Data:

Camera footage.

Personal Data Processing Purposes:

Ensuring Physical Space Security.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected by means of cameras in the workplaces of our Company.

3.4.5. Professional Experience Information

Processed Personal Data:

Educational Background and Details, Employment Background and Details, Diploma Information, Foreign Language Information, Computer Usage Information, Position/Title Information

Personal Data Processing Purposes:

Execution of Application Processes of Employee Candidates; Execution of Communication Activities; Planning Human Resources Processes.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected through CVs sent to our Company via e-mail, Private Employment Agencies (İŞKUR, Kariyer.net and others), other channels (Linkedin and others) and your declarations.

3.5. SUPPLIER AUTHORISATION

The following personal data are collected from the Authorities of the Suppliers who supply goods/services to Pure7 by reaching an agreement and/or concluding a contract with Pure7 for the following purposes and methods.

3.5.1. Identity Information

Processed Personal Data:

Name – Surname, Signature Circular, Signature, Photocopy of Identity Card.

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Execution of Financial and Accounting Affairs; Execution of Communication Activities; Execution of Goods / Service Procurement Processes; Execution of Logistics Activities; Execution of Contract Processes; Follow-up of Requests / Complaints; Providing Information to Authorised Persons, Institutions and Organisations.

Methods of Collection of Personal Data:

The above-mentioned personal data are collected through contracts, forms, request / order and request return e-mails, invoices and documents related to procurement activities.

3.5.2. Contact Information

Processed Personal Data:

E-Mail Address, Contact Address, Mobile Phone Number

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Execution of Financial and Accounting Affairs; Execution of Communication Activities; Execution of Goods / Service Procurement Processes; Execution of Logistics Activities; Execution of Contract Processes; Follow-up of Requests / Complaints; Providing Information to Authorised Persons, Institutions and Organisations.

Methods of Collection of Personal Data:

The above-mentioned personal data are collected through contracts, forms, request/order and request return e-mails, invoices and documents related to procurement activities.

3.5.3. Physical Space Security

Processed Personal Data:

Camera footage.

Personal Data Processing Purposes:

Ensuring Physical Space Security.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected through cameras that record images at the workplace of our Company.

3.5.4. Finance

Processed Personal Data:

Invoice Information, Bank Account Information, Current Account Information

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Execution of Finance and Accounting Affairs; Execution of Supply Chain Management Processes; Providing Information to Authorised Persons, Institutions and Organisations.

Methods of Collection of Personal Data:

The above-mentioned personal data are collected through contracts, forms, request / order and request return e-mails, invoices and documents related to procurement activities.

3.6. SUPPLIER EMPLOYEE

The following personal data are collected from the Employees of the Suppliers who supply goods/services to Pure7 by reaching an agreement and/or concluding a contract with Pure7 for the following purposes and methods.

3.6.1. Identity Information

Processed Personal Data:

Name – Surname, Signature, Identity Photocopy.

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Execution of Financial and Accounting Affairs; Execution of Communication Activities; Execution of Goods / Service Procurement Processes; Execution of Logistics Activities; Execution of Contract Processes; Follow-up of Requests / Complaints; Providing Information to Authorised Persons, Institutions and Organisations.

Methods of Collection of Personal Data:

The above-mentioned personal data are collected through contracts, forms, request / order and request return e-mails, invoices and documents related to procurement activities.

3.6.2. Contact Information

Processed Personal Data:

E-Mail Address, Contact Address, Mobile Phone Number.

Personal Data Processing Purposes:

Execution of Activities in accordance with the Legislation; Execution of Financial and Accounting Affairs; Execution of Communication Activities; Execution of Goods / Service Procurement Processes; Execution of Logistics Activities; Execution of Contract Processes; Follow-up of Requests / Complaints; Providing Information to Authorised Persons, Institutions and Organisations.

Methods of Collection of Personal Data:

The above-mentioned personal data are collected through contracts, forms, request/order and request return e-mails, invoices and documents related to procurement activities.

3.6.3. Physical Space Security

Processed Personal Data:

Camera footage.

Personal Data Processing Purposes:

Ensuring Physical Space Security.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected through video recording cameras in our Company’s workplace.

3.7. VISITOR

The following personal data are collected from people who visit Pure7 workplace for other reasons.

3.7.1. Physical Space Security

Processed Personal Data:

Camera footage.

Personal Data Processing Purposes:

Ensuring Physical Space Security.

Methods of Collecting Personal Data:

The above-mentioned personal data are collected through cameras that record images at the workplace of our Company.

  1. Within the scope of KVKK, we would like to enlighten you in the capacity of Data Controller. Pursuant to Article 4 of the LPPD, your personal data and special categories of personal data for which we have specified the purposes of processing and collection methods above;
  1. In accordance with the law and good faith,
  2. Accurate and, where necessary, up to date,

iii. For specific, explicit and legitimate purposes,

  1. ii. In connection with, limited and proportionate to the purpose for which they are processed,
  2. It will be kept and processed for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
  1. Transfer of Your Personal Data

Your personal data, within the purposes listed above, in accordance with the KVKK and all relevant legislation in force;

  • To our shareholders,
  • Our business partners,
  • Our suppliers,
  • It may be transferred to authorised public institutions and organisations in line with the Company’s field of activity and purpose or in cases stipulated by the legislation on regulatory and supervisory institutions and official authorities.
  1. Storage and Deletion of Personal Data

Our Company stores the personal data it processes for the periods specified in the relevant legislation or in the Company procedures and Company policies, provided that they are not contrary to the relevant legislation.

In the event that no further period is specified in the legislation; personal data are stored for the period required to be processed in accordance with the practices of our Company and the customs of our Company’s commercial life, depending on the services provided by our company while processing that data, and after this period, only for the periods required in practice to constitute evidence in possible legal disputes. After the expiry of the specified periods, the personal data in question are deleted or destroyed by the methods defined in the Company procedures and policies.

Your Rights as a Data Subject

7.1. Within the framework of Article 11 of the KVKK,

Learn whether your personal data is being processed,
Request information if your personal data has been processed,

iii. To learn the purpose of processing personal data and whether they are used for their intended purpose,

To know the third parties to whom your personal data is transferred domestically or abroad,
To request correction of your personal data in case of incomplete or incorrect processing,
To request the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK legislation and other legislation,

vii. When you request the correction of incomplete or incorrect data and the deletion or destruction of your personal data, to request that this situation be notified to third parties to whom your personal data has been transferred,

viii. To object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems,

In case you suffer damage due to unlawful processing of personal data, you have the right to demand the compensation of this damage.

In order to exercise your above-mentioned rights, you, as the Data Subject, must submit the relevant Application Form;

“Burhaniye Mahallesi Yunus Emre Sokak No:10 Üsküdar/İstanbul” address, with wet signature, with the information and documents related to the subject of the application, in person or by mail or through a Notary Public,

By scanning the form, via e-mail to “kvkk@pure7.com.tr” via your e-mail address notified to Pure7 and registered with Pure7,

You can scan the form and send it to “pure7@hs01.kep.tr” via e-mail via your registered e-mail address.

CLICK HERE TO DOWNLOAD KVK APPLICATION FORM.

In the application that includes your explanations regarding the right you have as a Data Subject and that you will make to exercise your rights mentioned above and that you request to exercise;

Your request is clear and understandable,
That the matter you are requesting is related to you personally,

iii. If you are acting on behalf of someone else, you must be specifically authorized to do so,

Identity and address information,
Documents certifying the identity must be attached.

7.2. Your application will be finalized free of charge as soon as possible depending on the nature of the request and in any case within 30 (thirty) days at the latest upon receipt by the Company. However, if the transaction requires an additional cost, a fee may be charged according to the tariff determined by the Board.

Your request will be accepted or rejected with justification within this period, and the response will be notified to you in writing or electronically. In the event that the information and documents you submit to us are incomplete or incomprehensible, you will be contacted to clarify your application.

7.3. As a personal data owner, in cases where your application is rejected, not fulfilled, the answer given is found insufficient by you or the application is not responded in due time; You can apply to the Board within 30 (thirty) days from the date you learn the answer of our Company and in any case within 60 (sixty) days from the date of application.

Article 5 of the KVKK regulates the “Cases where your personal data can be processed without your explicit consent” and Article 28 of the KVKK regulates the “Exceptions” in the implementation of the Law.
In case of any incompatibility between the legislation in force and this Clarification Text, the Data Controller accepts that the legislation in force will be applied.

The Clarification Text entered into force on 18/01/2024 and is published on the Pure7 Website at the address “www.pure7.com.tr”.

In the event that all or certain articles of the Clarification Text are updated in order to comply with the changing conditions and legislation, the effective date will also be updated and re-announced.