CONFIDENTIALITY

Our company herewith commits to applying the Personal Data Protection Policies ("Policy") that fall under the purview of the Personal Data Protection Law numbered 6698 ("PDP Law") and the EU General Data Protection Regulation adopted by the European Commission on April 14, 2016, in line with the guidelines outlined in Article 4 of the PDP Law, as well as the provisions and objectives for processing such personal data stipulated in Articles 5 and 6 of the said law. These policies outline the company's methods and principles for the protection and processing of personal data. The policies include the reasons for which the Media Portals treat personal data, the means and aims for collecting personal data, the reasons, and procedures for transferring such personal data, and the rights of personal data registrants (people whose personal data are being processed). The term "Personal Data" as used in these policies refers to any identifiable information about a real person (e.g., name and surname, Turkish ID Number, e-mail, address, date of birth, credit card number, bank account number, and so on). In line with the PDP Law, each media portal is deemed to be acting in the capacity of a data supervisor, and the obligations and notifications are legal and binding on the media portals. On behalf of the media portals, the company accepted and adopted these policies.

ARTICLE 1 – BASIS FOR DATA COLLECTION AND OBLIGATIONS FOR CLARIFICATION
Pursuant to Article of the PDP Law, the Media Portals process data in accordance with the laws and strive to process personal data in accordance with Articles 5 and 6 of the PDW Law, as set forth in Article 4 of the same Law, which specifies the principles. In this context, the purposes of the personal data processing, the persons to whom the processed personal data are to be transferred, as well as the grounds for such transfer and methods of personal data collection, with an emphasis on the legal grounds, are outlined below, along with your rights posited in Article 11 of the said law.

1. Method of Collection of Personal Data – We may collect data automatically or in an unautomated manner through our headquarters, telephone, e-mail, website, social media domains, and the persons with whom we trade in verbal, written, and electronic forms, or information provided in the course of memberships created through the Media Portals, or such information acquired following provision of our services, and information demonstrating how you use them.  For example, anytime you visit the ilancep website or view our ads /contents, we may collect such information. Your personal data will be processed for as long as you use the firm's services and products, and such information will be updated to verify and maintain your information. Furthermore, your personal data will be processed if you visit other websites and/or social and digitalized domains to use our products or services or participate in social and commercial activities such as events, seminars, organizations, and vocational trainings organized by the Company and/or any third party with whom the Company has commercial contacts.
2. Aims and Resources:
2.1. Your personal information is processed  for the following reasons:
✓ Planning the events that the company helps facilitate or directly organizes, as well as making advertisements and promotions, when necessary,
✓ Carrying out the necessary actions for informing users of products and services, as well as other market players, determining commercial usage trends, and customizing when necessary.
✓ Ensuring the commercial security of the individuals and entities with whom the company has business relationship
✓ Determining the company's commercial planning and promotion activities.
2.2. Basis of Data
2.2.1. Approval by the Proprietor of the Personal Data
Data can only be processed with the explicit consent of the proprietor, as made evident in the statement submitted by the proprietor, in accordance with the objectives set forth therein, provided that the proprietor is informed about data processing and is willing to consent.
2.2.2. If the law specifically allows the personal data that are under the proprietorship is handled in compliance with the law and within the limits permitted by the law. 2.2.3. Impracticability
The data owner's personal data may be processed if it is essential to process the personal data of a person who is unable to express consent owing to factual impossibility or whose consent will not be regarded valid, in order to safeguard his or another person's life and corporeal integrity.
2.2.4. Where the personal data must be handled due to direct causal relationship with the contract, any causal relationship with respect to establishment and execution of the contract, such personal data may be processed (an informative clause must be included in the contract).
2.2.5. Legal Obligations :  In order to fulfil legal obligations, media portals may handle the data owner's personal information.
2.2.6. Perspicuity of Personal Data : If the personal information of the data owner has been publicly disclosed, the company may process it, but only to the extent that it has been made public.
2.2.7. Data Processing Obligation for the Establishment or Protection of any Right:   Personal data of the data owner may be processed if data processing is intended for the establishment, exercise, or protection of a right.
2.2.8. Legitimate Interests of the Data Supervisor : Provided that the fundamental rights and freedoms of the personal data owner are not prejudiced, the personal data of the data owner may be processed by the Media Portals if data processing is necessary for the legitimate interests of the data supervisor.
3. Personal Data of Specific Nature : Pursuant to Article 6 of the PDP Law, personal data of “specific nature” (race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership of associations, foundations or trade unions, medical condition, sexual life, criminal conviction, and security measures, as well as biometric and genetic data) may be processed. If the owner of the personal data does not expressly consent, personal data can only be processed if the Board established by the PDP Law takes the specific steps to be established.

ARTICLE 2 TRANSFER OF DATA
Your personal data will be transferred to entities with which the company has business contacts, suppliers, sponsors and portals, shareholders of the company, public organizations and agencies, individuals who provide services, and/or other third parties and/or abroad in order to meet the requirements set out in these policies, as outlined in Articles 8 and 9 of the PDP Law. Through your membership in Media Portals, you are deemed to have consented to such transfers.
ARTICLE 3 DATA SECURITY
According to Article 12 of the PDP Law, media portals agree to take all necessary steps to prevent unauthorized processing of personal data, as well as unauthorized access to and storage of data. The Company takes all precautionary measures to avoid unauthorized third-party processing of personal data.
ARTICLE 4 RIGHTS
By applying to the Company’s Data Supervisor, the owner of the personal data will have the following rights :
a) Establishing whether or not personal data is processed.
b) If personal data has been processed, seeking information about it;
c) Determining the purpose of processing personal data and whether or not it is utilized in line with that purpose
d) Identifying the third parties to whom personal data is transferred in the country or abroad,
e) Seeking correction of personal data in case of incomplete or incorrect processing
f) Asking correction of personal data in case of incomplete or incorrect processing, and requesting notification of the transactions thus made in this context to the third parties to whom the personal data is exchanged,
g) Requesting the deletion or obliteration of personal data if the reasons for its processing have ceased, despite the fact that it has been processed in accordance with the provisions of the PDP Law and other applicable laws, and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been conveyed,
h) Raising objections to any subsequent outcome against the individual based solely on analyses of processed data performed by automated systems.
i) It has the right to claim for compensation in the event of a loss caused by the illegal processing of personal data. In terms of the accuracy and timeliness of the information and/or data, the Personal Data Owner bears all responsibility for providing incorrect information.
According to Article 7 of the PDP Law and the "Regulation on the Deletion, Obliteration, or Anonymization of Personal Data" related to this article, as well as Article 138 of the Turkish Criminal Code, if the reasons for processing the data disappear or the purpose of data processing ends, the personal data is deleted, destroyed, or anonymized by the data controller ex officio or at the request of the data owner or the relevant person, within the time periods specified in the regulations.
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