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Personal Data Protection and Privacy Policy


Website Confidentiality Agreement
During your visit to this website and your use of the service through this Site, how the information that we receive regarding you and the services you request will be used and protected are subject to this ‘’Confidentiality Agreement’’. You hereby accept the conditions stipulated in this ‘’Confidentiality Agreement’’ when you visit this website and request to use the services we provide through this Site.

I. Purpose of personal data protection and processing policy
Until today, data and information of our customers or potential customers are kept confidential and have never been shared with third parties by virtue of the sensitivity of our business as "Aktif Group of Companies". Personal data protection is our essential policy. Even before any legal regulation, our company and subsidiaries had attached a great importance to the confidentiality of personal data, adopted as a working principle and gave working instructions to the employees in compliance with this principle. As ‘’Aktif Group of Companies’’, we undertake to adhere to all responsibilities of Privacy Act. The principle of our companies to protect personal data also covers our subsidiaries.

II. Scope and change of personal data protection and implementation policy
This Policy prepared by our Company has been regulated in accordance with “Law on Protection of Personal Data” no. 6698 (“KVKK”). The Law has entered into force with all of its provisions as of today. The data received with your consent or pursuant to the other regulations as per to the Law shall be used to make our service more quality and to improve our services and quality policy. Again, some of the data we obtain are removed from the scope of personal data and anonymized. These data are used for statistical purposes and not subject to the enforcement of Law and our Policy. “Personal Data Protection and Implementation Policy of Aktif Group of Companies” aims and regulates the protection of the data which are automatically obtained from our customers, potential customers, employees and the customers and employees of the companies in cooperation with us for solution partnership and the other parties.
Our company reserves the right to change our Policy and Regulation – provided to comply with the Law and protect the personal data in a better way.

III. General principles on processing of the personal data
a) Being in compliance with the law and good faith
b) Being accurate and up to date, if necessary
c) Being processed for specified, explicit, and legitimate purposes
d) Being relevant, limited and proportionate to the purposes for which data are processed
e) Being stored only for the time designated by relevant legislation or necessitated by the purpose for which data are collected

Maximum Savings Policy/Scrimping Policy
Pursuant to our policy called as maximum savings policy or scrimping policy, the data received by “Aktif Group of Companies” are processed into the system as required. Thus, which data we will collect shall be determined according to the purpose. Unnecessary data shall not be collected. Other data submitted to our company are transferred to the information system of the company in the same way. Redundant information is not stored in the system, they are deleted or anonymized. These data may be used for statistical purposes. Health data among the special quality data are only kept in the system to provide better service to the customers and to protect their health.

Deletion of personal Data
When the retention period necessitated by the Law expires, judicial procedures are completed or other requirements no longer exists, these data shall be deleted, removed or anonymized automatically, by the company or upon the request of the relevant person.

Accuracy and Currency of Data
The data within the body of “Aktif Group of Companies” are processed as declared by the relevant persons as a rule. “Aktif Group of Companies” is not obliged to check up on the accuracy of the data declared by the customers or the persons in touch with “Aktif Group of Companies” and it’s also contrary to the Laws and our working principles. The declared data are regarded as correct and accurate. The principle of accuracy and currency of personal data has also been adopted by “Aktif Group of Companies”. The personal data processed upon the request of the relevant person or from official documents that are submitted to our company are updated. Necessary precautions are taken for this purpose.

Confidentiality and data security
Personal data are confidential and “Aktif Group of Companies” obeys the rule of confidentiality. Only authorized persons shall access the personal data. All necessary technical and administrative measures are taken to protect the personal data collected by “Aktif Group of Companies” and to prevent the damage on our customers and potential customers. Within this framework, it shall be ensured that the software complies with the standards, third parties are selected with caution and data protection policy is observed within the company.

IV. Purpose of data processing
Collection and processing of personal data by “Aktif Group of Companies” shall be executed in line with the purposes stipulated in the letter of clarification. The data are collected and processed to draw up contracts and provide better services to the customers.

V. Data of customer, potential customer and business and solution partners

Collection and processing of data for contractual relationship
In case of a contractual relationship with our customers and potential customers, the collected personal data may be used without the approval of the customers. However, this use shall be for the purpose of the contract. The data shall be used for better execution of the contract and as required by the services and updated, if necessary, by contacting the customers. Nevertheless, the data provided to us by our potential customers shall be processed to easier and more quality services later. These data shall be deleted upon requests in case of lack of any contractual relationship.

Data of Business and Solution Partners
Aktif Group of Companies” adopts as a principle to act in compliance with the laws when exchanging the data both with business and solution partners. The data are shared with the business and solution partners with the understanding of data confidentiality and as required by the services and it’s definitely ensured that these parties take measures regarding the data security.

Data processing for advertisement purposes
Electronic messages for advertisement purposes can only be sent to the persons with prior consent in compliance with the Law on the Regulation of E-Commerce and the Law on Commercial Communication and Commercial Electronic Messages. An explicit consent of the person is required to send advertisements. “Aktif Group of Companies” obeys the details of ‘’the consent’’ specified in the same legislation. The consent to be obtained should cover all commercial electronic messages that are sent to the electronic communication addresses of the recipients to promote and market the goods and services of the company, to promote the business or to increase the recognition level of the company with contents including greetings and wishes. This consent may be obtained via any electronic communication channel or at physical medium in written. The important thing is to obtain the declaration of the recipient that he/she accepts to receive commercial electronic messages and to have his/her full name and electronic communication address.

Data processing due to legal obligations of the company or being stipulated explicitly in the Law
Personal data may be processed without prior consent when it’s stipulated explicitly in the relevant legislation or to fulfill a legal obligation specified in the legislation. Type and scope of the data processes are required for data processing activity that is permitted by the Laws and they should comply with the relevant legal provisions.

Data processing of the company
Personal data may be processed pursuant to the legal purposes and the services of the company. However, the data shall not be used for services contrary to the laws under any circumstances.

Processing of special quality data
Pursuant to the Law, race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothes, membership of association, foundation or union, health, sexual choice, juridical sentence and data regarding safety measures and biometric and genetic data are among the special quality data. “Aktif Group of Companies” also takes adequate measures determined by the Board for the processing of special quality data.
Aktif Group of Companies” may process the special quality data only for the corresponding purposes to provide better services.

Data processed with automatic systems
Aktif Group of Companies” acts in compliance with the Law for data processed with automatic systems. The information obtained from these data without the explicit consent of the persons shall not be used against the person. However, “Aktif Group of Companies” may take decisions regarding the persons that it will perform process by using the data within the system.

User Information and Internet
In case of the collection, processing and use of personal data on the websites and other systems or applications belonging to Aktif Group of Companies, the related persons shall be informed about the privacy statement and cookies if needed. Users shall be informed about our applications on our websites. Personal data shall be processed as per the law.

Functional and Analytic cookies
Cookies includes the data about reminding your choices, using website effectively, optimizing the website so as to answer the demands of the user and how the visitors use the website. By qualification, these kinds of cookies may consist of personal information such as user name.

Third Party Cookies
Websites/mobile applications/mobile websites belonging to Aktif Group of Companies works with third party reliable and known advertisement providers Third party service providers place their own cookies to offer advertisements special to you. The cookies placed by third party collect, process the surfing information of the visitors on the websites and analyze them according to the ways of use.

Commercial cookies
Commercial cookies serve to offer the product/content with similar qualifications and enhance your usage experience by providing a developed and customized advertisement portfolio according to your fields of interest and choices. The holdup time of the session, permanent, functional and analytic and commercial cookies on the background is about 2 (two) months and the required settings can be done by browser settings. The removal operation, one of the settings, can be changed by means of the browser.

How to clear cookies?
Many browsers are adjusted automatically to accept and use the cookies as of the first installment of your computer. You are allowed to block the cookies or to be warned about the cookies by using help or setting menus of your browser. You can take advantage of the instruction or help option screens of your browser to obtain further information about the various methods of managing cookies or regulate the settings of your browser.

VI. Data of our employees

Processing of the data for business relations
Personal data of the employees may be processed without obtaining consent to the extent of requirements of health insurance and business relations. However, “Aktif Group of Companies” hereby undertakes the protection and confidentiality of the data of the employees.

Processing as per Legal Obligations
Aktif Group of Companies” may also processes the personal data of the employees without obtaining a separate consent to fulfill a legal obligation stipulated in the legislation or in case it’s explicitly specified in the legislation. This case is limited to the obligations arising from the Law.

Processing in Favor of the Employees
Aktif Group of Companies” may process the personal data without obtaining the consent for the procedures in favor of company employees like private health insurances. For the disputes arising from the business relations, “Aktif Group of Companies” may also process the data of the employees.

Processing of special quality data
Pursuant to the Law, race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothes, membership of association, foundation or union, health, sexual choice, juridical sentence and data regarding safety measures and biometric and genetic data are among the special quality data. Besides the consent of the relevant person, “Aktif Group of Companies” also takes adequate measures determined by the Board for the processing of special quality data. Special quality data may be processed limited to and related to the cases permitted by the Law without the consent of the person. The quality data obtained from the employees shall only be used for the corresponding purpose to allow them to benefit from the insurance and health services.

Data processed with automatic systems
The data processed regarding the employees with automatic systems may be used for in-house promotions and performance assessments. The employees reserve the right to appeal to the results against them and they should perform this process in compliance with the internal procedures. Appeals of the employees shall be evaluated again within the company.

Telecommunication and internet
The computers, telephone, e-mail and other applications allocated to the employees within the company shall only be used for business purposes. The employee cannot use any of these means allocated to himself/herself by the company for private purposes or communication. The company may control and monitor the data on these means. The employee undertakes not to keep any data or information apart from the business purposes on the computer, telephones or other means allocated to himself/herself as of his/her employment date.

VIII. Rights of the relevant person
Aktif Group of Companies” hereby agrees that the relevant person must provide his/her consent before processing the data within the scope of the Law and he/she reserves the right to determine the destiny of the data after the data is processed.

IX. Confidentiality Principle
The data of the employees and other persons within “Aktif Group of Companies” are confidential. Nobody can use, copy, reproduce, transfer these data for other purposes apart from the business purposes.

X. Process security
All necessary technical and administrative measures are taken to protect the personal data received by “Aktif Group of Companies” and to prevent the retention of them by unauthorized persons and to prevent the damage on our customers and potential customers. Within this framework, it’s ensured that the software complies with the standards, third parties are selected with care and data protection policy is followed within the company.

XI. Inspection
Aktif Group of Companies” carries out the internal and external inspections for protection of the personal data.

XII. Notification of Violations
Aktif Group of Companies” shall immediately act to remedy the violations in case a violation of personal data is notified. It shall mitigate or indemnify the damage of the relevant person. In case the personal data are obtained by the unauthorized persons, this case should be immediately notified to the Board of Personal Data Protection.