HIT INFORMATION CONSULTANCY SERVICES INDUSTRY AND TRADE INC. INFORMATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

The website www.hitsoft.com.tr is managed by HIT Information Consultancy Services Industry and Trade Inc.

The purpose of this Information Text on the Protection and Processing of Personal Data (Information Text) is to fulfill the obligation to inform regarding the use of personal data obtained during the use of the website www.hitsoft.com.tr (Internet Site) managed by HIT Information Consultancy Services Industry and Trade Inc., and/or received from third parties, in accordance with Article 10 of the Law on the Protection of Personal Data No. 6698 (Personal Data Protection Law-KVKK).

1.DATA CONTROLLER

With this Information Text on the Protection and Processing of Personal Data (“Information Text”), we, as Hit Information Consultancy Services Industry and Trade Inc. (“Company” or “Hitsoft”), would like to inform our valued customers within the scope of our obligation to inform under the Law on the Protection of Personal Data No. 6698 (“KVKK”) as the Data Controller.

2. DEFINITIONS

In this Information Text;

Data Subject: The real person whose personal data is processed,

Internet Site: The website with the domain name www.hitsoft.com.tr,

Personal Data: Any information relating to an identified or identifiable real person,

Processing of Personal Data: Any operation performed on personal data such as obtaining, recording, storing, preserving, altering, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, fully or partially automated or by non-automated means provided that they are part of any data recording system,

Authority: Personal Data Protection Authority,

Regulation: The Regulation on the Procedures and Principles of Application to the Data Controller, published in the Official Gazette dated 10/03/2018 and numbered 30356,

Data Controller: The real or legal person who determines the purposes and means of processing personal data, and who is responsible for the establishment and management of the data recording system,

3. LEGAL BASES AND METHODS OF PROCESSING PERSONAL DATA

Our company may process your personal data in accordance with the law and the rules of honesty, by taking into account Articles 4 and 5 of the Law No. 6698 on the Protection of Personal Data, for the specific, explicit, and legitimate purposes listed below:

When processing your data, we rely on the legal reasons of “the necessity of processing for the data controller to fulfill its legal obligation,” “the necessity of processing for the establishment, use, or protection of a right,” and “the necessity of processing for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”

Besides these, your Personal Data is processed by Hitsoft within the scope of your explicit consent or other legally permitted circumstances under the KVKK for the following purposes:

  1. Issuing invoices after the sales transaction within the scope of our commercial activities, fulfilling tax and other legal obligations (identity, communication, customer transaction, legal transaction information)
  2. Fulfilling the requirements of the contracts concluded with you,
  3. Selling all products manufactured and/or imported by Hit Soft and delivering them based on your preferred delivery method,
  4. Conducting return and exchange transactions if necessary,
  5. Sharing information with you through your preferred communication channel regarding the products you purchased or the campaigns/sweepstakes you participated in, determining transaction information,
  6. Creating and maintaining your membership registration on Hitsoft platforms based on your request,
  7. Conducting promotional/informational, marketing, and campaign activities if you have given communication permission, sending event newsletters,
  8. Conducting data analysis-research,
  9. Conducting insurance transactions if you have chosen a warranty (insurance) option when purchasing products,
  10. Transferring and tracking your complaints/requests to our Company, backing up/archiving, storing, and preserving transaction records,
  11. Processing to comply with information retention, reporting, and information obligations under relevant legislation and to fulfill our legal obligations.

Hit Soft will not use your personal data for processing purposes other than those stated here and will not transfer and/or disclose them to third parties without your explicit consent or for reasons stipulated by the relevant legislation.

Cases Not Requiring Explicit Consent: Pursuant to Article 5, Paragraph 2 of Law No. 6698, your personal data may be processed without your explicit consent if one of the following conditions exists: a) It is explicitly stipulated in the laws.

  • It is necessary to process the personal data of the person who is unable to disclose their consent due to actual impossibility or whose consent is not legally valid, to protect their or another person’s life or bodily integrity.
  • It is necessary to process the personal data of the parties to a contract, provided that it is directly related to the establishment or performance of the contract.
  • It is necessary for the data controller to fulfill its legal obligation.
  • The data has been made public by the data subject.
  • It is necessary to process data for the establishment, use, or protection of a right.
  • It is necessary to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

4. TO WHOM AND FOR WHAT PURPOSES PERSONAL DATA CAN BE TRANSFERRED

Our priority is not to transfer or disclose personal data.

Your personal data, within the scope of the laws and other legislation, and for the disclosed purposes;

  • To our group companies,
  • To companies we have authorized, companies that operate on our behalf and account, our representatives,
  • To regulatory and supervisory authorities, public institutions, or organizations explicitly authorized to request your personal data under their laws,
  • To business partnerships, suppliers, and contractor companies, banks, credit risk, and financial institutions, and other natural or legal persons within the scope of the commercial relationship established with you,
  • To tax and similar advisors, mandatory persons, institutions, and organizations related to legal follow-up processes, including auditors, third parties from whom we receive consultancy, and without limitation, to business partners, third parties providing services, authorized persons, and organizations within the country and abroad for the purposes specified above.

5. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

HİTSOFT processes your personal data for the duration required by the relevant laws and other regulations, to act in compliance with the laws and to fulfill legal procedures, or for the duration required to protect and exercise the rights that Hitsoft may have in possible future legal processes. At the end of these periods, personal data belonging to our customers will be deleted, destroyed, or anonymized by us.

Personal data processed for the purposes specified in Hitsoft's policy will be deleted, destroyed, or anonymized by our Company when the purpose requiring processing within the scope of KVKK no longer exists and the periods specified in the Regulation on the Deletion, Destruction, or Anonymization of Personal Data published in the Official Gazette dated October 28, 2017, and numbered 30224, and the Turkish Commercial Code No. 6102 expire.

6. YOUR RIGHTS AND EXCEPTIONS AS A DATA SUBJECT UNDER KVKK ARTICLE 11

The details of the right to apply and the application procedure are regulated in the Regulation on the Procedures and Principles of Application to the Data Controller published in the Official Gazette dated 10/03/2018 and numbered 30356. Pursuant to the relevant Regulation, real persons whose personal data are processed have the right to apply to the data controller. However, according to Paragraph 2 of Article 4 of the aforementioned Regulation, the exercise of this right is subject to the application being made in “Turkish.”

Pursuant to Article 11 of the Personal Data Protection Law, data subjects,

  • Learn whether personal data is being processed,
  • Learn the purpose of processing personal data and whether they are used in accordance with their purpose,
  • Request information regarding the processing of personal data,
  • Learn the third parties to whom personal data is transferred domestically or abroad,
  • Request the correction of personal data in case of incomplete or incorrect processing and request that the transaction carried out within this scope be notified to third parties to whom personal data is transferred,
  • Request the deletion or destruction of personal data in case the reasons requiring processing cease to exist, despite being processed in accordance with the provisions of Law No. 6698 and other relevant laws, and request that the transaction carried out within this scope be notified to third parties to whom personal data is transferred,
  • Object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
  • Request the compensation of the damage in case of damage due to the unlawful processing of personal data.

However, pursuant to Article 28 of the Personal Data Protection Law, you cannot exercise the above-mentioned rights except for the right to demand the compensation of the damage in the following cases:

  • It is necessary to process personal data for the prevention of crime or for a criminal investigation. b) Processing of personal data made public by the data subject.
  • Processing of personal data is necessary for the execution of supervisory or regulatory duties and for disciplinary investigation or prosecution by authorized and competent public institutions and organizations and professional organizations with public institution status, based on the authority granted by the law.
  • Processing of personal data is necessary for the protection of the economic and financial interests of the State regarding budget, tax, and financial matters.

The above-mentioned requests will be communicated to the Company as the data controller in writing or by other methods to be determined by the Personal Data Protection Board (“Board”).

In this context, you can submit your request regarding your above-mentioned rights to our e-mail address provided below, which may be updated from time to time, via your registered electronic mail (KEP) address, with a secure electronic signature, mobile signature, or by using the e-mail address previously notified by you to the Company and registered in the Company’s system (by attaching identity documents to your application form), or you can deliver it in person with a wet-ink signature to our postal address provided below, which may be updated from time to time, or send it via notary public.

In the application you will make to exercise your rights as a personal data subject and which includes explanations about the right you wish to use; the matter you request must be clear and understandable, the subject of the request must be related to you personally, or if you are acting on behalf of someone else, you must be specifically authorized in this regard and your authority must be documented, the application must include your identity and address information.

Hitsoft will conclude the requests in the application as soon as possible and at the latest within thirty days, free of charge (if there is no cost). However, if the transaction requires an additional cost, the fee specified in the tariff to be determined by the Personal Data Protection Board may be charged. If the response to the applications exceeds 10 (ten) pages, a transaction fee of 1.00 (one) TL will be charged for each page. If the response is requested to be given in a recording medium such as a CD or flash memory, a fee may be charged based on the cost of the requested recording medium.

Data Controller: Hit Information Consultancy Services Industry and Trade Inc.

Contact Phone +444 94 48

KEP Address: hitbilisim@hs03.kep.tr

Mailing address: Defterdar Mah. Otakçılar Cad. No:80 Kar Plaza K:2 Office No:19 Eyüp-Istanbul

E-mail address: kvkk@hitsoft.com.tr