GENERAL CLARIFICATION TEXT

Data Controller:
Odeon Software and Technology Joint Stock Company
Maslak Mah. Taşyoncası Sk. Maslak 1453 Site No:1G Door No:51 Sarıyer/Istanbul

As Odeon Software and Technology Joint Stock Company (hereinafter “OYT”), in our capacity as the data controller defined under the Law No. 6698 on the Protection of Personal Data (“KVKK”), we attach great importance to the security of your personal data that we process.

We would like to inform you regarding the processing of your personal data.

Data Subjects Whose Personal Data Are Processed, Data Processed, Purposes, Collection Methods and Transfer Parties

Employees

Detailed information regarding the personal data processed about employees is published in a manner accessible only to our employees, and they have been provided with detailed information on this matter.

Interns

Detailed information regarding the personal data processed about interns is published in a manner accessible only to our employees, and they have been provided with detailed information on this matter.

Shareholders/Partners/Board Members

Detailed information regarding the personal data processed about shareholders/partners/board members is published in a manner accessible only to our employees, and they have been provided with detailed information on this matter.

Job Application Processes

During the phase of job application to our company; your ıdentity (name, surname, maiden name (if any), signature, T.R. ID number, date of birth, place of birth, nationality, gender, family information, marital status, driver's license information), contact (phone number, e-mail address, address information), information on family members/relatives (phone number, e-mail address, address information), family member/relative information (name, surname, date of birth, mobile phone (emergency contact person), education information, occupation information), candidate information (CV information, applied position-title information, reference information, military status information, retirement information, salary expectation, name-surname of relatives/friends working within the holding, height, weight), professional experience information (education status information, courses attended, computer usage information, foreign language information, name-title of previous workplace, start and departure dates of previous workplace, duties at previous workplace, last salary received, reason for leaving) collected through printed forms, electronic forms, Kariyer.net, Linkedin, information and documents transmitted through companies providing head hunter services and information and documents declared by you; will be processed limited to the purposes of conducting / supervising business activities, conducting communication activities, planning human resources processes, conducting employee candidate / intern / student selection and placement processes, conducting application processes of employee candidates, conducting interview processes, conducting contract processes based on legal grounds under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract."; health information (health information that prevents working, blood group information), information on criminal convictions and security measures (criminal record (in case of criminal conviction and security measure record)); limited to the purposes of conducting / auditing business activities, planning human resources processes, conducting employee candidate / intern / student selection and placement processes, conducting application processes of employee candidates, conducting contract processes based on legal ground under Article 6, paragraph 3 of the KVKK "It is necessary for the fulfilment of legal obligations in the fields of employment, occupational health and safety, social security, social services, and social assistance".

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • If necessary, to Authorized Public Institutions and Organizations for the purposes of conducting activities in accordance with the legislation, informing authorized persons, institutions and organizations, and following up and conducting legal affairs,

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / auditing business activities, conducting communication activities, planning human resources processes and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Reference Control Process

During the reference control phase; your identity (name, surname) and candidate information (name-surname, company, company information, position-title information of the reference person) collected through printed forms; will be processed limited to the purposes of conducting / supervising business activities, conducting communication activities, planning human resources processes, conducting employee candidate / intern / student selection and placement processes, conducting application processes of employee candidates, conducting interview processes is processed based on legal ground under Article 5, paragraph 2 of the KVKK "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject".

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • If necessary, to Authorized Public Institutions and Organizations for the purposes of conducting activities in accordance with the legislation, informing authorized persons, institutions and organizations, and following up and conducting legal affairs,

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Personality Test Process

During the Personality Tests phase; your identity (name, surname), contact (e-mail address), candidate information (test result information) collected through the use of existing data in our systems and the personality inventory system; will be processed limited to the purposes of planning human resources processes, conducting employee candidate / intern / student selection and placement processes, conducting application processes of employee candidates, conducting contract processes; your transaction security (log records, IP address, device MAC address) information is processed limited to the purposes of conducting information security processes and conducting and auditing business activities based on legal ground under Article 5, paragraph 2 of the KVKK "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject".

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • If necessary, to Authorized Public Institutions and Organizations for the purposes of conducting activities in accordance with the legislation, informing authorized persons, institutions and organizations, and following up and conducting legal affairs,

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Legal Processes

In case it is subject to legal processes; your personal data collected during the provision of various services; will be processed limited to the purposes of conducting activities in accordance with the legislation, following and conducting legal affairs, informing authorized persons, institutions and organizations based on legal grounds under Article 5, paragraph 2 of the KVKK "It is necessary for compliance with a legal obligation to which the data controller is subject" and "Data processing is necessary for the establishment, exercise or protection of any right".

Your personal data may be transferred to authorized public, institutions and organizations in accordance with the legal regulations and legislation in order to fulfill our legal obligations by taking the necessary technical and organizational measures in accordance with Article 8 of the KVKK within the purposes listed above.

Job Application Processes

Your personal data regarding identity (name, surname, maiden name (if any), signature, T.R. ID number, date of birth, place of birth, nationality, gender, family information, marital status, driver's license information), contact (phone number, e-mail address, address information), information on family members/relatives (name, surname, mobile phone (emergency contact person), date of birth, education information, occupation information), candidate information (CV information, applied position-title information, reference information, military service status information, height, weight), professional experience information (education status information, courses attended, computer usage information, foreign language knowledge, name-title of the previous workplace, dates of starting and leaving the previous workplace, duty information at the previous workplace, last salary information, reason for leaving) will be collected through information and documents declared by you, printed forms, electronic forms, Kariyer.net, Linkedin, information and documents transmitted within the scope of companies providing head hunter services during the job application process. Your personal data will be processed limitedly for the purposes of conducting / supervising business activities, conducting communication activities, planning human resources processes, conducting employee candidate / intern / student selection and placement processes, conducting application processes of employee candidates, conducting interview processes, planning human resources processes, conducting contract processes based on legal grounds under Article 5, paragraph 2 of the KVKK “It is necessary to process personal data of the parties to a contract, provided that it is directly related to the conclusion or performance of the contract.”.

Furthermore, your data regarding health information (health information preventing you from working, blood type information) and information on criminal convictions and security measures (criminal record (in case of criminal conviction and security measure record)) is processed limited to the purposes of conducting / auditing business activities, planning human resources processes, conducting employee candidate / intern / student selection and placement processes, conducting application processes of employee candidates, conducting contract processes based on legal grounds under Article 6, paragraph 3 of the KVKK “It is mandatory for the fulfilment of legal obligations in the fields of employment, occupational health and safety, social security, social services and social assistance”.

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • If necessary, to Authorized Public Institutions and Organizations for the purposes of conducting activities in accordance with the legislation, informing authorized persons, institutions and organizations, and following up and conducting legal affairs

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Legal Processes

In case it is subject to legal processes; your personal data collected during the provision of various services; is processed limited to the purposes of conducting activities in accordance with the legislation, following and conducting legal affairs, informing authorized persons, institutions and organizations based on legal grounds under Article 5, paragraph 2 of the KVKK, "It is necessary for compliance with a legal obligation to which the data controller is subject." and "Data processing is necessary for the establishment, exercise or protection of any right.”.

Your personal data may be transferred to Authorized Public, Institutions And Organizations in accordance with the legal regulations and legislation in order to fulfill our legal obligations by taking the necessary technical and organizational measures in accordance with Article 8 of the KVKK within the purposes listed above.

Process of Obtaining Information and Documents

Within the scope of the process of obtaining information about the employees provided to us by the supplier, your identity (name, surname) and contact (telephone number, e-mail address) and personnel (position-title information, resume information, diploma information, certificate information) information collected through the information and documents provided by the supplier; will be processed limited to the purposes of conducting / auditing business activities, conducting goods / service procurement processes, conducting assignment processes; based on legal ground under Article 5, paragraph 2 of the KVKK “Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract" and for the purposes of conducting supply chain management processes, conducting assignment processes, conducting audit / ethical activities "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject".

Your personal data is not transferred to any third party domestically. Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Progress Payment and Overtime Tracking Processes

Within the scope of the processes of tracking the overtime of the supplier employee and determining the progress payments, your identity (name, surname), personnel (position-title information, progress payment information, number of days worked, office entry/exit dates and hours) and finance (progress payment amount, wage information) information collected through printed forms and e-mails; will be processed limited to the purposes of planning human resources processes, conducting financial and accounting affairs, conducting / supervising business activities, conducting audit / ethical activities based on legal ground under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract" and limited to the purposes of conducting / auditing business activities, ensuring the security of data controller operations, conducting financial and accounting affairs, ensuring overtime follow-up, "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject".

Your personal data is not transferred to any third party domestically. Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Financial Operations and Communication Processes

Within the scope of conducting financial operations and communication processes such as reconciliation, tax, credit, transfer transactions on behalf of the activities between OYT and the supplier, your identity (name, surname), contact (e-mail address, telephone number, residence/address information) and personnel (position-title information, department information, company information) information collected through e-mail, corporate applications and the use of existing data in our systems; will be processed limited to the purposes of conducting / auditing business activities, conducting communication activities, conducting business continuity activities, conducting financial and accounting affairs, conducting goods / service procurement processes based on legal ground under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract".

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • Suppliers for the purposes of conducting / auditing business activities, conducting financial and accounting affairs, conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Supplier Evaluation Processes

Within the scope of supplier evaluation processes your identity (name, surname) and contact (phone number, e-mail address) information collected through printed/digital forms and your existing data in our systems; will be processed limited to the purposes of conducting / auditing business activities, conducting supply chain management processes, conducting goods / service procurement processes based on legal ground under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract" and limited to the purposes of conducting supply chain management processes, conducting audit / ethical activities "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject".

Your personal data is not transferred to any third party domestically. Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Legal Processes

In case it is subject to legal processes; your personal data collected during the provision of various services; will be processed limited to the purposes of conducting activities in accordance with the legislation, following and conducting legal affairs, informing authorized persons, institutions and organizations based on legal grounds under Article 5, paragraph 2 of the KVKK "It is necessary for compliance with a legal obligation to which the data controller is subject" and "Data processing is necessary for the establishment, exercise or protection of any right".

Your personal data may be transferred to authorized public, institutions and organizations in accordance with the legal regulations and legislation in order to fulfill our legal obligations by taking the necessary technical and organizational measures in accordance with Article 8 of the KVKK within the purposes listed above.

Contract Processes

Within the scope of the contracts concluded between our suppliers and our company; your identity (name, surname, signature, signature circular, tax number, tax office, other information in the trade registry newspaper, position-title information), contact (telephone number, e-mail address) and finance (bank account information, invoice information) information collected through contracts, e-mail and information and documents declared by you; will be processed limited to the purposes of conducting / auditing business activities, conducting goods / service procurement processes, conducting contract processes, conducting storage and archive activities based on legal ground under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract".

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • Affiliates for the purposes of conducting business activities, executing contract processes, monitoring and executing legal affairs,
  • Suppliers for the purposes of conducting business activities, conducting contract processes, conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Supplier Evaluation Processes

Within the scope of supplier evaluation processes, identity (name, surname) and contact (phone number, e-mail address) information collected through printed/digital forms and your existing data in our systems; will be processed limited to the purposes of conducting / auditing business activities, conducting supply chain management processes, conducting goods / service procurement processes based on legal grounds under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract" and limited to the purposes of conducting supply chain management processes, conducting audit / ethical activities "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject".

Your personal data is not transferred to any third party domestically. Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Financial Operation Processes

Within the scope of the service we receive from our suppliers, carrying out financial operation processes such as realization of payments, letter of guarantee transactions, declaration and payment processes, current card/account opening, payment transfer transactions, your identity (name, surname, T.R identity number, tax ID number, tax office information, Mersis number, signature, position-title information), contact (e-mail address, telephone number, residence/address information, workplace address) and finance (payment information, bank account information, invoice information, collateral information, refund amount, receipt information) collected through e-mail, printed documents, corporate applications, information declared by you and the use of existing data in our systems, information; will be processed limited to the purposes of conducting / auditing business activities, conducting business continuity activities, conducting contract processes, conducting financial and accounting affairs, conducting goods / service procurement processes based on legal ground under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract"; limited to the purposes of conducting / auditing business activities, conducting financial and accounting affairs, conducting activities in accordance with the legislation "It is necessary for compliance with a legal obligation to which the data controller is subject" legal grounds.

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • Suppliers for the purposes of conducting / supervising business activities, conducting financial and accounting affairs, conducting storage and archive activities,
  • Authorized Public Institutions and Organizations for the purposes of providing information to authorized persons, institutions and organizations, conducting financial and accounting affairs, conducting / auditing business activities

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Legal Processes

In case it is subject to legal processes; your personal data collected during the provision of various services; will be processed limited to the purposes of conducting activities in accordance with the legislation, following and conducting legal affairs, informing authorized persons, institutions and organizations based on legal grounds under Article 5, paragraph 2 of the KVKK "It is necessary for compliance with a legal obligation to which the data controller is subject" and "Data processing is necessary for the establishment, exercise or protection of any right".

Your personal data may be transferred to authorized public, institutions and organizations in accordance with the legal regulations and legislation in order to fulfill our legal obligations by taking the necessary technical and organizational measures in accordance with Article 8 of the KVKK within the purposes listed above.

Communication Processes with Suppliers

Your personal data regarding identity (name, surname) and contact information (e-mail address, telephone number, position-title information, department information, company information) will be collected through open sources and e-mail within the scope of the processes of making plans and providing communications on the issues to be served within our company. Your personal data will be processed limitedly for the purposes of conducting communication activities, conducting goods / service procurement processes, conducting contract processes based on legal grounds under Article 5, paragraph 2 of the KVKK “It is necessary to process personal data of the parties to a contract, provided that it is directly related to the conclusion or performance of the contract.” and “Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.”.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Supplier Selection and Evaluation Processes

Your personal data regarding identity (name, surname) and contact information (e-mail address, telephone number, position-title information, department information, company information) will be collected through e-mail within the scope of the processes of conducting the selection and evaluation processes of suppliers within the framework of deciding to receive services within our company. Your personal data will be processed limitedly for the purposes of conducting goods / service procurement processes, conducting supply chain management processes, conducting audit / ethical activities, conducting storage and archive activities based on legal grounds under Article 5, paragraph 2 of the KVKK “It is necessary to process personal data of the parties to a contract, provided that it is directly related to the conclusion or performance of the contract.” and “Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.”.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Legal Processes

In case it is subject to legal processes; your personal data collected during the provision of various services; is processed limited to the purposes of conducting activities in accordance with the legislation, following and conducting legal affairs, informing authorized persons, institutions and organizations based on legal grounds under Article 5, paragraph 2 of the KVKK "It is necessary for compliance with a legal obligation to which the data controller is subject." and "Data processing is necessary for the establishment, exercise or protection of any right.".

Your personal data may be transferred to Authorized Public Institutions and Organizations in accordance with the legal regulations and legislation in order to fulfill our legal obligations by taking the necessary technical and administrative measures in accordance with Article 8 of the KVKK within the purposes listed above.

Onboarding and Offboarding Processes

In group companies, to carry out transactions such as preparing the computer during the recruitment phase, opening user accounts, granting access authorizations, granting access authorizations, embezzlement processes and closing the accounts during the exit phase your identity (name, surname), contact (phone number, e-mail address), personnel (position-title information, department information, company information, request date, request number, information about the device embezzled) and transaction security (username information, IP address, device MAC address information) information collected through corporate applications and information security devices; will be processed limited to the purposes of conducting access authorizations, conducting / supervising business activities, conducting information security processes, conducting assignment processes, conducting storage and archive activities based on legal grounds under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract"; will be processed limited to the purposes of ensuring the security of movable goods and resources, conducting employee satisfaction and loyalty processes, conducting employee benefits and benefits processes, conducting / auditing business activities "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject”.

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • Affiliates for the purposes of conducting business activities and communication activities

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Processes for Receiving Purchase Requests

Within the scope of the process of receiving purchase requests, your identity (name, surname), contact (e-mail address) and personnel (position-title information, department information, company information, request information) information collected through e-mail and corporate applications; will be processed limited to the purposes of conducting / auditing business activities, conducting business continuity activities, conducting goods / service procurement processes, conducting supply chain management processes based on legal ground under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract".

Your personal data is not transferred to any third party domestically. Your personal data are transferred in accordance with the "standard contract" transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Support Processes

Within the scope of technical or other support processes your identity (name, surname), contact (e-mail address) and personnel (position-title information, department information, company information, request information) information collected through e-mail; will be processed limited to the purposes of conducting / auditing business activities, following up requests / complaints, conducting information security processes, conducting access authorizations, conducting assignment processes based on legal ground under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract".

Your personal data is not transferred to any third party domestically. Your personal data are transferred in accordance with the "standard contract" transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Information Technology Processes

Within the scope of processes related to information technologies such as the log records process and VPN processes taken in accordance with Law No. 5651, your identity (name, surname), personnel (position-title information, department information, company information, request date, request number) and transaction security (log records, website login and exit information, user name and password information) information collected through your data available in our systems, corporate applications and information technology devices; will be processed limited to the purposes of conducting access authorizations, conducting / auditing business activities, conducting information security processes, conducting assignment processes based on legal grounds under Article 5, paragraph 2 of the KVKK "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract" and "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject”; will be processed limited to the purposes of conducting activities in accordance with the legislation, conducting information security processes, conducting / auditing business activities "It is expressly provided for by the laws" and "It is necessary for compliance with a legal obligation to which the data controller is subject".

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • If necessary, to Authorized Public Institutions and Organizations for the purposes of conducting activities in accordance with the legislation, conducting information security processes, informing authorized persons, institutions and organizations, and ensuring the security of data controller operations

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting access authorizations, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Legal Processes

In case it is subject to legal processes, your personal data collected during the provision of various services; will be processed limited to the purposes of conducting activities in accordance with the legislation, following and conducting legal affairs, informing authorized persons, institutions and organizations based on legal grounds under Article 5, paragraph 2 of the KVKK "It is necessary for compliance with a legal obligation to which the data controller is subject" and "Data processing is necessary for the establishment, exercise or protection of any right".

Your personal data may be transferred to authorized public, institutions and organizations in accordance with the legal regulations and legislation in order to fulfill our legal obligations by taking the necessary technical and organizational measures in accordance with Article 8 of the KVKK within the purposes listed above.

Contract and Communication Processes

Your personal data regarding identity (name, surname, signature, circular of signature, tax number, tax office, other information in the trade registry gazette), contact (telephone number, e-mail address, position-title information), customer transaction (request/complaint information) and finance information (bank account information, billing data) will be collected through information and documents by you, e-mail and contracts within the scope of contract and communication processes. Your personal data will be processed limitedly for the purposes of conducting / auditing business activities, conducting goods / service sales processes, conducting contract processes, conducting storage and archive activities, conducting financial and accounting affairs, following up requests / complaints, conducting customer relationship management processes based on legal grounds under Article 5, paragraph 2 of the KVKK “It is necessary to process personal data of the parties to a contract, provided that it is directly related to the conclusion or performance of the contract.”.

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • To Affiliates for the purposes of conducting business activities, executing contract processes, conducting communication activities, monitoring and conducting legal affairs,

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Financial Operation Processes

Your personal data regarding identity (name, surname, T.R. ID number, tax ID number, tax office information, Mersis number), contact (e-mail address, telephone number, address, work address) and finance (payment information, bank account information, invoice information, collateral information, refund amount, receipt information) will be collected through e-mail, existing data usage in our systems and corporate applications within the scope of conducting financial operation processes. Your personal data will be processed limitedly for the purposes of conducting financial operation processes such as current card/account opening, return payments and invoicing, collection and expense reflection in accordance with the services we provide is processed limited to the purposes of conducting financial and accounting affairs, conducting / auditing business activities, conducting goods / service sales processes, conducting contract processes based on legal grounds under Article 5, paragraph 2 of the KVKK “It is necessary to process personal data of the parties to a contract, provided that it is directly related to the conclusion or performance of the contract.”; will be processed limited to the purposes of conducting financial and accounting affairs, conducting / auditing business activities, conducting activities “It is necessary for compliance with a legal obligation to which the data controller is subject.”.

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • To Suppliers for the purposes of conducting / auditing business activities, conducting financial and accounting affairs, carrying out storage and archive activities

If necessary, to Authorized Public Institutions and Organizations for the purposes of conducting activities in accordance with the legislation and informing authorized persons, institutions and organizations

only as much as is necessary for the realization of the relevant objectives.

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Legal Processes

In case it is subject to legal processes; your personal data collected during the provision of various services; will be processed limited to the purposes of conducting activities in accordance with the legislation, following and conducting legal affairs, informing authorized persons, institutions and organizations based on legal grounds under Article 5, paragraph 2 of the KVKK "It is necessary for compliance with a legal obligation to which the data controller is subject" and "Data processing is necessary for the establishment, exercise or protection of any right".

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • To Affiliates for the purposes of conducting business activities, conducting communication activities, monitoring and conducting legal affairs,
  • Authorized Public Institutions and Organizations for the purposes of providing information to authorized persons, institutions and organizations, conducting / supervising business activities, following and conducting legal affairs

only as much as is necessary for the realization of the relevant objectives.

Shipping Processes

Your personal data regarding identity (name, surname, signature) will be collected through digital and printed forms within the scope of the shipping processes. Your personal data will be processed limitedly for the purposes of tracking the cargo delivered to our office and ensuring guest safety, limited to the purposes of ensuring the security of physical space, conducting / supervising business activities, ensuring the security of movable goods and resources, ensuring the security of data controller operations based on legal grounds under Article 5, paragraph 2 of the KVKK "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.”.

Your personal data is not transferred to any third party in Türkiye or abroad.

Judicial and Administrative Processes

Your personal data regarding identity (name, surname, T.R. ID number), contact (e-mail address, mobile phone number, work address), legal transaction (information within the scope of judicial and administrative file, information in the mediation file) and finance (amount of execution/seizure, bank account information, data of you who are mediators/counterparty/counterparty attorneys/creditor/debtor) will be collected through e-mail, official channels and printed documents within the scope of legal and official processes such as litigation, execution, seizure, mediation carried out before courts and official institutions/organizations. Your personal data will be processed limitedly for the purposes of conducting activities in accordance with the legislation, following and conducting legal affairs, providing information to authorized persons, institutions and organizations based on legal grounds under Article 5, paragraph 2 of the KVKK "Data processing is necessary for the establishment, exercise or protection of any right.".

Your personal data may be transferred by complying with the rules in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and organizational measures;

  • To Affiliates for the purposes of conducting / supervising business activities, following up and conducting legal affairs, and carrying out custody and archive activities
  • Authorized Public Institutions and Organizations for the purposes of conducting activities in accordance with the legislation, providing information to authorized persons, institutions and organizations, and following up and executing legal affairs

Your personal data in accordance with the “standard contract” transfer procedure in Article 9 of the KVKK regarding the transfer abroad and by taking the necessary technical and organizational measures;

  • To Suppliers located abroad for the purposes of conducting / supervising business activities, conducting communication activities and conducting storage and archive activities

only as much as is necessary for the realization of the relevant objectives.

Visitor Entry-Exit Tracking Process

Your personal data regarding identity (name, surname, T.R. ID number), contact (phone number) and physical space security (information about the visit (office entry/exit hours, date of visit, reason for visit), CCTV records) will be collected through digital forms and CCTV recording devices within the scope of the process of tracking visitor entrances and exits. Your personal data will be processed limitedly for the purposes ensuring physical space security, conducting / supervising business activities, ensuring the security of movable goods and resources, ensuring the security of data controller operations, creating and tracking visitor records based on legal grounds under Article 5, paragraph 2 of the KVKK “Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.” .

Your personal data may be transferred to the Authorized Public Institutions and Organizations in accordance with the legal regulations and legislation in order to fulfill our legal obligations by taking the necessary technical and administrative measures in accordance with Article 8 of the KVKK within the purposes listed above.

Guest Wifi Process

Your personal data regarding identity (name, surname), contact (e-mail address) and transaction security data (username and password information, IP address information, website login and exit information, device MAC address) will be collected through electronic forms within the scope of guest internet network access processes. Your personal data will be processed limitedly for the purposes carrying out activities in accordance with the legislation, carrying out information security processes, informing authorized persons, institutions and organizations according to the “It is necessary for compliance with a legal obligation to which the data controller is subject.”; executing access authorizations and ensuring the security of data controller operations based on legal grounds under Article 5, paragraph 2 of the KVKK “Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.”.

If necessary, your personal data may be transferred to Authorized Public Institutions and Organizations only to the extent necessary for the realization of the relevant purposes for the purposes of carrying out the activities in accordance with the legislation, carrying out information security processes, providing information to authorized persons, institutions and organizations, ensuring the security of data controller operations, by complying with the rules in Article 8 of the KVKK regarding domestic transfer and taking necessary technical and administrative measures.

Website Visitors

If you visit our website, your personal data regarding transaction security information (IP address information, website login and exit information, log record, device MAC address information) will be collected through information security systems, electronic devices and media (IP address information, website login and exit information, log record, device MAC address information). Your personal data will be processed limitedly for the purposes conducting information security processes, conducting activities in accordance with the legislation, conducting / auditing business activities based on legal grounds under Article 5, paragraph 2 of the KVKK “It is expressly provided for by the laws.”, “It is necessary for compliance with a legal obligation to which the data controller is subject.” and “Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.”.

If necessary, your personal data may be transferred to Authorized Public Institutions and Organizations only to the extent necessary for the realization of the relevant purposes for the purposes of carrying out the activities in accordance with the legislation, providing information to authorized persons, institutions and organizations, and following up and executing legal affairs, by complying with the rules in Article 8 of the KVKK regarding domestic transfer and taking the necessary technical and administrative measures.

In addition, if you use the contact forms on our website, identity (name, surname), contact (e-mail address, phone number), transaction information (request / complaint / suggestion information) will be collected through digital forms, conducting communication activities, tracking requests / complaints, conducting customer relationship management processes, conducting after-sales support services for goods / services, conducting the necessary research / investigations to fulfill the support services on the subject of the request. Your personal data will be processed limitedly for the purposes providing you with information and support services and management of information security processes based on legal grounds under Article 5, paragraph 2 of the KVKK "It is necessary to process personal data of the parties to a contract, provided that it is directly related to the conclusion or performance of the contract." and "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.".

If necessary, your personal data may be transferred to Authorized Public Institutions and Organizations only to the extent necessary for the realization of the relevant purposes for the purposes of carrying out the activities in accordance with the legislation, providing information to authorized persons, institutions and organizations, and following up and executing legal affairs, by complying with the rules in Article 8 of the KVKK regarding domestic transfer and taking the necessary technical and administrative measures.

2. What Are Your Rights Regarding Your Personal Data as a Data Subject?

Regarding your personal data you have the rights to;

  • To learn whether your personal data is being processed,
  • To request information if your personal data has been processed,
  • 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 in country or abroad,
  • To request correction of your personal data in case of incomplete or incorrect processing,
  • To request the erasure or destruction of your personal data within the framework of the conditions stipulated in the KVKK legislation,
  • When you request the correction of incomplete or incorrect data and the erasure or destruction of your personal data, to request that this situation be notified to third parties to whom we transfer your personal data,
  • To object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,
  • To claim for the compensation of this damage in case you suffer damage due to unlawful processing of personal data.

3. How to Exercise Your Rights?

If you wish, you can submit your applications and requests regarding your personal data via the Data Subject Application Form on our website;

  • With signature and copy of identity card Maslak Mah. Tasyoncasi Sk. Maslak 1453 Site No:1G Door No:51 Sarıyer/İstanbul address,
  • By applying to OYT in person with a valid identity document,
  • By signing with mobile signature or secure electronic signature and sending an e-mail to kvkk@odeontechnology.com,
  • By sending to our registered electronic mail address [...] by using a registered electronic mail (KEP) address and secure electronic signature or mobile signature
  • By sending to our address kvkk@odeontechnology.com from the e-mail address previously notified to OYT by the yourself and registered in our system

You can forward it to OYT.

Pursuant to the Communiqué on the Principles and Procedures For The Request To Data Controller, the application of the Data Subject must include the name, surname, signature if the application is in writing, T.R. identity number (if the applicant is a foreigner, his/her nationality, passport number or identity number, if any), residential or workplace address for notification, e-mail address for notification, telephone number and fax number, if any, and information on the subject of the request.

The Data Subject must clearly and comprehensibly state the matter requested in the application, which will be made to exercise the rights mentioned above and includes explanations regarding the right requested to be exercised. Information and documents related to the application must be attached to the application.

Although the subject of the request must be related to the applicant, if acting on behalf of someone else, the applicant must be authorized and this authorization must be documented (power of attorney). If the application is within the scope of sensitive data, the applicant must be specifically authorized in accordance with Article 10 of the Regulation on Personal Health Data. In addition, the application must include identity and address information and documents confirming the identity must be attached to the application.

Requests made by unauthorized third parties on behalf of someone else will not be evaluated.

How Long Will Your Requests Regarding the Processing of Your Personal Data Be Answered?

Your requests regarding your personal data are evaluated and answered as soon as possible and within 30 days at the latest from the date of receipt. If your request is accepted or rejected by explaining the reason, our response will be sent to you by mail or e-mail to the address you specified in the application, if possible, by the method in which your request was made. If the evaluation and decision-making process requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board shall be taken as basis.