Policies

PROTECTION AND PROCESSING OF PERSONAL DATA

PRIVACY POLICY AND INFORMATION NOTICE

As Internative Yazılım Anonim Şirketi, we highly value the confidentiality and security of the personal data you share with us and act with utmost sensitivity to protect fundamental rights and freedoms, particularly the right to privacy guaranteed under the Constitution.

In line with our obligation to inform you pursuant to the Personal Data Protection Law No. 6698 (“Law”), published in the Official Gazette dated 07.04.2016, the following matters are presented for your information.

1. Definitions of Technical Terms Used in This Information Notice

Explicit Consent: Consent based on being informed regarding a specific matter and declared with free will.

Anonymization: Rendering personal data impossible to associate with an identified or identifiable natural person, even when matched with other data.

2. Who Is the Data Controller?

The data controller in relation to the personal data shared via www.internative.net

is Internative Yazılım A.Ş., registered with Istanbul Chamber of Commerce under registration number 107998-5 and headquartered at:

Merdivenköy Mh. Yumurtacı Abdibey Cd. Nur Sk. No:1/1 A Blok Kat:12 D:115 İç Kapı No: 2 Business İstanbul, Kadıköy / İstanbul, 34732, Türkiye

Data Subject: The natural person whose personal data is processed.

Law: Personal Data Protection Law No. 6698 entered into force via Official Gazette dated 07.04.2016.

Personal Data: Any information relating to an identified or identifiable natural person.

Processing of Personal Data: Any operation performed on personal data by automatic or non-automatic methods provided that it is a part of a data recording system, including collection, recording, storage, retention, alteration, reorganization, disclosure, transfer, acquisition, classification, or prevention of access.

Board: Personal Data Protection Board.

Authority: Personal Data Protection Authority.

Data Processor: A natural or legal person that processes personal data on behalf of the data controller based on its authorization.

Data Recording System: Any system where personal data is structured and processed according to specific criteria.

Data Controller: A natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

3. For What Purposes Do We Process Your Personal Data?

We may collect personal data such as name-surname, contact information, company and position details, and address information from website users, customers, employees, potential customers, candidates, business partners, and suppliers.

Personal data processed via www.internative.net

includes name-surname, contact details, position and affiliated company details, and address information.

These personal data are processed for the following purposes:

• Executing quotation requests submitted through the website,

• Conducting marketing, promotion, communication, and customer satisfaction activities, including providing personalized offers, advantages, campaigns, and communication where necessary,

• Improving service quality, ensuring proper functioning of website features, identifying and fixing errors, conducting maintenance and backup operations,

• Conducting online payment processes when applicable in accordance with relevant regulations,

• Ensuring company activities comply with legislation,

• Conducting finance and accounting operations,

• Managing legal processes,

• Managing business operations, audits, and internal planning,

• Conducting archiving, R&D, strategic planning, and investment processes.

4. On What Legal Grounds Do We Process Your Data?

While processing your personal data, we comply with constitutional rights, the Personal Data Protection Law No. 6698, relevant regulations, board decisions, and applicable case law.

Our processing activities adhere to the following legal principles:

• Lawfulness and fairness,

• Accuracy and up-to-date processing where needed,

• Specified, clear, and legitimate purposes,

• Relevant, limited, and proportionate processing,

• Retention for the period required by law or processing purpose.

5. How Long Do We Store Your Personal Data?

Your personal data are retained only for the period required by applicable regulations or for the intended processing purposes. Upon expiration of these periods or when processing is no longer necessary, your data are deleted, destroyed, or anonymized.

6. How Do We Collect Personal Data?

Your personal data may be collected verbally, in writing, or electronically through:

• Our website,

• Social media platforms,

• Third parties with whom we cooperate,

• Business partners and service providers.

Your data are stored securely in digital and/or physical environments with necessary technical and administrative measures in place to prevent unauthorized access, loss, alteration, or misuse.

7. To Whom Do We Transfer Your Personal Data?

Your personal data may be transferred to:

• Company employees, shareholders, and business partners,

• Service providers, legal and financial advisors, auditors, and consultants,

• Regulatory authorities and legally authorized public institutions.

International data transfers shall only occur in compliance with Article 9 of the Law, ensuring sufficient data protection, explicit consent (where required), contractual safeguards, and approval from the Personal Data Protection Authority when necessary.

8. When Can Personal Data Be Processed Without Explicit Consent?

Your data may be processed without explicit consent where:

• Explicitly permitted by law,

• Necessary to protect a person’s life or physical integrity,

• Required for performance of a contract,

• Necessary for fulfilling legal obligations,

• Made public by the data subject,

• Required to establish, exercise, or defend a legal right,

• Necessary for legitimate interests of the data controller, provided it does not harm fundamental rights and freedoms.

9. What Are Your Rights Under Article 11 of the Law?

You have the right to:

• Learn whether your personal data is processed,

• Request information regarding such processing,

• Learn the processing purpose and whether it is used appropriately,

• Learn third parties to whom data is transferred domestically or abroad,

• Request correction of incomplete or inaccurate data,

• Request deletion or destruction of data under applicable conditions,

• Request notification of third parties regarding correction or deletion,

• Object to processing resulting in an unfavorable outcome,

• Request compensation if you incur damages due to unlawful processing.

10. How Can You Exercise Your Rights?

You may submit your request by:

• Completing the Data Subject Application Form on our website,

• Contacting us via email at support@internative.net

• Sending a notarized written request,

• Using other methods designated by the Board.

Responses will be provided within 30 days. If the procedure requires additional cost, a processing fee may be charged within the tariff set by the Board.

This Privacy Policy and Information Notice may be updated without prior notice due to legal amendments, regulatory decisions, technological developments, or other reasons. Therefore, we recommend reviewing this Notice periodically.