Eski Büyükdere Cd. No:61, 34415 Kâğıthane
0212 319 9700
info@bircom.com

Personal Data Protection Policy

BİRCOM TELEKOMÜNİKASYON VE BİLİŞİM HİZMETLERİ SAN. TİC. A.S. PROCUREMENT AND PROCESSING OF PERSONAL DATA

INFORMATION REGARDING AND ITS PROTECTION

GENERAL EXPLANATION AND DEFINITIONS

This informative text has been prepared in order to fulfill the “disclosure obligation” within the scope of Article 10 of the Law on the Protection of Personal Data No.6698.

The meanings of the following terms in the text of the information refer to the Law No. 6698, the definitions in the Regulations and Communiqués issued regarding this Law, and are as follows.

Personal data: All kinds of information regarding an identified or identifiable natural person,

Processing of personal data: Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, by means of non-automatic means, provided that personal data are fully or partially automated or are part of any data recording system, Any transaction performed on data such as classification or prevention of use,

Related person: Real person whose personal data is processed,

Explicit consent: Consent on a specific subject, based on information and declared with free will,

Making anonymization: Making personal data unrelated to a real person whose identity is known or can be determined under any circumstances, even by matching with other data,

Data controller: Natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system

Data processor: Real or legal person who processes personal data on behalf of the data controller, based on the authority given by him,

Data recording system: A recording system in which personal data are structured and processed according to certain criteria,

Contact person: by legal persons who are resident in Turkey and the Law of the non-resident legal entities data chief representative in Turkey to be issued based on this Act with respect to its obligations under secondary legislation, natural persons reported during Registry records by the responsible data for communication with the Agency ,

Personal data storage and destruction policy: The policy on which data controllers are the basis for the process of determining the maximum time required for the purpose for which personal data are processed and for deletion, destruction and anonymization.

INFORMATION ABOUT THE DATA CONTROLLER

In legal entities, the data controller is the legal entity (BİRCOM A.Ş.). Data responsible for its obligations under the Law of legal persons resident in Turkey, representing the entity empowered body / person or persons are fulfilled with ingenuity. The body authorized to represent the legal entity, in terms of the implementation of the Law,

It may assign one or more persons to the obligations to be imposed. This assignment does not remove the liability of the legal entity in accordance with the provisions of the Law.

LIGHTING OBLIGATIONS

Within the scope of the obligation to inform the relevant persons,

– Identity of the data controller and, if any, its representative,

– The purpose for which personal data will be processed,

– To whom and for what purpose the processed personal data can be transferred,

– The method and legal reason for collecting personal data,

– What are the rights of the persons whose personal data are processed,

is obliged to give information about. Also, regarding data security;

– To prevent unlawful processing of personal data,

– To prevent unlawful access to personal data,

– To ensure the protection of personal data,

In order to take the necessary security measures. BİRCOM A.Ş. does not disclose the personal data obtained by conducting the necessary audits in order to ensure the implementation of the provisions of the Law No.6698 in its own institution or organization, and does not use it for purposes other than processing.

PERSONAL DATA TO BE PROCESSED

BİRCOM A.Ş. The personal data to be processed by the Company are stated below, and new information may be added and / or changed when required and / or required by law.

Personal data subject to data processing;

– Name, Surname, TR No, Date of Birth, etc. ID information,

– Address, phone, fax, e-mail etc. contact information,

– Tax Office and Tax Number information,

– Information about profession and education,

METHODS OF OBTAINING PERSONAL DATA

Personal data can be obtained directly from the person concerned, online sales platforms, online forms, dealers, solution partner institutions and organizations and, but not limited to, the acquisition of the acquired data.

It can also be obtained indirectly according to its purpose. BİRCOM A.Ş. The data provided by our customers who make transactions through websites or mobile applications, consent of our customers and in accordance with the provisions of the legislation BİRCOM A.Ş. It is processed by.

www.bircom.com, www.kazananbayi.com owned by BİRCOM A.Ş.

The addresses www.hifilife.com and www.sennheiser.com.tr are websites that use cookies. Cookies; It is a file consisting mostly of letters and numbers that allows the device to be detected by storing it in the internet browser or hard disk of the device being used.

BİRCOM A.Ş. The online platforms belonging to will collect, process, share with third parties and securely store your browsing information in order to provide better service to its visitors and within the framework of its legal obligation, provided that it is not used for the purposes and scope specified in this Statement on Protection of Personal Data.

www.bircom.com, www.kazananbayi.com, www.hifilife.com and www.sennheiser.com.tr cookies; It stores log files, blank gif files and / or information collected through third-party sources to create a summary of your preferences. www.bircom.com, www.kazananbayi.com,

www.hifilife.com and www.sennheiser.com.tr in order to make special promotions for you, to offer promotions and marketing offers, to improve the content of the website or mobile application for you and / or to determine your preferences; It can monitor your browsing information on the site and / or your usage history on the site.

www.bircom.com, www.kazananbayi.com, www.hifilife.com and www.sennheiser.com.tr may match the information collected from you on the site through different methods or at different times, such as information collected online and offline, and can use together with information from sources.

BİRCOM A.Ş. on online platforms (www.bircom.com, www.kazananbayi.com,

www.hifilife.com and www.sennheiser.com.tr) use session cookies and persistent cookies. Session ID cookie expires when you close your browser. The persistent cookie remains on your hard disk for a long time. By following the instructions provided in the “help” file of your internet browser or by “www.allaboutcookies.org” or

You can remove persistent cookies and reject both session cookies and persistent cookies by visiting “www.youronlinechoices.eu”. If you refuse persistent cookies or session cookies, you may continue to use the website, mobile application, but you may not be able to access all functions of the website, mobile application or your access may be limited.

How Are Website Cookies Used?

www.bircom.com, www.kazananbayi.com, www.hifilife.com and www.sennheiser.com.tr cookies; It uses it to remember your preferences and to personalize your website / mobile application usage. This usage includes cookies that record your password and keep your website / mobile application session open continuously, thus saving you from the trouble of entering a password more than once each visit, and cookies that remember and recognize you on your next visit to the website / mobile application.

Access to www.bircom.com, www.kazananbayi.com, www.hifilife.com and www.sennheiser.com.tr websites

Google Analytics cookies are used to analyze users.

Where you connect to www.bircom.com, www.kazananbayi.com, www.hifilife.com and www.sennheiser.com.tr websites, what content you view on the website / mobile application and your visit

including tracking how you use the website / mobile application, such as its duration; uses it to determine how you use the website / mobile application.

Cookies on www.bircom.com, www.kazananbayi.com, www.hifilife.com and www.sennheiser.com.tr websites are used for advertisement / promotion purposes in order to present content and advertisements that are more appropriate to your interests and you.

In this way, when you use the website, mobile application, it offers you more suitable content, personalized campaigns and products, and does not offer content or opportunities that you previously stated that you did not want.

How does the Website use third party cookies for advertising and retargeting?

www.bircom.com, www.kazananbayi.com, www.hifilife.com and www.sennheiser.com.tr website cookies also; It can use search engines, website, mobile application and / or to activate “advertising technology” in order to offer you advertisements that you think may be of interest when you visit the websites where the website advertises. Advertising technology uses information about your previous visits to the website / mobile application and the websites / mobile applications where the website advertises in order to provide you with special advertisements. When serving these ads, a unique third-party cookie may be placed on your browser so that the website can recognize you. Your internet browser “help”

by following the instructions provided in the file or “www.allaboutcookies.org” or “www.youronlinechoices.eu”

You can remove persistent cookies and reject both session cookies and persistent cookies by visiting http://www.sony.net/

PURPOSE OF PROCESSING PERSONAL DATA

BİRCOM A.Ş. processes personal data for the following purposes. These purposes;

– Within the scope of tax laws, Turkish Commercial Code No. 6102 and other legal regulations, tax, etc.

fulfillment of liabilities regarding public receivables,

– Taking measures regarding the protection of consumer rights within the scope of the Law No. 6502 on the Protection of Consumers,

– The persons concerned are BİRCOM A.Ş. Receiving orders for the products they want to buy from, selling the products, delivering the products to the relevant persons, collecting the prices, selling the product

providing after-services, measuring customer satisfaction, collecting and evaluating complaints and suggestions, if any, regarding the product or service sold,

– Arrangement of distance sales contracts in purchases made through electronic commerce platforms, verification of the identity of the relevant person,

– Increasing the service quality,

– Carrying out campaigns, promotions, advertisements and promotional activities regarding products and services, providing information on these issues,

TRANSFER OF PERSONAL DATA

BİRCOM A.Ş. does not transfer personal data obtained for data processing purposes to third parties / institutions without the explicit consent of the data subject.

Cooperating program for public legal entities authorized to receive personal data such as the Turkish Currency Institution, Social Security Institution, Financial Crimes Investigation Board, Interbank Card Center, Credit Registry Office, domestic / foreign affiliates of BİRCOM A.Ş., companies operating as dealerships, will be able to transfer personal data to partner / solution partner institutions and organizations, PTT branches, logistics support service, consultancy and independent audit services, provided that the rights of the relevant person under Law No.

OBTAINING THE EXPRESS CONSENT OF THE RELATED PERSON IN THE PROCESSING OF PERSONAL DATA The personal data to be processed by BİRCOM A.Ş.

It is taken and processed. Explicit consent; It expresses the consent of the person concerned on a specific subject, which is based on information and will be explained freely.

In accordance with Article 5/2 of Law No.6698, in the event of one of the following conditions, personal data may be processed without the explicit consent of the person concerned.

– It is clearly stipulated in the laws.

– It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his consent due to actual impossibility or whose consent is not legally valid.

– It is necessary to process personal data belonging to the parties of the contract, provided that it is directly related to the establishment or performance of a contract.

– It is mandatory for the data controller to fulfill his legal obligation.

– It is made public by the person concerned.

– When data processing is mandatory for the establishment, use or protection of a right.

– Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

HOLDING PERIOD OF PERSONAL DATA

BİRCOM A.Ş. destroys the personal data (deletes, destroys or anonymizes the personal data) upon the expiration of the mandatory retention periods specified in the Laws and other legislation.

RIGHTS OF THE RELATED PERSON

The relevant persons apply to the data controller and ask about themselves;

– Learning whether personal data is processed,

– If personal data has been processed, to request information regarding this,

– Learning the purpose of processing personal data and whether they are used appropriately for their purpose,

– To know the third parties to whom personal data are transferred domestically or abroad,

– To request correction of personal data in case of incomplete or incorrect processing,

– To request the deletion or destruction of personal data within the framework of the conditions stipulated in the law,

– Request notification of changes in personal data to third parties to whom personal data are transferred,

– To object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,

– In case of damage due to unlawful processing of personal data, it has the right to demand the compensation of the damage.

APPLY TO THE DATA CONTROLLER

The real persons whose personal data are processed, are responsible for their requests within the scope of their rights specified in Article 11 of the Law numbered 6698, BİRCOM A.Ş. Can apply to. The persons concerned can benefit from this right provided that they submit their applications in Turkish. The relevant persons can send their requests to BİRCOM A.Ş. Can forward to. In this direction, the relevant persons request;

– In writing,

– Via registered electronic mail (KEP) address,

– Via secure electronic signature or mobile signature,

– The person whose personal data is processed by BİRCOM A.Ş. And BİRCOM A.Ş. By using the electronic mail address registered in the system of;

– Name, surname and signature if application is in writing,

– for citizens of the Republic of Turkey T. C. identification number, nationality for foreigners, passport number or identification number, if any,

– Place of residence or workplace address for notification,

– If any, notification e-mail address, telephone and fax number,

– Demand,

must be found. Information and documents on the subject must be attached to the application. Application requests can be made using the “Application Request Form”. For the applications to be made by the relevant persons, the communication channels specified in the “2-INFORMATION RELATED TO THE DATA RESPONSIBLE” section of this information text can be used.

BİRCOM A.Ş. concludes the requests in the application free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, a fee may be charged in the amount specified in Article 7 of the “Communiqué on Application Procedures and Principles to Data Officer”. In case the application is caused by the error of the data controller, the fee received is returned to the person concerned.

CONTACT US :

If you would like to learn more about BİRCOM A.Ş.’s data policies and how we use your personal data, you can send us an e-mail, call us or visit our company. A list of contact details is provided at the end of this Privacy Statement. In accordance with the Personal Data Protection Law No.6698, you can use the form found in this link [?] To use your rights regarding your personal data via any of the following channels:

– Apply in person at Sultan Selim Mahallesi, Eski Büyükdere Caddesi, No: 61, K: 3 D: 3 -34416 Kağıthane / İstanbul address or to our sales store by having your identity verified.

– Send your application by e-mail to info@bircom.com with your registered e-mail address

– Send an e-mail to our company’s info@bircom.com address with your secure electronic or mobile signature.

– Use another method included in the Communiqué on the Principles and Procedures of Application to the Data Controller.

Your application request will be concluded by our company within 30 (thirty) days. If the transaction requires cost, the tariff determined by the Personal Data Protection Board will be applied. If your application is rejected, we will notify you of the reason in writing or in electronic form.

Scope of this Privacy Statement

This is the Privacy Statement of BİRCOM A.Ş. and it is also valid for BİRCOM A.Ş.’s affiliates, group companies and outlets within the scope of processing personal data.

We may make changes to this Privacy Statement to comply with changes in the law and / or to reflect our changing data processing terms. This version was created on 08/08/2019. You can find the most recent version at www.bircom.com.

Contact of the Data Protection Officer

Country

Data Protection Authority

information

Turkey

info@bircom.com

Personal Data Protection Authority

Republic

0212- 319 97 00

https://www.kvkk.gov.tr/

CHANGES AND UPDATES

This informative text is prepared by the Law No. 6698 and the Regulations and Communiqués published within the scope of the said Law and BİRCOM A.Ş. Has been prepared within the scope of personal data processing purposes and policies. Relevant legal regulations and / or BİRCOM A.Ş. Necessary changes can be made in the information text in line with the changes that will occur in the personal data processing purposes and policies of. The most up-to-date version of the Information Text will be available at www.bircom.com.

Bircom Telekomünikasyon ve Bilişim Hizmetleri Sanayi ve Ticaret A.Ş.

Mersis Number: 0177035208000014

Address: Sultan Selim Mah. Eski Büyükdere Cad. No: 61 K: 3 D: 3 34416. Kağıthane / İSTANBUL

Phone: 0212 319 97 00

Fax: 0212 284 76 80

e-mail address: info@bircom.com