Corporate Communication, Board, and Data Subject Information Processes Policy

PURSUANT TO THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

CORPORATE COMMUNICATION, BOARD, AND DATA SUBJECT INFORMATION PROCESSES POLICY

INFORMATION

Under Article 11 of the Law No. 6698 on the Protection of Personal Data (“KVKK”), data subjects (defined as “relevant persons”) are granted the following rights:

To learn whether their personal data is processed,
If their personal data has been processed, to request information regarding such processing,
To learn the purpose of processing personal data and whether they are used in accordance with that purpose,
To learn the third parties to whom personal data is transferred domestically or abroad,
To request correction of personal data if it is incomplete or incorrectly processed and to request notification of such correction to third parties to whom personal data has been transferred,
Even if processed in accordance with the Law No. 6698 and other relevant provisions, to request deletion, destruction, or anonymization of personal data where the reasons requiring processing cease to exist, and to request notification of such action to third parties to whom personal data has been transferred,
To object to the occurrence of a result against them by analyzing processed data exclusively through automated systems,
To request compensation for damages in case of damages due to unlawful processing of personal data.

Webtures operates in compliance with the KVKK as the data controller. Our company respects the rights of you, our valued data subjects, and strives to assist in fulfilling your requests in your application. The right to apply to our company via the form prepared pursuant to Article 11 of the KVKK (“Data Subject Application Form”) belongs directly to the personal data owner. For applications made on behalf of third persons, a power of attorney appropriate for representing the relevant person must be submitted.

APPLICATION METHOD

Pursuant to paragraph 1 of Article 13 of the KVKK, applications to our company, acting as the data controller, regarding these rights must be submitted in writing or by other methods determined by the Personal Data Protection Board (“Board”).

After filling out and signing the Data Subject Application Form completely and clearly, and delivering it to our address specified below by hand or via registered mail with return receipt, we will respond to your application within 30 (thirty) days at the latest. Applications regarding rights must be submitted in writing via the Data Subject Application Form or by other methods determined by the Board.

Applications to our company “in writing” may be submitted by:

Personal application by the applicant,
Via a notary public,
By signing with a “secure electronic signature” as defined in the Electronic Signature Law No. 5070,
By sending to our registered electronic mail (KEP) address.

Explanations regarding written application channels and the notes to be stated in submissions are as follows:

Application Method	Address for Application	Note to be Stated in Submission
Personal Application	Esentepe Mahallesi Milangaz Cad. Kartal Vizyon St. A-2 Bl. No: 77/219 Kartal/Istanbul	“Information Request Within the Scope of the Law on the Protection of Personal Data” shall be written on the envelope.
Application via Notary Public	Esentepe Mahallesi Milangaz Cad. Kartal Vizyon St. A-2 Bl. No: 77/219 Kartal/Istanbul	“Information Request Within the Scope of the Law on the Protection of Personal Data” shall be written on the notification envelope.
Application with Secure Electronic Signature (Signed with secure electronic signature and submitted via Registered Electronic Mail (KEP))	webturesanonim@hs01.kep.tr	“Information Request Under the Law on the Protection of Personal Data” shall be written in the subject line of the email.
Application with Mobile Signature or Email (Using an email address previously notified by the data subject to the data controller and registered in the data controller’s system)	info@webtures.com	“Information Request Under the Law on the Protection of Personal Data” shall be written in the subject line of the email.

CASES OUTSIDE THE SCOPE OF THE RIGHT TO APPLY

Pursuant to Article 28 of the KVKK, since the cases below are excluded from the scope of the KVKK, data subjects will not be able to assert their right to apply:

Processing of personal data for purposes such as research, planning, and statistics by anonymizing for official statistics.
Processing of personal data for artistic, historical, literary, or scientific purposes, or within the scope of freedom of expression, provided that it does not violate national defense, national security, public security, public order, economic security, the privacy of private life, or personal rights, and does not constitute a crime.
Processing of personal data by judicial authorities or enforcement authorities relating to investigation, prosecution, trial, or execution proceedings.

Pursuant to paragraph 2 of Article 28 of the KVKK, except for the right to request compensation for damages, rights cannot be asserted in the following cases either:

Where processing of personal data is necessary to prevent crime or for criminal investigation.
Where personal data is processed which has been made public by the data subject themself.
Where processing of personal data is necessary for the performance of supervisory or regulatory duties and for disciplinary investigation or prosecution by authorized public institutions and organizations and professional organizations in the nature of public institutions, based on the authority granted by law.
Where processing of personal data is necessary to protect the state’s economic and financial interests in relation to budget, tax, and financial matters.

PROCEDURE AND TIME FOR RESPONDING TO APPLICATIONS

In accordance with Article 13 of the KVKK, our company will finalize applications made by data subjects, depending on the nature of the request, free of charge within 30 (thirty) days at the latest. However, if the transaction requires an additional cost, a fee in the tariff determined by the Board may be charged.

Our company may accept the application or reject it by explaining the reason, and notify the data subject in writing or electronically. An application may be rejected in the following cases:

It prevents the rights and freedoms of others,
It requires disproportionate effort,
The information is publicly available,
It endangers the privacy of others,
One of the cases excluded from scope under the KVKK exists.

RIGHT OF THE DATA SUBJECT TO COMPLAIN TO THE BOARD

Pursuant to Article 14 of the KVKK, in cases where the application is rejected, the response is deemed insufficient, or the application is not responded to in due time, the data subject may submit a complaint to the Board within thirty days from the date they learn the response of the data controller and in any event within sixty days from the application date. A complaint to the Board will not be possible without first applying to our company.

OTHER MATTERS

The Data Subject Application Form has been prepared to correctly identify your relationship with our company, to determine your personal data processed by our company (if any) completely, and to respond to your application accurately and within the legal period. In order to eliminate legal risks that may arise from unlawful and unjustified data sharing and especially to ensure the security of your personal data, our company reserves the right to request additional documents and information (such as a copy of identity card or driver’s license) for identity and authorization verification.

Our Company Information

Trade Name: WEBTURES DİJİTAL BİLİŞİM ANONİM ŞİRKETİ
Address: Esentepe Mahallesi Milangaz Cad. Kartal Vizyon St. A-2 Bl. No: 77/219 Kartal/Istanbul
Mersis No: 0800053943700021
KEP Address: webturesanonim@hs01.kep.tr
Email Address: info@webtures.com
Phone: +90 216 599 0495
Website: www.webtures.com