Privacy and KVKK Terms

Terms and Definitions

Within the scope of this policy:

INFOBIEN Information Technologies: Refers to INFOBIEN Information Technologies and Innovation Inc., the owner of the website,

Data Subject/Individual: Refers to the data subject,

Data Environment: Refers to any environment where personal data, whether fully or partially automated or non-automated but part of any data recording system, is processed,

Website: Refers to the website located at www.infobien.com,

Data Processor: Refers to the natural or legal person who processes personal data on behalf of the data controller,

Data Controller: Refers to the 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,

Law No. 5651: Refers to the Law on Regulation of Broadcasts on the Internet and the Fight against Crimes Committed through These Broadcasts,

Law No. 6698/GDPR: Refers to the Law on the Protection of Personal Data, respectively.

1. Scope and Purpose of the Privacy and Personal Data Protection Policy

This Privacy and Personal Data Protection Policy explains:

The methods and legal bases for collecting personal data,

The categories of individuals whose personal data are processed (Data Subject Categorization),

The categories of personal data processed in relation to these groups of individuals (Data Categories) and example data types,

How these personal data are used in which business processes and for what purposes,

The technical and administrative measures taken to ensure the security of personal data,

To whom and for what purpose personal data may be transferred,

The retention periods of personal data,

What rights individuals have regarding their personal data and how they can exercise these rights,

Disclosure of personal data to public authorities.

a. Methods of Collecting Personal Data and Legal Bases

INFOBIEN Information Technologies and Innovation Inc. collects personal data through auditory, electronic, or written means, cookies, and communications channels such as administrative and judicial authorities, in compliance with the personal data processing conditions specified in the Law on the Protection of Personal Data and within the legal bases specified in this Privacy and Personal Data Protection Policy.

b. Categorization of Data Subject Groups

INFOBIEN Information Technologies and Innovation Inc. categorizes the data subject groups whose personal data are processed in business processes and related activities as follows. However, personal data of other groups (such as consultants, educators) may also be processed in accordance with the personal data processing conditions specified in Articles 5 and 6 of the Law on the Protection of Personal Data and within the legal bases specified in this Privacy/Personal Data Protection Policy.

Internal Customer (INFOBIEN Information Technologies and Innovation Inc. Subsidiaries)

Online Visitor

Physical Visitor

Supplier or Supplier Employee (Outsourced Personnel) or Representative

Consultant

c. Data Categories and Example Data Types

1. Internal Customer (INFOBIEN Information Technologies and Innovation Inc. Subsidiaries)

• Identity Information: Name, surname

• Contact Information: Mobile phone, email address, landline

• Risk Management Information: IP address

• Transaction Security Information: Password, password information

• Legal Transaction and Compliance Information: Start and end time of the service provided, type of service provided, transferred data

1. Online Visitor

• Transaction Security Information: Mobile phone, password information

• Legal Transaction Information/Risk Management Information: IP address

• Legal Transaction and Compliance Information: Start and end time of the service provided, type of service provided, amount of data transferred

1. Physical Visitor

• Identity Information: Name, surname

• Transaction Information: Visit date and time

1. Supplier or Supplier Employee (Outsourced Personnel) or Representative

• Name and surname

• Contact Information: Email address, telephone

1. Consultant

• Identity Information: Name, surname

• Contact Information: Mobile phone, email address

• Professional Experience and Expertise Information: Education, certificate

d. How Personal Data Are Used in Which Business Processes and for What Purposes

Personal data is used by INFOBIEN Information Technologies and Innovation Inc. for the following purposes:

Processing online visitor data in compliance with relevant legislation,

Ensuring physical space security,

Improving services provided through platforms, developing new services, and providing related information,

Improving process management,

Resolving internal customer issues and complaints,

Ensuring communication with internal customers and providing support in line with the service provided,

Conducting statistical evaluations,

Determining and implementing commercial and business strategies of INFOBIEN Information Technologies and Innovation Inc.,

Establishing university cooperation, receiving support within the scope of joint projects,

Ensuring sustainability of R&D center,

Making necessary notifications for R&D sustainability,

Tracking accounting and procurement transactions,

Legal processes and compliance with regulations,

Responding to information requests from administrative and judicial authorities,

Planning internal reporting and business development activities,

Ensuring information and transaction security and preventing malicious use,

Planning and executing operational activities necessary to ensure that INFOBIEN Information Technologies and Innovation Inc.'s activities are conducted in accordance with INFOBIEN Information Technologies and Innovation Inc. procedures and policies