PRIVACY POLICY: Personal Data Protection and Processing Personal Data

This privacy notice aims to give you information on how Dijital İnsan Kaynakları ve Tasarım LTD. ŞTİ. (collectively referred to as ”DIGITALLICA”, “we”, “us” or “our” in this privacy notice) collects and processes personal data, including any data you may provide through our website when you sign up to receive our newsletter or white paper, enroll on a webinar or event, or inquire about a product or service. You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

• As DIGITALLICA we attach high importance to the security and confidentiality of your personal data and we adopt the highest level of security measures to keep your data safe. With DIGITALLICA’s “Data Controller and/or data processor” title, we operate in accordance with the Personal Data Protection Law No.6698 (“KVKK”) and the relevant legislations applicable in Europe, as stated in detail in this privacy notice.

• Disclosure Text About Processing Personal Data, (also referred to as “Disclosure Text”) in accordance with the article titled “Obligation of Data Supervisor” in the 10th article of KVKK, has been prepared to inform you in the most transparent way about the identity of the data controller, the method of collecting personal data and the legal base, the purpose for which data will be processed, to whom and for what purpose it can be transferred, data processing period and your rights listed in Article 11 of the KVKK.

• DIGITALLICA is the controller and responsible for your personal data. Our contact details are: Address: Akasya Towers Acıbadem Mah. Çeçen Sok. No:25 A Daire:150 Üsküdar – İSTANBUL; Email: info@digitallica.com.tr. For all data matters contact us by email.

• This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Disclosure Text About Processing Personal Data

Disclosure Text About Processing Personal Data, (“Disclosure Text”) in accordance with the article titled “Obligation of Data Supervisor” in the 10th article of KVKK, has been prepared to inform you in the most transparent way about the identity of the data controller, the method of collecting personal data and the legal base, the purpose for which data will be processed, to whom and for what purpose it can be transferred, data processing period and your rights listed in Article 11 of the KVKK.

1. What Personal Data Does DIGITALLICA Process?

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you.

From DIGITALLICA’s website, social media channels, mobile applications and similar means prepared and presented to you by us; identity data (name-surname, date of birth), contact information (business address, e-mail address, telephone numbers), professional experience (sector information, job title), marketing (cookie records) and some data on transaction security (IP address information, log records, password and password information, website / application login and exit information, your mobile device’s operating system and operating system version number) can be processed by DIGITALLICA.

The method of collecting your qualified personal data in the disclosure text is processed for the specified purposes and stated legal reasons by taking high-level security measures, and is shared only by being anonymized / unmatched with your identity, unless there is an explicit consent to share from you.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2. Processing Method and Legal Reason for Your Personal Data:

Your personal data may vary depending on your relationship with DIGITALLICA, and the data may be collected verbally, in writing, or electronically, by automatic or non-automatic means. We use different methods to collect data from and about you, including through our website, social media channels, during telephone calls, via email, during face-to-face meetings, at exhibitions, seminars and networking events. Your personal data can be created and updated as long as your relationship with DIGITALLICA continues and can be processed and kept in both digital and physical environments.

You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Request information about our products or services;

• Complete a contact form on our website;

• Subscribe to our publications or webinars;

• Request marketing to be sent to you.

Your personal data can be processed and transferred in line with the purposes stated in the third article below and within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law No. 6698. The legal basis for the processing of the Personal Data by DIGITALLICA is the “explicit consent” given by our users based on this disclosure text, our customers and DIGITALLICA’s legitimate interests provided that it does not harm the fundamental rights and freedoms of the users.

3. Purposes of Processing Your Personal Data:

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• In order to fulfill the contract to which you are a party, or to take steps at your request before entering into such a contract while preserving the confidentiality of your identity information,

• To carry out DIGITALLICA’S products and services by our relevant business unit for Real and /or legal third person institutions and organizations that have business relations with DIGITALLICA,

• To conduct listing, reporting, verification analysis studies regarding the usage of the products and services offered by DIGITALLICA, to produce statistical and scientific information on this issue, to improve our products and services accordingly, to increase the satisfaction of our products and services and to make customizations for the user in this context,

• To be able to conduct market research, for promotion, and to collect necessary information about our products and services, to evaluate complaints and suggestions, and to contact you directly through communication channels shared with DIGITALLICA,

• To support the execution of all Human Resources processes and policies of the EMPLOYER (data controller), who has signed a contract with DIGITALLICA,

• For DIGITALLICA and / or EMPLOYER (data controller)’s processes, and legal harmonization process of determining the business strategy, development, and implementation,

• To enable DIGITALLICA’s accreditation and evaluation studies,

• Planning and management of financing and invoicing of all services offered by DIGITALLICA and / or EMPLOYER (data controller),

• Training and development of employees upon request by the EMPLOYER (data controller),

• Fulfilling participation requests to organizations, trainings, seminars, etc.,

• Carrying out risk management and quality improvement activities,

• Taking all necessary technical and administrative measures for the system and applications within the scope of data security,

• To comply with a legal or regulatory obligation. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Purposes and within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Promotional offers from us

You will receive marketing communications from us if you have requested information from us about our products or services, purchased goods or services from us or if you inquired about our other activities and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any by emailing info@digitallica.com.tr at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of providing a product or service and processed for purposes other than marketing.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy below.

Cookie Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical/performance cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies: These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences.

Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via info@digitallica.com.tr

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. To Whom Processed Personal Data Can Be Transferred and For What Purpose

Your personal data can be processed and transferred when necessary within the scope of the Personal Data Protection Law No.6698 (“KVKK”) and the relevant legal legislation by DIGITALLICA and / or its subsidiaries and their subcontractors, legally authorized real and / or legal third person institutions and organizations, DIGITALLICA’s business partners, subcontractors, suppliers, contracted or cooperating in any field to carry out their products and services, real and / or legal third person institutions and organizations residing in the country within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK Law. The General Principles of this “Disclosure Text” are limited to the purposes specified in Article 3 titled “Purposes of Processing Your Personal Data ” in accordance with the “Conditions for Processing of Personal Data” specified in Article 5.

5. Data processing period:

Your personal data, limited to the purposes and legal basis specified in Article 3 of this Disclosure Text; will be processed in accordance with the data processing and limitation periods specified in the legislation that DIGITALLICA is subject to and all other relevant laws and other legal regulations.

If there is no legal regulation regarding the periods, this period is applied as ten (10) years from the date of the end of the service provided by DIGITALLICA, or closure of the user account for any software created by DIGITALLICA.

Regardless of whether you have a request after the end of this period; even if your personal data is matched with other data, all of the data that will make your identity specific or identifiable will be destroyed and made unrelated to you. In case of using your rights regulated by Article 6 of this disclosure text, your personal data will be anonymized by doing the same.

In case of changes in the laws regarding data processing periods, the new terms will be taken as basis.

6. Rights of Personal Data Owner based on Article 11 of KVKK

Within the framework of Article 11 of the Law, without prejudice to the conditions stipulated in article 28 of KVKK titled “Exceptions”, you can request the following from DIGITALLICA about your personal data;

a. Learning whether it has been processed,

b. Requesting information on this if it has been processed,

c. Learning the purpose of processing and whether it is used for stated purposes,

d. To know the third parties to whom they are transferred domestically or abroad,

e. To request correction if it is incomplete or incorrectly processed,

f. Requesting the deletion or destruction / destruction of your personal data within the framework of the conditions stipulated in Article 7 of the Law,

g. Request notification of the transactions made pursuant to subparagraphs (e) and (f) to third parties to whom personal data have been transferred,

h. Object to the emergence of a result against you because it is analyzed exclusively with automatic systems,

i. In case you suffer damage due to unlawful processing, you have the right to demand the compensation of the damage.

In case of a written request;

You can submit a written requests to DIGITALLICA with an ID document that identifies your profile or indicating that you are authorized to apply for the rights listed under Article 11 and by proxy with a notarized power of attorney, or through sending it by a notary to the address: “Akasya Towers Acıbadem Mahallesi Çeçen Sokak NO:25 A D:150 Üsküdar / İSTANBUL”.

Your requests submitted to DIGITALLICA will be answered in writing or electronically as soon as possible and within thirty days at the latest, in return for the transaction fee specified in the Article 7 of the Communiqué on the Principles and Procedures of Application to the Data Controller.

• I have explicit consent to the processing of my personal data defined in the KVKK Law in accordance with the form and conditions specified with the disclosure text, to be used and shared within the scope of the relevant processes limited to the purpose of processing, to be kept within the required period and confirm that necessary information has been provided to me regarding this matter.

I agree [  ]

I do not agree [  ]