Personal Data Processing Explanatory Text

Domain Name API (Atak Domain Bilgi Teknolojileri A.Ş.) Clarification Text on Processing Personal Data

What is KVKK?
The Law on Protection of Personal Data (KVKK) was accepted by the Turkish Grand National Assembly on 24.03.2016 and entered into force after being published in the Official Gazette dated 07.04.2016 with number 29677

The law is based on the compatibility of all data controller and institutions within the framework of basic purposes such as ensuring the confidentiality of personal data, protecting it and preventing unauthorized use. Our company, like all organizations, is obliged to comply with this Law and the personal data processed in all processes of our company are within this scope.

What is Data Processing?
Any transaction performed on personal data is considered as "data processing". Therefore, data processing includes archiving, storage, modification, rearrangement, disclosure, transfer, analysis and classification of data.

Who is Data Subject?
One of the expressions frequently mentioned in the law and our corporate policies is "related person" or "data subject". This refers to natural persons whose personal data are processed.

Who is Data Controller?
The data controller is the natural or legal person who determines the purposes and methods of processing personal data and is responsible for the establishment and management of the data recording system. At this point, our company becomes the Data Controller in terms of the data of our customers, visitors and employees.

Who is Data Processor?
Data processors are real or legal persons who process data on behalf of the data controller. These persons may also be a separate natural or legal person authorized by the data controller to process personal data.

Data Processing Rules
All data controllers are entitled to process data only when the following conditions are met or the data subject gives explicit consent:

As Domain Name API (Atak Domain Bilgi Teknolojileri A.Ş.), we attach importance to the security of your personal data. We are required to declare that we reserve the right to update this Statement on the Protection of Personal Data at all times within the framework of changes in the current legislation, Board Decisions and judicial decisions. With this sensitivity, it is of great importance for our Company to process and preserve all kinds of personal data belonging to all persons related to the Company, including those who benefit from our services as the Company, in accordance with the Personal Data Protection Law No.6698 ("KVK Law"). Your personal data will be processed by our company, and all kinds of transactions performed on your information, including obtaining, recording, storing, preserving, changing, disclosing, transferring, making available your information by automatic or non-automatic means refers to "processing personal data". In this context:

-The Law No. 6563 on the Regulation of Electronic Commerce includes provisions on the protection of personal data.
- Penal sanctions are foreseen in some cases for the protection of personal data through the provisions of the Turkish Penal Code No.5237.
- As a matter of fact, in order to fulfill our obligations arising from the Law on Consumer Protection No.6502 and the Regulation on Distance Contracts, data must be collected and used.
- Moreover, in accordance with the Law No. 6769, there are data that our company is obliged to keep. In accordance with this responsibility, we process your personal data as "Data Controller" as defined in the Personal Protection Law, as explained below and within the limits set by the legislation.

After this clarification text has been examined by you and the notification is made to our company, a consent text will be submitted by you Dear Addressee, so that all your personal data can be used within the scope of the business and commercial relationship to which our company is a party, limited to the requirements of this relationship. We must state that there is no requirement to sign the relevant consent text. In this context, after this clarification text of the consent text examined in detail and sufficiently and if it is found appropriate after all your questions are forwarded to our company, its approval is necessary in terms of its validity.

1) Data Controller and Representative
In accordance with Data Protection Law, your personal data can be processed by our company as the data controller within the scope described below.

2) Collection, Processing and Purpose of Processing Personal Data
In order to ensure that the activities carried out by our company are carried out in accordance with the relevant legislation and the procedures of our company, all relevant national / international legislation and secondary regulations published by national / international competent authorities based on these or related to them or their activities in order to fulfill its obligations and commitments within the scope of the contracts to which it is a party.

• Identity Information (name, surname, mother and father's name, mother's maiden name, date of birth, place of birth, marital status, copy of identity card and serial order number, TR identity number, passport information (for foreigners));
• Contact Information (address, e-mail address, contact address, registered electronic e-mail (KEP) address, telephone number)
• Location information
• Customer Transaction (call center records, invoice, promissory note, check information, information on the accounter, order information, request information)
• Risk Management (information processed to manage commercial, technical administrative risks)
• Finance (balance sheet information, financial performance information, credit and risk information, assets information)
• Visual and Audio Recordings
• Physical Space Security (entrance and exit registration information of employees and visitors, camera records)
• Transaction Security (IP address information, website login and exit information, username and password information)
• Marketing (shopping history information, survey, cookie records, information obtained through campaign work) and, besides this information;

Establishing contracts for all kinds of products and services you request from our company and arranging all other records and documents (in paper or electronic environment), making customer satisfaction calls, fulfilling sms / mail requests, providing the products and services in question, service and product conducting activities, performing participant and customer transactions, processing in accordance with the Terms of Service or the relevant product-specific contract, eliminating complaints in terms of the services offered and improving the services, Fulfilling the instructions of the customers in accordance with the law and the contract, Planning the human resources policies and processes of our company, and the scope of marketing activities, determination and evaluation of the purchasing habits of customers, determination of the marketing and service delivery process and results, and their statistical evaluation and execution; it will be processed within the scope of the personal data processing conditions and purposes specified in Articles 5, 6, 8 and 9 of the Data Protection Law for the purpose of protecting and storing data that are required to be protected and stored for certain periods by the administration.

3) To whom and for what purpose the processed personal data can be transferred
In relation to your personal data collected, in order to ensure that the activities carried out by our company are carried out in accordance with the relevant legislation and the procedures of our Company, all relevant national / international legislation and secondary regulations published by national / international competent authorities based on these or related to them or their activities:

• Confirming the identity information of the shopper / shoppers through the website and mobile applications,
• Establishing the contract requested by the Customer in terms of service and product,
• Recording the address and other necessary information for communication,
• Contacting customers regarding the conditions, current status and updates of the contracts concluded under the relevant articles of the Law on Consumer Protection in order to establish a distance sales contract and / or a sales contract, and provide the necessary information,
• Arrangement of all records and documents that will be the basis of processing in electronic or paper environment,
• Fulfilling the necessary obligations in accordance with the national / international legislation that our companyis subject to,
• Fulfilling the obligations that our companyis subject to in accordance with the contract concluded in the context of national / international legislation to which our companyis subject,
• Providing information to public officials on public security issues upon request and in accordance with the legislation,
• In order to provide a better shopping experience to customers, to provide information to customers about products and services that customers may be interested in, informing customers about campaigns, conducting activities that increase user experience by monitoring consumer movements, managing relations with market research, planning and implementation of after-sales service activities regulation and implementation of processes,
• Increasing customer satisfaction, making customer satisfaction calls, fulfilling sms / e-mail requests, determining the purchasing habits of customers who shop from the website and / or mobile applications, and direct and indirect marketing, personalized marketing and remarketing activities to be arranged according to the preferences of the customer. In this context, informing in electronic and / or physical environment through contracted organizations, target audience determination, cross-selling, personal segmentation, target setting, analysis and in-house reporting,
• Conducting R&D studies of the operation of our corporate website and mobile application and personalizing it according to consumer demands, preferences and needs,
• Fulfilling the obligations (identification, information storage, reporting, information) and commitments under the contracts to which our companyis a party;
• Elimination of customer complaints and improvement of services in terms of services provided by our company,
• Fulfilling the customers' instructions deemed appropriate to the law and contract,
• Planning our institution's human resources policies and processes,
• Determining the scope of service, product and marketing activities, determining the results and evaluating statistically and performing them,
• For evidence in a legal dispute,
• Fulfilling our obligations in accordance with the national and international legislation and rules that our companyis subject to, In addition to the sales and marketing activities of products and / or services, planning and maintaining, improving after-sales service processes, identifying and developing alternative production techniques, developing and / or increasing loyalty to the products and / or services offered by our company, within the framework of planning and implementation,
• Data that is required to be protected and stored for certain periods by the administration is processed in accordance with the consent of the customers and the provisions of the legislation for the purposes of protecting and storing the data for the periods specified in the relevant legislation.

Any personal data available within the scope of the above mentioned; it can be transferred to persons and institutions that have been granted permission to request and obtain relevant data, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Data Protection Law to companyofficials, third parties, domestic and foreign business partners, solution partners, suppliers, legally authorized public institutions and private persons, in accordance with the legislation that our companyis subject to, to obtain, save, store, change, update, periodically check, rearrange, classify, keep for the period required for the purpose for which they are processed or for the period stipulated in the relevant law, as an institutional, commercial and data controller and / or data processor , their legal or it works with our organization into the actual requirements depending on the service or public institutions and organizations that are legally required and / or 3rd party service provider who is resident in Turkey or in abroad, to be shared with vendors, including the transfer abroad in case of legal or service-related actual requirements.

4) Method and Legal Reason for Collecting Personal Data
Although your personal data may vary depending on your relationship with our Company, it may be collected verbally, in writing or electronically, by automatic or non-automatic methods, through our Institution's units and offices, website, social media channels, mobile applications and similar means. Your personal data collected in this way can be processed and transferred for the purposes specified in articles (2) and (3) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Data Protection Law. In addition, when you use our website to use the services of our Company, when you visit our Companyor our website, when you participate in the training, seminars or organizations organized by our Company, your personal data can be processed for the purposes specified in Article 3.

Again, if you use the website of our company, it stores the information collected by our companyin order to create an opinion about your preferences. In order to make special promotion for you on the website of our company, to organize promotional and marketing activities, to improve the content of the website and / or to determine your preferences, it can monitor your browsing information on the site and / or your usage history on the site.

Again, our customers who shop on our institution's website and / or mobile by credit card, by using credit card, bank transfer, payment system, they are deemed to have consented to share their personal data with the relevant company, whichever is chosen as the payment method of Bank, Transferwise, Paypal, Webmoney, Alipay, Stripe companies from which this service is purchased, and to be processed by the payment company. In this respect, it is also necessary to read and examine the payment policy page of the relevant payment systems before shopping with a credit card. The website of our companycan provide links to the websites of third parties and institutions other than our company. Although these links are used to provide information and / or facilitate the provision of a service, if you refer to the links of other websites, companies and individual institutions other than our institution's website, you should review the privacy rules and cookie policies of these sites separately.

In similar cases, our companydoes not have any responsibility for the sites other than its own website for obtaining and processing your personal data. In order to be informed about the current business and transactions of the relevant persons and institutions in terms of confidentiality and personal data, it is necessary to first examine the information on the relevant sites and, if any, send your questions to the relevant site management.

5) How Long Will Your Personal Data Be Processed?
Our companydetermines the retention periods of personal data by taking into account the national and international legislation to which it is subject and the purposes of processing the data subject to the process. In accordance with the KVKK, your personal data processed for the purposes specified in this Clarification Text, when the purpose required to be processed in accordance with Article 7 / f.1 of the KVKK is eliminated and / or when all periods including the time-out periods that we are obliged to process your data in accordance with the legislation, your personal data will be deleted, destroyed or anonymized and continue to be used by us after 24 months.

6) Your Rights Stipulated in Article 11 of Data Protection Law as Data Subject;
As data subject, if you submit your requests regarding your rights to our Companyusing the methods set out below in this Clarification Text, our Companywill finalize your request as soon as possible depending on the nature of the request. In this context, data subject has the right;

• Learning whether personal data is processed or not,
• Requesting information if personal data has been processed,
• Learning the purpose of processing personal data and whether they are used appropriately for their purpose,
• To know the third parties in the country or abroad to whom personal data have been transferred,
• To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data have been transferred,
• To request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear, despite the fact that it has been processed in accordance with the provisions of the Data Protection Law and other related laws, and to request the third parties to whom the personal data has been transferred,
• 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, he/she has the right to demand the compensation of the damage.

Pursuant to the paragraph 1 of Article 13 of Data Protection Law, your request for using your rights stated above shall be written to (Atak Domain Bilgi Teknolojileri A.Ş. Yenişehir Mah. Arda Sk. No: 36/1 Izmit - Kocaeli) You can forward as. We reserve the right to request from you in accordance with the tariff specified in article 13 titled "Application to the data controller" of the KVKK, in the event that our companyneeds to incur expenses in order to fulfill these requests. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application in writing to our Companyin accordance with the Data Protection Law. Within this framework, the channels and procedures you will submit your application in writing to our Companywithin the scope of Article 11 of Data Protection Law are explained below.

In order to use your rights stated above, you can send your request (Atak Domain Hosting Int. ve Bilgi Teknolojileri Ltd. Sti Yenişehir Mah. Arda Sk. No. : 36/1 Izmit - Kocaeli) by hand with documents identifying your ID, or send it via notary or other methods specified in Data Protection Law, or send your request to [email protected] with a secure electronic signature. If you want to receive more detailed information in terms of the information given above, you can reach us at 0090 262 325 92 22, e-mail address [email protected] for detailed information.

Without prejudice to the conditions stipulated in Article 28 of the Law titled Exceptions, your rights that you can use by applying to our Company within the framework of Article 11 of the Law are as follows:
• Learning whether your personal data is being processed or not,
• If your personal data has been processed, to request information regarding this,
• Learning the purpose of processing your personal data and whether they are used appropriately for their purpose,
• To know the third parties in the country or abroad to whom your personal data has been transferred,
• To request correction of your 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 Article 7 of the Law,
• Request notification of the transactions made pursuant to articles (d) and (e) above to third parties to whom your personal data have been transferred,
• Object to the occurrence of a result against you by analyzing your processed data exclusively through automated systems,
• Request compensation of your loss in case you suffer damage due to unlawful processing of your personal data.

We would like to state that we reserve the right to demand the expenses incurred by our company for the fulfillment of your requests according to the tariff specified in Article 13 of the Law concerning "Application to Data Controller."

* Personal Data Protection Law No.6698 entered into force after being published in the Official Gazette dated 7 April 2016 with number 29677.

Complaint Notice - E-Mail: [email protected]
Complaint Notice - Tel: 0090 262 325 92 22
Complaint Notice - Address: Yenişehir Mah. Arda Sk. No:36/1 Izmit - Kocaeli

7. How to Apply for Information?

You can get information about your rights under Article 11 of the Law “ruling the rights of interested parties” and regarding the application process in Article 6, and contact us using the “Personal Data Application Form”.