GENERAL DATA PROTECTIONS REGULATION

Privacy Notice on the Processing of Personal Data

The General Data Protection Regulation (GDPR), officially known as Regulation (EU) 2016/679, was adopted on 27 April 2016 and became enforceable on 25 May 2018. It was designed to harmonize data privacy laws across Europe, protect and empower all EU citizens’ data privacy, and reshape the way organizations across the region approach data privacy. The purpose of GDPR is to set conditions for the processing of personal data, protect the fundamental rights and freedoms of individuals in relation to data processing, and establish obligations for organizations that process personal data.

As Eurosoft Teknoloji Yazılım Anonim Şirketi, we act as a data controller and take necessary measures to ensure the protection of personal data in compliance with GDPR.

Principles of Personal Data Processing

Our Company adheres to the following fundamental principles in the processing of personal data:

Lawfulness, fairness, and transparency – Personal data is processed lawfully, fairly, and transparently.

Purpose limitation – Personal data is collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

Data minimization – Personal data is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

Accuracy – Personal data is accurate and, where necessary, kept up to date.

Storage limitation – Personal data is kept for no longer than is necessary for the purposes for which it is processed.

Integrity and confidentiality – Personal data is processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Methods of Collecting Personal Data

Depending on the services, products, or commercial activities provided by our Company, personal data may be collected through automated or non-automated methods, including but not limited to our offices, branches, business partners, call centers, websites, social media platforms, mobile applications, and in-person interactions.

Additionally, personal data may be processed when individuals contact our customer support center, visit our website, or participate in training sessions, seminars, events, and meetings organized by our Company.

Legal Basis for Collecting Personal Data

Personal data is collected in various forms, including verbal, written, or electronic means, to provide our products and services within the legal framework and to fulfill contractual and legal obligations. The legal bases for processing personal data include compliance with legal obligations, performance of contracts, legitimate interests, consent (where required), and protection of vital interests.

Purposes of Processing Personal Data

Personal data is processed for the following purposes:

Improving our services, developing new services, and informing customers about related updates.

Sending marketing communications to customers and prospective customers who have given consent.

Resolving customer inquiries and complaints.

Managing relationships with business partners and affiliated merchants.

Handling accounting and payment transactions.

Responding to administrative and legal requests from authorities.

Ensuring information security and preventing fraudulent activities.

Maintaining data accuracy and ensuring compliance with applicable regulations.

Transfer of Personal Data

Our Company may share personal data with its business partners, affiliated merchants, banks, financial institutions, independent auditors, payment and securities settlement systems, and electronic money institutions, as permitted by the relevant legislation. Personal data may also be transferred to entities located outside the European Economic Area (EEA) in accordance with GDPR provisions and appropriate safeguards, such as Standard Contractual Clauses (SCCs) or adequacy decisions issued by the European Commission.

We retain personal data in accordance with legal requirements. If an individual requests the deletion of their personal data, such requests will be fulfilled in compliance with applicable laws and retention periods. During this period, personal data will not be processed or shared with third parties except where legally required.

Rights of Data Subjects Under GDPR

Under GDPR, individuals have the following rights regarding their personal data:

The right to be informed about the processing of their personal data.

The right of access to their personal data.

The right to rectification of inaccurate or incomplete data.

The right to erasure (right to be forgotten) under certain conditions.

The right to restrict processing under certain circumstances.

The right to data portability.

The right to object to processing based on legitimate interests.

The right not to be subject to automated decision-making, including profiling.

The right to lodge a complaint with a supervisory authority.

How to Exercise Your Rights

In accordance with Article 12 of GDPR, individuals may submit their requests regarding their rights as follows:

By sending a written request, along with identifying information, to our Company’s registered address: Huzur Mah. Azerbaycan Cad. Skyland Istanbul Sitesi No 4D/1, Apt No: 77, Sariyer/Istanbul. By sending an electronically signed request via email to info@eurosoftkpm.com.

By other methods that may be designated by relevant data protection authorities. Our Company will process such requests free of charge within one month unless an extension is required. If a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act on the request For any questions regarding this Privacy Notice, you may contact us via email at info@eurosoftkpm.com.

This document has been prepared in compliance with GDPR and outlines how Eurosoft Teknoloji Yazılım A.Ş. processes and protects personal data.

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