DISCLOSURE TEXT

ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

FOR CONTRACTS RELATING TO SUPPLIERS/CUSTOMERS

As Innova Bilişim Çözümleri Anonim Şirketi (‘Innova’), we give the necessary care and importance to comply with the Law No. 6698 on the Protection of Personal Data (‘Law’) and we strive to take all the maximum measures. In accordance with the Law, we process your personal data in the capacity of data controller. This Disclosure Text on the Protection and Processing of Personal Data (‘Disclosure Text’) contains our explanations on the purposes of data processing, data categories we collect, the methods and legal bases for collecting data, to whom and for what purposes your personal data can be transferred, the duration of data processing and your rights regarding your data.

1. Which of Your Personal Data are Processed and How?

Innova has the right to process general and special categories of personal data with the explicit consent of the data subject, or without explicit consent in cases stipulated in Articles 5 and 6 of the Law. In this context, Innova may process the following types of personal data in accordance with the terms and conditions set forth in the Disclosure Text. Regarding the contracts concluded with Innova, your personal data below may be processed:

- Name, Surname, Turkish Identity/Tax ID number, Contact Information, Address, Signature,

- Invoice content, Invoice and Order information,

- Your bank account details.

2. What are the Purposes of Processing Your Personal Data by Innova?

The purposes of processing your personal data are limited to the legal bases classified below:

Based on the legal reason that it is clearly stipulated by law and is mandatory for the data controller to fulfil its legal obligations;

- To ensure compliance with the retention obligations stipulated in the legislation,

- Making evaluations regarding your applications submitted to Innova within the scope of exercising your rights specified in Article 11 of the Law regarding your personal data processed by us, finalising them in accordance with the legislation and carrying out the necessary transactions within this framework,

- Providing information to the authorised institutions arising from the legislation and fulfilling the requests of official institutions,

- Ensuring the currency and accuracy of contact information,

- Fulfilment of notification obligations arising from the legislation.

Based on the legal reason that data processing is mandatory for the establishment, exercise or protection of a right;

- Storage of personal data during the general statute of limitations in order to constitute evidence in possible future disputes.

Based on the legal reason that data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject;

- Conclusion of the contract between you and Innova, fulfilment of all kinds of obligations arising from this relationship and establishment of necessary communications,

- Providing support services for sales, orders and similar processes carried out within the scope of the relationship between you and Innova,

- Ensuring the legal, technical, commercial and business security of Innova and the relevant persons who have a business relationship with us,

- Determining and implementing the commercial and business strategies of Innova,

- Follow-up and execution of legal affairs,

- Management of transactions and requests related to the follow-up of financial and sales records,

- Execution of accounting and finance processes,

- Carrying out the necessary work by our relevant business units for the realisation of the commercial activities carried out by Innova, planning business strategies and carrying out related business processes,

- Carrying out audit and ethics activities,

- Receiving, evaluating and finalising your requests and complaints.

 3. To Whom and for What Purpose is Your Personal Data Transferred to?

Within the scope of our legitimate interests, your personal data processed by Innova, limited to the purposes mentioned in this disclosure text and in accordance with Articles 5 and 6 of the Law, may be transferred to Türk Telekomünikasyon Anonim Şirketi and Türk Telekomünikasyon group companies, companies we have authorised, companies operating on behalf and account of our Company and our representatives, our contracted suppliers, banks, credit risk and financial institutions and tax and similar consultants, mandatory persons related to legal follow-up processes, public institutions and organisations and third parties from whom we receive consultancy, including auditors, and business partners, third parties from whom services are received, authorised persons and organisations for the purposes mentioned above.

4. What are Your Rights as a Data Subject?

You can always contact Innova to receive information about the following issues within the scope of the Law;

- To learn whether your personal data is being processed or not,

- To learn the purposes of processing and whether the data processing is in accordance with the purposes,

- To receive information on the third parties to whom your personal data are transferred to,

- To request correction in case of incomplete or incorrect processing and to request the deletion of your personal data if the conditions are met and to request notification of such deletion  to third parties to whom personal data is transferred to,

- To object to the emergence of a result to your detriment if personal data processing is done  exclusively through automated systems,

- To claim damages in case of loss due to unlawful data processing,

- To request the deletion or destruction of your personal data in the event that the purposes requiring its processing cease to exist.

You can send your applications to exercise your data subject rights through the Data Subject Application Form; a notary public or other methods determined by the Personal Data Protection Board, or you can send it to innova@hs03.kep.tr with a secure electronic signature. Your request will be replied to as soon as possible and within thirty (30) days at the latest in accordance with the Law. However, if the transaction requires an additional cost, Innova reserves the right to charge a fee in accordance with the Law over the tariff determined by the Personal Data Protection Board.

Innova Bilişim Çözümleri Anonim Şirketi