narbulut

Personal Data Protection

KVKK

Personal Data Protection

Personal Data Protection
KVKK

KVKK Clarification Text

01

Purpose of the Clarification Text and Our Company's Position as Data Controller

Our company Nar Bulut Bilgi Teknolojileri San. ve Tic. A.Ş. (“Narbulut” and/or “Company”) has the title of “data controller” within the scope of the Law on the Protection of Personal Data No. 6698 (“Law”) in terms of personal data regarding customers, and this Clarification Text aims to inform the relevant customers regarding the personal data processing activities carried out by Narbulut and related issues in accordance with the said Law.

In the following cases where the personal data processing conditions in Articles 5(2) and 6(3) of the Law specify the terms, express consent of the customers must be obtained in order for Narbulut to process personal data. Regarding processes that do not require explicit consent Clarification Text data processing activities are carried out within the scope of the in the Clarification Text is processed in accordance with the stated legal principles.

02

Purpose of Processing Customers' Personal Data

Customers’ personal data is processed by Narbulut for the purposes of conducting necessary work by business units to enable relevant persons to benefit from the products and services offered, and to carry out related business processes. Narbulut performs customer relations management processes, including but not limited to determining target audiences, carrying out activities that increase customer experience for products, conducting promotional and marketing activities, executing direct and indirect marketing, running personalized marketing and remarketing activities, carrying out personalized segmentation, reporting, analysis and research regarding activities, market research, planning and execution of customer satisfaction activities. It can be processed in line with the approval of the Customer and can be processed for these purposes within the scope of planning and execution of the relevant marketing processes of Narbulut’s products and/or services in general, including the purpose of recommending and promoting the products and services offered by Narbulut to the relevant people by considering their viewing, visiting their habits and needs, and planning and execution of customer relationship management processes, and planning and execution of the processes of creating and/or increasing loyalty to the products and/or services offered by Narbulut. As the Clarification Text may be shared with specified parties.

03

Personal Data to Be Processed with Customers' Explicit Consent and Processing Purposes

Personal data to be processed with explicit consent and the processing purposes are specified in the Consent Text.

04

Transfer of Customers' Personal Data

Customers’ personal data may be transferred by Narbulut to the following parties for the purposes of conducting necessary work by business units to enable relevant persons to benefit from the products and services offered, and to carry out related business processes: business partners, suppliers, legally authorized public institutions and organizations, and legally authorized private persons, in accordance with the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, within the framework of the principles and conditions set forth in this Clarification Text. As stated in the Clarification Text, the Customer’s personal data may be shared within the scope of the purposes specified therein.

05

Method and Legal Basis of Collecting Personal Data

Personal data is collected from customers electronically. The personal data collected for the above-mentioned legal reasons is processed and transferred in accordance with the conditions specified in Articles 5 and 6 of the Law, within the scope of this Clarification Text and as required by explicit consent, in accordance with the purposes detailed above in this Clarification Text.

06

Rights of Customers as Data Subjects

Pursuant to Article 11 of the Law, data subjects have the following rights;

  • To learn whether personal data is being processed about them,

  • If personal data has been processed, to request information about it,

  • To learn the purpose of processing personal data and whether they are used in accordance with their purpose,

  • To know the third parties to whom personal data is transferred domestically or abroad,

  • To request correction of personal data if it is incomplete or inaccurately processed,

  • To request deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the Law,

  • To request that the transactions carried out pursuant to the above two items be notified to third parties to whom personal data has been transferred,

  • To object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,

  • To demand compensation for damages in case of loss due to unlawful processing of personal data.

In accordance with Article 13(1) of the Law, the application regarding the exercise of the above-mentioned rights must be submitted to us in writing or by other methods determined by the Personal Data Protection Board. In this context, the application can be delivered to us in person, sent to our e-mail address, or submitted through other methods determined by the Board.

Pursuant to Article 13(2) of the Law, requests included in the application will be concluded free of charge as soon as possible and within thirty days at the latest depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Board may be charged. Personal Data Protection Law Application Form can be accessed via the relevant link.

KVKK

KVKK Explicit Consent Text

01

Explicit Consent Text

Our company Nar Bulut Bilgi Teknolojileri San. ve Tic. A.S. (“Narbulut” and/or “Company”) has the title of “data controller” within the scope of Personal Data Protection Law No. 6698 (“Law”) in terms of personal data regarding customers, and this Consent Text aims to obtain the explicit consent of customers regarding the personal data processing activities carried out by Narbulut and stated below in accordance with the said Law.

In the following cases where the personal data processing conditions in Articles 5/2 and 6/3 of the Law cannot be met, express consent of the customers must be obtained in order for Narbulut to process personal data. Regarding processes that do not require explicit consent Clarification Text Data processing activities are carried out within the scope of In the Clarification Text Data is processed in accordance with the stated basic principles.

In this context, customers’ personal data is collected by Narbulut within the scope of Law No. 6698. In the Policy on Processing and Protection of Personal Data It is processed for the purposes specified under Chapter 3 – Article IV and in accordance with the procedure herein. Accordingly, personal data; creating campaigns for customers, offering special opportunities that Narbulut customers can use for Narbulut by Narbulut business partners, cross-selling, determining the target audience, carrying out activities that increase user experience by tracking customer movements, developing the functioning of Narbulut’s website and mobile application and personalizing it according to customer needs, direct and non-direct marketing, carrying out personalized marketing and remarketing activities, carrying out personalized segmentation, targeting, analysis and in-company reporting activities, market research, planning and execution of customer satisfaction activities, It can be processed in line with the approval of the Customer and can be processed for these purposes within the scope of planning and execution of the sales and marketing processes of Narbulut’s products and/or services in general, including the purposes of recommending and promoting the products and services offered by Narbulut to the relevant people by customizing them according to their tastes, usage habits and needs, and planning and execution of customer relationship management processes, and planning and execution of the processes of creating and/or increasing loyalty to the products and/or services offered by Narbulut. In the Clarification Text may be shared with specified parties.

KVKK APPLICATION

KVKK Application Form

01

Entrance

Personal No. 6698 Personal data owners who are defined as relevant persons in the Data Protection Law (“KVK Law”) (“Hereinafter referred to as “Applicant”) are granted the right to make certain requests regarding the processing of their personal data in accordance with Article 11 of the KVK Law. In accordance with the first paragraph of Article 13 of the KVK Law, applications regarding these rights to our Company, which is the data controller, can be made in writing or to the Personal Data Protection Board. (“Board”) must be forwarded to us by other methods determined by the Company. In this context, applications to be made in writing to our Company can be made by printing this form; system.Below, information specific to written application channels on how written applications will be delivered to us. is given.Application MethodPersonal Application (Must come in person and declare identity) ***1Notification via notary ***2Application AddressDeposite Business and Outlet Center, A1 Blok 325A İkitelli Başakşehir / İstanbulBapplication Information to be Specified Information to be Specified”Information Request within the Scope of the Personal Data Protection Law” will be written on the envelope. ***1″Information Request within the Scope of the Personal Data Protection Law” will be written on the notification envelope. ***2Via Registered Electronic Mail (KEP) with “secure electronicsignature”narbulut@hs02.kep.tr(“Personal Data Protection Law Information Request” will be written in the subject line of the e-mail.)Our Company has previously notified By e–mail from the e-mail address registered in the system–kvkk@narbulut.com(Personal Data Protection Law Information Request” in the subject line of the e-mail )Our Company will be able to request additional information to verify the identity of the Applicant in applications made by e-mail. In addition, after the other methods determined by the Board are announced, our Company will announce how applications will be received through these methods. Your applications submitted to us will be based on the nature of the request, in accordance with the 2nd paragraph of Article 13 of
02

Applicant contact information

A1. For Citizens of the Republic of Türkiye:
Name:  
Surname:  
TR Identification Number:  
Phone and Fax Number:  
E-mail: (If you specify, we will be able to respond to you faster.)
Residence or Workplace Address:  
A2. For Foreigners:
Name:  
Surname:  
Nationality:  
Passport Number /
Identification Number:		 
Phone and Fax Number:  
E-mail: (If you specify, we will be able to respond to you faster.)
Residence or Work Address:  
03

Please indicate your relationship with our Company

(such as customer, business partner, employee candidate, former employee, third-party company employee, shareholder)

☐ Customer☐ Visitor☐ Business partner☐ Other:
The unit you are in contact with within our company:
Subject :
☐ Former Employee          *****Years I Worked:
☐ I Made a Job Application / Resume Sharing          *****Date:
☐ I am a Third Party Company Employee          *****Please specify the company and position information you work for
☐ Other:
04

Please specify your request within the scope of the KVK Law in detail

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05

Please select the method by which you will be notified of our response to your application

☐ I would like it to be sent to my address. ☐ I would like it to be sent to my email address. (If you choose the email method, we can respond to you faster.) ☐ I would like it to be sent to my email address. (In case of receipt by proxy, a notarized power of attorney or authorization document is required) This application form has been prepared to determine your relationship with our Company, to fully identify your personal data processed by our Company, if any, and to respond to your application accurately and within the legal time frame. In order to eliminate legal risks that may arise from unlawful and unfair data sharing and especially to ensure the security of your personal data, our Company reserves the right to request additional documents and information (copy of ID card or driver’s license, etc.) for identity and authorization verification. Our Company does not accept liability for requests arising from incorrect or outdated information regarding your requests submitted within the scope of this form, or from unauthorized applications.Applicant (Personal Data Subject) Full Name : Application Date : Signature :  In the Personal Data Protection Law No. 6698 (“KVK Law”) personal data subjects defined as the relevant person (“Hereinafter referred to as “Applicant” ), Article 11 of the KVK Law grants the right to make certain requests regarding the processing of personal data.In accordance with the first paragraph of Article 13 of the KVK Law; applications regarding these rights to our Company, which is the data controller, can be made in writing or to the Personal Data Protection Board (Board) must be communicated to us through other methods determined by the Board.In this context, written applications to our Company can be made by printing this form; By the Applicant’s personal application, Through a notary, Signed by the Applicant with a secure electronic signature as defined in the Electronic Signature Law No. 5070, to the Company’s registered narbulut@hs02.kep.tr electronic mail address, Via email sent from the Applicant’s email address previously provided to our Company and registered in our Company’s system, can be delivered to us. Below, information is provided about written application channels regarding how written applications should be delivered to us. Application Method   In-Person Application (Must come in person and present identification) ***1 Notification through a notary ***2 Application Address Deposite Business and Outlet Center, A1 Blok 325A İkitelli Başakşehir / İstanbul Information to be Stated in the Application The envelope should be marked “Information Request under the Personal Data Protection Law”. ***1 The notification envelope should be marked “Information Request under the Personal Data Protection Law”. ***2 “Secure electronic signature” signed via Registered Electronic Mail (REM) narbulut@hs02.kep.tr (The email subject should read “Information Request under the Personal Data Protection Law”.) Via email from the email address previously provided to our Company and registered in our system kvkk@narbulut.com (The email subject should read “Information Request under the Personal Data Protection Law”.) Our Company may request additional information and take necessary measures to verify the Applicant’s identity in applications made via email by the Applicant. In addition, after the other methods determined by the Board are announced, our Company will announce how applications will be received through these methods.Your applications submitted to us will be answered within thirty days from the date your request reaches us, based on the nature of the request, in accordance with the 2nd paragraph of Article 13 of the KVK Law. Our responses will be delivered to you in writing or electronically in accordance with Article 13 of the KVK Law. Applicant contact information: A1. For Citizens of the Republic of Türkiye: Name: Surname: TR ID Number: Phone and Fax Number: E-mail: (If you specify, we can respond to you faster.) Residence or Workplace Address: A2. For Foreigners: Name: Surname: Nationality: Passport Number / ID Number: Phone and Fax Number: E-mail: (If you specify, we can respond to you faster.) Residence or Workplace Address: Please indicate your relationship with our Company. (Customer, business partner, employee candidate, former employee, third-party company employee, shareholder, etc.)  ☐ Customer ☐ Visitor ☐ Business Partner ☐ Other: Department you are in contact with in our Company : Subject : ☐ Former Employee          *****Years of Employment : ☐ Job Application / Resume Submitted          *****Date : ☐ Third-Party Company Employee          *****Please specify your company and position ☐ Other: Please specify your request within the scope of the KVK Law in detail: Please select the method by which our response to your application will be communicated to you: ☐ I would like it to be sent to my address. ☐ I would like it to be sent to my email address. (If you choose the email method, we can respond to you faster.) ☐ I would like it to be sent to my email address. (In case of receipt by proxy, a notarized power of attorney or authorization document is required) This application form has been prepared to determine your relationship with our Company, to fully identify your personal data processed by our Company, if any, and to respond to your application accurately and within the legal time frame. In order to eliminate legal risks that may arise from unlawful and unfair data sharing and especially to ensure the security of your personal data, our Company reserves the right to request additional documents and information (copy of ID card or driver’s license, etc.) for identity and authorization verification. Our Company does not accept liability for requests arising from incorrect or outdated information regarding your requests submitted within the scope of this form, or from unauthorized applications. Applicant (Personal Data Subject) Full Name : Application Date : Signature :
KVKK POLICY

KVKK Data Processing Policy

01

Scope of the Law and Our Company's Rights and Obligations Arising from the Law

General Principles Regarding the Processing of Personal Data

Purposes of Personal Data Processing and Sharing within the Scope of the Law

  • Purposes Regarding the Processing of Personal Data

  • Purposes Regarding the Sharing of Personal Data

Section 1. Purpose and Enforcement of the Policy

Law No. 6698 on the Protection of Personal Data (“Law”) entered into force on April 7, 2016. In accordance with this Law on the Protection of Personal Data, Nar Bulut Bilgi Teknolojileri San. ve Tic. A.Ş. holds the title of “Data Controller”.

In this context, this “Personal Data Processing and Protection Policy” has been prepared with the aim of informing individuals whose personal data is processed by our Company (“Data Subjects”).

Section 2. Scope of the Policy

This policy applies to all personal data processing activities carried out wholly or partially by automated means or by non-automated means provided that they are part of a data recording system, regarding real persons whose personal data is processed. Pursuant to Article 28 of the Law on the Protection of Personal Data No. 6698, this Policy does not apply to the processing of personal data by natural persons relating to themselves or their family members living in the same residence, provided that it is not disclosed to third parties and that data security obligations are complied with; to the processing of personal data for purposes such as research, planning, statistics and the like by anonymizing personal data for official statistics; to the processing of personal data for artistic, historical, literary or scientific purposes or within the scope of freedom of expression, provided that national defense, national security, public safety, public order, economic security, right to privacy or personal rights are not violated or that no crime is committed; to the processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to ensure national defense, national security, public safety, public order or economic security; and to the processing of personal data by judicial authorities or enforcement authorities in connection with investigation, prosecution, trial or execution proceedings.

02

Processing of Personal Data by Our Company

Categorization of Personal Data Processed by Our Company

Within the scope of the activities of our Company, categories of personal data regarding the following data subject groups are processed:

  • Identity information

  • Contact information

  • Customer transaction information

  • Financial information

  • Physical space security information

  • Transaction security information

  • Legal transaction information

  • Customer complaint and request management information

Purposes of Processing Personal Data by Our Company

Personal data is processed by our Company within the framework of the following purposes:

  • Execution of human resources processes

  • Performance of activities in accordance with legislation

  • Execution of finance and accounting processes

  • Ensuring physical space security

  • Follow-up of legal affairs

  • Execution of goods/service procurement processes

  • Execution of goods/service sales processes

  • Execution of business continuity activities

  • Execution of logistics activities

  • Management of communication activities

Transfer of Personal Data by Our Company and Parties to Whom Data Transfer is Made

Our Company may transfer personal data to third parties in Turkey and abroad for the purposes stated above, in compliance with the conditions and purposes of personal data processing set forth in Articles 8 and 9 of the Law.

03

Rights of Data Subjects Arising from the Law

Rights of Data Subjects

Pursuant to Article 11 of the Law, everyone has the right to apply to the data controller and;

  • Learn whether personal data is being processed,

  • Request information if personal data has been processed,

  • Learn the purpose of processing personal data and whether they are used in accordance with their purpose,

  • Know the third parties to whom personal data is transferred domestically or abroad,

  • Request correction of personal data if it is incomplete or inaccurately processed,

  • Request deletion or destruction of personal data within the framework of Article 7,

  • Request notification of transactions carried out to third parties to whom personal data has been transferred,

  • Object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,

  • Demand compensation for damages in case of loss due to unlawful processing of personal data.

Exercise of Rights

Section 1. Purpose and Enforcement of the Policy

Law No. 6698 on the Protection of Personal Data (“Law”) entered into force on April 7, 2016. In accordance with this Law, Nar Bulut Bilgi Teknolojileri Sanayi ve Ticaret Anonim Şirketi, acting as the Data Controller, presents the following policy regarding the processing and protection of personal data.

Applications regarding the exercise of rights must be submitted to us in writing or by other methods determined by the Personal Data Protection Board (“Board”). In this context, applications may be delivered in person to our Company address, sent via registered mail, or submitted through the “Personal Data Protection Law Information Request” form.

KVKK CLARIFICATION TEXT

For Candidates Applying for Jobs

KVKK Clarification Text

01

Personal Data

 

In accordance with the Law on the Protection of Personal Data No. 6698 (“Law”), the candidate’s name/surname, place/date of birth, telephone number, contact information, marital status, criminal record, education status, educational information, work experiences, foreign language knowledge, seminars, conferences and certificate programs attended, references and all data identifying the relevant person, including but not limited to the candidate’s evaluation of the candidate by the relevant unit. All kinds of information and documents, such as notes, are within the scope of personal data.

Your personal data mentioned above; It may be processed by “Narbulut Bilgi Teknolojileri Sanayi Ve Ticaret Anonim Sirketi (hereinafter referred to as NARBULUT) as the “Data Controller” in accordance with the descriptions explained below.

 

02

For what purpose will personal data be processed?

 

Your personal data;

  • Evaluating your job application request and suitability for the relevant position,
  • Executing and finalizing the recruitment process
  • Submitting the application form and job interview invitations
  • Planning the human resources processes and improving the recruitment process
  • In case the result is negative, your application will be evaluated for similar or other positions in the future and in this context, you will be contacted. will be processed.

 

03

To whom and for what purpose the processed personal data can be transferred

 

Your personal data may be shared with the authorities legally authorized to request personal data in order to fulfill their legal obligations and the purposes specified in this Clarification Text, the personal data transfer provisions of the Law, and third party real and legal persons with whom we are affiliated at home or abroad, service provider companies and their officials, our business partners and our Company shareholders, our group companies, through third party cookies (e.g. Google cookies), provided that they are limited to the reasons and purposes stated in our Cookie Policy. and can be transferred abroad, limited to the data that these cookies can access.

 

04

Method and Legal Reason for Collecting Personal Data

 

Within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, your personal data is collected in the physical environment by voice, written, visual or electronic methods, including electronic media such as keeping log records, e-documents uploaded to the internet system, e-mail, based on your explicit consent and the legal reason that data processing is mandatory for the establishment, exercise or protection of a right.

 

05

Data Owner's Rights Listed in Article 11 of the Law

 

According to Article 11 of the Law; The data owner can apply to NARBULUT using the methods determined by the Personal Data Protection Board; Knowing,

  • Requesting correction of personal data if they have been processed incompletely or incorrectly and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,
  • Requesting the deletion or destruction of personal data in case the reasons requiring processing are eliminated, even though it has been processed in accordance with the law and other relevant legal provisions, and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,
  • Objecting to the emergence of a result against the person by analyzing the processed data exclusively through automatic systems.
  • In case of damage due to the unlawful processing of personal data, they have the right to demand compensation for the damage.

    • In order to exercise your rights stated above, you must submit your request in writing to NARBULUT, including the necessary information and documents to identify your identity and an explanation of the right you wish to exercise among the rights specified in Article 11 of the Law. You must send it to the e-mail address href=”mailto:kvkk@narbulut.com”>kvkk@narbulut.com. Your requests will be concluded by NARBULUT as soon as possible depending on the nature of the request. If the transaction upon your request requires a cost, NARBULUT may charge a fee within the scope of the tariff determined by the Personal Data Protection Board.

     

    06

    Storage Period, Destruction and Deletion of Personal Data

     

    • The purpose requiring processing or storage has disappeared,
    • Withdrawing the explicit consent given by the data owner,
    • The data owner has a request subsequently conveyed to NARBULUT,
    • The data controller is obliged to do so due to legal obligation, court or request of the Personal Data Protection Authority,
    • The maximum period requiring the storage of personal data has passed and it is justified to keep personal data for a longer period of time. If there are no conditions that make it possible, your personal data will be deleted, destroyed or anonymized.
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