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REGARDING THE PROCESSING OF PERSONAL DATA CLARIFICATION TEXT

Data Controller:

INNERLIB YAZILIM ARAŞTIRMA DANIŞMANLIK SANAYİ VE TİCARET LİMİTED ŞİRKETİ (Company)

Kuriş Tower, No:2, Interior Door No:31, Cevizli D-100 South Side Road, Cevizli, Kartal, Istanbul, Turkey

This Clarification Text on the Processing of Personal Data (“Text”) explains how we process your personal data when you visit our website, if you are logged in as a user, in connection with INNERLIB Services provided to you as described in our user agreement (collectively, “Services”).

As INNERLIB YAZILIM ARAŞTIRMA DANIŞMANLIK SANAYİ VE TİCARET LİMİTED ŞİRKETİ (Company), we have prepared this clarification text in order to inform you about the processing of your personal data, as we attach importance to the security of your personal data that we process in the capacity of data controller defined in the Personal Data Protection Law No. 6698 (“KVKK”).

Purpose and Legal Reason for Processing Your Personal Data

Your personal data is processed in accordance with the Law No. 6698 on the Protection of Personal Data and secondary regulations within the framework of the following purposes and legal reasons:

INNERLIB processes the categories of personal data described below. Which data is collected may vary depending on which parts of the Services you use.

Account Creation Data:

- Username,

- Contact information (e-mail address),

- IP address,

- Subscription type,

- Technical information (such as time logs linked to account creation).

Usage Data:

- Data about your app and website usage (search history, content you create, etc.),

- Online identifiers (technical data such as advertising ID, device and platform versions, language settings, URL details and browser type).

Payment Data:

- Depending on the payment method selected, information such as purchase history and the sending history of the payment earned.

Cookie Data:

- It may be used to facilitate your access to the website and to remember your settings.

  1. In this context, your personal data is processed by the Company for the purposes of providing, developing and improving services (diversification of content), securing services (implementing technical and administrative measures for security and fraud prevention purposes), conducting communication activities, conducting / supervising user activities, conducting business continuity activities, conducting activities in accordance with the legislation, conducting user content processes, conducting contract processes and following up requests / complaints.

  2. Your communication and customer transaction data processed on a process-specific basis will be processed based on the legal grounds of “It is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract” and subparagraph (f) “It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.” in accordance with subparagraph (c) of paragraph 2 of Article 5 of the KVKK.

  3. Your transaction security data will be processed based on the legal grounds of subparagraph (a) of paragraph 2 of Article 5 of the KVKK “It is clearly stipulated in the laws” and subparagraph (ç) “It is mandatory for the data controller to fulfill its legal obligation.”.

  4. Innerlib does not directly request sensitive personal data from data subjects. The data subjects do not include their sensitive personal data in the “User Registration” voluntarily or on their own initiative. Innerlib processes the special categories of personal data of the data subjects transmitted in the aforementioned manner, provided that it is related to the subject of the request and limited to this purpose, within the scope of the legal reason “the explicit consent of the data subject” in Article 6/2 of the Law. It will be deemed that you have obtained the personal data of third party data subjects in accordance with the law and transferred them to us and that you have informed the data subjects about the processing of these data.

Transfer of Personal Data

Your personal data,

To Authorized Public Institutions and Organizations for the purposes of providing information to authorized public institutions and organizations and conducting activities in accordance with the legislation, to our Suppliers and Business Partners for the purposes of conducting communication activities, conducting/supervising business activities, conducting activities to ensure business continuity, conducting activities in accordance with the legislation, conducting contract processes and following up requests/complaints,

It may be transferred in accordance with Article 8 of the KVKK.

Your Rights Regarding Your Personal Data

Regarding your personal data;

  1. Learn whether your personal data is being processed,

  2. Request information if your personal data has been processed,

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

  4. To know the third parties in Turkey or abroad to whom your personal data is transferred,

  5. To request correction of your personal data in case of incomplete or incorrect processing,

  6. To request the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK legislation,

  7. When you request the correction of incomplete or inaccurate data and the deletion or destruction of your personal data, to request that this situation be notified to third parties to whom we transfer your personal data,

  8. To object to the occurrence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems and

  9. If you suffer damage due to unlawful processing of personal data, you have the right to demand compensation for this damage.

How Can You Exercise Your Rights?

You can submit your applications and requests regarding your personal data through the Data Subject Application Form;

By sending your applications and requests with wet signature and documents certifying your identity to “Kuriş Tower, No:2, Interior Door No:31, Cevizli D-100 South Side Road, Cevizli, Kartal, Istanbul, Turkey”, by sending it to Innerlib Yazılım Araştırma Danışmanlık Sanayi ve Ticaret Limited Şirketi, by personally applying to Innerlib Yazılım Araştırma Danışmanlık Sanayi ve Ticaret Limited Şirketi with a valid identity document, by signing with mobile signature or secure electronic signature and sending an e-mail to info@ınnerlib.com.

Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, the application of the Data Subject must include the name, surname, signature if the application is in writing, Turkish ID number (if the applicant is a foreigner, his/her nationality, passport number or ID number, if any), residential or workplace address for notification, e-mail address for notification, telephone number and fax number, and information on the subject of the request.

The Relevant Person must clearly and comprehensibly state the matter requested in the application, which will be made to exercise the above-mentioned rights and includes explanations regarding the right it requests to exercise. Information and documents regarding the application must be attached to the application.

Although the subject of the request must be related to the applicant's person, if acting on behalf of someone else, the applicant must be authorized and this authorization must be documented (power of attorney).

If the application is within the scope of sensitive data, the applicant must be specifically authorized in accordance with Article 10 of the Regulation on Personal Health Data. In addition, the application must include identity and address information and identity-verifying documents must be attached to the application.

Requests made by unauthorized third parties on behalf of someone else will not be evaluated.

How long will your requests regarding the processing of your personal data be answered?

Your requests regarding your personal data will be evaluated and answered within 30 days at the latest from the date of receipt. If your application is evaluated negatively, justified reasons for rejection will be sent to the address you specified in the application by e-mail or postal mail, especially by one of the methods selected in the Relevant Person Application Form.