Personal Data Protection – “Website Visitor (Internet)” Clarification Text
As the Data Controller, DATASURGERY Software and Consulting Inc. (“Traick”) processes your personal data in accordance with the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and other applicable legislation.
Pursuant to Article 10 of the KVKK, data controllers are required to inform data subjects regarding the processing of their personal data.
This Clarification Text has been prepared in accordance with the Communiqué on the Principles and Procedures to be Followed in Fulfilling the Obligation to Inform, published by the Turkish Personal Data Protection Authority, in order to fulfill our statutory obligation to inform data subjects.
Definitions
For the purposes of this Clarification Text, the following terms shall have the meanings assigned to them under the Turkish Personal Data Protection Law No. 6698 (“KVKK”):
- Personal Data means any information relating to an identified or identifiable natural person.
- Processing of Personal Data means any operation performed on personal data, wholly or partly by automated means or by non-automated means provided that they form part of a data recording system, including but not limited to collection, recording, storage, retention, alteration, reorganization, disclosure, transfer, acquisition, making available, classification or restriction of personal data.
- Data Subject means the natural person whose personal data is processed.
- Data Controller means the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.
- Obligation to Inform means the obligation of the data controller, or any person authorized by the data controller, to inform the data subject regarding: the identity of the data controller, the purposes for processing personal data, the recipients to whom personal data may be transferred and the purposes of such transfers, the method and legal basis for collecting personal data and the rights of the data subject under Article 11 of the KVKK.
Data Subject
As your personal data are processed by Traick in connection with your visit to our Website, you are regarded as a Website Visitor and are considered a Data Subject under the Turkish Personal Data Protection Law.
Data Controller
With respect to your personal data, DATASURGERY Software and Consulting Inc. (“Traick”) acts as the Data Controller, determining the purposes and means of processing your personal data and being responsible for the establishment and management of the relevant data recording systems.
Collection of Personal Data
Your personal data may be collected directly from you through electronic means using both automated and non-automated methods.
- Automated methods: Transaction Security Information (IP Address, Connection Date and Time, Session Termination Time).
- Non-automated methods: Identity Information (First Name, Last Name) and Contact Information collected when you complete the contact form; E-mail Address, Subject of your inquiry and Message Content.
The same categories of personal data may be collected through more than one collection method where applicable.
Purposes and Legal Grounds for Processing Your Personal Data
Pursuant to Article 5/2(c) of the KVKK, where processing is necessary for the establishment or performance of a contract, your personal data are processed for the following purposes: establishing and managing potential business relationships, conducting contractual processes and maintaining communication between the parties. For these purposes, the following personal data may be processed: First Name, Last Name, E-mail Address, Subject of Communication and Message Content.
Pursuant to Article 5/2(f) of the KVKK, where processing is necessary for the legitimate interests of the Data Controller, provided that such processing does not violate the fundamental rights and freedoms of the data subject, your personal data may be processed for the following purposes: ensuring the security of our Website, preventing unauthorized access and fraudulent activities, providing technical support services, monitoring and improving system performance, managing information security processes, fulfilling our legal obligations and establishing evidence in the event of legal disputes. For these purposes, the following categories of personal data may be processed: Transaction Security Information, IP Address, Connection Time, Session End Time, Log Records and Cookies.
In accordance with Article 7/2 of the Law on the Regulation of Publications on the Internet and Combating Crimes Committed through Such Publications (Law No. 5651), your personal data may also be processed for fulfilling statutory record retention obligations and carrying out archive and storage activities required under applicable legislation.
Transfer of Personal Data
Where required under Article 28(1) of the KVKK, your personal data may be disclosed to competent public authorities without your explicit consent and without the obligation to provide prior notice.
In addition, where expressly required by law or upon the lawful request of competent public authorities, your personal data may be transferred to authorized governmental institutions, including ministries and other administrative authorities, strictly within the limits prescribed by applicable legislation.
Your personal data may also be transferred, to the extent necessary for the processing purposes and subject to appropriate technical and organizational safeguards, to recipients located within Türkiye or abroad in accordance with the KVKK and other applicable legislation. Such recipients may include: cloud service providers, information technology service providers, hosting service providers, business partners, providers of technical support services, legally authorized public authorities and legally authorized private entities where required by law.
All international and domestic data transfers are carried out in accordance with Article 9 of the KVKK, based on the applicable legal transfer mechanisms and appropriate technical and administrative security measures.
Your Rights
Under Article 11 of the Turkish Personal Data Protection Law No. 6698, you have the right to:
- learn whether your personal data is being processed;
- request information regarding the processing of your personal data;
- learn the purposes for which your personal data is processed and whether they are used accordingly;
- learn the third parties to whom your personal data have been transferred, whether within Türkiye or abroad;
- request the correction of inaccurate or incomplete personal data;
- request the deletion or destruction of your personal data where the legal conditions are met;
- request that the actions taken regarding correction, deletion or destruction be notified to the third parties to whom your personal data have been transferred;
- object to any outcome arising against you because of the exclusive processing of your personal data through automated systems; and
- request compensation for damages arising from unlawful processing of your personal data.
In accordance with the KVKK, requests relating to these rights must first be submitted to the Data Controller before an application may be made to the Turkish Personal Data Protection Board.
Method of Contact to Data Controller
You may submit your requests regarding your personal data by using one of the following methods:
- By Registered Mail or Written Application: DATASURGERY Software and Consulting Inc., Ahmet Yesevi Mah. Kerem Sk. No: 9, A-Block, Office No: 404-13, Pendik, Istanbul, Türkiye
- By Registered Electronic Mail (KEP): datasurgeryas@hs01.kep.tr
- By E-mail: info@traick.ai
Further information regarding the procedures and principles for submitting applications to the Data Controller can be found in the Communiqué on the Procedures and Principles of Application to the Data Controller published by the Turkish Personal Data Protection Authority.
DATASURGERY Software and Consulting Inc.