This clarification text has been prepared within the scope of Article 10 of the Law on the Protection of Personal Data No. 6698 (“KVKK”) and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Obligation to Inform.
1) Data Controller and Protection of Personal Data
As ODC İş Çözümleri Danışmanlık Ticaret A.Ş (hereinafter referred to as “SmartMessage”) in the capacity of Data Controller, we attach importance to the fact that all kinds of personal data are within the scope of the Personal Data Protection Law No. 6698 (“KVKK”) in the processing and protection of personal data and that they are processed and stored in accordance with this law. In this context, our Company processes the data of our potential customers, employees, interns, employee candidates, shareholders, officials, suppliers, consultants, companies we cooperate with and their employees, shareholders, officials, visitors and people who are in contact with our company, including but not limited to our customers who benefit from our products and services, as “Data Controller”.
2) Our Online Visitors
2.1. Your Processed Personal Data:
Usernames and passwords, IP address and other internet identifiers, Account settings, browser type and versions, time zone and location settings, compatible browser plug-ins, types and versions, operating systems and platform, other technologies on the devices you use to access information about our website and the use of our website, products and services, within the scope of Article 5 of the Law, Rounds 8 and 9 It is processed by automatic or non-automatic means based on the reasons for compliance with the law listed in the provisions of the article and given below.
2.2 Purposes of Processing Your Personal Data:
Our website uses cookies to ensure security by detecting suspicious actions, to increase functionality and performance in line with users’ preferences, to develop and personalize products and services, to facilitate access to these services, and to fulfill contractual and legal responsibilities.
2.3 Legal Reason for Processing Your Personal Data
- Having your explicit consent,
- It is clearly stipulated in the laws,
- Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
- It is mandatory for the fulfillment of the legal obligation,
- It has been made public by the person concerned,
- Data processing is mandatory for the establishment, exercise or protection of a right,
- Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller.
3) Our Physical Visitors
3.1 Your Processed Personal Data:
Within the scope of your visit to our workplace, if there is a request for name, surname, TCKN, telephone, e-mail address, visitor entry and exit registration information, security camera recordings, wireless internet access; Your IP address, internet entry-exit log records can be processed.
3.2 Purpose of Processing Your Personal Data:
- Monitoring with camera recording to ensure security in the campus building,
- Obtaining visitor information in order to keep a report on the entrance and exit of the campus,
- Provision of wireless internet network for guests.
3.3 Legal Reason for Processing Your Personal Data
- It is clearly stipulated in the laws,
- Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract, to provide the requested products and services and to fulfill the requirements of the contracts you have concluded,
- It is mandatory for the fulfillment of the legal obligation,
- It has been made public by the person concerned,
- Data processing is mandatory for the establishment, exercise or protection of a right,
- Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller.
4. Our Suppliers
4.1 Your Processed Personal Data:
- Identity Information (Name-Surname, T.C./TaxID number, Signature, Information on the first page of the ID).
- Contact Information (Phone number, Address, E-mail address, Social media account).
- Information on legal proceedings.
- Financial Information (Bank account information).
- Call center voice recording.
4.2 Purpose of Processing Your Personal Data:
- To be able to carry out promotional and marketing activities,
- To be able to carry out marketing analysis studies,
- To be able to provide communication activities,
- To be able to carry out the proposal processes for services and products,
- To be able to follow up on requests / complaints,
- Fulfillment of legal obligations arising from the legislation, execution of legal, litigation and administrative affairs.
- To be able to carry out storage and archive activities.
4.3 Legal Reason for the Processing of Your Personal Data
- Being clearly stipulated in the laws,
- Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
- It is mandatory for the data controller to fulfill its legal obligation, 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, It has been made public by the data owner,
- Explicit consent.
5. Our Customers/Potential Customers:
5.1 Your Processed Personal Data:
- Credentials. (Name-surname, T.C. identity number, tax number, signature, information on the first page of the identity)
- Contact Information. (Phone number, address, e-mail address)
- Customer Transactions. (Voice recording, price information, customer reviews)
- Customer Transaction Data. (Information such as order and request information, promissory note and check information)
- Visual Recording Data. (Photo info)
- Call center voice recording.
- Professional experience data.
- Financial information. (Credit card information, IBAN number information, bank account information, invoice, debt, collection information)
- Legal Transaction Information. (In case of dispute, case file information, warnings and data contained in judicial/administrative correspondence)
5.2 Purpose of Processing Your Personal Data:
- Execution of service sales processes,
- Execution of after-sales support services,
- Submission of service offerings,
- Execution of contract processes,
- Execution of communication activities
- Sending e-mails or gifts for celebration and congratulations within the scope of customer relationship management
- Carrying out organization and event management activities,
- Execution of travel and accommodation processes,
- Determining the target audience of customers and carrying out marketing activities,
- Execution of finance and accounting processes,
- Execution of advertising, campaign and promotion processes,
- Payroll/budget reporting process,
- Execution of legal processes,
- Providing information to authorized persons, institutions and organizations,
- Execution of storage and archive activities,
- Execution of Contract and Membership Processes,
- Managing claims.
5.3 Legal Reason for the Processing of Your Personal Data
- It is clearly stipulated in the laws,
- Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
- It is mandatory for the data controller to fulfill its legal obligation,
- Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller,
- It has been made public by the data owner,
- Explicit consent.
6. Business Partners
6.1 Your Processed Personal Data:
- Your Identity Information: Name and surname, information on the front of the identity card, TCKN, passport number, tax number, signature,
- Your Contact Information: Address information, e-mail, phone number,
- Your Financial Information: Bank account and card information, invoice and debt information,
- Your Legal Transaction Information: Information in correspondence with judicial authorities, information in the case file,
- Call center voice recordings,
- Your Professional Experience Information: Information on professional competence.
6.2 Purpose of Processing Your Personal Data:
- Execution of goods and services procurement processes,
- Carrying out communication activities,
- Execution of contract processes,
- Carrying out audit activities,
- Fulfillment of legal obligations arising from the legislation,
- Execution of legal, litigation and administrative affairs,
- Execution of accounting processes,
- Providing information to authorized persons, institutions and organizations.
6.3 Legal Reason for Processing Your Personal Data
- It is clearly stipulated in the laws,
- Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
- It is mandatory for the data controller to fulfill its legal obligation,
- Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller,
- It has been made public by the data owner,
- Explicit consent.
7. Switchboard Processes / Call Center Lighting Statement
Your personal data is collected by our Company through fully or partially automatic or non-automatic means, provided that it is a part of any data recording system, electronically through our Company’s switchboard / telephone.
7.1 Your Processed Personal Data:
- Identity Information (Name, Surname, T.C./Tax identification number, information on the first page of the ID)
- Contact Information (Phone number, Address, E-mail address)
- Personal Information (Profession)
- Customer Transactions (Voice recording, Price information, Customer comments, Chat records)
- Financial Information (Credit Card information, IBAN number information)
- Request/Complaint Data
- Legal Transaction Data
- Information you voluntarily provide during interviews
7.2 Purpose of Processing Your Personal Data:
- Execution of Information Security Processes,
- Execution / Supervision of Business Activities,
- Receiving and Evaluating Suggestions for the Improvement of Business Processes,
- Carrying out activities to ensure business continuity,
- Execution of goods / services, production and operation processes,
- Managing Customer Relationship Management Processes,
- Carrying out activities for customer satisfaction,
- Execution of Risk Management Processes, Execution of Storage and Archive Activities, Execution of Contract Processes,
- Follow-up of Requests / Complaints,
- Ensuring the Security of Data Controller Operations,
- Providing information to authorized persons, institutions and organizations,
- Execution of judicial and administrative processes,
- Execution of the legal obligations of the company
- It can be used as evidence in disputes that may arise in the future
Limited to its purposes; It is processed by us fully or partially automatically through the keeping of phone call voice recordings and the notes to be taken by the authorized person you are talking to. Your processed personal data may be shared with official institutions or organizations for the purposes of evidence in legal disputes or to prove the fulfillment of our legal obligations as ODC Business Solutions.
7.3 Legal Reason for Processing Your Personal Data:
- It is clearly stipulated in the laws,
- Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
- It is mandatory for the data controller to fulfill its legal obligation,
- Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller,
- It has been made public by the data owner,
- Explicit consent.
The information contained in the disclosure statement includes the issues applicable to the general processing activities of our company and is provided to the relevant persons separately when necessary or in the case of special disclosure statements depending on the nature of the situation. You can find the employee and candidate employee disclosure texts, the event disclosure statement regarding the transactions to be made over the web, the clarification statement regarding the business partnership processes and the customer clarification statements below.
Employee Clarification Text on the Protection and Processing of Personal Data
Employee Candidate Clarification Text on the Protection and Processing of Personal Data
Clarification Text for Event Participants on the Protection and Processing of Personal Data
Clarification Text for Business Partners on the Protection and Processing of Personal Data
9. Transfer of Personal Data
Your collected personal data may be transferred to legally authorized public institutions and companies with which we cooperate, within the scope of the realization of the above-mentioned purpose, within the conditions and purposes specified in Articles 8 and 9 of the KVKK in order for us to fulfill our legal obligations and benefit from the services we offer. Your collected personal data is collected in databases located at home and/or abroad (Google’s databases in Western Europe, Microsoft Azure’s databases in the Netherlands, HubSpot database in Ireland) based on your explicit consent.
10. Method of Personal Data Collection and Storage Period
Your personal data is collected by us during your visit or during the business / commercial relationship by physical and electronic methods for the purposes written herein or in databases located in the country and/or abroad based on your explicit consent (Google’s databases in Western Europe, Microsoft Azure’s databases in the Netherlands).
Your personal data is stored for the periods stipulated in the relevant legislation or required by the purposes of processing. Your data will be deleted, destroyed or anonymized ex officio or at your request if the legal reasons requiring data processing disappear.
11. The Personal Data Owner is entitled to comply with Article 11 of the Law No. 6698. Rights Listed in Article
As personal data subjects, if you submit your requests regarding your rights through the methods set out below, SmartMessage will finalize the request as soon as possible and within thirty days at the latest, depending on the nature of the request.
In this context, personal data owners;
- To learn whether personal data is processed or not,
- If personal data has been processed, requesting 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 in the country or abroad,
- Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to third parties to whom personal data has been transferred,
- Although it has been processed in accordance with the provisions of Law No. 6698 and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear, and to request the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
- Objecting to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,
- In case of damage due to unlawful processing of personal data, it has the right to demand the compensation of the damage.
In accordance with paragraph 1 of Article 13 of the Law No. 6698 and the Communiqué No. 30356 dated 10.03.2018 on the Procedures and Principles of Application to the Data Controller, you can submit your request regarding the exercise of your above-mentioned rights in Turkish and in writing or by using the registered electronic mail (KEP) address, secure electronic signature or the e-mail address previously notified to SmartMessage and registered in our system. In the applications, only information about the applicant will be given, and it will not be possible to obtain information about other family members and third parties. SmartMessage reserves the right to verify your identity before replying.
In your application;
- Your name, surname and, if the application is in writing, your signature,
- For citizens of the Republic of Turkey, yourC. identity number, if you are a foreigner, your nationality, passport number or identity number, if any,
- Your place of residence or workplace address for notification,
- Your e-mail address, telephone and fax number, if any,
- The subject of your request
It is mandatory to be present and information and documents related to the subject, if any, must be attached to the application.
You can make your applications that you want to make in writing to the address of our Company, which is the data controller, Fatih Sultan Mehmet Mahallesi Balkan Caddesi No: 62/A 34771 Ümraniye-Istanbul by attaching the necessary documents. You can access the application form here .
You can make your applications to the kvkk@smartmessage.com e-mail address you want to make via e-mail . You can make your applications that you want to make through KEP to our KEP address odciscozumleri@hs02.kep.tr.
Depending on the nature of your request, information and documents that will allow identification must be provided to us completely and accurately. If the requested information and documents are not provided properly, there may be disruptions in the full and qualified conduct of the investigations to be carried out by SmartMessage based on your request. In this case, SmartMessage declares that it reserves its legal rights. For this reason, your application must be submitted completely and containing the requested information and documents according to the nature of your request.
References
It will be done free of charge unless a fee schedule is published with the decision to be taken by the Personal Data Protection Board. If the answers to the applications exceed 10 (ten) pages, a processing fee of 1.00 (one) TL will be charged for each page. If the answer is requested to be given in recording media such as CD or flash memory, a fee will be charged according to the cost of the desired recording medium. If you are acting on behalf of someone else in the matter you request, you must be specifically authorized in this regard and your authority must be documented, the application must contain identity and address information, and documents proving your identity must be attached to the application.
This Clarification Text will be valid as of the date it is published by SmartMessage. SmartMessage may amend this Privacy Notice at any time, if necessary. The changes to be made become effective upon the publication of the Clarification Text on the corporate web address of the smartmessage.com.
