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Customer Clarification Text on Personal Data Processing

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 Disclosure Obligation. 

As ODC İş Çözümleri Danışmanlık Ticaret A.Ş. (hereinafter referred to as “SmartMessage”)  residing at Fatih Sultan Mehmet Mahallesi Balkan Cad. No: 62 A Ümraniye/İstanbul, we attach importance to the fact that all kinds of personal data are within the scope of the Law on the Protection of Personal Data No. 6698 (“KVK Law”) and that they are processed and stored in accordance with this law. In this context, our Company processes the data of our potential customers, including but not limited to our customers who benefit from our products and services, our employees, interns, employee candidates, shareholders, officials, suppliers, consultants, companies we cooperate with and their employees, shareholders, officials, visitors and persons in contact with our company as “Data Controller”. 


For What Purpose and on What Legal Basis Is Your Personal Data Processed? 

Your personal data specified below (“Data Subject”, “you”, “your”, “your”) is required by SmartMessage for the planning and execution of advertising and marketing campaigns, the planning and execution of SmartMessage’s corporate communication and management activities, the processing of  legal / financial transactions related to the purchase and sale of services, the performance of the contract and (without prejudice to yours) is necessary for our legitimate interest processable. 

  • Identity Information (Name, Surname, T.R./Tax ID number, information on the first page of the ID) 
  • Contact Information (Phone number, Address, E-mail address) 
  • Personal Information (Occupation) 
  • Physical Space Security Information (Entry-exit recording information, Camera image and sound recordings) 
  • Customer Transactions (Voice recording, Price information, Customer comments, Chat records) 
  • Finance Information (Credit Card information, IBAN number information) 

In the absence of the reasons for compliance with the law in Articles 5/2 and 6/3 of the KVKK, the relevant personal data (s) can only be processed based on your explicit consent. We would like to remind you that you have the possibility to withdraw your consent at any time. 

If you give your consent, as SmartMessage, we will process your personal data by sending you promotional, advertising and marketing materials related to our fields of activity and scope of services and e-mails, sms and calls with details of our services in order to ensure that you are aware of our services, activities and events and to participate in the campaigns we organize.  We will also store your personal data in order to be able to periodically send you the materials related to the details of this service and our advertising-marketing materials (such as surveys, market research, satisfaction searches). 

To Whom and For What Purposes Can Personal Data Be Transferred? 

Your personal data, 


  • To the CMS, Authorized Public Institutions and Organizations, which is an Authorized Private Law Legal Person, for the purpose of carrying out the activities in accordance with the legislation within the scope stipulated by the legal regulation, informing the authorized persons, institutions and organizations and carrying out the permission processes  


  • Your personal data collected will be processed by us during your visit to our site based on your explicit consent or during the business / commercial relationship by physical and electronic methods and based on the purposes written herein or your explicit consent, WordPress data located in the USA (in the SmartMesassege databases located in Turkey) and/or abroad (Google’s databases located in Western Europe, Microsoft Azure’s databases in the Netherlands, HubSpot database in Ireland), WordPress data located in the USA are collected at their bases. 


It will be transferred in accordance with the rules in Article 8 of the KVKK regarding the transfer of personal data and the legal reasons for the processing of personal data stipulated in Articles 5 and 6 of the KVKK and by taking the necessary technical and administrative measures. 


Method of Personal Data Collection and Retention Period 

If your personal data is specified in the law or the relevant legislation for the storage of the data, the data in question must be stored for at least this period. If a period of time is not stipulated in the law or related legislation; provided that it is relevant, limited and proportionate to the purposes for which it is processed, it is stored in the manner stipulated in the legal relationship established with you in accordance with your participation in the event, program and/or project and for the period of time required. 


KVKK Article 11. Your Rights Under and How to Contact Us 

We would like to point out that you have the following rights in accordance with Article 11 of the Law on the Protection of Personal Data: 

  • To learn whether your personal data is processed or not, 
  • If your personal data has been processed, to request information about it, 
  • To learn the purpose of processing your personal data and whether they are used in accordance with their purpose, 
  • To know the third parties to whom your personal data is transferred domestically or abroad, 
  • In case your personal data is processed incompletely or incorrectly, to request their correction and to notify third parties that the transaction carried out within this scope is transferred to your personal data, 
  • To request the deletion of your personal data in the event that the reasons requiring processing disappear or if it is requested to be destroyed, despite the fact that your data has been processed in accordance with the relevant provisions of the Law and other regulations, and to request that your personal data transferred in this context be notified to third parties in case of processing, 
  • To object to the occurrence of a result against you by analyzing your processed data exclusively by means of automated systems, 
  • Requesting the compensation of your personal data in case of damage due to unlawful processing. 

How can you exercise your rights as a data subject? 


Application Method 

If you wish to submit your applications and requests regarding your personal data, the Relevant Person Application Form ……………. through; 


  • By having a valid identity document with you that will allow us to verify your identity, personally applying to SmartMessage’s Fatih Sultan Mehmet Mahallesi Balkan Cad. No: 62 A Ümraniye/İstanbul address and physically submitting your application, 
  • By sending it to Fatih Sultan Mehmet Mahallesi Balkan Cad. No: 62 A Ümraniye/İstanbul with a wet signature and a signature declaration (if you have previously submitted a document confirming your signature within the scope of any relationship, you do not need to provide a signature declaration separately) so that we can check your signature, 
  • You can send us a via KEP. 


In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, the relevant person must have the name, surname, signature if the application is in writing, T.R. identity number (nationality, passport number or identity number if the applicant is a foreigner), residential or business address based on the notification, electronic mail address, telephone number and fax number, if any, and information about the subject of the request. 


The person concerned must clearly and comprehensibly state the matter requested in the application containing explanations of the right he / she will make and request to use in order to exercise the above-mentioned rights. Information and documents related to the application must be attached to the application. 


Although the subject of the request must be related to the person of the applicant, if acting on behalf of someone else, the applicant must be specifically authorized in this regard and this authority must be documented (power of attorney). In addition, the application must contain identity and address information and documents confirming identity must be attached to the application. 


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


How Long Does It Take to Respond to Your Requests Regarding the Processing of Your Personal Data? 

Your requests regarding your personal data are evaluated and answered as soon as possible and within 30 days at the latest from the date of receipt by us. If your request is accepted or rejected by explaining the reason, our response will be forwarded to you by the method in which your request is made, especially by mail or electronic mail to the address you specify in the application, if possible.