1. Information as Data Controller

As Harju maakond, Kuusalu vald, Pudisoo kula, Männimäe, 74626 ESTONYA (“Advist”), we show maximum sensitivity to the security of your personal data. Your personal data is processed and stored in accordance with the Law on Protection of Personal Data No. 6698 (hereinafter referred to as “KVKK”). KVKK was published in the Official Gazette dated 7 April 2016 and numbered 29677. The relevant law is regulated to protect the fundamental rights and freedoms of real persons, including the privacy of private life, which is also protected by our Constitution and Turkish Penal Codes, and to determine the obligations of natural and legal persons who process personal data.

The purpose of arranging our personal data protection and processing policy (“KVK Policy”) is to create management instructions and procedural conditions for Advist to ensure that personal data is processed and protected in accordance with KVKK.

In accordance with KVKK, your personal data; It will be collected and processed within the scope described below by us as the data controller. As Advist, in accordance with the KVKK and in the capacity of Data Controller, your personal data is within the framework explained on this page; recorded, stored, updated, where permitted by law 3. may be disclosed/transferred to persons, classified and processed in the ways listed in KVKK.

1. Definitions

1. Processing of Personal Data

In accordance with the KVKK, your personal data that you share with Advist may be processed by us, in whole or in part, automatically or by non-automatic means provided that it is a part of any data recording system, by recording, storing, changing, rearranging, in short, as the subject of any transaction performed on the data. All kinds of operations performed on data within the scope of KVKK are considered as “processing of personal data”.

Advist will be able to collect and process the personal data collected through web pages, events, trainings or the portal in general for the following purposes:

• Collecting personal information in order to interact on web pages, events, trainings or portal,
• To provide personalized services to our users,
• To communicate with users, to inform them about services and opportunities,
• To perform the services we offer in accordance with the contracts,
• Sending newsletters or making promotions or notifications by e-mail,
• Making promotions or notifications via SMS,
• Answering incoming calls and responding to your support needs,
• Developing our current and R&D applications and creating the management process,
• Concluding the complaint in line with your request or in case of complaints on social media or if there is a complaint about the services we provide,
• We collect and process your data for use in various statistical evaluations, database creation and market research without revealing the identity of the user.

4. To Whom Personal Data Can Be Transferred And For What Purpose

By accepting the Personal Data Protection Policy, your personal data, for which you have given your explicit consent to be shared with Advis and its domestic and foreign business partners and platform users within the scope of Advist applications and services, can be collected, stored, processed, used, abroad or abroad. You have consented to the transfer with third parties with whom we have a contractual relationship, who have the same legal and technical responsibilities as us regarding data protection and security, and who comply with the provisions of the relevant legislation.

Your data regarding your Advis website visit or application, and your traffic information, such as your navigation information; legally authorized to request such information for your safety and for Advist’s performance of its obligations under the law (in cases where Advist has a legal or administrative obligation to notify or provide information such as, but not limited to, the fight against crime and the threat to state and public safety). can be shared with public institutions and organizations.

5. Method and Legal Reasons for Personal Data Collection

In accordance with the KVKK, your personal data that you share with Advist may be processed by us, in whole or in part, automatically or by non-automatic means provided that it is a part of any data recording system, by recording, storing, changing, rearranging, in short, as the subject of any transaction performed on the data. Your personal data may be collected when you purchase services or products from Advist, when you attend trainings, events, when you use Advist services, when you log in/apply to advertisements or marketing announcements, when you become a member or register, and in written/physical or electronic environment with cookies.

6. Personal Data Retention and Disposal Policy

6.1. Aim

Advist undertakes to comply with KVKK, relevant regulations and other personal data protection, processing and destruction regulations. Advist is subject to the deletion, destruction or anonymization of personal data, as well as in the 7th article of the KVKK. and the regulation on the deletion, destruction or anonymization of personal data dated 28 October 2017 and numbered 30224.

6.2. Definitions

Destruction: Deletion, destruction or anonymization of personal data.

Recording Media: Any environment where personal data is processed wholly or partially automatically or non-automatically provided that it is a part of any data recording system.

Anonymization of Personal Data: Making personal data incapable of being associated with an identified or identifiable natural person in any way, even by matching with other data.

Deletion of Personal Data: Deletion of personal data; making personal data inaccessible and unusable for Relevant Users in any way.

Destruction of Personal Data: The process of making personal data inaccessible, unrecoverable and unusable by anyone in any way.

Periodic Destruction: The deletion, destruction or anonymization process that will be carried out ex officio at repetitive intervals and specified in the personal data storage and destruction policy, in case all the conditions for processing personal data in the Law are no longer valid.

6.3. Scope and Recording Media

Your personal data, during the storage periods specified in the relevant legal regulations, during the period required by the processing purposes if no period is determined in the relevant legal regulations, personal data obtained during the process of registering with Advist or using the services of Advist, within the scope of our personal data inventory and the obligations specified in the KVKK legislation. are stored and then deleted, destroyed or anonymized in accordance with KVKK.

Our recording environments regarding personal data are as follows.

6.4. Legal and Technical Basis for Storage of Personal Data

Advist, 7th of KVKK. Article 138 of the Turkish Penal Code. It retains the personal data it processes pursuant to the article only for the period required by the personal data processing purpose, if it is stipulated in the relevant legislation or if a period is not stipulated in the legislation. If the purpose of processing personal data has expired or the storage period has come to an end, personal data will be stored only to the extent required and required by possible law.

Personal data that has been processed in accordance with the provisions of the KVKK and other relevant laws must be deleted, destroyed or anonymized by Advist ex officio or upon the request of the person concerned, in such a way that it cannot be used or retrieved in any way. The procedures and principles regarding the destruction or anonymization of personal data in accordance with the law will be fulfilled in accordance with the principles and rules set forth in the regulation.

6.5. Storage and Disposal Periods of Personal Data

7. Technical and Administrative Measures Regarding Personal Data

12. KVKK. In accordance with the article, Advist’s obligations regarding data security in its capacity as data controller;

• Personal data;
• To prevent illegal processing,
• To prevent illegal access,
• To take all kinds of technical and administrative measures to ensure its preservation,
• It is in the form of making or having the necessary audits done within the organization.

Advist pays attention to data processing and tax security in accordance with the above obligations. Personal data of employees of Advist 3. takes the necessary measures to prevent sharing it with other persons, and otherwise notifies the relevant person and the Board.

at Advist ;

• Network security and application security are provided.
• A closed system network is used for personal data transfers via the network.
• Key management is implemented.
• Security measures are taken within the scope of procurement, development and maintenance of information technology systems.
• The security of personal data stored in the cloud is ensured.
• There are disciplinary regulations that include data security provisions for employees.
• Training and awareness activities are carried out periodically for employees on data security.
• An authorization matrix has been created for employees.
• Access logs are kept regularly.
• Institutional policies on access, information security, use, storage and destruction have been prepared and started to be implemented.
• Data masking is applied when necessary.
• Confidentiality commitments are made.
• The authorizations of employees who have a change of job or quit their job in this field are removed.
• Current anti-virus systems are used.
• Firewalls are used.
• The signed contracts contain data security provisions.
• Extra security measures are taken for personal data transferred via paper and the relevant document is sent in confidential document format.
• Personal data security policies and procedures have been determined.
• Personal data security issues are reported quickly.
• Personal data security is monitored.
• Necessary security measures are taken regarding entry and exit to physical environments containing personal data.
• The security of physical environments containing personal data against external risks (fire, flood, etc.) is ensured.
• The security of environments containing personal data is ensured.
• Personal data is reduced as much as possible.
• Personal data is backed up and the security of the backed up personal data is also ensured.
• User account management and authorization control system is implemented and these are also followed.
• In-house periodic and/or random audits are conducted and made.
• Log records are kept without user intervention.
• Existing risks and threats have been identified.
• Protocols and procedures for special quality personal data security have been determined and implemented.
• If sensitive personal data is to be sent via e-mail, it must be sent in encrypted form and using a KEP or corporate mail account.
• Secure encryption / cryptographic keys are used for sensitive personal data and are managed by different units.
• Intrusion detection and prevention systems are used.
• Penetration test is applied.
• Cyber security measures have been taken and their implementation is constantly monitored.
• Encryption is done.
• Personal data transferred in portable memory, CD and DVD media are encrypted and transferred.
• Data processing service providers are periodically audited on data security.
• Awareness of data processing service providers on data security is ensured.
• Data loss prevention software is used.

Advist takes all the technical and administrative measures specified in the law, board resolutions and guidelines to prevent unlawful access to personal data, and all technical and administrative measures regarding cyber attacks on personal data of third parties. Advist monitors the security of the data inventory, system and software security that it creates in accordance with the legislation, and reports to the authorized person or to the board if requested, and ensures the protection of personal data as stipulated in the legislation.

8. Rights of the Relevant Person

KVKK No. 6698 11. The article entered into force on 07 October 2016, and in accordance with the relevant article, the rights of the Relevant Person after this date are as follows:

Relevant Person, by applying to Advist.com;

1. Learning whether personal data is processed or not,
2. If personal data has been processed, requesting information about it,
3. Learning the purpose of processing personal data and whether they are used in accordance with the purpose,
4. Knowing the third parties to whom personal data is transferred at home or abroad,
5. Requesting correction of personal data in case of incomplete or incorrect processing,
6. 7 of the KVKK. Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in the article,
7. In case of correction, deletion or destruction of personal data, requesting the notification of these transactions to the third parties to whom the personal data has been transferred,
8. Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
9. It has the right to demand the compensation of the damage in case of loss due to the unlawful processing of personal data.
10. Application and Application Method to the Data Controller

As a data controller, Ortabayır Mahallesi Şair Çelebi Sk. Gürtaş Business Center Apt. No: 1/3 Kağıthane/İstanbul, Advist.com respects the rights of you, valuable data owners, and tries to help you fulfill your requests in your application. 11 of KVKK. The right to apply to our company with this form prepared in accordance with the article, belongs directly to the personal data owner. In applications to be made on behalf of third parties, a power of attorney must be available to represent the relevant person.

13 of KVKK. In accordance with the first paragraph of the article; Applications regarding these rights to our company, which is the data controller, must be submitted to us in writing or by other methods determined by the Personal Data Protection Board (“Board”).

We will respond to your application within 30 (thirty) days at the latest, after you fill out and sign the KVK Application Form (“KVK Application Form”) on Advist completely and clearly and send it to our address below by hand or by registered mail. Applications to be made regarding this issue must be submitted in writing via this Personal Data Owner Application Form or by other methods determined by the Personal Data Protection Board (“Board”).

In this context, applications to be made to our company in “written” form, by printing out this form;

• With the personal application of the applicant,
• through a notary,
• It can be forwarded to us by sending it to our Company’s registered e-mail address, signed by the applicant with the “secure electronic signature” defined in the Electronic Signature Law No. 5070.

Our Company Information

Company : EDULEGAL OÜ

Address : Harju maakond, Kuusalu vald, Pudisoo küla, Männimäe,74626 ESTONIA

Organization No: 14555486

Email Address: [email protected]

Web Page : advist.com

Phone : +372 5849 3516

10. Force

This Policy enters into force on the date of its publication and remains in effect until it is removed from the website. Our Website Personal Data Protection and Data Policy is dated 29.06.2020. In case of renewal of all or certain articles of the Policy, the effective date of the Policy will be updated.

ADVIST.COM
REGARDING THE PROCESSING AND PROTECTION OF PERSONAL DATA
LIGHTING TEXT

1. Information as Data Controller

As Edulegal OÜ (“Advist”), we show maximum sensitivity to the security of your personal data. Your personal data is processed and stored in accordance with the Law on Protection of Personal Data No. 6698 (hereinafter referred to as “KVKK”). KVKK was published in the Official Gazette dated 7 April 2016 and numbered 29677. The relevant law is regulated to protect the fundamental rights and freedoms of real persons, including the privacy of private life, which is also protected by our Constitution and Turkish Penal Codes, and to determine the obligations of natural and legal persons who process personal data.
The purpose of arranging our personal data protection and processing policy (“KVK Policy”) is to create management instructions and procedural conditions for Advist to ensure that personal data is processed and protected in accordance with KVKK.
In accordance with KVKK, your personal data; It will be collected and processed within the scope described below by us as the data controller. As Advist, in accordance with the KVKK and in the capacity of Data Controller, your personal data is within the framework explained on this page; recorded, stored, updated, where permitted by law 3. may be disclosed/transferred to persons, classified and processed in the ways listed in KVKK.

Definitions

1. WHICH BASES ARE YOUR PERSONAL DATA PROCESSING?

4 of KVKK. and 10. Personal data categories, data types and bases processed in accordance with Articles of Association are listed in the table below.

In accordance with the KVKK, your personal data that you share with Advist may be processed by us, in whole or in part, automatically or by non-automatic means provided that it is a part of any data recording system, by recording, storing, changing, rearranging, in short, as the subject of any transaction performed on the data. Your personal data may be collected when you buy products or services from Advist, when you attend trainings, events, when you use Advist services, when you log in/apply to advertising or marketing announcements, when you become a member or register, and in written/physical or electronic environment with cookies.

In the capacity of Advist data controller and taking all necessary technical and administrative measures, your personal data;

The Constitution of the Republic of Turkey, international conventions to which our country is a party, and the Law on the Protection of Personal Data No. 6698 (“KVKK”), within the framework of all legislation regarding the protection of personal data, in accordance with the 4th Law of the KVKK. contained in the article;

• Compliance with the law and the rules of honesty,
• Being accurate and up-to-date when necessary,
• Processing for specific, explicit and legitimate purposes,
• Being connected, limited and restrained with the purposes of processing,
• It will operate in accordance with the principles of storage for the period required by the relevant legislation or for the purpose for which they are processed.

1. METHOD OF COLLECTION OF PERSONAL DATA AND LEGAL REASONS FOR THE COLLECTION

In accordance with the KVKK, your personal data that you share with Advist may be processed by us, in whole or in part, automatically or by non-automatic means provided that it is a part of any data recording system, by recording, storing, changing, rearranging, in short, as the subject of any transaction performed on the data. All kinds of operations performed on data within the scope of KVKK are considered as “processing of personal data”.

Advist will be able to collect and process the data of its users through web pages and calls in general for the following purposes:

• Collecting personal information in order to enable interaction through our website,
• To provide personalized services to our users and to increase user satisfaction by making the user experience better,
• To contact our users to the extent permitted by us, to inform them of services and opportunities,
• To perform the services we offer in accordance with our contracts,
• Sending newsletters or making promotions or notifications by e-mail,
• Making promotions or notifications via SMS,
• Answering your calls and responding to your support needs,
• Developing our current and R&D applications and marketing the product in the management process,
• Concluding the complaint in line with your request or in case of complaints on social media or if there is a complaint about the services we provide,
• We collect and process your data in order to use it in various statistical evaluations, database creation and market research without revealing the identity of the user.

The personal data collection activity carried out by Advist is in accordance with the 5th article of the KVKK. 2 of the article. in accordance with the paragraph;

• It is compulsory for the fulfillment of our legal obligations,
• Being mandatory within the scope of Advist’s legitimate interests, provided that it does not violate your fundamental rights and freedoms,
• It is clearly stipulated in the laws,
• Provided that it is directly related to the establishment or performance of a contract, it is carried out based on the reasons why it is necessary to process the personal data of the parties to the contract.

1. TO WHOM IS YOUR PERSONAL DATA TRANSFERRED TO?

By accepting the Personal Data Protection Policy, within the scope of Advist and Advist applications and services, your personal data, which you have given your explicit consent to be shared with domestic and foreign business partners, employees and cooperating third parties, in order to provide you with various advantages; You consent to the collection, storage, processing, use, transfer. In addition, this information is only legally and technically the same with us regarding data protection and security, with which we have a contractual relationship, in order to provide the services to be provided to you flawlessly, to deliver your possible shipments in a healthy manner, to deliver our notifications on time via telephone, sms and/or e-mail. It will be shared with third parties who have responsibilities and comply with the provisions of the relevant legislation, only in case of need and to the extent necessary.

Your data regarding your visit to the Advist website or membership, and your traffic information, such as your browsing information; Public institution that is legally authorized to request this information for your safety and for the purpose of fulfilling its obligation before the law (in cases where there is a legal or administrative obligation to notify or provide information, such as, but not limited to, the fight against crime and the threat to state and public security). and its organizations.

1. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

Regarding your personal data;

KVKK No. 6698 11. The article entered into force on 07 October 2016, and in accordance with the relevant article, the rights of the Relevant Person after this date are as follows:

Relevant Person, by applying to Advist;

1. Learning whether personal data is processed or not,
2. If personal data has been processed, requesting information about it,
3. Learning the purpose of processing personal data and whether they are used in accordance with the purpose,
4. Knowing the third parties to whom personal data is transferred at home or abroad,
5. Requesting correction of personal data in case of incomplete or incorrect processing,
6. 7 of the KVKK. Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in the article,
7. In case of correction, deletion or destruction of personal data, requesting the notification of these transactions to the third parties to whom the personal data has been transferred,
8. Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
9. It has the right to demand the compensation of the damage in case of loss due to the unlawful processing of personal data.
10. APPLICATION AND APPLICATION METHOD REGARDING YOUR PERSONAL DATA

Edulegal OÜ, located at Harju maakond, Kuusalu vald, Pudisoo Küla, Männimäe, 74626 ESTONIA, operating in compliance with the KVKK as a data controller, respects the rights of you, valuable data owners, and tries to help you fulfill your requests in your application. 11 of KVKK. The right to apply to our company with this form prepared in accordance with the article, belongs directly to the personal data owner. In applications to be made on behalf of third parties, a power of attorney must be available to represent the relevant person.