CPM YAZILIM A.Ş.PDPL ELUCIDATION TEXT
This elucidation text is intended to ensure that the elucidation obligation on the use of rights of CPM Yazılım A.Ş. arising pursuant to the Law on real persons (“Data Owner”), processing of personal data and the use of these rights within the context of the Law on Protection of Personal Data (“the Law”) no.6698 in compliance with the 10th article of the Law is fulfilled.
1. Purpose of Processing and Transferring Personal Data
As CPM Yazılım A.Ş. in the capacity of (“Data Responsible”) residing at the address “Flatofis İstanbul, Otakçılar Cad. No: 78 Aquacourt Kapısı Kat:1 D Blok No: 73 Eyüp – İstanbul”, we may process your personal data for the purposes below:
Personal data is processed within the scope of personal data processing terms specified in the 5th and 6th articles of the Law being limited to the following purposes of the Company in compliance with the legal order and the Law:
- Management of judicial / administrative processes, response to requests from public institutions, fulfilment of legal obligations in accordance with legal regulations, resolution of legal disputes,
- Receiving a discount from purchases from contracted websites and institutions,
- Creation of participant registration in events / trainings organized by CPM Yazılım A.Ş., issuing of certificates / participation certificates, determination of awards / gift owners and their delivery,
- Getting CPM Yazılım employees benefit from primary and secondary rights arising from employment contracts, evaluation of their performance and activities,
- Providing call centre and remote support services, tracking the number of calls and the content,
- Creating a user account for employees, providing in-company identity and food card,
- Creating records of participation of employees in trainings and their certification,
- Event management,
- Execution / tracking of financial reporting and risk management procedures,
- Planning and execution of the audit activities to ensure that the activities of the Group Companies are carried out in accordance with the relevant legislation,
- Supporting Group Companies with respect to personnel procurement processes and compliance with relevant legislation,
- Supporting Group Companies for the realization of companies and partnership law transactions,
- The best planning and implementation of human resources policies, the execution of personnel procurement processes,
- Developing the services offered on the website and eliminating the errors on the site,
- Ensuring contact / communication,
- Creating statistics and analysing uses,
- Conducting commercial relations with the firms, suppliers cooperated with, firms from which service is received, reporting within the framework of cooperation,
- Establishment, execution and termination of business relationship / contract,
- Management of relationships with partners or suppliers,
- Realization of works for the preservation of reputation,
- Planning of secondary rights and benefits to be provided to itself and Group Companies and supporting the execution processes,
- Contacting Personal Data Owners who convey their requests and complaints to it and providing request and complaint management,
- Ensuring the legal, commercial and physical security of itself and business partners,
- Evaluation of all questions, requests, suggestions, complaints and applications submitted in writing, orally or electronically, including those relating to personal data, and responding to them,
- Ensuring corporate functioning, planning and execution of management and communication activities,
- Establishing communication for satisfaction measurement surveys,
- Conducting market research,
- Introduction of CPM employees in social media sharing,
- Contract negotiation, draw up and execution,
- Registering users to the systems specific to the products and services offered,
- Customizing the products and services offered in accordance with the requirements; updating and development of these due to customer needs, legal and technical developments,
- In the case of participation in an organization on behalf of the Company, creating the registration of the participant,
- Ensuring the transportation organization of company employees, monitoring of company pool vehicles,
- Execution / follow up of company’s legal affairs,
- In the event of the company’s merger with another company, division, transfer of the whole or a part of it, meeting the consequences arising from this legal procedure,
- Ensuring the security of the Website and Applications with internal and environmental security of the company,
- Proper planning, execution and management of commercial partnerships and strategies,
- Being able to offer the products and services,
- Getting the Personal Data Owners benefit from the products and services in the best way and customizing and recommending them according to their requests, needs and wishes,
- Payment and collection of product, service and service costs, determination of collection method,
- Ensuring the highest level of data security,
- Creating databases,
- Analysis of the use of the Web Site,
- Conducting Investor Relations,
- Announcement of new or existing products, services and campaigns, conducting sales and marketing activities,
- Providing information to regulatory authorities arising from legislation,
- Creating and tracking visitor records,
If the processing activity carried out for the aforementioned purposes does not meet any of the conditions stipulated in the Law, your explicit consent shall be sought regarding the relevant processing.
2. Persons to whom Personal Data shall be transferred
Personal Data can be shared with our business and solution partners, banks and third parties who perform technical, logistic and other transactions on our behalf in order to ensure that the services provided to you are complete and perfect, and only to the extent that they are appropriate with the quality of the service. These third parties are those who are obliged to reach the relevant information in order to provide the relevant services completely and perfectly.
Apart from these, your Personal Data may be transferred – only being limited to the relevant person or the institution – in order that the service is provided completely and perfectly in cases such as being obligated to share the data with other third persons, it being mandatory so that the Company can fulfil its legal liabilities, being explicitly stipulated in the laws or there being a judicial/administrative instruction given in compliance with the laws.
Some of the Personal Data may be shared with advertisers only in an anonymized form, together with information from other users, to ensure that ads can be tailored to the audience.
Anonymized data is information that cannot be matched to you, i.e. our visitors / customers, and does not include your identity information or render your identity specifiable. Your privacy is assured in anonymous data.
3. Method and Legal Purpose of Personal Data Collection
Personal Data are collected in order to be able to fulfil the liabilities fully and correctly within the framework of the following reasons: being explicitly stipulated in the laws for the purpose of realizing the purposes included in the Policy in various ways such as call centre, Company website, mobile application with technical and other methods in all kinds of oral, written, electronic environment with the purpose of inspecting its compliance with the 1st Article regulating the purpose of the Law and the 2nd Article regulating the scope of the Law, execution of the Contract between the parties, being required for the legal benefits of the Company with the purpose of being able to manage particularly the legal processes and being mandatory for the establishment and maintenance of a right and the data is processed by the Company or the data processors assigned by the Company.
4. Rights of the Personal Data Owner Pursuant to the PDP Law
In accordance with Article 10 of the Law, the Company informs you of your rights, provides guidance on how to exercise these rights and carries out all necessary internal operation and administrative and technical arrangements. The Company explains to the persons of whom Personal Data is collected that they have the following rights pursuant to the 11th article of the Law:
- Learning whether Personal Data has been processed,
- Requesting relevant information if Personal Data has been processed,
- Learning the purpose of processing Personal Data and whether these are used suitably for its purpose,
- Knowing the third parties to which Personal Data is transferred inland or abroad,
- Requesting correction of personal data in case of incomplete or incorrect processing,
- Requesting the deletion or destruction of Personal Data in accordance with the provisions stipulated in the 7th article of the Law,
- Requests the transactions made in accordance with the provisions of Article 11 (d) and (e) of the Law to be notified to third parties where personal data is transferred,
- Objection to the emergence of a result in the detriment of the person by analysing the processed data exclusively through automated systems,
- Claiming that the loss is compensated if he/she has incurred loss due to unlawful processing of Personal Data.
5. Use of the Rights of the Personal Data Owner
Personal Data Owners can communicate their requests related to the rights listed in the 4th article of this Policy to the Company free of charge with the information and documents that determine their identities and with the methods specified below or other methods determined by the Personal Data Protection Agency by completing and signing the Application Form you may reach from application form link:
- After the application form is completed, its copy with wet signature shall be delivered by hand or notary to the address “Flatofis İstanbul, Otakçılar Cad. No: 78 Aquacourt Kapısı Kat: 1 D Blok No: 73 Eyüp – İstanbul,
- After the application form is completed and signed with your “secured electronic signature” within the scope of Electronic Signature Law no. 5070, the form with the secured electronic signature shall be sent via e-mail to the address [email protected] or [email protected] ,
- Delivering the application form by the applicant by coming personally and applying with the document authenticating his/her identity and with the information and documents related to the application subject by using the e-mail address notified previously to the Company and registered in the Company’s system.
In order for third parties to request applications on behalf of the personal data owners, a special power of attorney issued by notary public on behalf of the applicant must be present.
6. Company’s Procedure and Period to Respond Applications
The company shall complete the claims in the application free of charge within 30 days at the latest according to the nature of the request. However, if the transaction in question requires additional costs, the fee determined by the Personal Data Protection Agency may be charged. The Company may accept the request as well as deny it providing its justification; notifies its response in writing or in electronic form. In case the application request is accepted, the Company does what is necessary.
7. Personal Data Owner’s Right to Complain to the Personal Data Protection Authority
In cases of rejection of the application, inadequate response or failure to respond to the application in its period; the owner of the data has the right to complain to the Agency within sixty days from the date of receipt of the response.