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Any information within the scope of Personal Data as detailed below, which identifies your identity or makes you identifiable, shall be processed by RCT Danışmanlık Hizmetleri Limited Şirketi (hereinafter referred to as RCT), acting in its capacity as the Data Controller, in strict compliance with the provisions of the Law No. 6698 on the Protection of Personal Data (KVKK) .

The term "processing of personal data" encompasses any operation performed upon personal data, whether wholly or partially by automated means, or by non-automated means provided that the data forms part of a structured filing system . These operations include, but are not limited to, the collection, recording, storage, preservation, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization, or prevention of use of such data .

The Law No. 6698 on the Protection of Personal Data entered into force upon its publication in the Official Gazette dated 07.04.2016, numbered 29677 . Any personal data lawfully obtained by our company prior to the enactment of this law shall continue to be processed and maintained in full conformity with this Clarification Text and the terms and conditions prescribed under the KVKK .

At RCT, we emphasize that we attach the utmost importance to safeguarding your personal data . We carry out all our corporate activities with the continuous awareness that data security is paramount in the services we deliver to you . Our core principle while processing your personal data throughout our services is to respect your right to privacy and to defend your fundamental rights and freedoms .

Purposes and Legal Grounds for Processing Personal Data

In order to provide services within the framework of the legislation and related regulations to which our company is subject, to assess your requirements, and to offer you an enhanced level of service in the future, your personal data—including your personal information, address, telephone number, tax number (if any), and any other information categorized as personal data under the KVKK—will be recorded . This data is processed to generate the necessary documentation and records for transactions conducted in physical or electronic environments; to fulfill our information storage, reporting, and disclosure obligations toward all judicial and administrative authorities in line with applicable legislation; to execute our services within the legal boundaries we are subject to; and to carry out other operations requested from or offered by our Company .

In accordance with the second paragraph of Article 5 of the Law, titled “Conditions for the processing of personal data,” personal data may be processed without obtaining the explicit consent of the data subject if any of the following conditions are met :

a) It is explicitly sanctioned or prescribed by law .

b) It is mandatory for the protection of life or physical integrity of the data subject or another individual when the data subject is physically or legally incapable of granting consent .

c) The processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the formation or performance of said contract .

d) It is imperative for compliance with a legal obligation to which the data controller is subject .

e) The relevant data has been made public by the data subject himself/herself .

f) Data processing is mandatory for the establishment, exercise, or protection of a legal right .

g) Processing is necessary for the legitimate interests of the data controller, provided that such processing does not infringe upon the fundamental rights and freedoms of the data subject .

Transfer of Your Personal Data

Your personal data maintained by our Company may be transferred to individuals, institutions, organizations, and relevant third parties within the framework of legal restrictions, as mandated or permitted by the laws, regulations, and other applicable legislation to which we are bound .

Deletion, Destruction, and Anonymization of Personal Data

(a) Personal data processed in accordance with this Law or other relevant legislation shall be deleted, destroyed, or anonymized either ex officio (by the data controller's own motion) or upon the explicit request of the data subject, should the underlying reasons necessitating its processing cease to exist .

(b) The provisions contained in other specific laws concerning the deletion, destruction, and anonymization of personal data are strictly reserved .

(c) The procedures and principles governing the deletion, destruction, and anonymization of personal data shall be set forth by a dedicated regulation .

Methods for Collecting Personal Data

Your personal data is gathered through various channels, including but not limited to declaration/information forms and other documents related to sales, returns, exchanges, and all other business transactions; notifications issued under your approval and/or signature; electronic approvals and/or signatures; and via our physical branches, web pages, and similar platforms, in oral, written, or electronic formats pursuant to the relevant legislation .

Rights Under Article 11 of the Law

By applying to the data controller, you are entitled to exercise the following rights as a data subject :

a) Learn whether or not your personal data have been processed .

b) Request information regarding the processing activity if your data have been processed .

c) Learn the specific purpose of processing your personal data and verify whether they are utilized in line with that purpose .

d) Know the third parties to whom your personal data have been transferred, whether within the country or abroad .

e) Request rectification in the event that your personal data have been processed incompletely or inaccurately .

f) Request the deletion or destruction of your personal data within the framework of the conditions specified under Article 7 .

g) Request that the operations performed pursuant to indents (e) and (f) be notified to the third parties to whom your personal data have been transferred .

h) Object to any outcome that occurs to your detriment exclusively through the analysis of your personal data via automated systems .

i) Claim compensation for damages in the event that you incur a loss due to the unlawful or non-compliant processing of your personal data .

Data Controller Contact Details

The data controller to whom you may submit your applications under the scope of the law is as follows :

Company Title: RCT Danışmanlık Hizmetleri Limited Şirketi

Address: Maslak Mah. Bilim Sokak No:5 K:13 Sarıyer İstanbul / Türkiye

Depending on the nature of the request, the data controller shall finalize the queries included in the application free of charge and within a maximum of thirty days . However, if the execution of the request entails an additional cost, the fee prescribed in the tariff determined by the Personal Data Protection Board may be charged .

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