Privacy Policy

Personal Data Protection and Privacy Policy

Website Privacy Policy

How the information we obtain about you and the services you request will be used and protected during your visit to this website and your use of the services we offer through this site is subject to the conditions set out in this "Privacy Policy". By visiting this website and requesting to benefit from the services we offer through this site, you agree to the terms set forth in this "Privacy Policy".

I.Purpose of Personal Data Protection and Processing Policy

Thank you for your interest in our website. The security of your data is extremely important to us and we take all necessary measures to protect your data. Our website can generally be used without providing any personal data. However, if you want to use the products and services specified on our website through our site, it may be necessary to process your personal data.

The Law on the Protection of Personal Data No. 6698 ("Law") entered into force on April 7, 2016 after being published in the Official Gazette. The Law sets out the procedures and principles regarding the processing of personal data by real or legal persons who are classified as "data controllers" of personal data and determine the purposes and means of processing personal data, and are responsible for the establishment and management of the data recording system.

Personal data is all information relating to an identified or identifiable natural person. A natural person may be identified, directly or indirectly, in particular by means of a name, an identification number, location data, an online identifier or a physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person. The data controller, on the other hand, is the natural or legal person, authority, institution or other body that determines the purposes and means of processing personal data, alone or together with others.

Data controllers are obliged to enlighten and inform the real persons whose data are processed while obtaining the data of the real person. Within the scope of this obligation, data controllers include data owners;

The identity of the data controller and its representative, if any,
For what purpose personal data will be processed,
To whom and for what purpose the processed personal data can be transferred,
The method and legal reason for collecting personal data,
It is obliged to inform about the other rights listed in Article 11 of the Law.

The subject of this Policy is our Company's real and legal person customers, real person officials, shareholders and employees of legal entity customers, prospective customers, our group companies, real person officials, partners and employees of our business partners and suppliers, our employee candidates, people who have worked in our company from past to present, interns, visitors, company officials and partners, business partners and candidate suppliers and other third parties and the company. Issues regarding the processing of personal data of employees are in accordance with the legal regulations

Policy on the protection of employee personal data given to company employees in the form

It is organized within the scope of.

Scope and Amendment of Personal Data Protection and Processing Policy This Policy, prepared by our company, has been prepared in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK"). The law has entered into force with all its provisions as of today. The data obtained from you with your consent or in accordance with other laws listed in the Law will be used to improve the quality of the services we offer, to improve the services offered to you and our quality policy. Again, some of the data we have are depersonalized and anonymized. These data are used for statistical purposes and are not subject to the application of the Law and our Policy. Defe Global LLC Personal Data Protection and Processing Policy aims to protect the automatically obtained data of our customers, prospective customers, employees, customers and employees of companies working in solution partnership with us or other persons and includes regulations regarding these. Our company has the right to change our policy and Regulation on the condition that it complies with the law and better protection of personal data.

III.Basic Rules Regarding the Processing of Personal Data

General Principles Regarding the Processing of Personal Data

KVKK m.4. Accordingly, personal data should be processed in accordance with the procedures and principles specified in the legal legislation. In this context, data controllers must comply with the general principles specified in Article 4 of the KVKK and stated below, in addition to fulfilling the obligation to inform:

Compliance with the law and honesty rules.
Being accurate and up-to-date when necessary.
Processing for specific, explicit, and legitimate purposes.
Being relevant, limited and restrained to the purpose for which they are processed.
To be kept for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

Purposes of Personal Data Processing and Transfer within the Scope of the Law

Purposes Regarding the Processing of Personal Data

Personal data cannot be processed without the consent of the real person who owns the data. However, in some cases (KVKK Articles 5 and 6), personal data may be processed without explicit consent.

Personal data in accordance with Article 5 of the KVKK,

Data processing is clearly stipulated in the law,

The person who is unable to express his consent due to actual impossibility or whose consent is not legally valid, himself or someone else.

It is mandatory to process the relevant data for the protection of life or bodily integrity,

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,
Data processing is mandatory for the data controller to fulfill its legal obligation,
Personal data 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 person concerned, in cases where data processing is mandatory for the legitimate interests of the data controller, the data may be processed without the consent of the real person whose data is processed.

In addition, with the idea that the person will be exposed to discrimination if learned, data related to health, sexual life, sexual preference, ethnicity, race, political opinion, belief, sect, dress, membership of foundations or unions, criminal convictions and security measures, and biometric and genetic data have been determined as "special quality" data in the law and have aggravated the conditions for processing this data. Accordingly, sensitive data may be processed under the following conditions, except in cases where explicit consent is obtained:

Data related to the data owner's religion, sect or other beliefs, ethnic origin, race, philosophical belief, political opinion, criminal conviction and security measures, disguise and dress, data related to membership in associations, foundations or unions, and biometric and genetic data may be processed in cases specified by law.
Data related to health and sexual life may be processed by persons, institutions and organizations that have the responsibility of confidentiality for the purpose of protecting public health, medical diagnosis, planning health tasks and financing, preventive medicine, maintaining and managing treatment and care processes.
Purposes of Sharing Personal Data

In order to share the personal data obtained with a third person or institution, explicit consent must be obtained from the relevant data owner in this direction. However, according to Article 8 of the KVKK, data transfer can also be provided under the conditions where data processing is allowed, and in this case, if the conditions specified in Section 2.II.a above are met, personal data transfer can be made even if the data owner does not have explicit consent.

The transfer of personal data to third parties in the country or abroad is subject to special conditions. Personal data; In the presence of the explicit consent of the real person who owns the data, or in the presence of one or more of the other conditions mentioned above, but without the explicit consent of the real person who owns the data; In the event that the necessary protection measures are taken in the country where the relevant data is transferred and there is no necessary protection measure in the country where the relevant data is transferred, data can be transferred abroad, provided that the data controller undertakes the necessary protection together with the data controller in the country to which the data is transferred and permission is obtained from the board.

Exclusions

Pursuant to Article 28 of the KVKK, legal provisions will not be applied in the following cases:

Processing of personal data by real persons within the scope of activities related to themselves or their family members living in the same residence, provided that they are not given to third parties and the obligations regarding data security are complied with.
Research by anonymizing personal data with official statistics,

processing for purposes such as planning and statistics.

Processing of personal data for artistic, historical, literary or scientific purposes or within the scope of freedom of expression, provided that it does not violate national defense, national security, public security, public order, economic security, privacy of private life or personal rights or does not constitute a crime.
Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to ensure national defense, national security, public security, public order or economic security.

Judicial authorities regarding the investigation, prosecution, trial or execution of personal data or Execution Authorities by Processing.

IV.Deletion of Personal Data

When the periods required to be kept by law expire, judicial processes are completed or other requirements disappear, personal data is deleted, destroyed or anonymized by our company automatically or upon the request of the person concerned.

As a rule, the data within the body of Defe Global LLC is processed as declared by the relevant persons upon their declaration. Defe Global LLC is not obliged to investigate the accuracy of the data declared by customers or persons who contact Defe Global LLC, and this is not done legally and due to our working principles. The declared data are considered correct. The principle of accuracy and up-to-dateness of personal data has also been adopted by Defe Global LLC. It updates the personal data that our company has processed from the official documents received by it or upon the request of the person concerned. It takes the necessary precautions for this.

V.Privacy and Data Security

Personal data is confidential and Defe Global LLC respects this confidentiality. Personal data can only be accessed by authorized persons within the company. All necessary technical and administrative measures are taken to protect the personal data collected by Defe Global LLC and to prevent them from falling into the hands of unauthorized persons and to prevent our customers and potential customers from being victims. In this context, it is ensured that the software complies with the standards, the third parties are carefully selected and the data protection policy is complied with within the company.

VI.Data Processing Purposes

The collection and processing of personal data of Defe Global LLC will be carried out in line with the purposes specified in the clarification text. The data is collected and processed for the purpose of establishing the contract and providing better service to customers.

Within the scope mentioned above, our company processes personal data for the following purposes:

Planning, auditing and executing data security processes,

Creation and implementation of data technologies infrastructure,

Planning and execution of activities to provide rights and advantages to employees,

Corporate communication for employees and/or planning and/or execution of the activities of corporate social responsibility and/or non-governmental institutions in which employees participate,
Supervision, planning and execution of employees' access to data authorizations,

Supervision and follow-up of the working activities of the employees,

Follow-up of financial and/or accounting affairs,

Follow-up of legal, litigation and enforcement processes,

Planning and follow-up of human resources processes,

Planning and/or execution of the processes of ensuring the effectiveness/efficiency and/or appropriateness of the works,
Planning and execution of data access authorizations of business partners and/or suppliers,
Management of relations with business partners and/or suppliers,

Planning and/or execution of occupational health and/or safety processes,

Planning and/or execution of activities to ensure business continuity,

Planning and execution of corporate communication activities,

Planning and execution of corporate governance activities,

Planning and execution of logistics activities,

Planning and execution of customer relationship management processes,

Planning and/or execution of customer satisfaction activities,

Follow-up of customer requests and complaints,

Execution of personnel procurement processes,

Obligations arising from the employment contract and/or legislation for the employees of the company

fulfillment,

Planning and execution of company audit activities,

Planning and execution of external training activities,

Planning and execution of the operational activities necessary to ensure that the company's activities are carried out in accordance with the company procedures and/or legal regulations,
Planning and/or execution of in-house training activities,

Ensuring the security of company operations,

Ensuring the security of the company's headquarters, branches and warehouses,

Planning and/or executing the processes of creating and/or increasing loyalty to the products and/or services offered by the company,
Planning and/or execution of the company's production and/or operational risk processes,
Realization of corporate and partnership law transactions,

Follow-up of contract processes and/or legal requests,

Execution of strategic planning activities,

Planning and execution of supply chain management processes,

Wage management,

Planning and execution of production and/or operation processes,

Planning and execution of market research activities for the sale and marketing of products and services,
Planning and execution of marketing processes of products and/or services,

Planning and execution of sales processes of products and/or services,

Ensuring that the data is accurate and up-to-date,

Providing information to authorized institutions based on the legislation,

Creation and follow-up of visitor records

VII.Categorization of Personal Data Processed by Our Company

The personal data and categories processed by our company are as follows:

Data Category

Personal Data Categorization Description

Identity Data

Data contained in documents such as driver's license, identity card, residence record, passport, lawyer's ID, marriage certificate (eg. TCKN, passport number, identity card serial number, name-doyad, photograph, place of birth, date of birth, age, place of registration, occurrence

Example of identity card)

Contact Information

Information used to contact the natural person concerned

(eg. Residential address, e-mail address, mobile phone number)

Location Data

Used to determine the location of the data owner

data (e.g. location data obtained during vehicle use)

Customer Data

Data of our customers who benefit from our goods and services

(e.g. customer number, profession information, etc.)

Customer Data

Every transaction made by buyers who benefit from our goods and services

data on various transactions (e.g. requests, instructions, orders, etc.)

Customer Transaction Data

Personal data regarding the records and documents taken at the entrance to the company's headquarters, branches and warehouses, during the presence in the headquarters, branches and warehouses (e.g. visit data, visual and audio data, camera

records, etc.)

Physical Space Security

Data

Personal information processed in order to ensure the administrative, technical, legal and commercial security and integrity of our company and related persons

Process

Reliability

Data

Personal data processed for your security (technical, administrative, legal and commercial) and to fulfill our company's legal obligations

Risk Management

Data

To eliminate the commercial, technical and administrative risks of our company

Personal data processed for the purpose

Financial Data

Personal data required to achieve this purpose for the purpose of auditing and reporting accounting and financial transactions (e.g. debit and credit balance, loan amount, credit card

information, loan payments, loan interest rate and amount, etc.)

Personnel Data

4857 Numbered Work Article 75 of the Law Work as required appropriate The obligation to keep the personnel file of the employees of the company and this

Any personal data processed within the scope

Employee Candidate

Data

Personal data obtained during the application evaluation and interview process within the framework of the employee-employer candidate legal relationship between the data owners who share their information to apply for a job with our company and our company (eg resume,

educational information, language results, etc.)

Running Process

Data

Personal data related to all kinds of work-related transactions performed by company employees (e.g. records of company computers, entry-exit records, business trips, data on trainings attended,

e-mail traffic monitoring information, vehicle location and usage information, etc.)

Employee Practice and Career

Development Data

Personal information processed for the purpose of evaluating the performance of company personnel and planning and executing career development in line with HR policies (e.g. performance

reports, interview results)

Benefits and benefits

Data

Follow-up of the fringe benefits and benefits offered to the company's personnel

personal information processed for the provision and benefit of personnel (e.g. private health insurance, vehicle allocation)

Marketing Data

Company by marketing In its activities Use

Information (eg. price Offer Detection customer reports and determinations showing their habits and likes)

Legal Action

And Compliance Information

Fulfillment of our legal obligation as a company,

To be able to exercise our rights such as defense, recourse, etc., litigation and enforcement

Personal data processed for the purpose of managing and monitoring processes

Control And

Inspection Information

To be able to fulfill the legal obligations of our company and

Personal data processed for the purpose of implementing company policies

Sensitive Personal Data

Data related to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic

Data

Request/Complaint Management Data

Personal data regarding the receipt and evaluation of customer complaints, the elimination of the subject of the complaint or the provision of alternative suggestions (e.g. requests and complaints regarding products or services,

records and reports)

Visual and

Audio Recordings

Visual and audio recordings associated with the personal data owner (eg.

photos, camera recordings, and audio recordings)

VIII.Customer, prospect and business and solution partners data Collection and processing of data for the contractual relationship

If a contractual relationship has been established with our customers and prospective customers, the collected personal data may be used without the customer's consent. However, this use takes place for the purpose of the contract. The data is used to the extent of better execution of the contract and the requirements of the service and is updated by contacting the customers when necessary. On the other hand, the data left to us by our prospects (potential customers) are processed in order to provide them with easier and higher quality service afterwards. This data will be deleted if it has not been converted into a contractual relationship upon request.

Business and Solution Partners Data

Defe Global LLC adopts the principle of acting in accordance with the law while sharing data with both business and solution partners. Data is shared with business and solution partners with a commitment to data confidentiality and only as much as the service requires, and these parties are forced to take measures to ensure data security.

Data processing for advertising purposes

In accordance with the Law on the Regulation of E-Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages, electronic messages for advertising purposes can only be sent to persons with prior approval. The explicit consent of the person to whom the advertisement will be sent is a must. Again, Defe Global LLC complies with the details of the "approval" determined in accordance with the same legislation .

Data transactions made due to the legal obligation of the company or expressly stipulated in the law Personal data may be processed without separate consent in order to clearly state the processing in the relevant legislation or to fulfill a legal obligation determined by the legislation. The type and scope of data processing must be necessary for the legally permitted data processing activity and must comply with the relevant legal provisions.

Company's Data Processing

Personal data may be processed in line with the service provided by the company and its legitimate purposes. However, the data cannot be used for unlawful services in any way.

Processing of Sensitive Data

Defe Global LLC may process sensitive data only for the purpose for which they were collected, with the consent of the persons, in order to provide better services.

Data Obtained Through Membership Transactions

If you are a member of Defe Global LLC, your personal data that you share with us for the membership process is processed in our systems. If you subscribe to our system via Facebook, Google or other social media tools; Your information provided to the partners of the relevant social media tool, such as your name, surname, profile picture and e-mail address, is accessed and transferred to Defe Global LLC systems.

Data Processed by Automated Systems

Defe Global LLC acts in accordance with the Law regarding the data processed through automated systems. The information obtained from these data cannot be used against the person without the explicit consent of the persons. However, Defe Global LLC can make decisions about the persons it will process by using the data in its own system.

Functional and Analytical Cookies contain data about remembering your preferences, effective use of the website, optimizing the site to respond to user requests, and how visitors use the site. Due to their nature, these types of cookies may contain your personal information such as username, etc.

Third Party Cookies

Defe Global LLC websites/mobile applications/mobile websites work with third-party trusted, well-known advertising providers. Third-party service providers place their own cookies in order to provide you with tailored advertisements. Cookies placed by third parties collect and process the navigation information of visitors on websites and analyze how they use them.

Commercial Cookies

It helps to increase your usage experience by offering similar products to the product/content you target in line with your interests and choices, and by offering a more advanced, personalized advertising portfolio. The retention period of the above-mentioned session, permanent, functional and analytical and commercial cookies in the background is approximately 2 (two) months, and the necessary adjustments can be made in the personal internet browser settings. The process of removing from these settings may vary depending on the internet browser.

How can I delete cookies?

Many internet browsers are set to automatically accept and use cookies from the first time they are installed on your computer. By using the help or settings menus of your internet browser, you can block cookies or warn when cookies are sent to your device. You can use your browser's instruction or help options screen to learn about the different ways to manage cookies and get detailed information on how to adjust the settings of the browser you are using.

IX.Data belonging to our employees Processing of data for the business relationship

The personal data of our employees may be processed without consent to the extent necessary in terms of business relations and health insurance. However, Defe Global LLC ensures the confidentiality and protection of the data of its employees.

Processing in Accordance with Legal Obligations

Defe Global LLCmay process the personal data of its employees without obtaining separate approval in order to clearly state the processing in the relevant legislation or to fulfill a legal obligation determined by the legislation. This issue is from the law Resulting With obligations limited.

Processing for the Benefit of Employees

Defe Global LLCmay process personal data without obtaining consent for transactions that are in the interest of company employees, such as private health insurances. Also for disputes arising from business relationships Defe Global LLC, Employees belong Data can handle.

Processing of Sensitive Data

According to the Law, data related to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are sensitive personal data. Defe Global LLC also takes adequate measures determined by the Board in addition to the consent of the person concerned in the processing of sensitive personal data. Sensitive personal data can be processed without the consent of the person, but only in relation to and limited to the cases permitted by the Law. In order for our employees to benefit from insurance and health services, the qualified data obtained from them is used only for the purpose.

Data Processed by Automated Systems

Data processed in relation to automated systems in relation to employees can be used in internal promotions and performance evaluations. Our employees have the right to object to the result against them and they do this by following the internal procedures. Employees' objections are also evaluated within the company.

Telecommunications & Internet

Computers, telephones, e-mails and other applications allocated to employees within the company are allocated to the employee for business purposes only. The employee cannot use any of these means allocated to him by the company for his private purposes and communication. The Company can control and supervise all data on these tools. The employee undertakes that he will not keep any other data or information other than work on the computer, phones or other tools allocated to him from the moment he starts work.

X.Transfer of personal data domestically and internationally

Personal data may be shared by Defe Global LLC with business and solution partners and affiliates of Defe Global LLC in order to provide the service.

Defe Global LLC will process the personal data to the following persons and

will be able to transfer it to institutions for certain purposes;

Limited to ensure the fulfillment of the purposes for which the business partnership was established

to the business partners of Defe Global LLC,

To the suppliers of Defe Global LLC, limited to the purpose of ensuring that the services outsourced by our Company from the supplier and necessary to carry out the commercial activities of our Company are provided to our Company,
To the solution partners of Defe Global LLC, limited to ensuring the execution of our company's commercial activities that require the participation of affiliates,
To affiliates of Defe Global LLC .
Defe Global LLC has the authority to transfer personal data domestically and internationally in accordance with the other conditions in the Law and subject to the consent of the person, within the conditions determined by the Board in the law.

XI.Rights of the Person Concerned

Defe Global LLC acknowledges that within the scope of the Law, the data subject has the right to obtain his/her consent before the data is processed, and that he/she has the right to determine the fate of his/her data after the data is processed.

Regarding personal data by applying to our contact person announced by Defe Global LLC on our website;

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,
Correction of personal data in case of incomplete or incorrect processing

Don't want

Within the framework of the conditions stipulated in Article 7, the deletion of personal data or its destruction

Don't ask for it,

Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom 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.
On the other hand, individuals do not have a right regarding anonymized data within the Company. Defe Global LLC may share personal data with relevant institutions and organizations in order to exercise the legal powers of a judicial duty or state authority in accordance with the business and contractual relationship.

Real persons whose data is processed will be able to use the Application Form published on our website to exercise the above-mentioned rights.

Applications can be made by sending an e-mail to the info@defeglobal.com address or by sending an e-mail to our Company's previously specified e-mail address, together with the documents that will enable the identification of the real person who owns the relevant data, by hand or through a notary public or by other methods specified in the legislation . If another method is determined by the Personal Data Protection Board, applications can also be submitted by this method.

With the above-mentioned methods, your requests are evaluated and answered within a maximum of thirty days from the submission of your request. In this context, our company reserves the right to request additional information and documents from the applicant in order to evaluate and determine whether the applicant real person is the relevant data owner. As a rule, applications are considered free of charge by our company. However, if a fee is determined by the board for the application of the data owner, our company will have the right to charge a fee based on this determined figure.

.XII. Privacy Policy

The data of employees and other persons in Defe Global LLC are confidential. No one may use, copy, reproduce, transfer this data to others, or use it for purposes other than business purposes for any other purpose without compliance with the contract or law.

XIII.Transaction Security

All necessary technical and administrative measures are taken to protect the personal data collected by Defe Global LLC and to prevent them from falling into the hands of unauthorized persons and to prevent our customers and potential customers from being victims. In this context, the software must comply with the standards, the third parties must be carefully selected and the company must also

It is ensured that the data protection policy is complied with. Security measures are constantly renewed and improved.

XIV.Control

Defe Global LLC carries out the necessary internal and external audits for the protection of personal data.

XV.Notification of Violations

When Defe Global LLC is notified of any violation of personal data, it takes immediate action to remedy the violation. It minimizes the damage of the person concerned and compensates the damage. When personal data is obtained by unauthorized persons, it immediately notifies the Personal Data Protection Board.

Applications can also be made according to the procedures specified in the https://www.isteyimgocteyim.com addresses regarding the notification of violations.

This agreement was last updated on 10/11/2024.

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