KVKK Customer Privacy Notice

As SISTEM PATENT A.S. (the "Company"), registered with IZMIR Trade Registry Directorate under trade registry number 141865, tax ID 7710339023 at Karsiyaka Tax Office, with its registered office at Adalet Mah. Sht. Polis Fethi Sekin Cad. No:6 Ventus Tower Floor:18 D:184 Bayrakli-IZMIR / Izmir, acting as "Data Controller" in accordance with Law No. 6698 on the Protection of Personal Data and the regulations, communiqués, and circulars issued under it, and the decisions and announcements of the Personal Data Protection Authority (the "Authority"), together with other secondary legislation and practices (collectively "KVKK"), we act with the utmost care to ensure the security of your personal data. Accordingly, we process your personal data in the manner set out below and within the limits prescribed by KVKK.

1. Personal Data Processed

Your personal data processed by us, collected through the methods described below for the purposes of establishing electricity subscriptions and managing subscription processes, is as follows:

2. Purposes of Processing Personal Data

Within the scope of Sistem Patent A.S.'s activities, your personal data is processed by our Company for:

Fulfilling our obligations under Law No. 6698 on the Protection of Personal Data and the secondary arrangements, decisions, announcements, and practices of the Authority,
Fulfilling our obligations under Law No. 6502 on the Protection of Consumers and the secondary arrangements, decisions, announcements, and practices of the relevant public institutions and organizations,
Following and running legal matters in accordance with the legislation and arrangements set out above,
Providing information requested by the relevant/authorized public institutions and organizations when necessary,
Running sale of goods/services processes between the customer and the Company, and operations, after-sales support, and customer relations services,
Running and auditing business activities and risk-management processes,
Receiving and evaluating recommendations for improving business processes,
Running our Company's retention and archiving activities,
Ensuring our Company's business continuity,
Running finance and accounting matters,

Within the limits set by KVKK, and in a manner that is always connected with, limited to, and proportionate to these purposes, in accordance with the law and good faith.

3. Legal Grounds for Processing Personal Data and Transfer of Data

Within the purposes set out above, your personal data is processed on the basis of one or more of the legal grounds set out in Article 8(2)(a) of KVKK and Article 5(1) and 5(2)(a), (c), (ç), and (f), namely: express provision in the laws; a direct connection with the conclusion or performance of a contract; processing being required to fulfill a legal obligation; or processing being required for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject; and may be transferred to:

Independent audit firms with which we have a contractual relationship,
Legal persons with which we have a dealership relationship,
Law offices with which the Company has an agency relationship,

And, where necessary, to agents and representatives authorized by you, to regulatory and supervisory authorities and to other official bodies such as courts and enforcement offices, and to other public institutions and organizations that are legally authorized to request your personal data.

4. Methods of Collecting Personal Data

Your personal data is collected by legal persons with which we have a dealership relationship and by officers and staff of the Sales Unit, through means such as email, phone, the website, various paper forms, and records, by automated or non-automated methods, orally, in writing, or in electronic form, on the basis of sharing made by you, or through documents sent to the Company by legally authorized public institutions and organizations and recorded by us.

5. Rights of Data Subjects Under the Law

You may apply to our Company at any time to:

Learn whether your personal data is being processed,
Request information if your personal data has been processed,
Learn the purpose of the processing of your personal data and whether it is used in line with that purpose,
Know the third parties to whom your personal data is transferred within Turkey or abroad,
Request correction of your personal data if it has been processed incompletely or inaccurately,
Request deletion or destruction of your personal data within the framework of the conditions set out in Article 7 of KVKK,
Request that actions taken under Article 11(d) and (e) of KVKK be notified to the third parties to whom your personal data has been transferred,
Object to a result that arises against you as a consequence of the processed data being analyzed exclusively through automated systems,
Claim compensation for any damages suffered as a result of the unlawful processing of your personal data.

You may request to exercise your rights. You can send requests relating to your rights and the application of KVKK by completing the application form you can obtain from us, signing it by wet signature, and sending it to the Company address by notary or registered mail with return receipt, or in person; or, after signing it with your secure electronic signature, sending it from your KEP (registered electronic mail) address or the email address already registered in the Company's data registry system, to [email protected]. Where responses to requests within this scope are provided in writing, our Company will respond free of charge up to 10 pages; each page beyond 10 will be charged at a processing fee of 1 Turkish lira. If the response to the application is provided on a recording medium such as CD or flash memory, the fee that may be charged by the Company cannot exceed the cost of the recording medium.

Under the "Communiqué on the Principles and Procedures for the Application to the Data Controller", your application for exercising your rights as a data subject must: clearly and understandably state the subject of your request, be about you personally, and if you are acting on behalf of someone else, include a special power of attorney certified by a notary. Applications are required to include the following: full name, signature, Turkish ID number, residence or workplace address, email address, phone and fax number, and the subject of the request. Applications that do not contain these items will be rejected by our Company.

The Company reserves the right, at any time, to amend this notice based on grounds arising from KVKK, its secondary legislation, and decisions of the Authority. Changes to the notice and the updated text will take effect immediately as of the date they are communicated to you.