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TİTRA TEKNOLOJİ A.Ş. – PERSONAL DATA PROCESSING DISCLOSURE STATEMENT

Dear Data Subject,

This Disclosure Statement has been prepared by Titra Teknoloji Anonim Şirketi (“TİTRA”) in accordance with Article 10 of the Law No. 6698 on the Protection of Personal Data (“KVKK” or “Law”) titled “Obligation of the Data Controller to Inform” and the Communiqué on the Principles and Procedures to Be Followed in Fulfillment of the Obligation to Inform. Its purpose is to inform you about your personal data processed during your visit to our website (“www.titra.com.tr”).

1- IDENTITY OF THE DATA CONTROLLER

As TİTRA, we act as the “Data Controller” in accordance with the Law and relevant legislation regarding the personal data obtained. You can reach us through the following contact channels:

2- METHOD AND LEGAL BASIS FOR COLLECTING YOUR PERSONAL DATA

2.1. Method of Collection

Your personal data such as name-surname, father’s name, place of birth, date of birth, mobile phone, address, phone number, signature, email, account number, etc., are collected when you fill out the application form available at “www.titra.com.tr”, through contracts, petitions, or via cookies used on the website.

2.2. Legal Basis for Collection

Your personal data are stored in physical and/or electronic media based on the legal grounds stated in Articles 5 and 6 of the Law, such as the necessity of processing for the establishment, exercise, or protection of a right, and the necessity of processing for the legitimate interests of the data controller, such as the follow-up of your requests and complaints.

3- PURPOSES OF PROCESSING PERSONAL DATA

The personal data collected by TİTRA are processed in accordance with the principles of legality and fairness, being accurate and up-to-date, being processed for specific, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being stored only for as long as necessary for the purposes of processing or as required by relevant legislation.

The collected personal data are processed for the following purposes:

  • To carry out necessary operations and manage relevant business processes to conduct TİTRA’s activities; including establishing and managing the IT infrastructure, ensuring business continuity, planning or implementing corporate communication activities, event management, procurement processes, and sustainability activities.

  • To carry out advertising and promotional activities, including corporate identity activities, in compliance with Law No. 6698 on the Protection of Personal Data.

  • To process employee or candidate data and carry out internship, vocational training, scholarship, and educational program activities within the scope of relevant legislation and contracts.

  • To fulfill obligations related to storage, notification, reporting, and other legal requirements in compliance with applicable legislation.

  • To carry out necessary activities and manage relevant processes for those who will benefit from the products, services, and support provided by TİTRA.

  • To plan or implement the activities required to customize and recommend products, services, and support offered by TİTRA in accordance with user preferences, usage habits, and needs.

Your personal data will be processed in compliance with the data processing conditions specified in Articles 5 and 6 of the Law.

4- TRANSFER OF PROCESSED PERSONAL DATA

TİTRA may share the processed personal data in compliance with the conditions and purposes of personal data processing specified in Articles 8 and 9 of the Law and by taking the necessary security measures, with:

  • Its subsidiaries or affiliates,

  • Domestic/international public or private institutions, organizations, or legal entities from which services/support/consultancy are received or with which cooperation is established or which are project/program/finance partners,

  • Public institutions and organizations that are legally authorized to request such data,

  • Companies and other third persons or entities, consultants, shareholders, business partners, or other group companies.

5- RIGHTS OF THE DATA SUBJECT

Pursuant to Article 11 of the KVKK, you have the right to:

  • Learn whether your personal data are processed,

  • Request information if your personal data have been processed,

  • Learn the purpose of processing and whether they are used in accordance with the intended purpose,

  • Know the third parties to whom your personal data are transferred domestically or abroad,

  • Request the correction of your personal data if they are incomplete or incorrectly processed,

  • Request the deletion or destruction of your personal data within the framework of the conditions stipulated under the Law, even if they have been processed in accordance with the Law and other relevant legislation,

  • Request that the transactions carried out in accordance with your rights of correction, deletion, or destruction be notified to the third parties to whom your personal data have been transferred,

  • Object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems,

  • Request the compensation of the damage if you suffer damage due to unlawful processing of personal data.

6- EXERCISING RIGHTS RELATING TO PERSONAL DATA

Within the scope of the rights mentioned above, you may submit your requests in accordance with Article 11 of the Law and the Communiqué on the Procedures and Principles of Application to the Data Controller, either in writing or by filling out the “Personal Data Application Form” available at www.titra.com.tr and delivering it in person to our address, or by sending it to [email protected] using your email address.

Such applications will be accepted following identity verification and will be concluded as soon as possible and within 30 days at the latest depending on the nature of your request. No fee will be charged for up to 10 pages; for each page above 10, a processing fee may be charged in accordance with Article 7 of the Communiqué. If the response to your request is provided on CD, flash memory, or other recording media, the cost of the media will be charged.

For your application to be valid, it must include the following:

  • Full name and signature,

  • Turkish ID number (for citizens of the Republic of Türkiye),

  • Nationality, passport number, or identity number (for foreign nationals),

  • Residential or workplace address for notification,

  • If available, email address, phone number, and fax number,

  • Subject of the request.