KVKK Lighting Text


1) Data Responsible and Representative

In accordance with the Law on Protection of Personal Data No. 6698 (“Law No. 6698”), your personal data; ACRON Bilişim A.Ş., whose head office is İçerenköy neighborhood, epic street Odak plaza no: 03 Ataşehir Istanbul It will be processed by (hereinafter referred to as ACRON) within the scope described below.

2) Definitions

a) Open consent: Consent on a specific subject, based on information and announced with free will,
b) Anonymizing: Making personal data unrelated to an identifiable or identifiable natural person by any means, even by matching with other data,
c) President: The President of the Personal Data Protection Authority,
d) Relevant person: The real person whose personal data is processed,
e) Personal data: All kinds of information related to an identified or identifiable natural person,
f) Processing of personal data: Acquisition, recording, storage, preservation, modification, reorganization, disclosure, transfer, acquisition, acquisition of personal data in a fully or partially automated manner or non-automated provided that it is part of any data recording system. any action taken on data such as its introduction, classification or inhibition of its use,
g) Board: The Personal Data Protection Board,
h) Authority: The Personal Data Protection Authority,
i) Data processor: Real or legal person who processes personal data on his behalf based on the authority given by the data controller,
j) Data recording system: The recording system in which personal data is processed according to certain criteria,
k) Data controller: Real or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system,

3) For what purpose personal data will be processed

Our related business units for the development of business activities within the scope of your collected personal data, SAP Licensing and Consultancy Services, SAP Support Services, SAP System (Basis) Management, OpenText Solutions, E-Transformation Solutions, Industry Ready Solutions and other management consultancy and software services carried out by ACRON. The necessary works are carried out by the company and the related business processes are carried out, planning and execution of business activities, follow-up, planning and execution of ACRON’s commercial and / or business strategies, management of relations with business partners and / or suppliers, products and / or services offered by ACRON. Carrying out the necessary work to benefit the real persons and legal entities by our business units and solution partners and conducting the relevant business processes, planning the sales processes of the products and / or services. the use and marketing of products and / or services in marketing activities, including electronic commercial messages, for the creation and promotion of customized services, advertising, promotion, etc. by us. sending commercial electronic messages, carrying out activities for the determination of financial risks of customers, planning and execution of customer relations management processes, following contract processes and / or legal demands, following customer requests and / or complaints, changing conditions of the business world of products and services offered by the Company, usage Planning and execution of the activities required to be recommended and promoted to the relevant people and institutions by customizing them according to their habits and needs, planning and / or execution of the processes of establishing and / or increasing loyalty to the products and / or services offered by ACRON, planning and / or executing customer satisfaction activities. Ensuring the legal, technical and commercial occupational safety of ACRON and related persons who have a business relationship with ACRON, monitoring legal affairs, Company activities Personal data processing specified in Articles 5 and 6 of the Law No. 6698 for the purposes of planning and execution of the operational activities required for ensuring the execution in accordance with the related legislation and / or relevant legislation, planning and execution of the Company’s audit activities, planning and / or execution of the Company’s financial risk processes. will be processed within the terms and purposes.

4- Processing Conditions of Personal Data

a) Personal data cannot be processed without the express consent of the person concerned.
b) In the presence of one of the following conditions, it is possible to process personal data without seeking explicit consent of the person concerned:

ba) Clearly prescribed by law.
bb) A person who is unable to disclose his consent due to de facto impossibility or whose legal consent is not granted his consent is compulsory to protect himself or anyone else’s life or bodily integrity.
bc) The processing of personal data of the parties to the contract is necessary, provided that it is directly related to the establishment or performance of a contract.
bd) It is mandatory for the data controller to fulfill his legal obligation.
be) That the person concerned has been made public by himself.
bf) Data processing is mandatory for the establishment, use or protection of a right.
bg) Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

5-Processing conditions of special quality personal data

a) People’s race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, disguise and outfit, association, foundation or union membership, health, sexual life, criminal conviction and security measures and biometric and genetic data is a personal data of a special nature.
b) It is forbidden to process special personal data without explicit consent of the person concerned.
c) Personal data other than health and sexual life listed in the first paragraph can be processed without the express consent of the person concerned, in cases provided for by law. Personal data related to health and sexual life, however, for the purpose of protecting public health, preventive medicine, conducting medical diagnosis, treatment and care services, planning and managing health services and financing, without seeking the express consent of the person concerned or authorized institutions and organizations. processed.
d) In the processing of special quality personal data, it is also necessary to take adequate measures determined by the Board.

6) To Whom and For What Purpose the Processed Personal Data Can Be Transferred

Your collected personal data; Within the framework of ACRON’s business relations with you, it may be shared with our business partners, suppliers, shareholders, group companies, as well as legally authorized public institutions and / or private persons, limited to the purposes stated above. Your personal data may be transferred and processed at home or abroad within the framework of the conditions and purposes of transferring and transferring the personal data specified in Articles 8 and 9 of the Law No. 6698 and provided that the limits set out in the law are not exceeded.

7) Terms of Transfer of Personal Data

a) Personal data cannot be transferred without the explicit consent of the person concerned.
b) Personal data;

ba) In the second paragraph of the article 5 of the Law No. 6698,
bb) Provided that adequate measures are taken, in the third paragraph of Article 6 of the Law No. 6698,

If one of the specified conditions is found, it can be transferred without the explicit consent of the person concerned.

c) Other provisions in the laws relating to the transfer of personal data are reserved.

8-Transfer of personal data abroad

a) Personal data cannot be transferred abroad without the explicit consent of the person concerned.
b) Personal data, the existence of one of the conditions specified in the second paragraph of Article 5 of the Law No. 6698 and the third paragraph of the Article 6, and in the foreign country where the personal data will be transferred;

ba) Adequate protection is available,
bb) In the absence of adequate protection to undertake an adequate protection of data in Turkey and in charge of the foreign countries and the presence of a written permission of the Board,  can be transferred abroad without seeking the express consent of the person concerned.

c) Countries with sufficient protection are determined and announced by the Board.
d) Whether the Board has sufficient protection in the foreign country and whether it is permissible under paragraph (bb); also) international conventions to which Turkey is a party,

da) reciprocity regarding the status of the data transfer personal data between the requesting country and Turkey,
db) Regarding each concrete transfer of personal data, the nature and purpose and duration of the personal data,
dc) The legislation and practice of the country where the personal data will be transferred to,
dd) The measures committed by the data officer in the country where the personal data will be transferred,

If it is evaluated and needs, it decides by taking the opinions of the relevant institutions and organizations.

e) personal data, without prejudice to the provisions of international conventions, Turkey or in the interests of the person concerned will suffer a serious condition, but considering the views of relevant public institutions or organizations transferred abroad with the permission of the Board.
f) The provisions of Law No. 6698 and other laws related to the transfer of personal data abroad are reserved.

8) Method and Legal Reason of Personal Data Collection

Your personal data within the framework of ACRON’s relations with you, to maintain business relationship and continue commercial activities, to market its products and services more effectively, to learn the needs and demands of the customer target group, to develop products and services for these needs and demands, to promote the products and services developed. It is processed for various legal reasons in line with its objectives and is collected from sources such as e-mail in visual form, verbally and / or in writing, in electronic form. Your personal data collected for this legal reason can be processed and transferred within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698, for the purposes specified in Article 3 of this Lighting Text.

9) Rights of the Personal Data Owner

Everyone is concerned about himself by applying to ACRON as a data controller;
a) Learning whether personal data is processed,
b) If the personal data is processed, requesting information about it,
c) Learning the purpose of processing personal data and whether it is used in accordance with its purpose,
To know the third parties to whom personal data are transferred domestically or abroad,
d) Requesting correction of personal data if it is incomplete or incorrectly processed,
e) To request the deletion or destruction of personal data within the framework of the conditions stipulated in article 7 of Law No. 6698,
f) To request notification of transactions made in accordance with subparagraphs (d) and (e) to third parties to whom personal data are transferred,
g) To object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems,
h) In the event that personal data is damaged due to illegal processing, it has the right to demand the removal of the damage.

The Data Owner will forward his requests regarding the processing and transfer of his personal data to ACRON in writing or by e-mail and other methods accepted by the Board.

As the ACRON data controller, it finalizes the requests included in the application free of charge as soon as possible and within thirty days at the latest depending on the nature of the request. However, in case the transaction requires a separate cost, the fee determined by the Personal Data Protection Board may be charged.

ACRON accepts the request or rejects it by explaining its reason and informs the person in writing or electronically. In case the request in the application is accepted, it is fulfilled by ACRON. In case the application is caused by the error of ACRON, the fee collected is returned to the concerned person.

In case the application is rejected, the answer is insufficient or the application is not answered in due time; the person concerned may complain to the Board within thirty days from the date ACRON has learned the answer, and in any case within sixty days from the date of application.

This text was prepared by ACRON as a Data Officer within the framework of the Lighting Obligation under Article 10 of the Law on the Protection of Personal Data No. 6698 and presented to the data subject.

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