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OUR DISCLOSURE AND PRIVACY POLICY FOR THE PROTECTION OF PERSONAL DATA

Title : Entertech Inc.
Adress : ÜNİVERSİTE MAH. SARIGÜL SK. NO: 37 /1 İÇ KAPI NO: 97 AVCILAR / İSTANBUL
Phone number : +90 212 691 60 01
E-mail address : info@entertech.com.tr
Registered Electronic Mail (REM) : entertech@hs03.kep.tr

As Entertech, we have the data of our related parties (employee, customer, external provider) within the limits and rules of the Personal Data Protection Law No. 6698 for the purpose of conducting our services.

Especially considering the security of your personal data, we would like to enlighten you in accordance with the Law No. 6698 on the Protection of Personal Data in order to protect the privacy of private life, fundamental rights and freedoms.

As Entertech, we show maximum effort and sensitivity to the security of your personal data. In accordance with the legislation, as a data controller, all kinds of private and general personal data obtained within the scope of our business and service relationship will be recorded, stored, updated, disclosed to third parties, transferred, classified and processed in accordance with other procedures and principles specified in the legislation in line with the Personal Data Protection Law, in the manner detailed below and within the limits prescribed by the legislation.

Our principles regarding the processing of personal data

As Entertech, we have adopted the following principles:
a) To operate in accordance with the law and honesty rules,
b) Striving to ensure accuracy and currency,
c) Processing for specific, explicit and legitimate purposes,
ç) Being relevant, limited and proportionate to the purpose for which they are processed,
d) Retention of the data for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

What Data Do We Collect? What is Our Purpose for Collecting Data?

· Personal data is any information that personally identifies you or can be used directly or indirectly to identify you. We may collect your personal data during interactions with persons authorized to represent our organization through your participation in Entertech, your use of Entertech services or your provision of services.

· The categories of personal data we collect from you may vary depending on the nature of your interaction with us or the Entertech services you use, and may include one or more of the following:

· Identity and Contact Data; We may collect your personal and/or business contact information, including identification and passport data such as your name, surname, postal address, telephone number, fax number, e-mail address and other similar data and identifiers.
· Customer Transaction Data; We may collect your data such as call center records, invoice, promissory note, check information, order information, request information.
· Finance Data; we collect information necessary for the processing of payments and fraud prevention, including bank account numbers and other relevant billing information.
· Physical Space Security Data: We may collect your data such as entrance and exit registration information, camera recordings.
· Professional Experience; We can collect data such as education level, information on courses and seminars, foreign language knowledge, trainings and performance information, diploma information, CV information.
· Employment Data; We can collect employment data such as registration number, position name, department and unit, title, insurance entry / pension, social security number, projects worked, total monthly overtime information, time off data.
· Transaction Security Data; If you connect to the Entertech network, we may collect your data such as IP address information, website login and exit information.
· Marketing Data: We may collect your data such as shopping history, survey, information obtained through campaign work (see cookie policy)
· Visual and Audio Recordings; We may collect your data such as visual and audio recordings.
· Social Media Data; Data collected due to social media features that allow you to share information with your social networks and interact with us on various social media sites.
· Health Data; It refers to data such as disability status, health reports, health declaration document, health reports, pregnancy information, occupational disease records, employment examination form, blood type information, criminal record, information on legal proceedings, information on religion in the identity card (old).

Other Unique Identifying Information; Information you provide when you interact with our service centers, help desk or other customer support channels online, in person by phone or mail, your responses to customer surveys, or additional information you provide to us so that we can facilitate the delivery of Entertech services and respond to your questions are examples of other unique identifying information we collect from you.
Where necessary, as part of our anti-corruption compliance program and in line with our legal obligations, we obtain information to conduct due diligence audits of your business communications data.
Within the scope of our business activities in line with the data processing conditions specified in Articles 5 and 6 of the Personal Data Protection Law, we collect the data of all relevant parties within the scope of our business activities in line with the legal regulations and the continuity of our business processes, the establishment, protection, use of the right, to fulfill our contractual obligations, to carry out operations and for other purposes specified below.
For the Purpose of Customer Support and Satisfaction; We process for the purposes of comprehensive customer support, providing a seamless customer experience, personalizing the Entertech services and communications you receive.
Providing Communication and Administrative Purposes; We also communicate to provide information about Entertech services, however, your data is processed for reasons such as responding to your questions or requests, communications regarding service completion or post-service support operations, legally required communications.
For the Purpose of Providing Transaction Support; Entertech affiliates are processed and contacted for the purposes of completing purchases related to our products or services, processing payments, arranging shipments and deliveries, facilitating repair and return transactions.
For Security Purposes; We process your data to ensure the integrity and security of our website, products, services and to prevent security threats, fraudulent activities or other criminal or malicious activities that may compromise your information. We may also take additional security measures such as CCTV (Closed Circuit Camera System) to protect our locations. For the Purpose of Ensuring Employment; We process personal data of employees and employee candidates for the purposes of fulfilling all business operations such as evaluating job application requests and suitability for the relevant position, conducting, finalizing and communicating recruitment processes within the framework of human resources policies, conducting human resources processes, fulfilling obligations arising from employment contracts, fringe benefits and legislation, conducting legal and legal processes, conducting occupational health and safety processes, organizing and conducting business activities.
For the Purposes of Execution of Supply Chain Management Processes; We process the personal data of external providers and their officials whose services we benefit from for the purposes of conducting and maintaining business relations with external providers, conducting emergency management processes, conducting activities in accordance with the legislation, conducting logistics activities, conducting goods / service procurement processes, conducting contract processes, following up requests / complaints, ensuring the security of data controller operations. For Business Activities Purposes; Your data is processed for the purpose of carrying out ordinary business activities, including the provision of services, conducting business research and analytics, corporate reporting and management, quality assurance practices (which may include monitoring or recording calls to our customer support services).
For Research and Innovation Purposes; Your data is processed in order to develop new products, features and services by using research and development tools and combining data analysis activities.
For Marketing Purposes; Your data is processed in order to improve Entertech services and to carry out research and development for you.
Compliance with Laws; Your data is processed for the purposes of responding to applicable laws, regulations, court orders, government and law enforcement authorities' requests to operate our services and products appropriately, to protect ourselves, our users and our customers, and to resolve any customer disputes.

In addition to the above-mentioned purposes; Your personal data is processed within the scope of similar sub-purposes, provided that it is connected and measured with the purposes such as carrying out information security processes, carrying out financial and accounting affairs, ensuring the security of data controller operations, collection and following legal processes when necessary.

Method and Legal Grounds for Collecting Personal Data

Your personal data may be collected for the above-mentioned purposes, in accordance with the basic principles stipulated in the Law and in accordance with the basic principles stipulated in Article 5 of the Law, in case of actual impossibility, the legal obligation of the data controller, the establishment and performance of the contract, our legitimate interest as the data controller, the establishment, use and protection of the right, by our company by automatic or non-automatic means, through direct interactions from all kinds of service points, through the communication channels you reach us (telephone, mail, fax, social media, call center, web, survey, subscriber transactions, etc.), through automatic technologies or interactions (see Cookie Policy), through third parties or public sources (from various third parties that help provide services and services), from official institutions, applications, etc. b), through automated technologies or interactions (see Cookie Policy), through third parties or publicly available sources (from various third parties that help provide services and services), from official institutions, from our applications and business partners from which support services are received, from closed circuit recording systems.

In addition, in accordance with the Turkish Commercial Code No. 6102, Labor Law No. 4857, Turkish Code of Obligations No. 6098, Law No. 6563 on the Regulation of Electronic Commerce, 30998 Regulation on Commercial Communication and Commercial Electronic Messages, Occupational Health and Safety and Tax Legislation and other related legislation, your personal data, ensuring the business relationship, the execution of the service, the provision and continuity of services related to our activities, ensuring employment and carrying out human resources activities, The data may be processed by automatic or non-automatic methods as long as the purpose of data processing is valid in order to provide quality and accurate services within the scope of the contract and to measure and increase the quality of service, to provide information about the services, to transmit announcements and warnings, supplier relations, information research, determination and implementation of our company's strategies, customer service, planning, statistics, satisfaction studies, and to carry out the work and transactions to be carried out in accordance with the information storage, reporting and information obligations of our company requested by public institutions.

To Whom and For What Purposes the Processed Personal Data Can Be Transferred

We keep your Personal Data confidential. We do not sell, rent or trade your Personal Data to others. Unless we have your consent, we do not use or share your Personal Data in ways that are unrelated to the individuals we identify at the points where you provide data or as described in a controlling agreement.

Your personal data collected, provided that it is limited and measured for the purposes specified in the Disclosure Text, depending on and limited to the reasons that require its transfer within the scope of the Law and the relevant legislation; In carrying out our Business and Commercial activities, we hire service providers or Business partners to manage or support certain elements of the service on our behalf.
Your data may be shared with security companies, logistics companies, operator companies, banks, insurance companies, consulting firms, consultants, lawyers, customer support, parties providing services on our behalf, such as installation, technology services, e-mail service providers, data hosting, debt collection and management or support of the Entertech website and Entertech subsidiary companies in order to fulfill our contractual responsibilities.

Our service providers and business partners are contractually required to protect the personal data they receive from us and are prohibited from using personal data for any purpose other than that specified by Entertech.

We may also share your personal data when we believe in good faith that we have an obligation to do so, such as respond to plenary information requests from law enforcement agencies, regulators, courts and other government authorities, including to meet national security or other law enforcement requirements; comply with all laws, regulations, subpoenas or orders; investigate and assist in the prevention of security threats, fraud or other criminal or malicious activity, Enforce/protect the rights and property of Entertech and its affiliates, or protect the rights or personal safety of Entertech employees and third parties on or using Entertech property, to the extent permitted by applicable law and in accordance with the requirements of applicable law.

Furthermore, due to the transfer and storage technologies used, it is included in the scope of transfer abroad.

We assure you that your personal data will not be processed by our company for purposes other than those specified in this disclosure document.

Situations Where We May Process Your Personal Data Without Your Explicit Consent as Required by Law

Pursuant to Article 5 of the Law, although explicit consent is one of the conditions for personal data processing under the law, it is not the only element that gives legality to the data processing activity. The Law also stipulates conditions other than explicit consent for data processing. Accordingly, in the presence of one of the following conditions, it is possible to process personal data without seeking the explicit consent of the data subject:

a) Explicitly stipulated in the law,
b) It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his/her consent due to actual impossibility or whose consent is not legally valid,
c) Provided that it is directly related to the conclusion or performance of a contract, it is necessary to process personal data of the parties to the contract,
ç) It is mandatory for the data controller to fulfill its legal obligation,
d) It has been made public by the person concerned,
e) Data processing is mandatory for the establishment, exercise or protection of a right,
f) 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 data subject.

How Do We Protect Your Data?

All necessary technical and administrative measures are taken for the security of all personal data collected by Entertech. Within this framework, we take physical, technical, organizational and managerial measures against unauthorized access, misuse, disclosure or alteration in accordance with the requirements of the Personal Data Security Guide published by the LPPD board, ISO/IEC 27001 Information Security, ISO/IEC 27017 Cloud Services Information Security, ISO/IEC 27701 Privacy Information Management standards, European Union General Data Protection Regulation GDPR.

What are Your Rights Regarding Personal Data?

Regarding your personal data have a right to
• Learn whether your personal data is being processed or not,
• Request information if your personal data has been processed,
• Learn the purpose of processing personal data and whether they are used for their intended purpose,
• Know the third parties to whom your personal data is transferred domestically or abroad,
• Request correction of your personal data in case of incomplete or incorrect processing,
• Request the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVK legislation,
• Request that the situation be notified to third parties to whom we transfer your personal data, when you request the correction of incomplete or incorrect data and the deletion or destruction of your personal data,
• Object to the result in case a result arises against you by analyzing the processed data exclusively through automated systems and
• If you suffer damage due to unlawful processing of personal data, you have the right to demand compensation for this damage.

How Can You Exercise Your Rights Regarding Personal Data?

In accordance with paragraph 1 of Article 13 of the Personal Data Protection Law, you can make your request to exercise your rights mentioned above with the following methods and information in accordance with the "Communiqué on the Procedures and Principles of Application to the Data Controller" published on March 10, 2018, No. 30356.
Information required in the application content;
1. Name and surname of the applicant.
2. If the applicant is a citizen of the Republic of Turkey, Identity Number, if not, Passport number or Identity number, if any, together with his/her Nationality.
3. Applicant's residential or workplace address for notification.
4. Applicant's e-mail address, telephone or fax for notification.
5. The subject of the applicant's request.
6. Information and documents related to the subject of the applicant's request.

Application Methods;
1. The applicant can personally fill out the "Application Form" to Entertech Inc. address and deliver it to our headquarters by hand with a closed envelope and a note on the envelope with the note "Information Request as required by the Law on the Protection of Personal Data". 2. The applicant may send a notification to Entertech Inc. address through a notary public, but the phrase "Information Request as required by the Law on the Protection of Personal Data" must be added on the notification envelope.

3. With the «Secure Electronic Signature» defined in the Electronic Signature Law No. 5070, the applicant can personally apply to our company's Registered Electronic Mail entertechg@hs03.kep.tr with the note "Information Request in accordance with the Law on the Protection of Personal Data" in the subject section.

You can find our application form regarding your rights mentioned above here.