Personal Data Protection

OMWO Teknoloji A.Ş. attaches great importance to the confidentiality and security of your personal data and shows the highest level of sensitivity to the principle of safeguarding the fundamental rights and freedoms protected by the Turkish Constitution, especially the privacy of individuals. 

In accordance with Turkish Act No. 6698 on the Protection of Personal Data (the “KVKK”) and the relevant laws, in its capacity as data controller OMWO Teknoloji A.Ş. may process, record, store, update and maintain in order to continue and maintain its services, disclose to third parties, share, and anonymize any kind of information and documents, including the personal data provided by you (first name, last name, Turkish ID no., address, place of birth, date of birth, etc.), as well as all types of sensitive data (health information, biometric and genetic information, personal appearance, membership in associations, foundations, trade unions, criminal convictions, data on security measures, religion, ethnic origin, etc.).

OMWO Teknoloji A.Ş. will take all the necessary administrative and technical measures to protect the privacy of personal data processed in accordance with the relevant laws and regulations. Pursuant to the KVKK, personal data is processed in accordance with the law and the principle of honesty, while the accuracy of the data is ensured and updated as necessary. Care is taken to ensure that the data is processed for specific, explicit and legitimate purposes, that processing is only conducted in relation to the intended purpose, that it is limited and proportionate to that purpose, and that data is kept for lengths of time provided for in the relevant legislation or for lengths of time required for the purpose for which it is processed.

If the processed data is sensitive personal data as defined by the KVKK, personal data other than that relating to health and sex life may be processed without the express consent of the data subject in the cases provided for by the law. Personal data relating to health and sex life may be processed by persons or authorized institutions and organizations subject to confidentiality only for the purposes of public health protection, preventive medicine, medical diagnosis, treatment and care, health service planning and management, and financing, without the need to obtain the express consent of the data subject.

A. Purposes and legal grounds for the processing of personal data

Subject to the provisions and purposes stipulated under Articles 5 and 6 of the KVKK, your personal data may be processed for the following purposes: fulfillment, maintenance, execution, development of our activities in accordance with all information, documents, relevant laws and regulations, conducting of campaigns and similar activities to promote services and activities, sending out invitations, notification of new services, fulfillment of the requirements of contracts signed or to be signed, planning, statistics, conducting satisfaction surveys, ensuring security, sending emails, e-bulletin subscriptions, social media posts, filling out printed forms at events or during face-to-face interviews with employee candidates or written application forms, sending digital application forms through digital platforms, processing of personal data collected during recruitment processes in the event that candidates send their resumes by email, cargo, and similar methods, or by means of consultancy firms or by telephone, due to checks and inquiries that ensure the confirmation of the information provided by the candidate, special categories of personal data collected according to the nature of the job, the maintenance of the legal and commercial security of persons with whom we have a business relationship, determination and implementation of legal and financial affairs and similar commercial and business strategies, carrying out HR and accounting policies, conducting physical security checks and audits, complying with domestic and international legislation, complying with information transfer, storage and reporting obligations required by public institutions or other authorities, or providing you with continuously better and more reliable services.

B. Duration of storage of personal data

OMWO Teknoloji A.Ş. shall store personal data only for the periods specified in the relevant legislation or as necessary for the purpose for which it is processed. In this regard, it shall first determine whether a time limit for the retention of personal data is specified in the relevant legislation or not; if a time limit is specified, it shall act in accordance with that time limit; if no time limit is specified, it shall retain personal data for as long as is necessary for the purpose for which it is processed. Personal data shall be deleted, destroyed, or anonymized when the time limit expires or the reasons for processing it cease to exist.

C. Method for collection of personal data

Your personal data may be collected orally, in writing or electronically through automated or nonautomated means, through our website, social media channels, parties with whom we have a business relationship and/or from which we receive services that complement our activities, as well as innetwork organizations and other similar channels.

D. Transfer of personal data

Under the conditions and purposes set forth in Articles 8 and 9 of the KVKK, your personal data may be transferred to the company’s officers, shareholders, employees, business partners, service providers or third parties, legal, financial and tax advisors, auditors, consultants, organizations or individuals, and any public bodies and organizations authorized by law, such as the SGK (Turkish Social Security Institution), ministries, judicial authorities and/or foreign countries, in order for OMWO Teknoloji A.Ş. to fulfill its objectives within the scope of its activities, as well as to establish and implement strategies and ensure the implementation of human resources policies. If your personal data is transferred overseas, adequate protection must be ensured in the country to which the personal data is transferred, and in the absence

of adequate protection, the data controllers in Turkey and in the foreign country concerned must promise adequate protection in writing and obtain the approval of the Kişisel Verileri Koruma Kurumu (Turkish Personal Data Protection Authority). 

E. Rights of the data subject under Article 11 of the KVKK

As the data subject, you have the right to request the following from OMWO Teknoloji A.Ş.:

   • To find out if your personal data is being processed or not.

   • To request information if your personal data has been processed.

   • To learn the purpose for which your personal data has been processed and whether it has been used for its intended purpose.

   • To know the names of the third parties to whom your personal data is transferred domestically or abroad.

   • To request the rectification of errors in the event of incomplete or inaccurate processing of your personal data.

   • To request the rectification of errors in the event of incomplete or inaccurate processing of your personal data and to request that any action taken in this context is communicated to the third parties to whom your personal data has been transferred.

   • To request the erasure or destruction of your personal data when the reasons for it being processed cease to exist, even if the data has been processed in accordance with the provisions of the KVKK and other relevant provisions, and to request that any action taken in this context is communicated to the third parties to whom your personal data has been transferred.

   • To object to any detrimental impact resulting from your data being analyzed solely by automated systems.

   • To obtain compensation in the event of damages caused by the unlawful processing of your personal data.

   • It is important that the information/data you provide is accurate and kept up to date in order to exercise the rights over your data in accordance with the KVKK and other relevant legislation, and the responsibility arising from the provision of incorrect information rests solely with you.

   • It is important that the information/data you share is correct and transmitted accurately. This is necessary in order for you to exercise your rights and you are responsible for any liability arising from the provision of incorrect or inaccurate information.

   • We reserve the right to charge you for any costs we incur in fulfilling your requests in accordance with the tariff regulated in Article 13 of the KVKK “Information Request to the Data Controller”.

F. Cases in which personal data may be processed without the express consent of the data subject in accordance with the KVKK:

   • Where this is clearly provided for in the law.

   • Where it is mandatory for the protection of the life or physical integrity of a person who is unable to provide their consent due to it being impossible for them to do so or their consent not being legally valid.

   • Where it is necessary to process the personal data of parties to a contract, provided that the processing is directly related to the establishment or execution of that contract.

   • Where it is mandatory for the data controller to fulfill its legal obligation.

   • Where it has been made public by the data subject themselves.

   • Where data processing is mandatory for the establishment, exercising or protection of a right.

   • Where data processing is strictly necessary for the purposes of the data controller’s legitimate interests, provided that it does not adversely affect the fundamental rights and freedoms of the data subject.

G. Principles laid down in the KVKK

OMWO Teknoloji A.Ş. shall act in accordance with the Turkish Constitution, the general principles of the KVKK, and other relevant legislation on the protection and processing of personal data, and shall also observe the following principles with great care:

   • Ensuring that personal data processing activities comply with the law and the rule of honesty.

   • Ensuring that personal data is accurate and up to date when necessary.

   • Only processing personal data for specific, explicit, and legitimate purposes.

   • Ensuring that personal data is relevant, limited, and proportionate to the purpose for which it is processed.

   • Keeping the data for the length of time provided for by the relevant legislation or necessary for the purpose for which it is being processed.

H. Methods by which data subjects may exercise their rights/how to send an information request

If the data subject requests information in writing on any of the points mentioned above in Article E, the request must be answered no later than 30 days after it is forwarded to our institution in its capacity as data controller. If the action taken incurs additional costs, we reserve the right to charge the fees according to the tariff established by the Turkish Personal Data Protection Authority.