Privacy Policy and of Personal Data ('Clarification Notice')

KLE Bilgi Teknolojileri A.Ş. takes security measures at the highest possible level in order to ensure that your personal data is collected, stored and shared in accordance with law and is kept confidential.

Our aim; is to inform you in the most transparent manner regarding the way of receiving your personal data, the purposes of processing, the persons to whom it can be transferred, legal reasons and your rights in the direction of your satisfaction under the Constitution of Turkey, the International Conventions on Human Rights of which Turkey is the party, the Code of Protection of Personal Data numbered 6698 ('KVKK'), and other relevant legislation.

a) Data Protection Responsible :

Accordance with the KVKK, your personal data could be collected and processed by KLE Bilgi Teknolojileri A.Ş. (“KLE”) as data protection responsible to the extend described below.

b) Which Personal Data is Processed?

Personal data refers to any kind of information about the identity or identifiable person. Since products and services that people use, or requests and benefits, etc. may differ from person to person, all the information given below might not be applicable the for every real person. The personal data processed are given below, but not in that limited number.

Identity and Communication Information: ID number, name, surname, place of birth and date, marital status, gender, identity document and other identification information and other information that can identify your identity; contact information address, phone/fax number, such as e-mail address,

Subscription Information: Information about the customer number, subscription number, subscription type and status, subscription and usage of products and services; information on debt and payments, address information, segment information, e-billing information, information in the invoice and its contents, financial and debt information, payment tendencies, payment type, subscription status (cancellation, active etc.) personal information such as registration, personal information such as registration, telephone number, e-mail address, personal information that can identify the subscription, IP number, tariff and package information, basic subscription information such as limit and speed, campaign information,

Traffic and Location Information: Address information, location data, abroad country information and other similar locations, location information,

Information on Sales Channels: Information and documents you transmit during the sales process; your voice recordings which are kept in accordance with data and call center standards obtained when communication is made via e-mail, letter and other means; your voice record to be used as a confirmation of identity in your request; your data obtained through sales such as the demand and transaction information in the sales channels,

Information Regarding Use of Product and Service: Your preferences, habits and other usage information related to the use of products and services and cookies, application and usage information that can be collected via mobile applications,

In addition, your personal data may be processed, if you purchase any service or product of KLE; or register to get such particular service or product; or subscribe to KLE-related news bulletins, notices and other services; or if you have questions or complaints about a product or service; or you participate in prize draws or surveys; or you may be able to visit our internet site; or you visit these sites.

c) For what purposes Personal Data is processed:,

Your personal data will be processed in the format required by the Law in accordance with the principle of good faith, as accurate and up to date, in accordance with the law of the Republic of Turkey only for certain clear and legitimate purposes. Your personal data might be handled or processed by KLE and can be kept in systems and archive centres for the following purposes but not limited to:,

• submission, pricing and invoicing of products and services; the fulfilment and following-up of the transactions you have requested regarding the products and services ordered, purchased and / or used,,

• promotion and marketing of products and services; diversification of products and services, measurement; communication with you in this regard, being informed about discounts, campaigns and conditions; providing facilities like membership and utilization and fulfilment of the required procedures for the use of such opportunities,,

• confirmation of information and documents regarding your identity when necessary and taking required actions to prevent fraud, loss and fraud,,

• use for the development, inspection and analysis of products and services; evaluation of your interest in products and services, investigation of customer satisfaction; call centre service provision; answering questions, complaints and notices from you,,

• presentation, and the promotion and financial reconciliation of the products and services that we provide with our business partners and other third parties,,

• preservation of your information which must be kept in accordance with the relevant legislation; copying, back-up, control of the consistency of your information to avoid information loss and taking all necessary technical and administrative measures to ensure the security of your information,,

• delivery of electronic communications services, traffic management, marketing activities and informational devices, strategies, planning and business development, measurement of service quality and any other similar purposes.,

Your personal data that you share with our company, customer, supplier, dealer or employee can be processed, measured, transferred and classified to third parties in Turkey and abroad in accordance with KVKK and in connection with our activities, services and purposes.

c) For whom and for what purpose Personal Data can be transferred:

Your personal data may be shared within KLE in accordance with the KVKK and the applicable legislation for the purposes stated above, and also can be transferred, stored and used or classified for profiling; domestically and abroad, including but not limited to; our business partners, our business contacts, real or legal persons who process data on behalf of KLE, our service agents and subcontractors in the direction of the service we provide, or in cases where regulatory authorities such as regulatory supervisory agencies and Social Security Institution, such as authorities, ministries, judicial authorities.

d) The Method of Collection of Your Personal Data and the Legal Reason:

Your personal data can be collected by KLE or the actual or legal persons who process data on behalf of our Company, with the way of verbal, written, mobile application or electronically for the purpose and scope stated above but not limited to.

e) What Rights do you have as the data owner:

Within the frame of KVKK and other applicable legislation, your rights are:

i) to learn whether your personal data is processed,

ii) to request information about your personal data if it has been processed,

iii) to learn the purpose of processing personal data and whether they are used appropriately for their purpose,

iv) to know the third parties to whom your personal data is transferred in Turkey or abroad,

v) to request your personal data to be corrected if it is incompletely or incorrectly processed,

vi) to request your personal data to be deleted or destroyed within the framework of the provisions of the KVKK legislation,

vii) when you request the deletion or destruction of your personal data or correction of missing or incorrect data, to request third parties to be notified of such situation,

viii) to object to the existence of any negative consequence as a result of the analysis of processed data exclusively through automated systems,

ix) to claim compensation for damages if your personal data is processed unlawfully.

You may submit your request to exercise your rights stated above in writing or in accordance with another method if it was designated by the Personal Data Protection Board.

You can send your request in written format with your wet signature by mail or by hand, to Ikitelli OSB, Yıldız Teknik Üniversitesi Teknopark, YTÜ Teknopark Sok. No1/Z19 Başakşehir, Istanbul; or sending it to with a secure electronic signature.

While making an application exercising your right that you have a data owner please take into account the following points. Your request should be clear and understandable and include the identity and address information of the application and should certify the identity of the applicant, and if you make an application on behalf of anybody, you should certify that you are specifically authorized in this matter.

This Clarification Notice will always be up-to-date and available at the the KLE’s website, or its application or link.

Sincerely yours, KLE Bilgi Teknolojileri Anonim Şirketi