WITHIN THE SCOPE OF THE PROTECTION OF PERSONAL DATA IN ACCORDANCE WITH THE LEGISLATION ON THE PROTECTION OF PERSONAL DATA

INFORMATION TEXT

(“Information Text”)

1. PERSONAL DATA AND DATA CONTROLLER

This Information Text has been prepared by Akan Law Firm & Mediation (“Akan” or “Data Controller”) as the data controller within the scope of the Law No. 6698 on the Protection of Personal Data (“LPPD”) which is promulgated in the Official Gazette dated 07.04.2016 and numbered 29677, the Communiqué on the Procedures and Principles to be Followed in the Fulfilment of the Obligation to Inform and other relevant legislation and the decisions and regulations of the Personal Data Protection Board in order to fulfil the obligation to inform.

This Information Text has been prepared by Akan in order to inform its clients, potential clients, Website visitors, business and solution partners, persons from whom it receives services in accordance with a contractual relationship, its employees and interns, intern candidates and including but not limited to any other natural third person with whom it is in contact and from whom it obtains data (“Data Subject(s)”) within the scope of ensuring data confidentiality and security in accordance with the article titled “Obligation of Data Controller to Inform” in Article 10 of LPPD in relation to the identity of the Data Controller, the method and legal basis of collection of personal data, the purpose of processing such personal data, to whom and for which purposes the processed personal data may be transferred, the obligations of the Data Controller regarding the protection of personal data and what measures it takes, the duration of data processing and what the rights listed in Article 11 of LPPD are and how they may be used, the ways of submitting questions and suggestions and the effective period of the changes made.

In this context, personal data is any information relating to an identified or identifiable natural person including but not limited to data such as communication data, identity data, visual and audio data such as photographs, voice recordings, image and photo recording data, occupation and education data, IP and usage data belonging to Data Subjects (“Personal Data”).

The term “Personal Data” used in this Information Text also includes “Special Categories of Personal Data”. Special Categories of Personal Data means data relating to the race, ethnic origin, political opinion, philosophical belief, religion, religious sect or other belief, appearance, membership to associations, foundations or trade-unions, data concerning health, sexual life, criminal convictions and security measures, and the biometric and genetic data.

Your Personal Data mentioned above may be processed by Akan within the scope described below. You may contact Akan through the following contact information.

Akan Telephone Number: +90 212 351 36 00

Akan E-Mail address: [email protected]

Akan Internet Address: www.sanakan.av.tr

Akan Posting Address: Evliya Çelebi Mah. Sadi Konuralp Cad. No: 5/2 Beyoğlu İstanbul

2. COLLECTION METHODS OF PERSONAL DATA AND ITS LEGAL BASIS

Personal Data belonging to the Data Subjects may be processed within the scope of their explicit consent or within the scope of LPPD and other relevant legislation without seeking the consent of the Data Subject with one or more reasons of whether (i) “it is expressly provided for by the laws”, (ii) “processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract”, (iii) “it is necessary to comply with a legal obligation of the data controller”, (iv) “personal data have been made public by the data subject itself”, (v) “data processing is necessary for the establishment, exercise or protection of any right”, (vi) “processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject”.

Akan collects the Personal Data of the Data Subjects by means of physical or electronic transmission and data entry through the Website. In case of entering into a commercial or legal relationship with Akan in any way, Personal Data may be processed partially or wholly by Akan verbally, in writing or electronically either through automated means or by non-automated means with the explicit consent of the Data Subject or on the legal basis of (i) “processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract”, (ii) “it is necessary to comply with a legal obligation of the data controller”, (iii) “personal data have been made public by the data subject itself”, (iv) “data processing is necessary for the establishment, exercise or protection of any right”, and (v) “processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the Data Subject” stipulated in Article 5 Paragraph 2 of LPPD.

If there is no previously obtained explicit consent of the Data Subject, it is necessary to obtain an explicit consent declaration as per legal obligation for the Personal Data processed which does not fall into one of the reasons for compliance with the law mentioned above and stipulated in paragraph 2 of Article 5 of LPPD but as limited to the purposes of providing the services in question through the Website and ensuring the security of the Personal Data and/or shared information of the Data Subject. In such case, we hereby inform you that the explicit consent in question may be given electronically, with the same legal nature and value as the explicit consent with a written signature.

3. PURPOSES OF PROCESSING PERSONAL DATA

Personal Data is processed by Akan for the following purposes in accordance with Article 4 of LPPD and the rules of law and good faith;

• Establishment and performance of the legal consultancy contract,
• Fulfilment of all kinds of legal services and consultancy activities within the scope of the Attorneys’ Act and ensuring service continuity and reliability,
• Activities carried out to fulfil the obligations set out in the Attorneys’ Act,
• Carrying out legal processes and providing legal information,
• Resolution of legal disputes,
• Fulfilment of all legal and contractual obligations,
• To be able to use and protect the rights and requests arising from the legislation in force and to be able to process the requests,
• Prevention of fraud and false, incomplete or fraudulent declaration, ensuring security,
• Ensuring that the Personal Data is accurate and up to date,
• Meeting information requests and other requests from administrative and judicial units and public institutions or organisations or judicial authorities or relevant law enforcement agencies,
• Conducting client relations,
• Planning and organisation of strategic and operational processes,
• Job and internship application evaluations and human resources applications,
• Budget management and reporting,
• Improving the service provided and increasing the quality of service,
• Observing the visit traffic of the Website,
• Interpretation, development and improvement of the use of the Website,
• Carrying out cooperation and project processes with business partners and sharing the necessary information and/or data with business partners in line with the requirements within this scope,
• Recording the address and other necessary information for communication,
• Ensuring the submission of the invoice, management and control of the invoicing and payment process.

Akan shall process within the conditions and purposes specified in Articles 5 and 6 of LPPD in accordance with the law, morality and integrity as accurately and up-to-date to the extent that it was transmitted to Akan for specific, clear and legitimate purposes in connection with the purposes for which it is processed in a limited and measured manner and in a manner to adhere to the periods specified in LPPD and other relevant legislation. Personal Data shall be processed only for the purposes specified in LPPD, other relevant legislation and this Information Text and they shall be erased, destructed or anonymized automatically or upon the request of the Data Subject in the event that the reasons for the processing no longer exist and provided that the cases whereby legal storage necessities are reserved.

4. STORAGE PERIOD OF PERSONAL DATA

Personal Data are stored by Akan in line with legal obligations by taking into account the provisions of LPPD and other relevant legislation, the periods determined by all relevant legislation including Article 138 of the Turkish Criminal Law which is promulgated in Official Gazette dated 12.10.2004 and numbered 25611, the statute of limitations and the periods required by the purpose of processing. After the expiration of the relevant periods, Personal Data shall be erased, destructed or anonymised automatically or upon your request. If a period of time is not regulated in the legislation regarding how long Personal Data should be stored, Personal Data is processed for the period required by the processing purposes of Personal Data listed in this Information Text and then erased, destructed or anonymized.

5. SHARING AND TRANSFER OF PERSONAL DATA

The Personal Data of the Data Subjects are not disclosed and transferred to any third parties other than the lawyers and employees employed in Akan, interns who are doing internship, business partners with whom Akan cooperates or plans to cooperate and/or receives or plans to receive consultancy, support, legal services domestically and/or abroad and other third parties who are required to be disclosed during the follow-up of legal processes in accordance with Article 8 of LPPD within the framework of the confidentiality obligation under the Attorneys’ Act.

Personal Data obtained by Akan with the methods and for the purposes described above may be shared in accordance with Article 8 of LPPD within the knowledge of the Data Subject with all types of official public institutions and organisations such as and primarily courts and enforcement offices, notaries, land registry offices, tax offices in order to carry out all kinds of legal services and consultancy activities within the scope of the Attorneys' Act and other relevant legislation as well as with administrative and judicial authorities or relevant law enforcement agencies or public institutions or organisations and judicial authorities authorised to request such data in order to resolve legal disputes within the framework of Akan’s legal obligations or upon request pursuant to the relevant legislation provided that adequate and effective measures are taken as per the security and confidentiality principles specified in the LPPD and other relevant legislation.

Akan takes the necessary technical, administrative and legal measures to prevent any violation of rights during data transfer to third parties. In this context, Akan is not liable under any circumstances for the data protection policies of the third party receiving Personal Data and for any breaches that occur in the risk area under the responsibility of the third party.

6. PERSONAL DATA SECURITY

Akan’s obligations to provide the security of Personal Data is (i) to inform the Data Subjects in accordance with LPPD and other relevant legislation during the acquisition of Personal Data, (ii) to prevent the processing and access of Personal Data in breach of the law and integrity rules, LPPD and other relevant legislation; (iii) to take all kinds of technical, administrative and legal measures to provide that Personal Data is kept in accordance with LPPD and other relevant legislation and with appropriate period; (iv) to keep Personal Data accurate and up-to-date and, when necessary, to erase, destruct or anonymise it in accordance with LPPD and other relevant legislation; and (v) to carry out or procure the carrying out of all necessary audits in this context.

7. RIGHTS WITHIN THE SCOPE OF LPPD

Data Subjects have the following rights on Personal Data processed by Akan within the scope of Article 11 of LPPD;

a) to learn whether Personal Data is processed or not,

b) to demand for information as to if Personal Data has been processed,

c) to learn the purpose of the processing of Personal Data and whether such Personal Data is used in compliance with the purpose,

d) to know the third parties to whom Personal Data are transferred domestically or abroad,

e) to request the rectification of the incomplete or inaccurate Personal Data, if any,

f) to request the erasure or destruction of Personal Data under the conditions referred to in Article 7 of LPPD,

g) to request reporting of the operations carried out pursuant to sub-paragraphs (e) and (f) above to third parties to whom Personal Data have been transferred,

h) to object to the occurrence of a result against the person itself by analyzing the processed Personal Data solely through automated systems,

i) to claim compensation for the damage, if incurred, arising from the unlawful processing of Personal Data.

In order to exercise your rights mentioned above, you may submit your request containing the necessary information to identify your identity and your requests including your explanations regarding which right you wish to benefit among the rights specified in Article 11 of LPPD to the e-mail address of [email protected] or you may submit it in writing and with wet signature or by other methods to be determined by the Personal Data Protection Board to the address of Akan at “Evliya Çelebi Mah. Sadi Konuralp Cad. No: 5/2 Beyoğlu Istanbul” in person by hand, through a notary public or by other methods specified in LPPD. Please confirm the current application methods and content with the legislation before applying.

We kindly request that your application contains all of the following elements:

• Name, surname and wet signature.
• Republic of Turkey identification number for citizens of Republic of Turkey, nationality and passport number (or potential tax and/or identification number, if any) for foreigners.
• Residential or workplace address to be taken as basis for notification.
• Electronic mail address, telephone and fax number to be taken as basis for notification (if any).
• Subject of the request.

The Data Controller reserves the right to request additional information and documents during the application or during the evaluation of the application, if necessary.

Your requests in your application shall be finalized free of charge by Akan as soon as possible and within thirty (30) days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost for Akan, the fee in the tariff determined by the Personal Data Protection Board shall be collected. The Data Controller accepts the request or rejects it by explaining the reason and notifies the Data Subject in writing or electronically of its response. If the request in the application is accepted, the Data Controller shall do what is necessary. If the request arises from the fault of Akan, the collected fee shall be returned to the relevant person.

This Information Text was prepared on 01.12.2017 and was lastly updated on 21.01.2025. This Information Text may be updated, amended or repealed by Akan at any time in order to adapt to changing conditions and legislation. In case of any amendment in the Information Text, the effective date and content of the Information Text shall be updated by Akan and shall enter into force immediately and automatically upon its publication in the Website without the need for any additional approval or acceptance and shall become effective for the Data Subjects on the date of its publication.

We hereby declare as "Data Controller" within the scope of LPPD.

Akan Law Firm & Mediation

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ACCEPTANCE AND DECLARATION

I accept and declare that I have read and understood all of the Information Text above which has been prepared in relation to the identity of the data controller, by whom and for which purposes my personal data are processed, to whom and for which purposes my processed personal data may be transferred, the method and legal basis of collection of my personal data, the obligations of the data controller regarding the protection of my personal data and what measures it takes and the duration of data processing as per Article 10 titled “Obligation of Data Controller to Inform” of LPPD as well as my rights listed in Article 11 of LPPD and how they may be used, the ways of submitting questions and suggestions and the effective period of the changes made and which have been notified to me and that I have been informed in detail by Akan which has the title of data controller in this respect.
I accept, declare and undertake that I hereby give my explicit consent with my own free will with my consent herein to each of the processes (including transfers) specified in the Information Text above and subject to my explicit consent. I hereby accept and declare that I have also been informed on the fact that my explicit consent is in no way a prerequisite for the realization of a transaction, the provision of a service and therefore it is not obligatory for me to give explicit consent and that my Personal Data will be processed within the scope of the policies and procedures pertaining to the protection of Personal Data and confidentiality and in accordance with the matters contained in the Information Text and that I can always withdraw my explicit consent in terms of the processes made with my explicit consent.