D TECH CLOUD
PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA
Data Controller: D Tech Bulut Bilişim Anonim Şirketi (“D Tech Cloud”)
Demirören Medya Center, 100. Yıl Mah., 2264 Sok. No:1, Bağcılar / Istanbul
As D Tech Bulut Bilişim A.Ş. (hereinafter referred to as “D Tech Cloud”), we have prepared this Privacy Notice on the Processing of Personal Data (hereinafter referred to as the “Privacy Notice”) in order to inform the data subjects listed below regarding the processing, storage and transfer of your personal data within the scope of our activities arising from Law No. 6698 on the Protection of Personal Data (hereinafter referred to as the “KVKK”) and the relevant legislation and legal regulations.
- Our Job Applicants
- Online Visitor
- Representatives of Companies Purchasing Products or Services
- Representatives of Our Suppliers
- Employees of Our Suppliers
- Our Visitors
- Our Shareholders and Partners
| Employees |
Detailed information regarding the personal data processed in relation to Employees is published on the Information Security Management System Platform in a manner accessible only to our employees, and they have been provided with detailed information in this regard. If you are a former employee of D Tech Cloud, you may exercise your rights regarding the personal data processed during your period of employment by using any of the application channels specified in the “How Can You Exercise Your Rights?” section of this Privacy Notice. |
| Job Applicants | |
| Identity Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
|---|---|
Name, Surname, Date of Birth, Marital Status, Turkish ID Number, Photograph, Nationality (if stated in the CV), Other information shared by the job applicant in the CV, |
Conducting Job Applicant Recruitment Processes, Conducting Communication Activities, Planning Human Resources Processes, Conducting Business Activities, Conducting Retention and Archiving Activities, Conducting Contract Processes |
| Contact Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
E-mail Address, Contact Address, Mobile Phone Number |
Conducting Job Applicant Recruitment Processes, Conducting Communication Activities, Planning Human Resources Processes, Conducting Business Activities, Conducting Retention and Archiving Activities, Conducting Contract Processes |
| Personnel Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
CV Information, Military Service Status Information, Reference Information, Education Status Position/Title Information |
Conducting Job Applicant Recruitment Processes, Conducting Communication Activities, Planning Human Resources Processes, Conducting and Supervising Business Activities, Conducting Assignment Processes, Conducting Retention and Archiving Activities |
| Professional Experience Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
Education History and Details Employment History and Details Course Attendance Information Vocational Training Information Certificates Transcript Information Diploma Information, Foreign Language Information, Computer Skills Information |
Conducting Job Applicant Recruitment Processes, Planning Human Resources Processes, Conducting and Supervising Business Activities, Conducting Contract Processes, Implementing Compensation Policy, Conducting Retention and Archiving Activities |
| Legal Grounds for Processing Personal Data | Your personal data are processed by D Tech Cloud for the purposes listed above, based on the legal grounds set forth in Article 5 of the KVKK and the relevant legislation, namely:
and are processed based on these legal grounds. |
| Methods of Collecting Personal Data | The personal data specified above are collected through the job application form, other documents declared by you during the application, and Private Employment Agencies (e.g., LinkedIn, Kariyer.net). |
| Online Visitor | |
| Identity Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
|---|---|
| First Name and Last Name | Conducting Information Security Processes, Conducting Communication Activities, Managing Customer Relationship Management Processes, Conducting Activities Aimed at Customer Satisfaction, Managing Organizations and Events, Conducting Marketing and Analytics Activities, Conducting Advertising, Campaign and Promotional Processes, Conducting Sponsorship Activities, Monitoring Requests and Complaints, Providing Information to Authorized Persons, Institutions and Organizations |
| Contact Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
| E-mail Address | Conducting Information Security Processes, Conducting Communication Activities, Managing Customer Relationship Management Processes, Conducting Activities Aimed at Customer Satisfaction, Managing Organizations and Events, Conducting Marketing and Analytics Activities, Conducting Advertising, Campaign and Promotional Processes, Conducting Sponsorship Activities, Monitoring Requests and Complaints, Providing Information to Authorized Persons, Institutions and Organizations |
| Transaction Security Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
| IP Address Information, Website Login and Logout Information, Username and Password Information, Device token information (for push notifications), Device ID Information | Conducting Information Security Processes, Conducting Activities in Compliance with Legislation, Conducting Communication Activities, Managing Customer Relationship Management Processes, Conducting Activities Aimed at Customer Satisfaction, Managing Organizations and Events, Conducting Marketing and Analytics Activities, Conducting Advertising, Campaign and Promotional Processes, Conducting Sponsorship Activities, Monitoring Requests and Complaints, Providing Information to Authorized Persons, Institutions and Organizations |
| Legal Grounds for Processing Personal Data | Your personal data are processed by D Tech Cloud for the purposes listed above, based on the legal grounds specified in Article 5 of the KVKK and the relevant legislation: For obligations under Law No. 5651 and other legislation:
For data relating to membership procedures other than legal obligations:
and are processed based on these legal grounds. |
| Methods of Collecting Personal Data | The personal data specified above are collected through CVs submitted by you and the internship application form you complete. |
| Representative of Company Purchasing Products or Services | |
| Identity Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
|---|---|
Name and Surname Signature |
Providing information to authorized persons, institutions and organizations, Conducting activities in compliance with legislation, Conducting Finance and Accounting Activities, Conducting Communication Activities, Conducting and Supervising Business Activities, Conducting Retention and Archiving Activities, Conducting Contract Processes, Conducting Company / Product / Service Loyalty Processes, Providing After-Sales Support Services for Goods / Services, Conducting Goods / Services Sales Processes, Managing Customer Relationship Management Processes, Conducting Activities Aimed at Customer Satisfaction. |
| Contact Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
E-mail Address, Mobile Phone Number Contact Address, |
Conducting Finance and Accounting Activities, Conducting Communication Activities, Conducting and Supervising Business Activities, Conducting Goods / Services Sales Processes, Providing After-Sales Support Services for Goods / Services, Conducting Contract Processes, Monitoring Requests / Complaints, Managing Customer Relationship Management Processes, Conducting Activities Aimed at Customer Satisfaction. |
| Legal Grounds for Processing Personal Data | Your personal data are processed by D Tech Cloud for the purposes listed above, based on the legal ground specified in Article 5 of the KVKK and the relevant legislation, namely:
and are processed based on this legal ground. |
| Methods of Collecting Personal Data | The personal data listed above are collected during the customer experience (e.g., complaint management, satisfaction surveys, etc.), during the sales process through digital and printed forms (e.g., contracts), through online electronic forms (e.g., website contact form), or through other web technologies (e.g., cookies). |
| Employee of Company Purchasing Products or Services | |
| Identity Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
|---|---|
Name, Surname Turkish ID Number Position/Title |
Conducting Communication Activities, Planning Human Resources Processes, Conducting/Supervising Business Activities, Managing Organizations and Events, Carrying Out Management Activities. |
| Contact Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
E-mail Address, Contact Address, Business Telephone Number, Mobile Phone Number |
Conducting Communication Activities, Planning Human Resources Processes, Conducting/Supervising Business Activities, Managing Organizations and Events, Carrying Out Management Activities. |
| Legal Grounds for Processing Personal Data | Your personal data are processed by D Tech Cloud for the purposes listed above, based on the legal ground specified in Article 5 of the KVKK and the relevant legislation, namely:
and are processed based on this legal ground. |
| Methods of Collecting Personal Data | The personal data listed above are collected during the purchase process for products or services through web applications, mobile applications, information systems and electronic devices (e.g. telecommunications infrastructure, computers and telephones), participation in meetings or events (career days, fairs, etc.), supplier forms and similar forms, contracts (e.g. employment contracts, membership agreements, sales contracts, etc.), and other documents declared by the Data Subject. |
| Supplier Representatives | |
| Identity Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
|---|---|
Name, Surname, Turkish ID Number, Tax Identification Number, Signature Signature Circular |
Conducting Activities in Compliance with Legislation, Conducting Finance and Accounting Activities, Following Up and Conducting Legal Affairs, Conducting Internal Audit Activities, Conducting Communication Activities, Conducting and Supervising Business Activities, Conducting Retention and Archiving Activities, Conducting Contract Processes, Ensuring the Security of Data Controller Operations, Conducting Goods / Services Procurement Processes, Conducting Logistics Activities, Conducting Investment Processes, Providing Information to Authorized Persons, Institutions and Organizations, Conducting Supply Chain Management Processes, Monitoring Requests / Complaints |
| Contact Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
E-mail Address, Contact Address, Registered Electronic Mail (KEP) Address, Business Telephone Number, Mobile Phone Number |
Conducting Finance and Accounting Activities, Conducting Communication Activities, Conducting Business Activities, Conducting Retention and Archiving Activities, Conducting Goods / Services Procurement Processes, Conducting Contract Processes, Monitoring Requests / Complaints, Carrying Out Management Activities |
| Financial Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
| Bank Account Information | Conducting Audit / Ethics Activities, Conducting Activities in Compliance with Legislation, Conducting Finance and Accounting Activities, Conducting and Supervising Business Activities, Providing Information to Authorized Persons, Institutions and Organizations, Conducting Goods / Services Procurement Processes, Conducting Retention and Archiving Activities, Conducting Contract Processes, Conducting Supply Chain Management Processes, Carrying Out Management Activities |
| Customer Transaction Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
| Invoice, promissory note and check information | Conducting Activities in Compliance with Legislation, Conducting Finance and Accounting Activities, Following Up and Conducting Legal Affairs, Conducting Internal Audit Activities, Conducting Communication Activities, Conducting and Supervising Business Activities, Providing After-Sales Support Services for Goods and Services, Conducting Goods / Services Sales Processes, Conducting Retention and Archiving Activities, Conducting Contract Processes, Providing Information to Authorized Persons, Institutions and Organizations, Monitoring Requests / Complaints |
| Legal Transaction Information (In the Event of Any Dispute) | |
| Personal Data Processed | Purposes of Processing Personal Data |
| Information in correspondence with judicial authorities, information in correspondence with administrative authorities, information in court case files, records relating to salary attachment and similar matters, information contained in notices / warnings | Following Up and Conducting Legal Affairs, Conducting Internal Audit Activities, Conducting Risk Management Processes, Ensuring the Security of Data Controller Operations, Providing Information to Authorized Persons, Institutions and Organizations |
| Transaction Security Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
IP Address Information, Computer Screen Recording Information, Username Information |
Conducting Information Security Processes, Conducting Audit / Ethics Activities, Conducting Access Authorization Processes, Conducting and Supervising Business Activities, Ensuring Business Continuity, Conducting Retention and Archiving Activities, Ensuring the Security of Data Controller Operations |
| Legal Grounds for Processing Personal Data | Your personal data are processed by D Tech Cloud for the purposes listed above, based on the following legal grounds specified in Article 5 of the KVKK and the relevant legislation:
and are processed based on these legal grounds. |
| Methods of Collecting Personal Data | The personal data listed above are collected during the purchase process for products or services through web applications, mobile applications, information systems and electronic devices (e.g. telecommunications infrastructure, computers and telephones), participation in meetings or events (career days, fairs, etc.), supplier forms and similar forms, contracts (e.g. employment contracts, membership agreements, sales contracts, etc.), and other documents declared by the Data Subject. |
| Supplier Employee | |
| Identity Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
|---|---|
Name, Surname, Turkish ID Number, Social Security Institution (SGK) Registration Number, Identity Card / ID Copy Driver’s License Copy |
Conducting Audit / Ethics Activities, Conducting Activities in Compliance with Legislation, Following Up and Conducting Legal Affairs, Conducting Internal Audit Activities, Conducting and Supervising Business Activities, Conducting Risk Management Processes, Ensuring the Security of Data Controller Operations, Conducting Supply Chain Management Processes, Conducting Goods / Services Procurement Processes |
| Contact Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
E-mail Address, Contact Address, Mobile Phone Number, |
Conducting Communication Activities, Conducting Business Activities, Conducting Retention and Archiving Activities, Conducting Goods / Services Procurement Processes, Conducting Contract Processes |
| Financial Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
| Bank Account Information | Fulfilling Obligations Arising from Employment Contracts and Legislation, Conducting Activities in Compliance with Legislation, Conducting Finance and Accounting Activities, Managing Employee Benefits and Entitlements, Providing Information to Authorized Persons, Institutions and Organizations |
| Personnel Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
SGK Number Insurance Information |
Conducting Communication Activities, Conducting Business Activities, Conducting Retention and Archiving Activities, Conducting Goods / Services Procurement Processes, Conducting Contract Processes |
| Transaction Security Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
IP Address Information, Computer Screen Recording Information, Username Information |
Conducting Information Security Processes, Conducting Audit / Ethics Activities, Conducting Access Authorization Processes, Conducting and Supervising Business Activities, Ensuring Business Continuity, Conducting Retention and Archiving Activities, Ensuring the Security of Data Controller Operations |
| Legal Transaction Information (In the Event of Any Dispute) | |
| Personal Data Processed | Purposes of Processing Personal Data |
| Information in correspondence with judicial authorities, information in correspondence with administrative authorities, information in court case files, records relating to salary attachment and similar matters, information contained in notices / warnings | Following Up and Conducting Legal Affairs, Conducting Internal Audit Activities, Conducting Risk Management Processes, Ensuring the Security of Data Controller Operations, Providing Information to Authorized Persons, Institutions and Organizations |
| Physical Premises Security Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
Entry / Exit Record Information CCTV Records |
Conducting Information Security Processes, Conducting Audit / Ethics Activities, Conducting Access Authorization Processes, Conducting and Supervising Business Activities, Ensuring Business Continuity, Conducting Retention and Archiving Activities, Ensuring the Security of Data Controller Operations |
| Legal Grounds for Processing Personal Data | Your personal data are processed by D Tech Cloud for the purposes listed above, based on the following legal grounds specified in Article 5 of the KVKK and the relevant legislation:
and are processed based on these legal grounds. |
| Methods of Collecting Personal Data | Your personal data listed above are collected through printed forms, CCTV cameras, and information and documents declared by you. |
| Visitor | |
| Identity Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
|---|---|
Name, Surname, Turkish ID Number |
Conducting Emergency Management Processes, Conducting Information Security Processes, Monitoring Requests / Complaints, Ensuring Physical Premises Security, Ensuring the Security of Data Controller Operations, Ensuring the Security of Movable Property and Resources, Creating and Monitoring Visitor Records, Providing Information to Authorized Persons, Institutions and Organizations |
| Contact Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
| Mobile Phone Number | Conducting Emergency Management Processes, Conducting Information Security Processes, Conducting Communication Activities, Monitoring Requests / Complaints, Ensuring the Security of Data Controller Operations, Creating and Monitoring Visitor Records, Providing Information to Authorized Persons, Institutions and Organizations |
| Transaction Security Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
IP Address Information Website Login and Logout Information Device MAC Address Electronic Communication Records (such as usage records) Other traffic data |
Conducting Information Security Processes, Conducting Audit / Ethics Activities, Conducting Access Authorization Processes, Supervising Business Activities, Conducting Risk Management Processes, Conducting Retention and Archiving Activities, Ensuring the Security of Data Controller Operations |
| Physical Premises Security Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
Entry / Exit Record Information, CCTV Records Vehicle License Plate Information |
Conducting Emergency Management Processes, Ensuring Physical Premises Security, Conducting and Supervising Business Activities, Creating and Monitoring Visitor Records, Providing Information to Authorized Persons, Institutions and Organizations |
| Visitor Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
Person Visited Reason for Visit Duration of Visit Date of Visit |
Conducting Information Security Processes, Conducting Audit / Ethics Activities, Conducting Access Authorization Processes, Ensuring Physical Premises Security, Conducting Assignment Processes, Conducting Internal Audit, Investigation and Intelligence Activities, Ensuring the Security of Movable Property and Resources, Ensuring the Security of Data Controller Operations, Providing Information to Authorized Persons, Institutions and Organizations, Carrying Out Management Activities, Creating and Monitoring Visitor Records |
| Legal Grounds for Processing Personal Data | Your personal data are processed by D Tech Cloud for the purposes listed above, based on the legal grounds specified in Article 5 of the KVKK and the relevant legislation, namely:
and are processed based on these legal grounds. |
| Methods of Collecting Personal Data | The personal data listed above are collected through the visitor logbook and CCTV and security cameras. |
| Shareholder / Partner | |
| Identity Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
|---|---|
| Name, Surname | Conducting Information Security Processes, Conducting Audit / Ethics Activities, Conducting Access Authorization Processes, Conducting and Supervising Business Activities, Ensuring Business Continuity, Conducting Retention and Archiving Activities, Ensuring the Security of Data Controller Operations |
| Contact Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
E-mail Address, Contact Address, Mobile Phone Number |
Conducting Communication Activities, Conducting and Supervising Business Activities, Ensuring Business Continuity, Conducting Risk Management Processes, Conducting Contract Processes, Monitoring Requests and Complaints, Ensuring the Security of Data Controller Operations |
| Transaction Security Information | |
| Personal Data Processed | Purposes of Processing Personal Data |
IP Address Information, Computer Screen Recording Information, Username Information, Device IMEI Number, Device MAC Address |
Conducting Information Security Processes, Conducting Audit / Ethics Activities, Conducting Access Authorization Processes, Conducting and Supervising Business Activities, Ensuring Business Continuity, Conducting Retention and Archiving Activities, Ensuring the Security of Data Controller Operations, Providing Information to Authorized Persons, Institutions and Organizations. |
| Legal Grounds for Processing Personal Data | Your personal data are processed by D Tech Cloud for the purposes listed above, based on the following legal grounds specified in Article 5 of the KVKK and the relevant legislation:
and are processed based on these legal grounds. |
| Methods of Collecting Personal Data | They are collected through contracts, web applications, mobile applications, information systems and electronic devices (e.g. telecommunications infrastructure, computers and telephones), and other documents declared by the Data Subject. |
To Whom and for What Purposes May Your Personal Data Be Transferred?
Your personal data,
- to Authorized Public Institutions and Organizations, within the scope stipulated by legal regulations, for the purposes of conducting activities in compliance with legislation, following up and carrying out legal affairs, providing information to authorized persons, institutions and organizations, fulfilling obligations arising from employment contracts and legislation for employees, conducting and supervising business activities, and carrying out occupational health and safety activities, and
- within the scope of our contractual relationship during the conduct of our activities, to our Group Companies and Subsidiaries for the purposes of conducting information security processes, carrying out finance and accounting activities, ensuring physical premises security, following up and conducting legal affairs, planning human resources processes, conducting and supervising business activities, ensuring business continuity, conducting marketing analysis activities, carrying out supply chain management, and creating and monitoring visitor records,
- within the scope of our contractual relationship during the conduct of our activities, to our Business Partners and the Supplier Representatives and Employees with whom we work, for the purposes of conducting business activities, communication activities, logistics activities, sales processes for goods or services, after-sales support services for goods or services, monitoring requests and complaints, and managing organizations and events,
- within the scope of our contractual relationship during the conduct of our activities, to the Board of Directors for the purposes of conducting and supervising business activities and carrying out management activities,
- only the personal data of Job Applicants, subject to the permission they provide in this regard, to our Group Companies for the purposes of enabling our group companies to conduct more effective human resources policies and processes, offering an alternative or better position to a Job Applicant whose application has been unsuccessful within our other group companies where necessary, and creating a candidate pool,
may be transferred.
Do We Transfer Your Personal Data Abroad?
Personal data may be transferred only to the extent necessary for the relevant purpose, in compliance with the rules under Article 9 of the KVKK concerning transfers abroad and by taking the necessary technical and administrative measures.
What Are Your Rights as a Data Subject?
Under the KVKK and the relevant legislation, with respect to your personal data;
- to learn whether your personal data is being processed,
- to request information if your personal data has been processed,
- to learn the purpose of processing your personal data and whether such data is used in accordance with that purpose,
- to know the third parties to whom your personal data is transferred domestically or abroad,
- to request correction of your personal data if it is incomplete or incorrectly processed,
- to request the deletion or destruction of your personal data within the framework of the conditions stipulated under the KVKK legislation,
- to request that third parties to whom we have transferred your personal data be notified when you request correction of incomplete or inaccurate data or deletion or destruction of your personal data,
- to object to the occurrence of a result to your detriment as a result of the analysis of the processed data exclusively by automated systems, and
- to request compensation for the damage you incur due to the unlawful processing of your personal data,
you have the rights set out above.
How Can You Exercise Your Rights?
You may submit your applications and requests regarding your personal data:
- by sending them with a wet signature and a photocopy of your identity document to the address ‘Demirören Medya Center, 100. Yıl Mah., 2264 Sok. No:1, Bağcılar / Istanbul’,
- by applying in person to D Tech Bulut Bilişim A.Ş. together with a valid identity document,
- by sending them to our registered electronic mail address “[email protected]” via a registered electronic mail (KEP) address and a secure electronic signature or mobile signature,
- by sending them to our “[email protected]” address from the e-mail address previously notified to D Tech Bulut Bilişim A.Ş. by the Data Subject and registered in our system,
to D Tech Bulut Bilişim A.Ş.
Under the Communiqué on the Procedures and Principles of Application to the Data Controller, the application of the Data Subject must include the name, surname, signature if the application is made in writing, Turkish ID number (or passport number if the applicant is a foreign national), residential or business address for notification purposes, e-mail address, if any, for notification purposes, telephone number and fax number, as well as information regarding the subject of the request.
In the application to be made by the Data Subject to exercise the rights stated above, the requested matter, together with an explanation regarding the right sought to be exercised, must be stated clearly and understandably. Information and documents relating to the application must be attached to the application.
Although the subject of the request must concern the applicant personally, if the applicant is acting on behalf of another person, the applicant must be authorized to do so and such authority must be documented (power of attorney). If the application concerns special categories of personal data, the applicant must also be specifically authorized in this regard pursuant to Article 10 of the Regulation on the Processing of Personal Health Data. In addition, the application must contain identity and address information, and documents verifying identity must be attached to the application.
Requests made by unauthorized third parties on behalf of another person will not be considered.
How Long Will Your Requests Regarding the Processing of Your Personal Data Be Answered?
Your requests concerning your rights regarding your personal data will be evaluated and answered within 30 days at the latest from the date they are received by the relevant department. If your application is rejected, the reasons for rejection will be communicated to you at the address specified in your application, primarily by e-mail or post, and, where possible, by the method through which the request was submitted.