Processing of Personal Data

CLARIFICATION TEXT ON THE PERSONAL DATA PROTECTION LAW

1. Information Text on the Protection and Processing of Personal Data

1.1. Smart Software regarding the Personal Data Protection Law No. 6698 (KVKK) published in the Official Gazette No. 29677 dated April 7, 2016, in order to protect the fundamental rights and freedoms of individuals, especially the privacy of private life, in the processing of personal data and to determine the obligations of real and legal persons who process personal data. Sağlık San.Tic.A.Ş. As the Data Controller, we provide information in accordance with Article 10 of the Law titled “Information Obligation of the Data Controller”.

1.2. Smart Software Sağlık San.Tic.A.Ş. It has been prepared to ensure that the personal data of our citizens are processed in accordance with the relevant legislation, especially the Constitution of the Republic of Turkey and the international agreements to which our country is a party regarding Human Rights and the Personal Data Protection Law No. 6698 (KVKK) and that the relevant persons whose data are processed can effectively exercise their rights. All personal data shared with our company can be processed in accordance with the law, in connection with our activities and service purposes, and in a proportionate manner.

2. Definitions

2.1. The concepts of personal data, special personal data and data processing used in the information text are used based on the definitions made in KVKK. Mentioned in KVKK;

2.1.1. Personal Data Protection Law (“KVKK”): Personal Data Protection Law No. 6698, which came into force by being published in the Official Gazette on April 7, 2016,

2.1.2. Personal Data: any information relating to an identified or identifiable natural person,

2.1.3. Data Processor: Real or legal person who processes Personal Data on behalf of the data controller, based on the authority given by the data controller,

2.1.4. Data Controller: The natural or legal person who determines the purposes and means of processing Personal Data and is responsible for establishing and managing the data recording system,

2.1.5. Processing of personal data: The concept means obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, obtaining, recording, storing, preserving, disclosing, transferring, taking over, personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. It refers to any operation performed on data, such as compiling, classifying or preventing its use.

3. Personal Data Processing Principles

3.1. Personal data of the data owner specified in Article 4 of KVKK; In accordance with the law and the rules of honesty, accurate and up-to-date when necessary, for specific, clear and legitimate purposes; related to the purpose for which they are processed, limited and proportionate; The data will be processed by the data controller Company within the scope of the purposes stated below, in accordance with the rules of retention for the period stipulated in the relevant legislation or for the period required for the purpose for which they are processed.

4. Purpose of Processing Your Personal Data

4.1. In accordance with Articles 4, 5 and 6 of the KVKK, your personal data;

4.1.1. In accordance with the law and the rule of honesty,

4.1.2. In connection with the purposes of processing, in a limited and measured manner,

4.1.3. Accurate and up to date,

4.1.4. They will be processed for certain clear and legitimate purposes and for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed.

4.2. Your personal data is carried out by our business units to make you benefit from the products and services offered by our Company; Recommending the products and services offered by our company to you; Planning and/or execution of market research activities for sales and marketing of products and services; Planning and/or execution of after-sales support services activities; Following up contract processes and/or legal requests, ensuring the legal, technical and commercial occupational safety of relevant persons in business relations; Ensuring that our company’s human resources policies are implemented, evaluating your job application, fulfilling our statutory and legal obligations if you are our employee; ensuring quality monitoring; tracking of supplied products; For security and identification purposes when you visit our business; Contacting you if you request information from our company; performance of this contract if you purchase a product; Planning, auditing and execution of information security processes; Establishing and managing information technology infrastructure; Follow-up of financial and/or accounting affairs; Follow-up of legal affairs; Planning and execution of business activities; Planning and execution of corporate communication activities; It will be processed within the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698 for the purposes of determining and implementing our company’s commercial and business strategies. The data of our employees may be processed by our Company or those authorized by our Company or those with whom our Company cooperates or is authorized, within the scope of our human resources policy or for operational reasons such as increasing the performance level and employee satisfaction and ensuring occupational safety and labor peace, as well as the obligations stipulated by the Labor Law, Labor and Social Security legislation and other legislation in force. It can be processed by real or legal persons.

5. Transfer of Personal Data

5.1. Your personal data; Our business units carry out the necessary work to benefit you from the products and services offered by our company; Customizing and recommending the products and services offered by our company according to the needs of you and your company; Ensuring that our company’s human resources policies are implemented; Ensuring the legal and commercial security of our Company and the people who have business relations with our Company; For the purposes of determining and implementing our company’s commercial and business strategies; It can be transferred to our business partners, suppliers, shareholders, affiliates, legally authorized public institutions and private individuals within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of Law No. 6698.

6. Collection Method and Legal Basis of Personal Data

6.1. Personal data is collected and processed by our company in connection with the legitimate purposes clearly stated above, in accordance with the law and the rules of honesty, by verbally, written and/or electronically, by providing verbal, written and/or electronic information to personal data owners in a clear and understandable manner and, when necessary, by obtaining their explicit consent. It is collected, used, recorded, stored and processed within the framework of the principle of proportionality, provided that it is limited. And also; Through different channels and based on different legal reasons within the framework of our company’s commercial purpose, such as contacting us, establishing a contractual relationship, visiting our business, transmitting your information to us for commercial activity purposes, sharing information in promotional organizations; It is collected in order to improve the products and services we offer and to carry out our commercial activities. Your personal data collected for this legal reason can be processed and transferred for the purposes specified in this Information Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

6.2. In addition, we ensure that your personal data will not be processed by our company for purposes other than those specified in this information document, and will not be transferred or stored to third parties at home or abroad.

7. Storage and Deletion of Data:

7.1. Our company stores the personal data it processes for the periods determined by the legislation, and if a separate period is not specified in the legislation; Personal data is stored for the period required to be processed in accordance with our Company’s practices and commercial life practices, depending on the services our company offers while processing that data, and after this period, only for the periods deemed necessary in practice to serve as evidence in possible legal disputes. After the specified periods expire, the personal data in question is deleted, destroyed or anonymized.

8. Rights of the Data Owner

8.1. Data owners may contact the Company acting as the data controller;

8.1.1. Learning whether personal data is processed or not,

8.1.2. Requesting information if your personal data has been processed,

8.1.3. Learning the purpose of processing personal data and whether they are used for their intended purpose;

8.1.4. Being informed about third parties to whom personal data are transferred at home or abroad,

8.1.5. Requesting correction of personal data if they are incomplete or incorrectly processed,

8.1.6. Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of KVKK No. 6698,

8.1.7. To request that the transactions carried out in accordance with paragraphs (d) and (e) of Article 11 of the KVKK be notified to third parties to whom personal data have been transferred,

8.1.8. Objecting to the emergence of a result that is unfavorable to the individual by analyzing the processed data exclusively through automatic systems,

8.1.9. In case of damage due to unlawful processing of personal data, they have the right to request compensation for the damage.

8.2. In order to exercise your above-mentioned rights, you can submit your written request, along with the necessary information that identifies you and your explanations regarding the right you want to use, to “www.shlife.com.tr” with a Personal Data Information and Processing Request Form with wet signature or to “info@shlife.com.tr”. You can send it to our registered e-mail address by using a secure electronic signature, mobile signature or the e-mail address previously notified to Smart Software Sağlık San.Tic.A.Ş. by the relevant person and registered in the data controller’s system. Applications must be made in Turkish.

8.3. In applications, name, surname and signature if the application is written, T.R. for citizens of the Republic of Turkey. It is mandatory to have an identity number, nationality for foreigners, passport number/identification number, notification-based residence or workplace address, notification-based e-mail address, telephone or fax number, if any, and the subject of the request.

8.4. In your application containing your explanations regarding the right you have as a personal data owner and which you request to exercise, in order to exercise your above-mentioned rights; The matter you are requesting must be clear and understandable, the matter you are requesting must be personally related to you, or if you are acting on behalf of someone else, you must be specifically authorized in this matter and your authority must be documented, the application must include identity and address information, and documents proving your identity must be attached to the application.

8.5. In this context, your applications will be finalized as soon as possible and within 30 days at the latest, and you will be informed.