PDP Law

CORPORATE GENERAL INFORMATION NOTICE REGARDING THE PROCESSING OF PERSONAL DATA

As Techcom Bilişim A.Ş. (“Techcom Bilişim”), within the framework of activities arising from the Law No. 6698 on the Protection of Personal Data (“KVKK”) and related legislation and regulations, we have prepared this information notice to inform you, our Visitors, Online Visitors, Customers, Potential Customers, Supplier Employees, and Supplier Representatives, about the processing, storage, and transfer of your personal data.

What Categories of Personal Data Do We Process and For What Purposes?

Your personal information is processed by Techcom Bilişim A.Ş. in accordance with the principles set out in Article 4.2 of KVKK, namely;

(i) compliance with law and honesty,

(ii) accuracy and updating when necessary,

(iii) processing for specific, explicit, and legitimate purposes,

(iv) being relevant, limited, and proportionate to the purposes for which they are processed,

(v) being retained for the period prescribed by relevant legislation or necessary for the purpose of processing,

within the scope of our business relationships established and ongoing with our partners (an individual may fall into more than one category) for the purposes stated below.

Visitors

Identity information of visitors (e.g., name, surname), physical security information (e.g., camera recordings);

processed for the purposes of creating and monitoring visitor records and ensuring physical security of premises.

Online Visitors

Security information related to transactions of our online visitors (e.g., IP address), marketing information (e.g., purchase history, cookie records), and identity and contact information (e.g., email address) provided by the visitor;

processed for the purposes of legal compliance of activities, information security processes, tracking requests/complaints, conducting communication activities, providing information to authorized persons, institutions, and organizations, and enabling access to our website via the internet.

Customers

Identity and contact information of our individual customers or the authorized persons and/or employees of our corporate customers, customer transaction information (e.g., order details), physical security data, financial information (e.g., balance sheet data), legal transaction information, marketing data (e.g., purchase history);

processed for purposes including legal compliance of activities, conducting finance and accounting operations, managing business activities/audits, conducting logistics activities, post-sales support services for goods/services, sales processes for goods/services, marketing analysis, contract management, providing information to authorized persons/institutions, ensuring physical security, resolving legal disputes, storage and archiving activities, risk management, managing loyalty processes related to company/products/services, and communication activities.

Potential Customers

Identity and contact information of potential individual customers or authorized persons and/or employees of corporate potential customers, customer transaction data, physical security information, marketing data;

processed for managing sales processes of goods/services, contract management, ensuring physical security, and conducting marketing analysis.

Supplier Employees

Identity, contact, and physical security information of supplier employees;

processed for communication activities, managing business operations/audits, ensuring physical security, supply chain management, logistics activities, legal compliance, and occupational health and safety activities.

Supplier Representatives

Identity, contact, physical security information, customer transaction data, financial data, marketing information, and legal transaction data of real or corporate supplier representatives;

processed for business management/audits, procurement processes, finance and accounting operations, contract management, investment processes, physical security, and legal case follow-ups.

How Are Your Personal Data Collected?

The personal data mentioned above are collected physically (e.g., order forms, contracts, visitor forms), electronically (e.g., telecommunications infrastructure, computers, phones), from third parties (e.g., credit reference agencies such as KKB and Findeks), from our website, or through other documents declared by the relevant person, either automatically or manually.

What Is the Legal Basis for Collecting Your Personal Data?

Your personal data are processed by Techcom Bilişim A.Ş. based on the legal grounds specified in Article 5 of KVKK for the purposes explained above, including;

(i) Explicitly provided for in laws,

(ii) Necessary for the establishment or performance of a contract to which the data subject is a party,

(iii) Required for the data controller to fulfill a legal obligation,

(iv) Necessary for the establishment, exercise, or defense of a right,

(v) Necessary for the legitimate interests of the data controller provided that it does not violate the fundamental rights and freedoms of the data subject.

Do We Transfer Your Personal Data to Third Parties?

a) Visitors’ personal data may be shared with law enforcement and judicial authorities when requested due to legal disputes or statutory obligations.

b) Online visitors’ personal data may be shared with judicial authorities and authorized public institutions when required by law or to resolve legal disputes.

c) Customers’ personal data may be shared with authorized public institutions for compliance, legal follow-up, and information provision; with affiliated companies, IT companies, suppliers, cargo companies, insurance companies, banks, and financial consultants to the extent necessary for business operations, risk management, and service delivery. Data may also be shared with legal firms and judicial authorities as evidence in future legal disputes.

d) Potential customers’ personal data may be shared with legal firms and judicial authorities as evidence in potential future legal disputes.

e) Supplier employees’ personal data may be shared with authorized public institutions for legal compliance and communication, and with affiliated companies, IT companies, suppliers, cargo companies, banks, and financial consultants as necessary for service delivery. Legal firms and judicial authorities may also receive these data as evidence in future legal disputes.

f) Supplier representatives’ personal data may be shared with authorized public institutions, affiliated companies, IT companies, suppliers, cargo companies, banks, and financial consultants for legal compliance, business management, and service delivery purposes. Legal firms and judicial authorities may also be given this data as evidence in legal disputes.

Do We Transfer Your Personal Data Abroad?

Techcom Bilişim A.Ş. does not transfer your personal data abroad.

How Can You Exercise Your Rights Regarding Your Personal Data?

You can submit your requests within the scope of Article 11 of KVKK regulating the rights of the relevant persons via the “Data Controller Application Procedure and Principles Communiqué” available at Techcom Bilişim A.Ş.’s website (“https://techcom.com.ng/”) through the “Data Controller Application Form” prepared to facilitate your application.

Data Controller: Techcom Bilişim A.Ş.

Address: Atakent Mh. Türkler Cd. No:49/1 Ümraniye/Istanbul

Email: kvkk@techcom.com.ng