Privacy Policy

As Seenooks Software and Information Technologies Inc. (“Seenooks Software” or the “Company”), we respect the personal data we process in the course of our activities and pay close attention to the security of personal data in compliance with applicable regulations and universal values. In this regard, Seenooks Software carries out personal data processing activities in accordance with Law No. 6698 on the Protection of Personal Data (the “Law”), global and local company policies, and other applicable regulations.

The Personal Data Protection and Privacy Policy (the “Policy”) outlines Seenooks Software’s compliance with the Law regarding its websites, www.seenooks.com and app.seenooks.com (the “Site”), and/or mobile applications accessible via mobile devices, tablets, and other technological tools (the “Application”). Depending on your relationship with Seenooks Software, you may access further details regarding the processing of your personal data through specific documents prepared accordingly

1. Processed Personal Data

Personal data is processed in compliance with the principles set forth in Article 4 of the Law:

● Processing in accordance with the law and good faith: Seenooks Software adheres to legally prescribed rules in every processing activity, processes data only for limited purposes, and considers the interests and reasonable expectations of data subjects.

● Accuracy and up-to-date nature of personal data: Seenooks Software ensures the accuracy and timeliness of processed personal data, conducting necessary checks. Data subjects have the right to request the correction or deletion of inaccurate or outdated data.

● Processing for specific, explicit, and legitimate purposes: Seenooks Software ensures that processing activities are conducted for legitimate purposes, defining each detail in advance and making processing activities clearly understandable for data subjects.

● Processing relevant, limited, and proportionate to the purpose: Seenooks Software collects personal data only to the extent necessary for its processing activities and within the scope of the defined purposes.

● Retention for the required period: Personal data is deleted, destroyed, or anonymized once the purpose of processing ceases or the legally mandated retention period expires.

Within the scope of its relationship with the data subject, Seenooks Software processes different categories of personal data for each processing activity, ensuring compliance with the data minimization principle. The Company only processes necessary and relevant personal data to carry out its operations, manage relationships between parties, and fulfill legal obligations. The following categories of data are processed:

2. Purposes of Personal Data Processing

Personal data is processed in accordance with the Law and its secondary regulations for the following purposes:

• Ensuring information security processes
• Establishing and managing IT infrastructure
• Conducting audits and ethical activities
• Compliance with legal regulations
• Managing finance and accounting activities
• Managing company/product/service engagement processes
• Conducting communication activities
• Executing and supervising business activities
• Receiving and evaluating improvement suggestions
• Ensuring business continuity
• Managing after-sales service processes
• Managing sales processes of goods/services
• Conducting product and operational processes
• Fulfilling legal obligations
• Managing customer relationship processes
• Conducting customer satisfaction activities
• Managing advertising and marketing activities
• Conducting archiving and storage activities
• Managing contractual processes
• Tracking requests/complaints
• Managing commercial activities
• Ensuring data controller operations security
• Providing information to authorized individuals, institutions, and organizations
• Conducting administrative activities

3. Collection Methods and Legal Basis of Personal Data

Personal data is collected by Seenooks Software in compliance with applicable legislation, through written, verbal, printed, and electronic means based on the purposes stated above. Personal data obtained through the Site and/or Application is processed based on the following legal grounds under Article 5/2 of the Law:

• ● Necessity of processing for the establishment or performance of a contract
• ● Explicitly made public by the data subject
• ● Necessity of processing for the establishment, exercise, or protection of a legal right

Additionally, in cases where required, personal data is processed based on the explicit consent of the data subject as per Article 5/1 of the Law.

4. Transfer of Personal Data and Purpose of Transfer

Collected personal data may be transferred within the scope of Articles 8 and 9 of the Law to:

• Service providers of Seenooks Software,
• Authorized public institutions and law enforcement authorities upon request or in case of legal disputes.

During data transfers, Seenooks Software takes all necessary administrative and technical measures, ensuring compliance with relevant regulations and Personal Data Protection Board decisions. Special data transfer agreements are executed with third parties, and appropriate commitments are obtained regarding data security.

5. Data Security Measures

Seenooks Software implements all necessary technical and administrative measures for the security and protection of personal data, in compliance with applicable regulations and Personal Data Protection Board decisions. These measures include:

• Ensuring network and application security
• Using closed systems for network-based data transfers
• Securing cloud-stored personal data
• Implementing data security policies and procedures
• Conducting access logging and monitoring
• Implementing confidentiality agreements
• Using up-to-date antivirus systems
• Restricting access based on an authorization matrix
• Conducting regular security audits
• Ensuring the security of physical environments containing personal data

In compliance with the Personal Data Protection Board’s Decision No. 2018/10, Seenooks Software has also established a separate policy and procedure for special categories of personal data. Personal data is retained for the legally mandated period or as long as necessary for the purpose of processing. Once these periods expire, the data is deleted, destroyed, or anonymized according to the Regulation on Deletion, Destruction, or Anonymization of Personal Data. The regular data destruction period is set at six months.

6. Rights of Data Subjects

According to Article 11 of the Law, data subjects have the following rights:

• To learn whether their personal data is processed
• To request information regarding their processed personal data
• To learn the purpose of processing and whether data is used accordingly
• To know third parties to whom data is transferred domestically or abroad
• To request correction of inaccurate or incomplete data
• To request deletion or destruction of personal data under Article 7
• To request notification of correction, deletion, or destruction to third parties
• To object to automated decisions producing unfavorable results
• To demand compensation for damages incurred due to unlawful data processing

Requests regarding these rights may be submitted in writing or through registered electronic mail, secure electronic signature, mobile signature, or via the email address registered in Seenooks Software's system.

7. Contact Information

Seenooks Software and Information Technologies Inc.

Email: support@seenooks.com

Address: Üçevler Mah. 72.(220) Sokak, Aknil Plaza No:6/17, Nilüfer / Bursa

KEP Address: ………………