SİSTEMDC SUNUCU VE İNTERNET HİZMETLERİ
PRIVACY NOTICE UNDER THE TURKISH PERSONAL DATA PROTECTION LAW NO. 6698 (KVKK)
Translation notice: This English text is provided for information purposes only. In the event of any discrepancy between this translation and the Turkish version, the Turkish version shall prevail.
As SistemDC Sunucu ve İnternet Hizmetleri (hereinafter "SistemDC" or the "data controller"), we value the personal data and privacy of our customers (hereinafter the "customer"). Personal data obtained in line with the principles of respect for privacy and fundamental rights and freedoms is processed by our company within the scope of the Personal Data Protection Law No. 6698 (hereinafter "KVKK").
Definition: Under Article 3 of KVKK, processing is defined as any operation performed on personal data, such as recording, storage, retention, alteration, reorganization, disclosure, transfer, acquisition, making available and classification.
PERSONAL DATA COLLECTED AND METHOD OF COLLECTION
To the extent permitted by law, the following information that you provide in the registration form when signing up on our website in order to use our services is recorded and used by SistemDC:
Personal Data Collected:
- ▸ Your name and surname
- ▸ Your company name (if any)
- ▸ Your address details
- ▸ Your telephone numbers
- ▸ Your e-mail address
- ▸ Your billing account details (if any)
- ▸ Your Turkish ID number
- ▸ Your access and traffic data
- ▸ Your e-mail correspondence
- ▸ Your call center telephone conversations
- ▸ Your communications and interactions with our social media accounts
Method of Collection:
We collect this data through your submission to us verbally, physically or electronically, for the reasons provided by law, in order to fulfil our legal obligations and perform the sales contract between SistemDC and the customer.
PURPOSES FOR WHICH PERSONAL DATA IS RECORDED AND USED
Your personal data will be processed by SistemDC for the following purposes, within the scope of the personal data processing conditions and purposes set out in Articles 5 and 6 of KVKK:
- 1. Providing products or services, planning pre-sales and after-sales processes, planning and executing technical support operations, and ensuring continuity of communication when carrying out infrastructure or technical maintenance, repair and installation services for the service provided.
- 2. Keeping financial and accounting records.
- 3. Improving our service quality.
- 4. Obtaining the approval of the person performing or requesting any risky transaction and verifying their identity.
- 5. Providing information to judicial and administrative authorities upon request.
- 6. Where the consent box has been ticked, periodic campaign activities and, within this framework, sending newsletters and notices.
- 7. Performing customer risk analysis and carrying out security checks.
LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
Your personal data is processed on the basis of the following legal grounds set out in Article 5(2) of KVKK:
- ▸ (c) Processing is directly related to the conclusion or performance of a contract
- ▸ (ç) Processing is necessary for us to comply with a legal obligation (Law No. 5651, the Tax Procedure Law, the Turkish Commercial Code, etc.)
- ▸ (e) Processing is necessary for the establishment, exercise or protection of a right
- ▸ (f) Processing is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms (service and network security, prevention of fraud and abuse)
Sending campaigns, newsletters and commercial electronic messages is based solely on your explicit consent; you may withdraw your consent at any time.
TO WHOM AND FOR WHAT PURPOSES PERSONAL DATA MAY BE TRANSFERRED
Privacy Principle: Your personal data is not sold, rented or shared with third parties for marketing purposes. It is transferred only to the service providers and competent authorities listed below, and only for the stated purposes.
Your personal data is transferred to the servers of the applications we use to carry out certain activities, as follows:
Payment Transactions:
For collecting payments and issuing refunds on credit card payments, your name, surname, invoice number, amount and payment date are transferred to PayTR Ödeme ve Elektronik Para Kuruluşu A.Ş., our virtual POS service provider.
Important: Your credit card details are never stored on our systems, either automatically or even at your request.
Invoicing:
In order for our finance department to send invoices to customers, invoice data is recorded with the company and software of Paraşüt Yazılım Teknolojileri A.Ş., from which we obtain a registered electronic mail service.
Accounting Services:
In order to prepare stamp tax returns and approve invoices, the customer's name, surname, Turkish ID number, tax office, country, city, tax number and contract amount may be transferred to our accounting firm.
SMS Notifications:
For account verification codes and service notifications, your name, surname and telephone number are transferred to our SMS service provider in Türkiye.
Transfers Abroad:
As the servers of the following services are located abroad, the relevant data is transferred abroad within the scope of Article 9 of KVKK:
- ▸ Cloudflare, Inc.: for the security and availability of our website; when you visit the site, your IP address and browser information are processed through this infrastructure.
- ▸ Google (Google Workspace): our corporate e-mail service; the e-mails you send us and the personal data they contain are stored in this service.
- ▸ Google Analytics and Google reCAPTCHA: for website usage statistics and form security; the cookies used are described in our Cookie Policy.
Legal Obligations: In addition to the above, personal data is shared with the General Directorate of Security (EGM), public prosecutors and courts due to our legal obligations.
RIGHTS OF THE DATA SUBJECT UNDER KVKK
Pursuant to Article 11 of KVKK, you have the right to apply to us in order to:
- ▸ Learn whether your personal data is being processed
- ▸ Request information about the processing if your personal data has been processed
- ▸ Learn the purpose of the processing and whether the data is used in line with that purpose
- ▸ Know the third parties in Türkiye or abroad to whom your personal data is transferred
- ▸ Request correction of your personal data if it has been processed incompletely or inaccurately
- ▸ Request the deletion or destruction of your personal data under the conditions set out in Article 7 of KVKK
- ▸ Request that any correction, deletion or destruction be notified to the third parties to whom your personal data has been transferred
- ▸ Object to any outcome to your detriment arising from the analysis of the processed data exclusively by automated systems
- ▸ Claim compensation for damages if you suffer loss due to unlawful processing of your personal data
Response Time: Requests submitted to SistemDC in this regard will be concluded within 30 days at the latest.
HOW TO APPLY
To exercise the rights listed above, you may use either of the following methods:
Method 1: Signed Written Application
Address:
SistemDC Sunucu ve İnternet Hizmetleri
Yenimahalle Devrengeç Cd. No:9 / Daire:6
Yıldırım / BURSA, Türkiye
Delivery: May be sent through a notary public
Method 2: E-mail
From your registered or previously known e-mail address, together with proof of identity:
Note: Identity verification is required for both methods. Your applications will be assessed within 30 days at the latest.
Retention Period:
Your personal data is retained for the period required by the purpose of processing and for the periods prescribed by the relevant legislation (e.g. the periods under the Tax Procedure Law and the Turkish Commercial Code for invoices and accounting records, and under Law No. 5651 for traffic data). When these periods expire, your data is deleted, destroyed or anonymized.
For persons whose agreement was terminated or whose order was cancelled under Articles 6, 8.8 or 15.3 of the Service and Use Agreement, the name/company name, e-mail address, telephone number, Turkish ID/tax number and the IP address used when ordering are retained for 3 years from the date of termination or cancellation for the purpose of preventing fraud and abuse, on the legal grounds of KVKK Art. 5/2-e (establishment, exercise or protection of a right) and Art. 5/2-f (legitimate interest), and are used only to assess new orders.
Our Security Commitment:
As SistemDC, we take all necessary technical and administrative measures to keep your personal data secure at the highest level. Your data is protected against unauthorized access, loss or alteration.
SİSTEMDC SUNUCU VE İNTERNET HİZMETLERİ
Yenimahalle Devrengeç Cd. Erol Saçmacı Apt. B Blok No:9 D:6 Yıldırım/BURSA, Türkiye
Tax No: 9640610925 | ASN: 211804 | Tel: +90 224 334 02 42 | www.sistemdc.com
E-mail: satis@sistemdc.com
Turkey (Türkçe) 
