INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA

1. Data Controller and Representative

With regard to the processing of your personal data, Talya Yazılım ve Bilişim Anonim Şirketi acts as the Data Controller, and your personal data is processed by the Company within the framework explained below and always in compliance with the Law No. 6698 on the Protection of Personal Data (“Law No. 6698”). Detailed information regarding the purposes for which your personal data is processed by us can be found in the Privacy Policy.

2. Purpose of the Information Notice

This Information Notice on the Processing of Personal Data (“Information Notice”) has been prepared for the purpose of informing the relevant persons about the personal data processing activities carried out by the Company within the scope of the Law No. 6698 on the Protection of Personal Data (“KVKK”) and the relevant legislation.

Within the scope of events, meetings, conferences, organizations, and similar activities organized by its customers, the Company processes the personal data of participants, invitees, visitors, employees, suppliers, business partners, and other relevant persons in accordance with the principles set forth in the KVKK and the relevant legislation. The Social Attend platform and mobile applications created through this platform may be used in events and organizations organized or carried out by the Company’s customers.

3. Purposes of Processing Your Personal Data

Depending on the nature of the activity and the relationship between the data subject, the relevant institution, and the Company, the following personal data may be processed:

Identity information (name, surname, and similar information),
Contact information (telephone number, e-mail address, address, and similar information),
Employment information (company name, title, position, and similar information),
User Information, User Transaction Information, and Financial Information: membership information, membership ID number, data regarding the date and time you use the Company’s services, the terms and filtering preferences you use when searching on the Site, your preferences, ratings and comments, the pages you visit, errors occurring during use, invoice and payment information, balance information (data such as copies of receipts relating to invoices sent to users and payments received from users, invoice number, invoice amount, and invoice issuance date).
Event and organization information (attendance information, registration information, flight and accommodation information, event preferences, and similar information),
Location Information: specific or approximate location information relating to your location, such as GPS data, obtained by us while you use the Company’s services,
Transaction Security Information: login credential information, password information, operating system, device information, log records, and similar technical information,
Marketing Information: reports and evaluations showing your habits and preferences, notifications, targeting information, cookie records, and similar information,
Complaint Management Information: complaints you make through the Site,
Risk Management Information: IP address,
Application usage information,
Device and technical information (operating system, device information, log records, and similar technical information),
Visual and audio recordings (if photographs/videos are taken within the scope of the event),
Complaint and Recommendation Records: information relating to requests, complaints, and communication processes.
Information Created by the User: created events, event information (name, location, date), event details, shared photographs and videos. Data anonymized within the framework of Articles 3 and 7 of the Law shall not be considered personal data pursuant to the aforementioned provisions of the Law, and processing activities relating to such data shall be carried out without being bound by the provisions of this Privacy Policy.

Your personal data may be collected through the following means, by automated or non-automated methods:

Event and organization registration forms,
Physical or electronic forms,
Websites and online registration systems,
Social Attend platform and mobile applications,
E-mail, telephone, and other communication channels,
Registration and entry procedures carried out at event venues,
Through Company employees, service providers, or business partners,
Information provided directly by You,
Other methods permitted by the applicable legislation.

The personal data collected from You may be processed for the following purposes:

Planning and conducting events, meetings, conferences, and organizations,
Creating and managing event participant registrations,
Carrying out participant verification and entry procedures,
Communicating event programs and announcements to participants,
Providing services offered within the scope of the event,
Communicating with participants,
Managing requests and feedback,
Providing and operating mobile applications and digital services,
Ensuring the security of the Application and services,
Detecting and resolving technical issues,
Improving service quality,
Creating statistics regarding the use of events and applications,
Conducting information security processes,
Fulfilling legal obligations,
Responding to requests from authorized public institutions and organizations,
Conducting the Company’s legal and commercial activities,
Protecting the Company’s legitimate interests,
Establishing, exercising, or protecting rights in potential disputes.

You may obtain information as to whether your personal data is being processed by submitting an application to the Company.

The personal data you share with the Company may be processed in order for You to benefit from the services provided through the Site and the Mobile Application (“Site”), including the registration of your membership on the Site, making updates to your membership registration, carrying out the Company’s commercial activities, including improving the services offered by the Company and provided through the Site, introducing new services and providing You with the necessary information in this regard, determining and implementing commercial and business strategies, ensuring the legal and commercial security of the Company and persons having business relations with the Company, providing You with the necessary information in this regard, and fulfilling the obligations arising from the nature of these activities.

Such personal information may be used to contact You or to improve your experience on the Site or the Mobile Application (such as managing the communication management process and conducting satisfaction surveys, etc.). It may also be used within the scope of internal reporting and business development activities for various statistical evaluations without disclosing your identity, creating databases, and conducting market research.

For activities that may constitute the public disclosure of all your information within the scope of the event, your explicit consent is also obtained separately pursuant to Article 6/1 of the Law, and this consent is used solely for the purpose of carrying out such public disclosure.

The aforementioned information may be processed and stored by the Company for direct marketing, digital marketing, remarketing, targeting, profiling, and analysis purposes, may be transferred to third parties, and You may be contacted through such information for the purpose of promoting various applications, products, and services and providing notifications regarding maintenance and support activities.

The Company may also process personal data without obtaining your additional consent as the Data Subject and may share such personal data with third parties pursuant to Articles 5 and 8 of the Law and/or in the presence of exceptions provided for under the applicable legislation.

The main circumstances in question are set forth below:

Explicitly provided for by law,
Where it is mandatory for the protection of the life or physical integrity of the person who is unable to express their consent due to actual impossibility or whose consent is not legally recognized, or of another person,
Where the processing of personal data is necessary, provided that it is directly related to the establishment or performance of a contract between the Data Subject and the Company,
Where it is mandatory for the Company to fulfill its legal obligations,
Where the personal data has been made public by the Data Subject themselves,
Where data processing is mandatory for the establishment, exercise, or protection of a right,
Where data processing is mandatory for the legitimate interests of the Company, provided that this does not harm the fundamental rights and freedoms of the Data Subject.

As stated above, the Company may use cookies and, within this scope, may process data and transfer it to third parties for the purpose of processing within the scope of analysis services provided by third parties, solely to the extent required by such analysis services.

The aforementioned technical communication files are small text files sent by the Site to the Data Subject’s browser to be stored in the main memory. By storing information about the status and preference settings regarding a website, the technical communication file facilitates the use of the Site in this respect.

The technical communication file is designed and used for the purposes of obtaining statistical information about how many people use websites over time, for what purpose and how many times a person visits a particular website and how long they stay, and assisting in the dynamic generation of advertisements and content from user pages specially designed for users.

The technical communication file is not designed to retrieve any personal data from the main memory other than the information specified above. Most browsers are initially designed to accept technical communication files; however, users may change their browser settings at any time to prevent the receipt of technical communication files or to receive a warning when a technical communication file is sent.

4. Processing Method of Personal Data

Your personal data is obtained and processed through the Social Attend platform and mobile applications prepared by Social Attend, by fully or partially automated methods where You have approved the sharing, or by non-automated/physical methods, provided that they are part of a data recording system.

Your personal data is processed upon obtaining your explicit consent pursuant to Article 5/1 of Law No. 6698. In addition, where the conditions are met, it may be processed pursuant to Article 5/2(c) of the Law for the establishment, performance, and termination of the contract to be concluded with You; pursuant to Article 5/2(ç) of the Law for the Company to fulfill its legal obligations; pursuant to Article 5/2(e) of the Law for the establishment, exercise, or protection of a right; and pursuant to Article 5/2(f) of the Law within the scope of the legitimate interests of the Data Controller, provided that this does not harm the fundamental rights and freedoms of the relevant persons.

Records relating to the processing activities carried out within the scope of your explicit consent are automatically logged in the system for the purpose of proving consent. The log records kept within this scope are limited to the date and time on which consent was given, user ID information, transaction records, and IP information.

The data processed within the scope of the event is retained for the period required by the purpose of processing, depending on the duration of the processing purposes, in accordance with the Data Controller’s obligation to provide evidence under the KVKK; upon expiry of this period, it is irreversibly deleted or anonymized.

5. Parties to Whom Your Personal Data May Be Transferred and Purposes of Transfer

Your personal data may be shared with and transferred, in accordance with the legal limitations and to the extent required by and proportionate to the purpose and requirements of the relevant transaction, to business partners, intermediary service providers, natural or legal persons from whom services are received, suppliers, and consultants with whom services are provided for purposes such as fulfilling the Processing Purposes specified above, sending commercial electronic communications, processing, storing, and protecting data, provided that the security of such data is ensured through confidentiality agreements and in compliance with Articles 8 and 9 of Law No. 6698.

Personal data may be transferred to natural or legal persons established in Türkiye, as well as abroad for processing and retention either in Türkiye or outside Türkiye (to countries where an adequate level of protection for the protection of personal data is provided and/or to countries where an adequate level of protection is not provided, provided that the conditions specified under the KVKK are complied with).

In addition, personal data may be shared with public institutions or organizations that are legally authorized to request and receive such data, where required by law.

6. Rights of Personal Data Subjects, Personal Data Security and Right to Apply

Your personal data is collected within the scope of the business relationship between You and the Company, through e-mail, telephone, web services, internal systems, and other channels through which You contact us in physical and electronic environments, based on the personal data processing conditions specified in Articles 5 and 6 of the Law.

Your collected personal data is collected based on the following legal grounds: where explicitly provided for by law, where it is mandatory for the Company to fulfill its legal obligations, where it is directly related to the establishment and performance of a contract, based on legal grounds relating to the legitimate interests of our Company, and based on the legal condition of explicit consent with respect to your personal data or the fulfillment of contractual and legal obligations.

The Company protects your personal data in accordance with all technical and administrative security controls required to be implemented pursuant to information security standards and procedures. Such security measures are provided at a level appropriate to potential risks, taking technological capabilities into consideration. As the Company, we ensure that these procedures are maintained at the same level in accordance with the protocols concluded with our business partners and other parties, and the necessary controls are carried out.

As a Personal Data Subject, pursuant to Article 11 of Law No. 6698, You have the following rights:

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 your personal data is used in accordance with its purpose,
To know the third parties to whom your personal data is transferred, either within Türkiye or abroad,
To request the correction of your personal data if it has been processed incompletely or incorrectly,
To request the deletion or destruction of your personal data,
To request that the operations carried out regarding the correction, deletion, or destruction of your personal data be notified to third parties to whom your personal data has been transferred,
To object to the occurrence of a result against You by analyzing your processed data exclusively through automated systems,
To demand compensation for the damage in case You suffer damage due to the unlawful processing of your personal data.

As Personal Data Subjects, You may submit your requests regarding your rights by contacting the Company. Your requests will be concluded as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request.

Relevant persons may submit these requests by completing the “Application Form for the Data Subject Pursuant to the Law on the Protection of Personal Data” and submitting it personally, by mail or cargo, or electronically via e-mail to info@socialattend.com.

If the transaction requires an additional cost, a fee may be charged to You in accordance with the tariff to be determined by the Personal Data Protection Board.

7. Transfer of Personal Data

Your personal data may be transferred, in accordance with the conditions stipulated under the KVKK and the relevant legislation, for the purposes of fulfilling the purposes of processing and carrying out the services, to:

Social Attend service provider,
Technical infrastructure and hosting service providers,
Software and technology service providers,
Service providers involved in event organization,
Business partners and suppliers,
E-mail, communication, analysis, and similar technical service providers,
Authorized public institutions and organizations,
Legally authorized private individuals or organizations.

The transfer of your personal data to third parties is carried out only where the legal conditions stipulated under the relevant legislation are met and is limited to the purpose of processing.

TALYA YAZILIM VE BİLİŞİM ANONİM ŞİRKETİ –
SOCIAL ATTEND

UNDERTAKING FOR THE TRANSFER OF PERSONAL DATA ABROAD WITHIN THE SCOPE OF THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

In this Undertaking, Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend, as the data exporter, and Amazon Web Services EMEA SARL, established abroad, as the data recipient, undertake that they have fulfilled and will fulfill the obligations specified below pursuant to subparagraph (b) of the second paragraph of Article 9 of Law No. 6698.

1. Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend, as the data exporter and Data Controller, undertakes that it has fulfilled and will fulfill the following obligations:

a) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend undertakes that personal data has been processed and transferred in accordance with Law No. 6698 and other relevant legislation.

b) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend has taken all necessary technical and administrative measures to ensure an appropriate level of security according to the nature of the personal data, in order to prevent the unlawful processing of personal data, prevent unlawful access to personal data, and ensure the preservation of personal data, and is assured that these measures have also been taken by the data recipient, Amazon Web Services EMEA SARL.

c) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend has informed the data recipient, Amazon Web Services EMEA SARL, that the transferred personal data will be processed in accordance with Law No. 6698 and the provisions of this agreement.

d) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend has informed the data recipient, Amazon Web Services EMEA SARL, about Law No. 6698 and other relevant data protection regulations to which it is subject.

e) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend has informed the data recipient, Amazon Web Services EMEA SARL, that if the transferred personal data is obtained by others through unlawful means, it is required to notify this situation to it as soon as possible. Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend shall notify the relevant person and the Personal Data Protection Board of this data breach as soon as possible.

f) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend shall submit to the Board the notifications it receives from the data recipient, Amazon Web Services EMEA SARL, within the framework of the provisions of the relevant legislation.

g) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend shall immediately inform the Board as soon as possible about any issues arising in relation to the fulfillment of the provisions contained in this agreement by the data recipient, Amazon Web Services EMEA SARL.

h) Although it has been agreed that the data recipient, Amazon Web Services EMEA SARL, shall respond to questions received from relevant persons and the Board, if it is unable to respond, Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend shall respond to the relevant person or the Board within a reasonable period of time, based on all information and documents in its possession.

i) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend may suspend the transfer of data or terminate the agreement until the relevant breach is remedied in the event that the data recipient, Amazon Web Services EMEA SARL, violates its obligations specified in this agreement.

j) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend shall notify the Board as soon as possible in the event that the data transfer is suspended or the agreement is terminated.

k) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend undertakes that the data recipient, Amazon Web Services EMEA SARL, has the administrative and technical competence required to fulfill its obligations arising from these provisions.

2. Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend, as the data recipient and Data Controller, undertakes that it has fulfilled and will fulfill the following obligations:

a) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend has taken all necessary technical and administrative measures to ensure an appropriate level of security according to the nature of the personal data, in order to prevent the unlawful processing of personal data, prevent unlawful access to personal data, and ensure the preservation of personal data.

b) Amazon Web Services EMEA SARL shall be jointly responsible with such persons for taking the measures specified in subparagraph (a) where personal data is processed on its behalf by another natural or legal person. Persons operating under the authority of Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend, including data processors, shall process personal data only and exclusively in accordance with the instructions they receive from the data recipient.

c) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend shall process personal data in accordance with Law No. 6698 and the agreement between Amazon Web Services EMEA SARL and Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend. If compliance with the Law and the agreement cannot be ensured for any reason, Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend shall be immediately informed of the matter. In this case, Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend may suspend the data transfer and may terminate the agreement.

d) Amazon Web Services EMEA SARL accepts, declares, and undertakes that there is no national regulation contrary to the agreement with respect to the personal data to be transferred pursuant to the agreement. In the event of any change in legislation during the term of the agreement that is likely to affect the data recipient’s fulfillment of its undertakings set forth in the agreement, it shall immediately notify the authorized representatives of Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend. In this case, Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend may suspend the data transfer and shall have the right to terminate the agreement.

e) Amazon Web Services EMEA SARL shall immediately notify Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend of requests received from a judicial authority concerning the transferred personal data. In this case, Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend may suspend the agreement or shall have the right to terminate the agreement, depending on the nature of the request.

f) Amazon Web Services EMEA SARL shall duly respond, as soon as possible, to questions received from Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend under the agreement and shall comply with the decisions and opinions of the Board regarding the processing of the personal data subject to the transfer.

g) Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend has the authority to conduct or have conducted audits regarding whether the undertakings and obligations have been fulfilled, and Amazon Web Services EMEA SARL shall provide the necessary facilitation in this regard.

h) Amazon Web Services EMEA SARL agrees that, in the event of termination of this agreement or expiration of its term, at the discretion of Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend, it shall return the personal data subject to the transfer, together with its backups, to the data exporter or completely destroy the personal data. If there are provisions in the legislation preventing the data recipient from fulfilling this obligation, it shall take the necessary administrative and technical measures to ensure the confidentiality of the personal data subject to the transfer and shall cease the data processing activity.

i) Amazon Web Services EMEA SARL acknowledges that it has the administrative and technical competence required to fulfill its obligations arising from these provisions.

j) Where Amazon Web Services EMEA SARL is required to transfer the personal data subject to the agreement to a subcontractor while performing the services subject to the agreement, Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend shall be informed in a verifiable manner and its approval shall be obtained. The agreement to be concluded between Amazon Web Services EMEA SARL and the subcontractor shall, at a minimum, include the provisions of the agreement between Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend and Amazon Web Services EMEA SARL and the provisions contained in this Undertaking.

The Data Exporter, Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend, and the Data Recipient, Amazon Web Services EMEA SARL;

undertake that they shall not disclose the personal data they process to any other person in violation of the provisions of Law No. 6698 and shall not use such personal data for purposes other than the purpose of processing.

On behalf of the Data Exporter:

Full Name:
Talya Yazılım ve Bilişim Anonim Şirketi – Social Attend

Full Address: Fulya Mah. Büyükdere Cad. No: 74 D/10 Torun Center Şişli/Istanbul

Contact Number: +90 850 441 44 90

E-mail: info@socialattend.com

(Other information, if any, that needs to be specified for the agreement to be binding.)

Signature/Stamp

On behalf of the Data Recipient:

Full Name: Amazon Web Services EMEA SARL

Full Address: Amazon Web Services EMEA SARL
38 Avenue John F. Kennedy
L-1855 Luxembourg
Luxembourg

Contact Number:

E-mail: privacy@amazon.com

(Other information, if any, that needs to be specified for the agreement to be binding.)

Signature/Stamp

UNDERTAKING ANNEX 1

Categories of Data Subjects

The transferred personal data relates to the following categories of data subjects (e.g., employee data, customer data):
 ………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

Data Categories

The transferred personal data relates to the following data categories (personal data or special categories of personal data):
 ………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

Purposes of the Data Transfer

The data transfer is carried out for the following purposes:
 ………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

Legal Basis for the Data Transfer

……………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………..

Recipient and Recipient Categories

The transferred personal data may only be shared with the recipients specified below:
 ………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

Technical and Administrative Measures to Be Taken by the Data Recipient

………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

Additional Measures Taken for Special Categories of Personal Data

Additional Useful Information

(Retention periods and other relevant information)
 ………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

Contact Information of the Contact Person

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INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA

1. Data Controller and Representative

2. Purpose of the Information Notice

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