Merzigo Personal Data Processing and Cookie Policy

As Key Networks Holding Anonim Şirketi (“Merzigo”), we highly value the privacy and security of your Personal Data.

In this regard, ensuring that all Personal Data belonging to our customers, business associates, and all individuals related to Merzigo is processed and stored in compliance with the Law No. 6698 on Personal Data Protection (“KVKK“) is among our top priorities. As the “Data Controller” under KVKK, we would like to inform you about the purposes of processing your Personal Data, the methods and reasons for collecting your data, your rights regarding your Personal Data, and how you can exercise these rights, including the procedures and principles for submitting requests.

1. What is Personal Data? What Personal Data Do We Collect?

Personal Data refers to any information that can be associated with your identity, such as your name, surname, Turkish ID number, address, telephone number, vehicle and license plate information, family status, IP address, and bank account details (“Personal Data”). Special Categories of Personal Data include sensitive information such as race, ethnic origin, political opinions, philosophical beliefs, religion, sect, or other beliefs, clothing, association, foundation or union membership, health data, sexual life, criminal convictions and security measures, biometric data, and genetic data (“Special Categories of Personal Data”). The statements made regarding your Personal Data in this document also apply to Special Categories of Personal Data.

Accordingly, Merzigo may collect Personal Data from its customers, business associates, employees, employee candidates, platform (internet/mobile sites and applications) users, visitors, business partners, and authorized representatives and employees of similar entities with which have business relationships with Merzigo, in compliance with KVKK when necessary.

• Identity Data: Information pertaining to an individual’s identity, such as name and surname, collected from our customers, business associates, employees, employee candidates, platform (internet/mobile sites and applications) users, visitors, business partners, and authorized representatives and employees of similar entities with which we have business relationships.

• Contact Data: Information that facilitates communication with an individual, such as phone number, address, and email address, collected from our customers, business associates, employees, employee candidates, platform (internet/mobile sites and applications) users, visitors, business partners, and authorized representatives and employees of similar entities with which we have business relationships.

• Financial Data: Depending on the legal relationship our company establishes with the relevant data subject, this includes information such as salary, balance sheets, accounting records, and bank account details, collected from our customers, business associates, employees, employee candidates, platform (internet/mobile sites and applications) users, visitors, business partners, and authorized representatives and employees of similar entities with which we have business relationships.

• Physical Space Security Data: Personal data such as security and camera recordings obtained during entry and presence in a physical location, collected from our customers, business associates, employees, employee candidates, platform (internet/mobile sites and applications) users, visitors, business partners, and authorized representatives and employees of similar entities with which we have business relationships.

• Communication and Complaint Management Data: Personal data obtained during the processes of receiving and evaluating any request or complaint directed to our company, collected from our customers, business associates, employees, employee candidates, platform (internet/mobile sites and applications) users, visitors, business partners, and authorized representatives and employees of similar entities with which we have business relationships.

• Other Data: This includes data processed for technical transaction security, investment information, cookies, and data collected automatically through various means, collected from our customers, business associates, employees, employee candidates, platform (internet/mobile sites and applications) users, visitors, business partners, and authorized representatives and employees of similar entities with which we have business relationships.

• How and Why Do We Collect/Process Your Personal Data?

We collect your Personal Data for the primary purposes and methods listed below, as well as through additional channels that may be introduced in the future, using automated or non-automated means, in oral, written, or electronic form.

We collect your Personal Data via our internet and mobile platforms (internet/mobile websites and applications), our social media accounts operated on behalf of Merzigo on various social media platforms, through communication methods such as email, short message service (“SMS”), or multimedia messages (“MMS”). Additionally, we collect data within the scope of Merzigo’s commercial activities through contracts executed with you or the company you represent, commercial offers, printed and electronic forms, business cards and other documents you provide during our visits, as well as from third parties such as Merzigo’s group companies, business connections, and service/product suppliers, and from sources including the Trade Registry. Your Personal Data may be collected partially or entirely through automated means or through non-automated methods as part of a data recording system.

We process your Personal Data based on one or more of the following legal grounds:

• Your explicit consent;
• Where permitted by the laws and regulations in force in the Republic of Türkiye;
• Where it is necessary for the protection of the life or physical integrity of yourself or another person in cases where you are unable to give consent due to actual impossibility;
• Where necessary for the performance of a contract to which you or your company is a party to;
• Where necessary for compliance with our legal obligations;
• Where your Personal Data has been made public by you;
• Where necessary for the establishment, exercise, or protection of legal or contractual rights of Merzigo;
• Where processing is necessary for our legitimate interests, provided that it does not infringe your fundamental rights and freedoms.

As Merzigo, we retain all processed Personal Data in compliance with the Personal Data Protection Law (KVKK) and other applicable legislation for the periods mandated therein. In any case, we continue to implement all necessary administrative and technical measures to ensure their security as long as the legitimate purposes for processing remain valid.

• For What Purposes Do We Process Your Personal Data?

We process the Personal Data we collect according to their nature for the following general purposes:

• Fulfilling contractual obligations under agreements executed by Merzigo and ensuring the provision of products and services.
• Monitoring and fulfilling obligations arising from legal regulations and responding to consumer applications.
• Tracking, evaluating, and managing requests and complaints from customers and related individuals, providing support services, managing customer satisfaction, and conducting planning, statistical analysis, and satisfaction surveys.
• Conducting quality assessment and improvement efforts to provide better and more reliable products and services and ensure sustainability, as well as auditing business partners and other related entities.
• Carrying out marketing and advertising activities for products and services offered by Merzigo, including promotions, campaigns, offers, events, and providing information about new products and services, as well as managing corporate communication activities.
• Conducting marketing and Customer Relationship Management (CRM) activities.
• Organizing corporate communication events and parties and informing participants, as well as conducting market research studies.
• Enhancing our website and mobile platform to provide a more efficient and personalized user experience by analyzing visitor statistics such as the number of users, types of users, visit frequency, behaviors, and geographical locations. Additionally, presenting personalized content, campaigns, and advertisements to users based on their interests and needs using cookies.
• Ensuring the legal and commercial security of Merzigo and individuals in business relationships with Merzigo, such as planning administrative operations related to communications, ensuring the physical security and monitoring of company locations, evaluating and auditing business partners, customers, and suppliers, and managing legal compliance processes.
• Retaining transaction history information after the termination of legal relationships to serve as evidence in case of disputes or in order to exercise legal rights.
• Determining and implementing commercial, legal, and business strategies of Merzigo.
• Managing human resources, accounting, and financial policies of Merzigo.
• Planning, auditing, and implementing information security processes.
• Ensuring compliance with national and international regulations, fulfilling reporting obligations, and providing requested information to public institutions and authorities.
  
• Do We Transfer Your Personal Data to Third Parties and/or Abroad?

We share your Personal Data with other Merzigo group companies located both in Türkiye and abroad. As Merzigo, we commit to ensuring that your Personal Data is securely stored and is not unlawfully processed.

In the presence of the legal grounds mentioned above, we may transfer your Personal Data to our business partners, suppliers, banks, financial institutions, legal and tax consultancy firms, and other related parties both in Türkiye and abroad, such as but not limited to EU countries, the United States, OECD countries, and India. This includes storage, archiving, IT support such as server, hosting, software, cloud computing, and call center services provided by third parties abroad.

Apart from these cases, Personal Data that requires explicit consent will only be transferred with your explicit consent to group companies, business partners, suppliers, banks, financial institutions, and consulting firms located in both Türkiye and abroad, as well as to authorized institutions and organizations for the designated purposes.

Additionally, Merzigo may transfer data to the following third parties within legitimate purposes and legal boundaries: (1) institutions and organizations defined by laws and regulations; (2) Tax and legal consultants, auditors, and other external professional advisors; (3) IT system providers and customer satisfaction-focused marketing service providers that offer services or products to Merzigo.

By agreeing to this policy, you consent to the transfer and processing of your Personal Data to Merzigo group companies located in the United States and the United Kingdom where necessary for the above-mentioned purposes.

• Your Rights and Application Procedure
• Your Rights Regarding Your Personal Data

Under Article 11 of the Personal Data Protection Law (KVKK), you have the following rights regarding your Personal Data processed within Merzigo and its affiliates:

• To learn whether your Personal Data is being processed or not,
• To request information regarding the processing of your Personal Data
• To learn the purpose of processing Personal Data and whether they are used in accordance with that purpose
• To learn the third parties to whom Personal Data is transferred, whether domestically or internationally
• To request the rectification of incomplete or inaccurate Personal Data
• To request notification of corrections, deletions, or destruction of Personal Data to third parties to whom Personal Data has been transferred
• To request the  erasure or destruction of your Personal Data in the event that the grounds for processing no longer exist or if your data becomes outdated
• To object to the occurrence of a result against you by analyzing the data processed solely through automated systems,
• To claim compensation if you suffer damage due to the unlawful processing of Personal Data

You may submit your requests regarding these rights by filling out the application form below and sending it to us via the email address info@merzigo.com.

1. Application

You may submit your requests regarding your Personal Data by completing the application form below and sending it to our company in writing or via registered electronic mail (KEP), secure electronic signature, mobile signature, or the email address you have previously provided to us and is registered in our system.

Merzigo will process the requests submitted to it as soon as possible and no later than thirty (30) days, free of charge, depending on the nature of the request. If fulfilling your request incurs a cost, we may charge only the fees determined by the Personal Data Protection Board. To access the application form, please click here.

Merzigo may accept or reject requests submitted to it, providing justification for any rejection, and will inform the applicant in writing or electronically. If the request is accepted, Merzigo is obliged to take the necessary action immediately.

1. Complaint

If your request submitted to Merzigo is rejected, if you are not satisfied with the response provided by Merzigo, or if you do not receive a response, you have the right to file a complaint with the Personal Data Protection Authority within thirty  (30) days from the date the response was communicated to you, or if no response was provided, within thirty (30) days from the end of the response period.

• Data Controller Identity Information

The term “Merzigo” used in this document refers to the legal entity established in Türkiye, and this text has been prepared for the relevant data subjects whose data is processed by the company specified below as the data controller.

Title: Key Networks Holding Anonim ŞirketiAddress: Akat Mh. Ebulula Mardin Cd. No:24/1, 34335 Beşiktaş/İstanbul Phone: +90 212 282 15 02 E-mail: info@merzigo.com Registered electronic mail (KEP):