Clarification Text

on the Protection and Processing of PII

Clarification Text

on the Protection and Processing of PII

The purpose of this information is to inform regarding the use of PII obtained during the use of the BTguru website and applications managed by BTguru Labs Bilişim Teknolojileri ve Danışmanlık A.Ş. (hereinafter referred to as “BTguru“) and/or received from third parties in accordance with Article 10 of the Turkish PII Protection Law No. 6698 (hereinafter referred to as “KVKK”) is its fulfillment.

BTguru makes every effort to comply with the applicable legislation regarding the processing and protection of PII in line with the company’s internal regulatory rules. In line with this effort and responsibility, great importance is attached to the processing and preservation of all kinds of PII belonging to all persons who share their information with BTguru within the scope of the relevant legislation. In this context, PII is processed by BTguru (in the capacity of Data Controller) as explained below and within the limits ordered by the legislation, and these information provisions can be updated and changed by publishing them on the BTguru website. Such updates and changes will be effective from the date of publication by BTguru.

1. Definitions

In this text.

BTguru means BTguru Labs Bilişim Teknolojileri ve Danışmanlık A.Ş. and BTguru website.
Personally Identifiable Information (PII) means any information relating to an identified or identifiable natural person.
Processing of PII means all kinds of activities carried out in the process of obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, transferring, making available, classifying, preventing the use of PII, until deletion, destruction or anonymization,
Turkish Protection of Personally Identifiable Information Law (“KVKK”) means Turkish Law No. 6698 on the Protection of Personally Identifiable Information.
Data Controller means the natural or legal person who determines the purposes and means of processing PII and is responsible for the establishment and management of the data recording system.

2. Data Controller

Regarding the PII processed on the BTguru website, the Data Controller is BTguru. PII will be collected and processed in accordance with the Constitution of the Republic of Türkiye, the Conventions to which Türkiye is a party, the KVKK and all other relevant legislation.

3. Collected PII

The PII processed on the BTguru website are name, surname, email address, mobile phone number of the persons who contact BTguru either via contact form, e-mail or SMS.

4. Purpose of Processing PII

PII will be processed within the conditions and purposes of processing the PII specified in the basic principles regulated by the KVKK and the 5th and 6th articles of the KVKK.

5. Where is PII Processed and Stored?

PII collected by BTguru is stored electronically and redundantly on servers located within the borders of the Republic of Türkiye (located in the Turkcell İletişim Hizmetleri A.Ş. infrastructure provided by IHS Software & Telecommunication FP Ltd.) belonging to the institution from which the server service is received and processed in line with and limited to the purposes of this information.

6. To Whom and for What Purpose Can PII Be Transferred?

PII can be shared with legally authorized judicial and administrative authorities, lawyers and/or auditors where necessary, in order to protect BTguru‘s legal rights and fulfill its obligations. All necessary technical and administrative measures can be provided and transferred by BTguru in line with the PII processing conditions and purposes specified in Article 8 of the KVKK.

7. Retention Period of PII

The PII collected will be retained for the period necessary for the purpose for which they are processed. In addition, BTguru will store PII in case of any dispute and within the scope of the dispute, limited to the purpose of carrying out administrative and judicial processes, and for the duration of the statute of limitations determined in accordance with the relevant legislation.

8. PII Collection Method and Legal Reason

PII are collected, used, recorded, stored and processed by BTguru within the framework of the principle of proportionality, in accordance with the law and the rules of honesty, in connection with and limited to the legitimate purpose clearly stated in this information, by providing clear and understandable written information to the PII owner, if necessary, by obtaining the explicit consent of the PII owner. The processing of all kinds of data obtained by these methods is based on the legal reasons specified in Articles 5 and 6 of the KVKK.

Clearly stipulated in the laws.
Processing is mandatory in order to fulfill BTguru‘s legal obligation.
Directly related to the establishment or performance of the contract and the processing is necessary for the establishment and performance of the contract.
Processing is necessary for the fulfillment of BTguru’s legitimate interest.
The data has been made public by the owner of the PII.
Data processing is mandatory for the establishment, exercise or protection of a right.
Obtaining the explicit consent of the PII owner.

9. Rights of the Data Owner

In the event that PII owners submit their requests regarding their rights to BTguru through the methods stated below, BTguru will finalize the request as soon as possible and within thirty (30) days at the latest, depending on its nature.

The response to the application will be communicated to the applicant electronically via e-mail. In this context, PII owners have the following rights in accordance with Article 11 of the KVKK:

To learn whether their PII is processed or not,
If PII has been processed, requesting information about it,
To learn the purpose of processing PII and whether they are used in accordance with their purpose,
To learn the third parties to whom PII is transferred within the country or abroad,
Requesting correction of PII in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to third parties to whom PII has been transferred,
Although it has been processed in accordance with the provisions of the KVKK and other relevant laws, to request the deletion or destruction of PII in the event that the reasons requiring its processing disappear, and to request notification of the transaction made within this scope to the third parties to whom the PII has been transferred,
Objecting to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,
Requesting compensation for the damage in case of damage due to unlawful processing of PII.

The following information and documents must be included in the application regarding the above-mentioned rights, and if available, the relevant information and documents must also be attached to the application:

First name, last name, phone number, and e-mail address.
If the application is in writing, the applicant’s handwritten (wet) signature.
If the application is electronic, the (electronic) signature of the applicant with the Qualified Electronic Certificate as defined in the Turkish Electronic Signature Law No. 5070.
Republic of Türkiye Identity Number for citizens of the Republic of Türkiye; Foreigner Identity Number if available for citizens of other countries, nationality and passport number if not.
The address of the place of residence or workplace for the notification,
e-Mail address, telephone or fax number subject to the request, if any,
The subject of the request (in simple, clear and understandable terms).

The application can be made by choosing any of the following methods:

BTguru Labs Bilişim Teknolojileri ve Danışmanlık A.Ş. “Atatürk Mh. Ertuğrul Gazi Sk. No 2E/331 Ataşehir 34758 Istanbul, Türkiye” (Republic of Türkiye Identity Card, Republic of Türkiye Driver’s License, etc. a document confirming the identity must be present, otherwise the application will not be processed).
BTguru Labs Bilişim Teknolojileri ve Danışmanlık A.Ş. “Atatürk Mh. Ertuğrul Gazi Sk. No 2E/331 Ataşehir 34758 Istanbul, Türkiye” by sending it to the address through a notary public.
btguru@hs01.kep.tr By sending a Registered Electronic Mail (KEP) message to the address, (electronically) signed with a Qualified Electronic Certificate as defined in the Turkish Electronic Signature Law No. 5070.

10. Precautions and Commitments Regarding PII Security

BTguru will not disclose the PII it obtains to anyone else in violation of this Clarification Text, KVVK provisions and basic principles, and will not use it outside the purposes and limits of processing.

BTguru is committed to protecting PII securely. In order to prevent the unlawful processing of PII and unlawful access to PII, and to ensure the protection of PII, it carries out technical and administrative measures to ensure the appropriate level of security by using various methods and security technologies.

BTguru declares and undertakes that it will carry out the necessary warning and audit activities for third parties to comply with the commitments under this article in case of sharing PII when necessary and mandatory.