ICRYPEX | Clarification Text For Personal Data

ICRYPEX BİLİŞİM A.Ş.

PERSONAL DATA CLARIFICATION TEXT

Data Controller:

ICRYPEX BİLİŞİM ANONİM ŞİRKETİ (“ICRYPEX” or “Company”)

Maslak Mah. Maslak Meydan Sok. Spring Giz Plaza N:5/57 34398 Sarıyer/İstanbul

As ICRYPEX, we show maximum sensitivity for the security of personal data and the protection of fundamental rights and freedoms, especially privacy in the processing of your personal data, while continuing our activities.

A part of your personal data is processed by ICRYPEX as a data controller. With this Clarification Text, we inform you about your personal data, the way your personal data is collected and transferred, the purposes of processing, legal reasons, and your rights in accordance with the provisions of the Law on the Protection of Personal Data No. 6698 ("KVKK").

ICRYPEX reserves the right to update this Clarification Text at any time within the framework of changes that may be made in the legislation and changes in the purposes of processing and transferring personal data. You can always easily follow the updates made via our website.

Groups of Person

1. Person Receiving the Product or Service (Customer)

Personal Data Processed

Data Categories	Data Processed
Identity	Name, Surname, T.R. Identity Number, Date of Birth, Nationality, Foreign Identity Number (For Foreign Nationals Only)
Contact	E-mail Address, Mobile Phone Number
Transaction Security	IP information connected to the system, device information connected to the system, Date of Membership to the System
Customer Transaction	Call Center Records

Your personal data specified above are processed by us with the membership form you filled in during membership, and if you complete the Customer Level Verification procedures, your personal data will be processed by us in addition to the abovementioned ones.

Data Categories	Data Processed
Identity	Place of Birth, Names of Mother and Father, Identity Serial No, Validity Date and Place of Issue, Place of Registry, Signature Sample, Previous Surname, Photograph, Marital Status, Gender, Religion, Blood Group, Passport Issue and Validity Date and Issuing Authority Information, Passport Photo
Contact	Address Information, Invoice Proving that the Address Registered is in the Name of the Customer and Information on the Invoice
Visual Records	Photo (Selfie)
Professional Experience	Information Regarding the Company for which the Customer is Authorized, the Position and Title of the Customer within the Company (Only for the Representatives of Legal Entity Customers)
Finance	Bank Account Information, Bank Statement for the Last 3 Months, Crypto Addresses, Assets in our Stock Market

Purposes of Processing Personal Data

Data Categories	Purposes of Processing
Identity	Execution of Internal Audit Activities Ensuring the Security of Data Controller Operations, Conducting Sales and Marketing Activities Conducting Communication Activities, Execution/Supervision of Business Activities Follow-up and Control of Requests/Suggestions/Complaints Conducting Activities Aimed at Customer Satisfaction Execution of Production and Operation Processes of Goods/Services Conducting Activities to Ensure Business Continuity Follow-up and Execution of Legal Affairs
Contact	Execution of Internal Audit Activities Ensuring the Security of Data Controller Operations, Conducting Sales and Marketing Activities Conducting Communication Activities, Execution/Supervision of Business Activities Follow-up and Control of Requests/Suggestions/Complaints Conducting Activities Aimed at Customer Satisfaction Execution of Production and Operation Processes of Goods/Services Conducting Activities to Ensure Business Continuity Execution of Customer Relations Processes Follow-up and Execution of Legal Affairs
Visual Records	Execution of Internal Audit Activities Ensuring the Security of Data Controller Operations, Execution of Production and Operation Processes of Goods/Services Follow-up and Execution of Legal Affairs
Professional Experience	Execution of Internal Audit Activities Ensuring the Security of Data Controller Operations, Execution of Production and Operation Processes of Goods/Services Follow-up and Execution of Legal Affairs
Finance	Execution of Internal Audit Activities Ensuring the Security of Data Controller Operations, Execution of Production and Operation Processes of Goods/Services Conducting Activities to Ensure Business Continuity Execution of Customer Relations Processes Follow-up and Execution of Legal Affairs
Transaction Security	Execution of Internal Audit Activities Ensuring the Security of Data Controller Operations, Execution of Information Security Processes Conducting Activities to Ensure Business Continuity Follow-up and Execution of Legal Affairs
Customer Transactions	Follow-up and Control of Requests/Suggestions/Complaints Conducting Activities Aimed at Customer Satisfaction Execution of Information Security Processes Follow-up and Execution of Legal Affairs

Legal Reasons for Processing Personal Data

Data Categories	Legal Reasons
Identity	Processing of personal data belonging to the parties to the agreement is necessary, provided that it is directly related to the establishment or execution of the agreement Data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the Data Subject are protected Mandatory for the data controller to fulfill her/his legal obligation, Obtaining the explicit consent of the Data Subject Explicitly prescribed in laws
Contact	Processing of personal data belonging to the parties to the agreement is necessary, provided that it is directly related to the establishment or execution of the agreement Data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the Data Subject are protected Mandatory for the data controller to fulfill her/his legal obligation, Explicitly prescribed in laws
Visual Records	Processing of personal data belonging to the parties to the agreement is necessary, provided that it is directly related to the establishment or execution of the agreement Data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the Data Subject are protected Mandatory for the data controller to fulfill her/his legal obligation,
Professional Experience	Processing of personal data belonging to the parties to the agreement is necessary, provided that it is directly related to the establishment or execution of the agreement Data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the Data Subject are protected Mandatory for the data controller to fulfill her/his legal obligation, Explicitly prescribed in laws
Finance	Processing of personal data belonging to the parties to the agreement is necessary, provided that it is directly related to the establishment or execution of the agreement Data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the Data Subject are protected Mandatory for the data controller to fulfill her/his legal obligation, Explicitly prescribed in laws
Transaction Security	Processing of personal data belonging to the parties to the agreement is necessary, provided that it is directly related to the establishment or execution of the agreement Data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the Data Subject are protected Mandatory for the data controller to fulfill her/his legal obligation, Explicitly prescribed in laws
Customer Transaction	Required for the performance of the agreement Legitimate Interests of the Company

In addition, for the purposes of tracking requests/complaints and conducting/controlling communication activities if you contact us via the Call Center and/or Chat Screens, the information you provide in phone calls and other information you share via message will be processed based on the legal reason that it is required to process the personal data of the parties to the agreement, provided that it is directly related to the establishment and performance of an agreement as per the Article 5/2 subparagraph (c) of the KVKK.

2. Online Visitors

Personal Data Processed

Data Categories	Data Processed
Identity	Full Name
Contact	E-mail Address, Mobile Phone Number
Transaction Security	IP information connected to the system, Device information connected to the system
Customer Transaction	Call Center Records

Purposes of Processing Personal Data

Data Categories	Purposes of Processing
Identity	Conducting Sales and Marketing Activities Conducting Communication Activities, Execution/Supervision of Business Activities Follow-up and Control of Requests/Suggestions/Complaints
Contact	Conducting Sales and Marketing Activities Conducting Communication Activities, Execution/Supervision of Business Activities Follow-up and Control of Requests/Suggestions/Complaints
Transaction Security	Execution of Information Security Processes
Customer Transaction	Follow-up and Control of Requests/Suggestions/Complaints Execution of Information Security Processes

Legal Reasons for Processing Personal Data

Data Categories	Legal Reasons
Identity	Processing of personal data belonging to the parties to the agreement is necessary, provided that it is directly related to the establishment or execution of the agreement Data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the Data Subject are protected Mandatory for the data controller to fulfill her/his legal obligation,
Contact	Processing of personal data belonging to the parties to the agreement is necessary, provided that it is directly related to the establishment or execution of the agreement Data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the Data Subject are protected Mandatory for the data controller to fulfill her/his legal obligation,
Transaction Security	Data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the Data Subject are protected Mandatory for the data controller to fulfill her/his legal obligation,
Customer Transaction	Required for the performance of the agreement Legitimate Interests of the Company

By Means of Which Methods Is Your Personal Data Collected?

Your abovementioned Personal Data are processed by electronic means if;

you fill out the Membership Form during membership,
you upload documents to the system for Customer Level Verification,
you contact us using the Call Center and/or Chat Screens.

To Whom And For What Purposes Your Personal Data May Be Transferred?

Your personal data can be transferred to;

our Suppliers for and limited to the purpose of Managing Information Security Processes, Follow-up and Execution of Legal Affairs, Execution of Finance and Accounting Affairs, Execution of Supply Chain Management Processes, Carrying out Internal Audit Activities, and
our Authorized Public Institutions and Organizations, upon request, for the Follow-up and Execution of Legal Affairs and Providing Information to Authorized Persons, Institutions and Organizations.

Also, your Personal Data that we collect and process during your membership, will be recorded in our systems provided by our suppliers providing cloud infrastructure services, who are located abroad and whose servers are located abroad, and therefore will be transferred abroad in line with your explicit consent to carry out information security processes, business activities, storage and archiving activities, to ensure the quality of service we provide and service continuity, by observing the rules in Article 9 of the KVKK titled "Transferring Personal Data Abroad" and by adopting the necessary technical and administrative measures.

How Long Is Your Personal Data Stored?

Your personal data must be kept for at least this period, if a period is determined in the law or the relevant legislation for data storage. If a period is not foreseen in the law or the relevant legislation; it is stored for reasonable periods determined in connection with the purposes of processing, provided that it is limited and measured.

What Are Your Rights Regarding Your Personal Data as a Data Subject?

Regarding your personal data, you are entitled to;

Learn whether your personal data is processed,
Request information if your personal data has been processed,
Learn the purpose of processing personal data and whether it is used for the intended purpose,
Knowledge of third parties, to whom your personal data is transferred at home or abroad,
Request correction if your personal data is incomplete or incorrectly processed,
Request the deletion or destruction of personal data in accordance with the conditions provided in the KVKK legislation,
When you request the correction of incomplete or inaccurate data and the deletion or destruction of your personal data, request that third parties to whom we have transferred your personal data are notified of this situation,
Object to the raise of a consequence, which is against the person herself/himself, by means of analysis of processed data exclusively through automated systems, and
Request compensation if you suffer damages due to wrongful processing of your personal data.

How can you exercise your rights as a Data Subject?

You can forward all your requests and objections regarding your personal data such as information, correction, deletion, destruction to our Company through the methods specified in the “RELEVANT PERSON APPLICATION FORM” or other methods determined by the Personal Data Protection Board.

Mailing address : Maslak Mah. Maslak Meydan Sok. Spring Giz Plaza N:5/57 Sarıyer/İstanbul

E-mail address : [email protected]

REM Address : [email protected]

In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, the name, surname, if the application is in writing, the signature of the Data Subject in the application, T.R. identity number (if the applicant is a foreign national, passport number or identity number, if any), the place of residence or workplace address for notification, the e-mail address, telephone number and fax number for notification, if any, and information on the subject of the request are mandatory.

The Data Subject must clearly and comprehensibly state the subject requested in the application, which includes explanations regarding the right to be exercised and will be submitted to use the abovementioned rights. Information and documents related to the application must be attached to the application.

Although the subject of the request must be related to the applicant herself/himself, the applicant must be specifically authorized in this regard and this authority must be documented (power of attorney) if the applicant is acting on behalf of someone else. In addition, the application must contain identity and address information, and documents confirming identity must be attached to the application.

Requests by unauthorized third parties on behalf of someone else will not be considered.

How Long Will Your Requests Regarding the Processing of Your Personal Data Be Answered?

Your requests regarding your personal data are evaluated and answered as soon as possible and within 30 days at the latest from the date they are received by the Company. If your request is accepted or rejected by explaining the reason, our reply will be sent to the address you specified in the application, primarily by mail or e-mail, if possible, in the same manner as your request.

We undertake that your personal data will always be processed in accordance with the relevant legislation and our Company's own data protection policies, your personal rights will be protected, your personal data will be kept confidential, we will take all necessary technical and administrative measures to ensure confidentiality and security, and that we will show due diligence.

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