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Personal Data Protection Privacy Notice

This text has been prepared by Alkur Kapı Sistemleri A.Ş. as data controller pursuant to Personal Data Protection Law No. 6698 (KVKK), to inform you about the purposes for which your personal data is processed, to whom and for what purpose it may be transferred, the method of collection, the legal basis, and your rights under Article 11 of KVKK. The final legal text will be updated with attorney approval.

Data controller

Under Law No. 6698 on the Protection of Personal Data (“KVKK”), the data controller is Alkur Kapı Sistemleri Anonim Şirketi (“Company”). General contact e-mail address: info@alkur.com.tr.

Personal data processed

Personal data may be processed in categories such as identity, contact, request and communication content, written chat and audio (voice) recordings, technical records related to transaction security (e.g. IP, browser information, logs) and measurement and marketing data collected via cookies (e.g. Google Analytics, Meta Pixel) — through our website, our contact and quotation forms, our AI-assisted assistant, voice-call and messaging (e.g. WhatsApp) channels, telephone, e-mail and fair / event channels. Cookie-based measurement and marketing tools are loaded only with your explicit consent and may transfer data to the relevant provider (for Meta Pixel, Meta Platforms — abroad); details are explained in the Cookie Policy.

Processing purposes

Your personal data may be processed for the purposes of fulfilling your request and the contract, managing customer and visitor relations, providing information and technical support, developing our products and services, fulfilling our obligations arising from legislation, monitoring legal disputes and managing information security processes.

Processing may be carried out on the basis of one or more of the legal grounds set out in Articles 5 and 6 of the KVKK, including: being expressly provided for by law, being directly related to the establishment or performance of a contract, the data controller’s fulfilment of a legal obligation, the establishment or protection of a right, legitimate interests, or your explicit consent.

Transfer

Your personal data may be transferred to suppliers from whom services are procured for the realisation of these purposes (e.g. hosting/server, e-mail delivery, CRM, automation, messaging and voice-call infrastructure), to business partners, consultants, official authorities and authorised public institutions and organisations, in accordance with KVKK and related legislation and provided that the necessary security measures are taken. Where a transfer abroad is involved, the conditions set out in Article 9 of the KVKK — an adequacy decision, appropriate safeguards (e.g. standard contractual clauses notified to the Board) or the prescribed occasional cases — are observed.

Collection method and retention period

Data may be collected through automatic or non-automatic means, electronically or via physical channels. Retention periods are limited to the maximum durations determined in connection with the relevant legislation and the purpose of processing; at the end of the period the data is deleted, destroyed or anonymised. The specific retention period for voice and written conversation records under the AI-assisted assistant is stated in the section below.

AI-assisted assistant, voice calls and messaging channels

The Company may offer an AI-assisted digital assistant (chatbot) through the website chat window, voice calls over the telephone and messaging channels such as WhatsApp. The assistant is used to answer your questions, direct you to the relevant department and, in line with your request, initiate an e-mail or quotation.

Data processed. On these channels your identity and contact information (name, e-mail, telephone), the content of your request, written chat records and, on voice calls, audio records (a voice recording and/or a transcribed version of the call) may be processed. Voice calls may be recorded for service quality and to handle your request accurately; where a recording is made you are informed at the start of the interaction and, where deemed necessary, your explicit consent is obtained. These records are used solely to carry out your request; your voice is not processed for identity verification (biometric recognition).

Automated processing. The assistant is an automated system; it provides information and initial routing. Final commercial assessment and quotations are concluded through review by our staff. Your rights regarding solely automated processing are stated in the “Your rights under KVKK” section below.

Retention period. Voice and written conversation records under the assistant are retained for a maximum of one month (30 days), limited to and proportionate with the purpose; at the end of this period they are deleted, destroyed or anonymised. If your request turns into a quotation or contract process, the relevant contact and request information may continue to be processed within the scope of the legislation and retention obligations applicable to those processes.

Transfer abroad. Hosting/server, automation and messaging infrastructure providers are used to deliver this service, and some of these providers may be located abroad (e.g. in European Union countries). Any transfer abroad is carried out on the basis of one of the methods under Article 9 of the KVKK — as updated by the amendment of 12 March 2024 — namely the existence of an adequacy decision, in its absence the provision of appropriate safeguards (e.g. standard contractual clauses notified to the Board), or, in the prescribed occasional cases, obtaining your explicit consent.

Your rights under KVKK

Pursuant to Article 11 of the KVKK, you have the right to apply to the data controller and: learn whether your personal data is processed, request information if it is processed, learn the purpose of processing and whether they are used in accordance with their purpose, know the third parties to whom they are transferred at home or abroad, request correction if processed incompletely or incorrectly, request deletion or destruction within the framework of the conditions set out in the KVKK, request that correction / deletion be notified to the third parties to whom the data has been transferred, object to an outcome unfavourable to you arising solely from the analysis of automated systems, and request compensation if you incur damage due to unlawful processing.

Application

To exercise your rights, you may apply to the Company in writing — along with information confirming your identity — or by other methods determined by the Board. Response times for your application are subject to the periods foreseen in the KVKK and secondary regulations.

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