PROTECTION OF PERSONAL DATA DISCLOSURE TEXT

Sender Ödeme Hizmetleri A.Ş. (“Sender”) is highly sensitive about the security of your personal data. Accordingly, this Disclosure Text has been prepared to inform and explain that all types of personal data belonging to our employees, job applicants, customers benefiting from our products and services, potential customers, and all other persons related to our Company, as well as visitors to our website, are processed and stored by our Company, acting as the Data Controller, in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and related regulations, in connection with and proportionate to our activities and purposes as explained below.

1. Methods of Collecting Your Personal Data

Your personal data may be collected, including but not limited to, the following methods: connection information recorded as required by legislation while using our website and social media accounts, communication forms you fill out electronically, forms filled at our workplaces, offices, and facilities, written or verbal communications with our Company via online channels, emails sent to our Company, information and documents sent via tools such as fax or mail, information and documents shared during phone calls or directly in meetings with our Company, information and documents shared during meetings and events organized by our Company, and contracts signed with our Company. These data are collected in oral, written, or electronic formats, in whole or in part, by automated or non-automated means, in compliance with Articles 1 and 2 of the KVKK.

2. Purposes of Processing Your Personal Data

Your personal data may be processed by our Company, acting as the Data Controller, and/or by authorized representatives, individuals, or entities with whom our Company cooperates. These purposes include executing and performing our payment services and business activities, planning and carrying out our service sales processes, improving and diversifying our products and services, conducting the necessary activities to enable related persons to benefit from these services, informing you about our products and services, measuring your satisfaction with our products and services, managing your requests and complaints, conducting the necessary quality and standard audits, planning, auditing, and executing information security processes, determining and implementing our commercial and business strategies, planning and executing business continuity activities, managing finance, accounting, and invoicing processes, following legal procedures, fulfilling legal obligations, maintaining communications with official institutions, and, when necessary, providing information required by regulations. Other purposes include fulfilling reporting and other obligations prescribed by law, ensuring the accuracy and currency of data, securing Company operations, protecting the legal, technical, and commercial job security of persons in a business relationship with our Company, and ensuring the compliance of Company activities with Company procedures and relevant legislation. All these activities are carried out for operational purposes in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK.

3. Personal Data Processed Based on Your Explicit Consent

Sender may process your personal data, as described in this section, based on your explicit consent, which you provide by approving this Disclosure Text. The personal data you share with Sender, including identity information, contact details, employee candidate information, visitor entry/exit records, customer transaction information, connection details, transaction security data, risk management data, legal transaction and compliance information, physical space security data, marketing data, and other general or sensitive personal data, may be processed, transferred, and stored for the purposes specified above in compliance with the personal data processing conditions outlined in Articles 5 and 6 of the Law.

4. Situations Where Explicit Consent Is Not Required

According to Article 5(2) of the KVKK, Sender may process personal data without your explicit consent in the following cases: when explicitly required by law, when necessary to protect the life or physical integrity of the individual or another person who is unable to express consent due to actual impossibility or whose consent lacks legal validity, when processing is directly related to the establishment or execution of a contract involving the data subject, when required to fulfill a legal obligation of the data controller, when the data subject has made their data public, when necessary for the establishment, use, or protection of a legal right, and when processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject. Except for these exceptions and the circumstances prescribed by legislation, all personal data, including sensitive data, cannot be processed without explicit consent.

5. Recipients of Your Personal Data

The personal data collected by Sender may be shared and transferred, in line with the purposes described above and within the scope of Articles 8 and 9 of the Law, with affiliates, shareholders, business partners, suppliers, auditors, service providers, legally authorized public institutions and organizations, private institutions and organizations, professional organizations, and similar entities. They may also be shared with regulatory and supervisory authorities, persons authorized by legislation, and other individuals or entities permitted by law for the purposes of carrying out the commercial activities of the Company as required.

6. Your Rights

Under Article 11 of the KVKK, as a personal data owner, you have the following rights: to learn whether your personal data has been processed, to request information regarding such processing if it has occurred, to learn the purpose of processing your data and whether it is being used in line with those purposes, to know the third parties, domestically or internationally, to whom your personal data has been transferred, to request the correction of incomplete or incorrect data and to have this correction notified to third parties to whom the data has been transferred, to request the deletion, destruction, or anonymization of your personal data when the reasons for processing no longer exist and to have this notification made to the third parties to whom the data has been transferred, to object to any results arising against you through automated analysis of your processed data, and to demand compensation for damages incurred due to the unlawful processing of your personal data.

To exercise your rights regarding your personal data, you may send an email to info@send-r.com or fill out the form available in the contact section on our website at www.send-r.com. Sender will resolve your request within 30 days at the latest.