PERSONAL DATA PROTECTION LAW – PRIVACY NOTICE

ProSMT Electronics Personal Data Privacy Notice (KVKK Compliance)

Acting as the data controller, ProSMT Electronics Inc. (the “Company”) has prepared this disclosure text in accordance with Article 10 of the Law on the Protection of Personal Data No. 6698 (“KVKK”) titled “Data Controller’s Obligation to Inform” and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform, published in the Official Gazette No. 30356 on March 10, 2018, to explain and inform you about the processing of your personal data.

The text below informs you about the purposes, legal grounds, collection methods, and possible recipients of your personal data held by the Company under this law.

METHODS AND LEGAL BASIS FOR PERSONAL DATA COLLECTION

As the data controller, the Company collects your personal data, including sensitive personal data, through verbal, written, or electronic means with your explicit consent, in line with KVKK and other relevant legislation, arising from legal obligations, contracts, requests, commercial practices, and principles of good faith. The collection methods include but are not limited to:

  • Membership forms completed electronically or physically

  • Member login on B2B, B2C websites, applications, or social networks

  • Contact forms on the Company’s websites or third-party websites

  • Online shopping applications, cookies, and mobile apps

  • Various contracts signed with the Company, emails, faxes, and letters sent to the Company

  • Third parties processing data on behalf of the Company or supporting membership programs

  • Employees and customer service channels including digital marketing and call centers

  • Social media channels and search engines (Google, etc.)

  • Membership and other contracts, campaigns, applications, forms, and offers

  • Dealers and other sales networks

The collected data may be processed and transferred according to Articles 5 and 6 of the Law and as described in this Disclosure and Consent Notice.

PURPOSES OF PERSONAL DATA PROCESSING

As the data controller, the Company may collect, record, store, modify, update, periodically review, reorganize, classify, and retain personal and/or sensitive personal data obtained through all communication channels with your explicit consent, either fully or partially. These data may be shared with:

  • Third parties or legal entities collaborating with the Company

  • Group companies or partner companies

  • Public authorities as required by law

  • Third parties within or outside Turkey

The data may be processed for purposes such as:

  • Providing services to our customers

  • Determining and developing commercial and marketing strategies with your consent

  • Informing you about campaigns

  • Recording suggestions and complaints

  • Understanding your needs to provide better services

  • Conducting analyses and profiling for sales and marketing activities

  • Establishing higher service standards

  • Determining and implementing the Company’s commercial and business strategies

All processing is in compliance with KVKK and related legislation.

TRANSFER OF PERSONAL DATA

The Company may share your personal data:

  • With your explicit consent

  • In compliance with security and confidentiality principles under KVKK

  • Within Turkey or abroad with adequate security measures

Possible recipients include:

  • Group companies, business partners, and affiliates

  • Dealers, IT service providers, and server/cloud service providers

  • Companies providing data processing, customer satisfaction measurement, profiling, and sales/marketing support

  • Customers, suppliers, and auditing firms

  • Public authorities authorized to request data under legal obligations

RIGHTS OF DATA SUBJECTS UNDER ARTICLE 11 OF KVKK

You may request the following from the Company:

  1. To learn whether the Company processes your personal data and which data is processed

  2. To learn the purpose of processing and whether your personal data is used accordingly

  3. To know third parties to whom personal data is transferred domestically or abroad

  4. To request correction of incomplete or inaccurate personal data and notification of such corrections to third parties

  5. To request deletion or destruction of personal data in accordance with the law

  6. To request notification of actions taken regarding correction, deletion, or destruction of personal data to third parties

  7. To request compensation for damages caused by unlawful processing of personal data

  8. To obtain a copy of your personal data

For inquiries and requests regarding your personal data, you may contact the Company.