INFORMATION TEXT / IN RELATION TO PROTECTION AND PROCESSING OF THE PERSONAL DATA

A joint stock company organized under the laws of the Turkish laws, residing at the address Harbiye Mahallesi, Maçka Caddesi, Vehbi Bey Apartmanı, No: 18, Kat: 1, Teşvikiye, Şişli, Istanbul, registered under the trade register number 42523-5 with Istanbul Trade Registry Office and having the e-mail address info@basisystems.com, BASI Systems Pilates Sanayi Ticaret Anonim Şirketi (“BASI Systems”), as a company having adopted the principle of compliance with the legal order, takes the maximum care regarding compliance with the legislation in relation to processing the personal data mainly the Constitution of the Republic of Turkey with Number 2709, Law on Protection of Personal Data (“PPD Law”) with number 6698 and Turkish Criminal Code with number 5237 and, determining fundamental principles relating to ensuring confidentiality and security of personal data it collects and processes, carries out comprehensive studies for application of these principles.

Within this scope, in order to fulfill its obligation to inform as regulated in Article 10 of PPD Law, Basi has formed this Information Text in relation to Protection and Processing of the Personal Information and aims at informing you regarding the identity of the data controller and – if any – his/her/its representative, at which scope and under which conditions your personal data is processed and with which purposes it may be transferred, the method of collecting the data and the legal reason thereof as well as your rights referred to in Article 11 of the PPD Law.

Your personal data is processed by BASI Systems within the scope and under the conditions disclosed in this Information Text in relation to Protection and Processing of the Personal Information and within the legal limits.

I. Data Controller and his/her/its Representative.

Your personal data is processed by BASI Systems as “the data controller” as referred to in Article 3 of PPD Law.

II. Legal Basis.

Your personal data is processed by BASI Systems in accordance with the provisions of the legislation in relation to the processing of the personal data, mainly the Constitution of the Republic of Turkey with Number 2709, PPD Law and Turkish Criminal Code with number 5237.

III. General Principles in relation to Processing of the Personal Data.

Your personal data is processed by BASI Systems in compliance with the purpose of the PPD Law and the following general principles regulated within the scope of the PPD Law:

o Compliance with the law and the rules of good faith;

o Being correct and, when required, being current;

o Processing for definitive, explicit and legitimate purposes;

o Being connected with, limited to and measurable considering the purpose for which it is processed;

o Being kept for a period as much as the period foreseen by the relevant legislation or required for which it is processed

IV. The Purposes for which your Personal Data is processed

Your personal data is processed by BASI Systems in compliance with the purpose of the PPD Law and the general principles regulated within the scope of the PPD Law and within the scope of the conditions for processing the personal data as referred to in Articles 5 and 6 of the PPD Law with the following purposes:

o Conducting and managing the processes of legal compliance of BASI Systems;

o Determining, planning and applying the commercial policies and business strategies of BASI Systems in short, medium and long term;

o Carrying out the commercial activities conducted by BASI Systems (including the activities of communication, advertisement, publicity, marketing, sales, distribution and otherwise putting into trade area) in compliance with the principles and policies of Basi and the relevant legislation and carrying out the necessary studies within this scope;

o Carrying out and managing the administrative operations and activities conducted by BASI Systems;

o Benefitting from the products and services offered by BASI Systems sufficiently and making the necessary studies within this scope;

o Enhancing the quality of the products and services provided by BASI Systems and offering/proposing such products and services by customizing them according to the tastes, behaviors of use and needs of customers;

o Arranging / organizing contests, campaigns, promotions and draws in relation to the products and services offered by BASI Systems and carrying out the necessary procedures and making the necessary information within this scope;

o Protecting the commercial standing of BASI Systems and the confidence it has formed before public;

o Designing, planning, implementing the activities of human resources of BASI Systems and supporting the same;

o Regulating the records and documents which constitute basis for the procedures of BASI Systems;

o Ensuring the commercial and legal safety of the BASI Systems and the real persons with whom BASI Systems has direct or indirect business/commercial relationship as well as their assets, prevention of fraud and minimizing the credit risks;

o Determination of the profiles of real persons with whom BASI Systems has direct or indirect business/commercial relationship;

o Confirming and recording the identity/address and other information of real persons with whom BASI Systems has direct or indirect business/commercial relationship;

o Being able to evaluate the questions, opinions and suggestions of real persons with whom BASI Systems has direct or indirect business/commercial relationship, organizing the satisfaction surveys, conducting and managing the evaluation / complaint management and standing survey processes;

o Conclusion, execution, conduct, finalization of the agreements between Basi and real persons with whom BASI Systems has direct or indirect business/commercial relationship and preparation of other documents within the scope of these agreements;

o Preparation of the order forms in relation to the products and services needed by BASI Systems;

o Contacting the real persons with whom BASI Systems has direct or indirect business/commercial relationship via e-mail, mail, telephone and other means of communications;

o Updating the website named http://basisystems.com of BASI Systems (“Website”) in line with the preferences of real persons with whom BASI Systems has direct or indirect business/commercial relationship and recognizing such persons when they returned to the Website; and/or

o Fulfillment of the obligations of BASI Systems and ability of BASI Systems to exercise its rights within the scope of the PPD Law.

V. Method of the Collecting the Personal Data and Legal Reason of the Collection of Personal Data

Your personal data is collected by BASI Systems in compliance with the purpose of the PPD Law and the general principles regulated within the scope of the PPD Law within the conditions for processing the personal data referred to in Articles 5 and 6 of the PPD Law with the purposes contained in Heading IV of the Information Text in relation to Protection and Processing of the Personal Data by automatic ways in part or in whole or non-automatic ways on condition that they are the part of any data recording system based on various contractual and legal grounds differing in terms of every business/commercial relationship established with BASI Systems verbally, in writing and visually by way of the Website, call centers, other means of electronic communication, mobile apps, cookies, social media networks (such as Facebook, Instagram, Twitter, Google+, Youtube, LinkedIn, Spotify) and other means and channels serving to record and transmit signs, audio and/or video belong to BASI Systems as well as trainings, seminars, fairs and organizations organized by BASI Systems.

It should be stated that the Website is a website using cookies. The website shall process your information of navigating within conditions of processing the personal data referred to in Articles 5 and 6 of the PPD Law in compliance with the purpose of the PPD Law and the general principles regulated within the scope of the PPD Law for the purpose of providing better services to real persons with whom BASI Systems has direct or indirect business/commercial relationship and for such persons to benefit from the subscription and membership procedures. The detailed information about the cookies we use for the purpose of collecting your navigation information shall be given in a pop-up screen when you first enter the Website.

Generally, browsers accept the cookies automatically. Recording the cookies to browsers may be prevented by activating the option of preventing the cookies from browser settings. Since the option of preventing cookies may differ according to browsers, the way of preventing the cookies envisaged for relevant browsers is stated in such browsers (For instance, in Google Chrome, we recommend that this procedure be followed up by closing “the option of allowing the websites to record and read the cookie data”. From browsers, the previously recorded data may also be deleted). We should state right away that even if you decline the cookies, you may continue to use the Website, however, you may not have access to all functions of the website or your access may be restricted.

VI. To whom and with which Purposes your Personal Data may be transferred

Your personal data may be transferred by BASI Systems in compliance with the purpose of the PPD Law and the general principles regulated within the scope of the PPD Law within the conditions of transfer of personal data as referred to in Articles 8 and 9 of the PPD Law with the purposes contained in Heading IV of the Information Text in relation to Protection and Processing of the Personal Data to the existing/former controlling and subsidiary companies of BASI Systems, its affiliates, branches, business associates, shareholders, directors, representatives, employees, advisors (including legal and financial consultants), suppliers, dealers, sub-contractors, assistants, assignees, successors, persons conducting or participating in the conduct of the commercial activities of BASI Systems irrespective of whether there is any agreement between BASI Systems and them (including the activities of communication, advertisement, publicity, marketing, sales, distribution and otherwise putting into trade area) (including the persons from whom the services of storage of data on cloud environment, cargo and postal service, the service of sending the commercial electronic transmissions, surveying service and quality control services are received), such other persons with whom BASI Systems has relationship in other ways, persons having organic bond with BASI Systems in terms of management, capital and contracts, and legally competent public institutions and organizations (including the courts and ministries).

It should be stated that the situation that BASI Systems or the assets of BASI Systems are transferred by any third party present both at home and/or abroad either in part or in whole as a result of the merger, takeover, sale of assets, transfer of business, consolidation or winding up taking place at BASI Systems is also among the methods of transferring your personal data.

VII. Security

BASI Systems uses SSL (Secure Sockets Layer) encryption technology with a view to protecting your personal data. You may ensure that your personal data is processed by keeping the same in confidence by using the SSL (Secure Sockets Layer) compatible browser like Microsoft Internet Explorer or Mozilla Firefox. It should be stated that BASI Systems follows up the technological developments closely and takes into consideration such developments when taking the security measures.

VIII. The Option of Choosing

In case you realize your membership procedures by sharing your e-mail information over the Website, notifications/newsletters are sent by BASI Systems to you. However, we would like to remind you that you always have the right to give up receiving such notifications. If you do not want to be included in the Notifications/Newsletter list, you may be delisted whenever you want by clicking on the button ““unsubscribe/quit the newsletter” in the undermost section of the notification/newsletter forwarded to you.

IX. Your Rights listed in Article 11 of the PPD Law as the Data Subject

The rights that real persons whose personal data is processed have in accordance with Article 11 of the PPD Law are as follows:

o Learn whether or not her/his personal data have been processed;

o Request information as to processing if her/his data have been processed;

o Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose;

o Know the third parties in the country or abroad to whom personal data have been transferred;

o Request rectification in case personal data are processed incompletely or inaccurately and requesting that the operations carried out within this scope is notified to third parties to whom the personal data is transferred;

o In case the grounds requiring the processing the personal data disappear despite the fact that the personal data has been processed in compliance with the provisions of the legislation in force, mainly the Constitution of the Republic of Turkey with number 2709, the PPD Law and Turkish Criminal Code with number 5237, request that personal data is deleted, removed or anonymized and request that the procedures done within the scope are notified to third parties to whom the personal data is transferred.

o Object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems;

o Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data.

It is sufficient that you convey your applications relating to your rights contained in Heading IX of the Information Text in relation to Protection and Processing of the Personal Data to the address written in this Information Text in relation to Protection and Processing of the Personal Data of BASI Systems by hand in writing and with original signature, by means of postal service or registered electronic mail address, secure electronic signature, mobile signature or by means of the electronic mail address registered in BASI Systems’ system in an express and understandable way by also adding the documents determining your identity like ID/address information (name, family name, signature, Republic of Turkey ID number for nationals of the Republic of Turkey, nationality information for foreign nationals, passport number and – if any – the ID number, the residence or workplace address for notification purposes, if any, electronic mail address for notification purposes, telephone and fax number). Other methods of application determined / to be determined by the Board of Protection of Personal Data are reserved.

Your application shall be replied by BASI Systems free of charge within 30 (thirty) days at the latest according to nature of your application. However, in case of existence of an application of the nature requiring fee to be received in the sense of the provisions of the PPD Law and relevant legislation, BASI Systems shall receive the fee on the tariff determined / to be determined by the Board of Protection of Personal Data for such applications of yours.

© BASI Systems 2018