Commercial Electronic Communication Privacy Notice

One Human Yazılım ve Bilişim Danışmanlığı San. Tic. A.Ş.

Clarification Text on the Processing of Personal Data

COMMERCIAL ELECTRONIC MESSAGE

As One Human Yazılım ve Bilişim Danışmanlığı San. Tic. A.Ş. (“OneNewOne” or the “Company”), the protection of your personal data that we obtain while carrying out our processes is one of our primary priorities. We attach great importance to ensuring the security of your personal data and to its use/processing in accordance with the legislation.

This clarification text contains information on how we process your personal data within the scope of sending commercial electronic messages to you.

Which of your personal data do we process, for what purposes, and based on which legal grounds?

Article 5 of the Personal Data Protection Law (the “Law”) regulates the legal grounds for the processing of personal data. Below we have provided the purposes for which we process your personal data and the legal grounds we rely on within the scope of these purposes:

Processed Data	Data Processing Purposes	Legal Ground for Data Processing
Identity (name – surname) Contact (phone number, e-mail address) Other (permission information)	Informing you about campaigns, promotions, events, surveys, and opportunities in line with your communication permission preferences (such communications allow us to increase your loyalty and satisfaction with our products/services).	Law art. 5/1 Explicit consent of the data subject
Identity (name – surname) Contact (e-mail address) Transaction Security (IP address, log records) Other (permission information) Legal Action (information in correspondence with judicial authorities, information in the case file)	Providing you with clarification in the online environment within the scope of sending commercial electronic messages and reporting the records regarding your approval obtained in the online environment to the authorized institutions and organizations.	Law art. 5/2-(ç) Fulfilling our legal obligations.

With whom and for what purposes do we share your personal data?

Your personal data is shared with third parties in compliance with the rules regarding the transfer of personal data in the Law and relevant legislation. The parties with whom we share and the purposes of sharing within this scope are as follows:

Authorized Institutions and Organizations: Fulfilling our legal obligations in cases where they request information or documents from our Company or we are required to make a notification to these institutions. (For example; transferring to İleti Yönetim Sistemi A.Ş. in order to fulfill the notification obligation within the scope of the Regulation on Commercial Communication and Commercial Electronic Messages)

Suppliers and Business Partners: Receiving support from suppliers in order to fulfill the purposes stated under the heading “Which of your personal data do we process, for what purposes, and based on which legal grounds?” above (e.g., if you have given explicit consent for sending commercial electronic messages, receiving support from suppliers within the scope of sending commercial electronic messages),

In the event of transferring your personal data, we act in accordance with the rules stipulated in Articles 8 and 9 of the Law.

Through which channels do we collect your personal data?

We collect your personal data through forms filled out in the electronic environment of the website, SMS, e-mail correspondence, and calls by automatic and partially automatic methods.

How can you exercise your rights regarding your personal data?

Article 11 of the Personal Data Protection Law regulates the rights of data subjects. Pursuant to this article, you have the following rights:

To learn whether your personal data is being processed,
To request information regarding this if your personal data has been processed,
To learn the purpose of processing your personal data and whether they are being used in accordance with their purpose,
To know the third parties to whom your personal data is transferred domestically or abroad,
To request the correction of your personal data in case of incomplete or incorrect processing and to request the notification of the transaction made within this scope to the third parties to whom your personal data has been transferred,
To request the deletion or destruction of your personal data in the event that the reasons requiring its processing disappear, despite being processed in accordance with the provisions of the Law and other relevant laws, and to request the notification of the transactions made within this scope and in case of incomplete or incorrect processing of your personal data to the third parties to whom your personal data has been transferred,
To object to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
To demand compensation for the damage in case you suffer damage due to the unlawful processing of your personal data.

You may choose the following methods to convey your requests regarding your aforementioned rights to the Company:

You can send an e-mail to info@onenewone.com from your e-mail address registered in our systems,
You may also choose other methods specified in the Communiqué on the Procedures and Principles of Application to the Data Controller.