SMART PHARMA PERSONAL DATA PROTECTION POLICY

In accordance with the Personal Data Protection Law No. 6698 (“KVKK”), your personal data will be processed, recorded, stored, updated, transferred, and/or classified by our Company in its capacity as Data Controller, within the framework explained below, for purposes related to business activities. In this context, our Company takes all necessary technical and administrative measures to ensure an appropriate level of security to prevent the unlawful processing, unlawful access, and protection of your personal data, primarily to protect the privacy of private life and the fundamental rights and freedoms of individuals as regulated by the Law and Regulations enacted to protect personal data.

Target Audience

The target audience of this text is all natural persons whose personal data is processed by our Company, excluding our employees or those who have applied for a job at our Company.

Processed Personal Data

The personal data processed by our Company as the data controller includes, but is not limited to, the following:

Name, surname
Turkish ID number
Address, phone number
Email address
Signature
Physical location/security video recording
Call center/service quality audio recording
Bank account number
Cookie records

Purposes and Legal Grounds for Processing Personal Data

The personal data you share may be processed for the following purposes:

To allow you and/or the institutions and organizations you represent to benefit from the products and services offered by our Company
To determine and implement the commercial and business strategies of our Company
To conduct marketing activities
To carry out business development and planning activities
To conduct administrative operations related to communication carried out by our Company
To ensure the physical security and control of locations used by our Company
To establish relationships with business partners/customers/suppliers (authorized or employees)
To ensure the fulfillment of contract requirements and financial reconciliation related to products and services offered together with our business partners, suppliers, or other third parties
To implement the human resources policies of our Company
To respond to calls made to our Company’s call center or to use the website
To participate in training, seminars, or organizations organized by our Company

Methods of Collecting and Storing Personal Data

The personal data you share with our Company may be collected through automated or non-automated methods, verbally, in writing, or electronically, through offices, branches, call centers, websites, social media platforms, mobile applications, and similar means. Your personal data will be stored in electronic and/or physical environments. Necessary business process designs and technical security infrastructure developments are implemented to prevent unauthorized access, manipulation, loss, and damage to your personal data obtained and stored by our Company.

Retention Period of Personal Data

Your personal data will be processed and stored by taking all necessary information security measures, provided that it is not used for purposes and scope other than those notified to you, for the duration required by the processing purpose and for the statute of limitations specified in the Law and other relevant legislation. When this period expires, your personal data will be removed from our Company’s data flows through deletion, destruction, or anonymization methods.

Transfer of Personal Data

Your personal data may be transferred within the scope of the laws and other legislation and for the purposes disclosed;

To Türk Telekomünikasyon A.Ş. and Türk Telekomünikasyon group companies
To companies, representatives authorized by us to operate on behalf of and on account of our Company
To regulatory and supervisory institutions, public institutions, or organizations authorized to request your personal data explicitly stated in their relevant laws
To business partnerships, supplier and contractor companies, banks, credit risk and financial institutions, and other natural or legal persons within the scope of the specified purposes
To tax and similar advisors, compulsory persons related to legal follow-up processes, institutions, and organizations, and third parties, including auditors, from whom we receive consultancy services
Without being limited to these, to business partners, service providers, authorized persons, and organizations for the above-mentioned purposes, within the country and abroad.

Rights Under Article 11 of the KVKK

By applying to our Company, you have the right to:

Learn whether your personal data is processed or not
Request information if your personal data has been processed
Learn the purpose of processing your personal data and whether it is used in accordance with its purpose
Know the third parties to whom your personal data is transferred domestically or abroad
Request correction of your personal data if it is incomplete or incorrectly processed
Request deletion or destruction of your personal data within the framework of the conditions set forth in Article 7 of the KVKK
Request notification of the transactions made as per your requests for correction or deletion to third parties to whom your personal data is transferred
Object to the occurrence of a result against you due to the analysis of the processed data exclusively by automated systems
Claim compensation if you suffer damage due to the unlawful processing of your personal data

Application Under Article 13 of the Personal Data Protection Law

In accordance with the first paragraph of Article 13 of the Personal Data Protection Law, you can submit your request to exercise your above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board.

Application Methods

To exercise your rights mentioned above, you can deliver your request letter along with the necessary identification information in person or send it signed via notary.