Privacy Policy

1-Purpose and Scope;

As Eksada Dış Ticaret Danışmanlık ve Yazılım A.Ş. (will be called as “EKSADA” or “Company”) we are fully aware how much you care about share and use of your personal data. This Privacy Policy aims to brief you about what kind of data is collected and processed by www.trcontact.com

According to relevant legislations, all necessary administrative and technical precautions are taken by EKSADA in order to protect your personal data. In this Policy, you will find brief explanations listed below about the principles adopted by “EKSADA” during process of personal data. If you want to have more detailed information about our Privacy Policy and “Personal Data Protection Legislation” Policy, Please click on the link (buraya link ilave edilecek) 

2-What kind of data we process?

In order to develop and upgrade the service we offer, inherently www.trcontact.com does process some personal and commercial data as listed below;

• Data submitted by the member during membership process
• Data collected through the usage of the platform
• Data which is not considered personal data but has commercial value
• Cookies and Cookie Management; data collected from the visitors, users and members during their visit or usage of our website www.trcontact.com  If you want to have more information about this issue, Please read our “Cookie Policy”

3- Our Purpose for Data Process;

• To perform and administer the membership agreement
• For accounting transactions and to follow-up financial relationship with the members
• To improve our the services and making them sustainable
• For “Customer Service Management” purposes
• For planning and executing corporate communication activities,
• For “Corporate Governance” activities
• For “Complaint and Request Management” purposes
• For “Legal Affairs” of company
• For planning and executing audit activities in accordance with local and global procedures and legislations.
• To provide information for authorized public institutions and organizations due to current legislations.

4- Do we share your personal data?

www.trcontact.com  does not share any of your personal or business data with any third parties, except with the below listed who are binding over full security of them. 

• EKSADA employees
• Business partners of EKSADA 
• Authorized public institutions and organizations due to current legislations.

5-How do we protect your personal data?

As the data controller and service provider, EKSADA ensures that our consent mechanism is in line with Turkish current “Law Privacy Act No: 6698” and its secondary regulations “Personal Data Protection Board. Also EKSADA ensures that we take all necessary technical and organizational measures to provide an appropriate level of security for the purposes of:

• To prevent unlawful processing of personal data
• To prevent unlawful access to personal data
• To ensure protection of your personal data

EKSADA is carrying out the necessary audits, or have them made, in its own institution or organization, in order to ensure the implementation of the provisions of the current law of privacy act No: 6698. Also EKSADA follows the latest developments in the legislation and practices made by Personal Data Protection Board and implements them immediately.

6-Which kind of request I can make about my personal data and how?

At the time when personal data are obtained, EKSADA or the person authorized by is obliged to inform the data subjects about the following:

• the identity of the data controller and of its representative, if any,
• the purpose of processing of personal data;
• to whom and for which purposes the processed personal data may be transferred,
• the method and legal basis of collection of personal data,
• other rights referred in Personal Data Protection Legislation Article 11.

7- Each person has the right to request to the data controller about him/her;

• to learn whether his/her personal data are processed or not,
• to demand for information as to if his/her personal data have been processed,
• to learn the purpose of the processing of his/her personal data and whether these personal
• data are used in compliance with the purpose,
• to know the third parties to whom his personal data are transferred in country or abroad,
• to request the rectification of the incomplete or inaccurate data, if any,
• to request the erasure or destruction of his/her personal data under the conditions referred to in Article 7,
• to request reporting of the operations carried out pursuant to above paragraphs and to third parties to whom his/her personal data have been transferred,
• to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,
• to claim compensation for the damage arising from the unlawful processing of his/her personal data.

8- The provisions of Personal Data Protection Law shall not be applied where:

A - Personal data are processed by natural persons within the scope of purely personal activities of the data subject or of family members living together with him/her in the same dwelling provided that it is not to be disclosed to third parties and the obligations about data security is to be complied with.

B- Personal data are processed for official statistics and provided that they are being anonymized for the purposes for such as research, planning and statistics.

C- Personal data are processed with artistic, historical, literary or scientific purposes, or within the scope of freedom of expression provided that national defense, national security, public security, public order, economic security, right to privacy or personal rights are not violated or the process does not constitute a crime.

Ç- Personal data are processed within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations duly authorized and assigned by law to maintain national defense, national security, public security, public order or economic security.

D- Personal data processed by judicial authorities or execution authorities with regard to investigation, prosecution, judicial or execution proceedings.

Provided that it is in compliance with and proportionate to the purpose and fundamental principles of this Law, Article 10 regarding the data controller's obligation to inform, Article 11 regarding the rights of the data subject, excluding the right to claim compensation, and Article 16 regarding the obligation to register with the Data Controller’s Registry shall not be applied in the following cases where personal data processing:

• is necessary for the prevention of committing a crime or for crime investigation.
• is carried out on the data which are made public by the data subject himself/herself.
• is necessary for performance of supervision or regulatory duties and disciplinary investigation and prosecution to be carried out by the assigned and authorized public institutions and organizations and by public professional organizations, in accordance with the power conferred on them by the law,
• is necessary for protection economic and financial interests of State related to budget, tax and financial matters.

Requests to the Data Controller;

The data subject shall make the request relating to the implementation of this law to EKSADA in writing or by other means to be determined by the Board.

The request form in our website www.trcontact.com will be filled and signed by applicant. Hard copy shall be handed to EKSADA either by himself/herself or can be notarized to the address disclosed in the same form.

Applicant can also send this form by “Registered Electronic Mail” (which is an alternative to conventional registered postal messages, as it offers the same legal validity) or from the e-mail address which had been declared during application for membership.

If the applicant is owner's representative, Legal power of attorney must be submitted with application.

Answering Procedure;

EKSADA shall act on the request or refuse it together with justified grounds and communicate its response to the data subject in writing or by electronic means. In case the demand in the request is accepted, it shall be fulfilled by EKSADA. If the request is made due to fault of EKSADA, the fee is refunded to data subject.

EKSADA shall conclude demands in the request within the shortest time by taking into account the nature of the demand and at the latest within thirty days and free of charge. However if the action requires an extra cost, fees may be charged in the tariff determined by the Board.

EKSADA may require the identity and address of the applicant and of its representative, if any, or may ask extra questions to the applicant in order to make the issue clear. 

Refusal to Answering Conditions;

As a result of the examination made upon complaint, If the processed data is for one of the below mentioned purposes, EKSADA may refuse to answer the applicant giving justification from the current law.

• If the data is to prevent committing a crime or for crime investigation
• If the data which are made public by the data subject himself/herself.
• If the data is for performance of supervision or regulatory duties and disciplinary investigation and prosecution to be carried out by the assigned and authorized public institutions and organizations and by public professional organizations, in accordance with the power conferred on them by the law.
• If the data is necessary for protection economic and financial interests of State related to budget, tax and financial matters.
• If the personal data owner's request may have the possibility to prevent the rights and freedoms of other people.
• If the request requires disproportionate effort.
• If the requested information is publicly available.