Disclosure Text on the Personal Data Protection Law
Parge Yazılım Danışmanlık Ticaret Anonim Şirketi
16.12.2019
Contents
1- Definitions and Abbreviations.
1.8. Processing of Personal Data:
1.10. Data Controller: Personal
1.11. Personal Data Protection Board:
1.12. Personal Data Protection Authority:
1.13. Personal Data Protection Law:
- Who is Responsible for the Security and Processing of Your Personal Data?
- For what purposes are your personal data processed?
- To Whom and For What Purposes Can Your Personal Data Be Transferred?
- By what methods and on what legal grounds is your personal data collected?
- How Long Is Your Personal Data Retained?
- What Rights Do You Have Over Your Personal Data?
- Revision Tracking
Entrance
As Parge Software Consulting Trade Incorporated Company (hereinafter referred to as “Pargesoft”), we exercise the utmost care to ensure the confidentiality and security of all our customers’ and visitors’ personal data in accordance with the Constitution of the Republic of Turkey, the Personal Data Protection Law No. 6698, and other relevant legislation. Your personal data is processed by us within the framework outlined below, in accordance with the provisions of the Personal Data Protection Law No. 6698 and related legislation, in our capacity as the “Data Controller”.
By agreeing to these rules, it is deemed that you are fully aware of them, have read them, and authorize Pargesoft to process your personal data in accordance with this content.
Pargesoft fulfills its obligation to provide information under Article 10 of the Personal Data Protection Law No. 6698 by providing the following explanations to customers, our websites (www.Pargesoft.com.tr www.bulut-ik.com www.olimposs.com www.erp365.com.tr www.crm365.com.tr) and/or web applications (payroll, e-transformation, e-invoice, e-reconciliation, e-collection).
Pargesoft reserves the right to update these Personal Data Protection Regulations in whole or in part at any time in line with changes made to the applicable legislation, and legal changes shall be binding on both PARGESOFT and its Customers/followers.
1- Definitions and Abbreviations
This section briefly explains specific terms, expressions, concepts, abbreviations, etc. used in the policy.
1.1. Explicit Consent: Approval given for data processing purposes only, based on information and free will, regarding a specific subject.
1.2. Anonymization: Making personal data unidentifiable to a specific or identifiable real person, even when matched with other data.
1.3. Employee: Pargesoft Personnel.
1.4. Service Provider: Personnel of companies (suppliers, subcontractors, customers, etc.) from which Pargesoft receives and/or provides services.
1.4a. Pargesoft Websites:
www.erp365.com.tr
1.4b. Pargesoft Project Management and Web Support Portals:
https://pargesoft.microsoftcrmportals.com/en-US/ (Support Request Portal)
1.4c. Pargesoft Social Media and Advertising Platforms
1.5. Data Subject (Relevant Person): The natural person whose personal data is processed.
1.6. Personal Data: Any information relating to an identified or identifiable natural person.
1.7. Special Category Personal Data: Information that could cause harm or discrimination to the relevant person if disclosed.
1.8. Processing of Personal Data: Any operation performed on data, such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, acquiring, making available, classifying, or preventing the use of personal data, whether fully or partially automated or non-automated, provided that it is part of a data recording system.
1.9. Data Processor: A natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller.
1.10. Data Controller: A natural or legal person who determines the purposes and means of processing personal data, is responsible for establishing and managing the data recording system, and is obliged to register with the Data Controllers Registry.
1.11. KVK Board: Personal Data Protection Board
1.12. KVK Institution: Personal Data Protection Institution
1.13. KVK Law: Personal Data Protection Law published in the Official Gazette dated April 7, 2016 and numbered 29677
1.14 Pargesoft Cookie Policy
At Pargesoft, we value your privacy and security. Our Cookie Policy, along with the principles of legality, fairness, and transparency, sets forth the principles of Cookies used in every web browser by Pargesoft to better serve you and personalize your experience. Click here to access more information about our Cookie Policy. Our Website
1.14.1. Cookies:
When using any of Pargesoft’s websites, these cookies are text files containing small pieces of information loaded by the internet browser and stored on a computer, mobile phone, or tablet.
1.14.2 Cookie Use
To provide you with better service, to enable you to benefit from membership benefits, and in accordance with our legal obligations, we will collect, process, and securely store our users’ browsing information, provided that it is not used for purposes and within the scope set forth in our Personal Data Protection Policy and this Agreement.
Pargesoft may match information collected from users through various methods, such as online and offline, or at different times, and use this information in conjunction with information obtained from other sources, such as third parties. Pargesoft may use “advertising technology” to deliver advertisements that it believes may be of interest to users.
Information about the cookies we use to collect your browsing information will be provided on our website via a “pop-up screen” when you first use the Pargesoft service.
1.14.3 Controlling Cookies
You can control or delete cookies as you wish. You can delete existing cookies on your computer and prevent cookies from being saved/set in most Internet browsers.
Session cookies and persistent cookies are used on all websites and web applications owned by Pargesoft. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period. You can remove persistent cookies and reject both session and persistent cookies by following the instructions in your internet browser’s “help” file or by visiting “www.allaboutcookies.org/” and “http://www.youronlinechoices.eu.”
If you reject persistent or session cookies, you can continue to use the website or our web applications, but you may not be able to access all of the website’s functionality, or your access may be limited.
1.14.4 Cookies Actively Used on Our Site
Cookies used on websites owned by Pargesoft are used for statistical data collection. This data does not contain any user identification. According to our cookie policy, user security and the ability to navigate our site safely are our top priority. Third-party cookie applications and functions used on our website
| Cookie Source | Short Description | Where Cookies Are Displayed | Definition |
| Google Analytics | This cookie is a cookie that analyzes movements on the site. | On all pages | These types of cookies allow us to collect statistical data and thus improve the presentation and use of the Site. Google adds social statistics and interest data to these statistics, allowing us to better understand users. |
| Google Conversion Tracking | This cookie indicates whether the user has reached the pages containing the cookie after clicking on the AdWords ad. | On all pages | These cookies collect information about how users use the site. Performance cookies allow us to identify the most frequently used areas of the site. |
| Facebook Pixel | These cookies keep track of users’ page and content orientation. | On All Pages | This cookie allows you to see ads according to your preferences by segmenting. |
Who is Responsible for the Security and Processing of Your Personal Data?
As Pargesoft, we are responsible for the security of all personal data you provide to us as the “Data Controller” in accordance with Personal Data Protection Law No. 6698.
Parge Yazılım Danışmanlık Ticaret Anonim Şirketi
İstanbul Ticaret Odası 571453
Ihlamurkuyu Mh. Gümüşsuyu Cd. Meral Plaza No:5/9 Ümraniye 34771 – İstanbul
Tel: +90(216) 575 6070 | Faks: +90 (216) 573 24 06
For what purposes are your personal data processed?
Your personal data is processed primarily to fulfill the obligations imposed on us by legislation, particularly Turkish Commercial Code No. 6102 and Tax Procedure Law No. 213.
In addition to fulfilling our legal obligations, your personal data is processed for purposes such as providing the highest level of service you request, ensuring your profile is readily available for your next service or product request, and quickly and accurately identifying the most suitable services and products for you. This process also aims to ensure our most important principle: customer satisfaction.
Your personal data may also be processed for the purposes of improving our products and services offered to you, announcing our products and campaigns, accurately planning, executing and managing management and communication activities and strategies, improving the services offered on the website, troubleshooting errors that occur on the site, contacting you when you submit your support/requests and complaints, managing your support/requests and complaints, improving service quality, enabling third parties to perform their technical, logistical and other similar functions as service providers on our behalf and, when necessary, ensuring that your payments are processed quickly and securely. Your support requests reaching us through the communication methods available at [email protected] and https://www.pargesoft.com/tr/iletisim/ are managed by the “Data Controller.” In order to ensure data security, we recommend that our company employees not transfer information via any means of communication (phone, Messenger, SMS, messaging applications such as WhatsApp) during or outside working hours. Our employees; Our company does not accept responsibility for the security of any messages, information and requests sent via SMS, Messenger or WhatsApp applications.
To Whom and For What Purposes Can Your Personal Data Be Transferred?
Persons required for the performance of the service
To ensure the complete and flawless nature of the services provided to you, your personal data may be shared with our business and solution partners, support platforms, banks, and third parties who perform other operations on our behalf, such as technical and logistics, only to the extent appropriate to the nature of the service. These third parties are the ones who must have access to the relevant information to ensure the complete and flawless provision of the relevant services.
Website hosting provider
Data contained on our website and portals (1.4a. and 1.4b.) is hosted in Pargesoft’s data center, or on servers located in location-independent cloud data centers that meet International Data Center standards, with all security measures in place. Access to these servers is solely authorized by Pargesoft, and data may not be transferred to the hosting provider for purposes other than hosting and ensuring its security. All necessary precautions are taken to prevent unauthorized access to the servers.
Persons legally required to share
Your personal data may be transferred—limited only to the relevant person or institution—if it is necessary for Pargesoft to fulfill its legal obligations, if it is expressly provided for by law, or if there is a legally issued judicial/administrative order.
Consultancy and auxiliary service providers
Your personal data may be transferred for the purposes of protecting Pargesoft’s rights and/or your rights and fulfilling legal obligations, and if data transfer is necessary for the fulfillment of these purposes; It may be transferred to third parties from whom we receive support in areas such as storage, archiving, IT support, security, and call centers; to affiliated companies, business partners, banks, and financial institutions from which we collaborate and/or receive services; to law offices and consulting firms from which we receive legal, tax, and similar support; and to other related parties and authorized institutions and organizations where transfer is necessary for the specified purposes.
Agencies and Advertisers
Some personal data may be shared with advertisers in an anonymized form, in aggregate form, along with information from other users, to ensure that ads (1.4c. Pargesoft Advertising Channels) are tailored to the target audience. Anonymized data cannot be matched with your visitors/customers and does not contain or make you personally identifiable. Your privacy is guaranteed with anonymized data.
If your personal data is to be transferred abroad, we will check, through reasonable procedures, whether there is sufficient protection in the foreign country to which your personal data will be transferred and, even if there is not sufficient protection, whether the necessary measures will be taken by the institution abroad to which your personal data will be transferred, as Pargesoft, to ensure adequate protection of your personal data. If there is any suspicion that your personal data will not be protected at an adequate level, your personal data will not be transferred abroad.
By what methods and on what legal grounds is your personal data collected?
Your personal data may vary depending on the services provided by our Company and the commercial activities of our Company; by automatic or non-automatic methods
- With the visits made by the employees of our company’s units and departments
- Through cookies on the website
- Social Media Channels
- With web-based support (1.4b.) applications,
- Via e-mail, SMS, WhatsApp and similar means, with registration and cookies,
- By obtaining business cards in one-on-one or group meetings, panels, fairs, etc.
- By filling out a CV or job application form in applications for employment to Pargesoft, either in person or electronically or through intermediary institutions,
- Through voice calls with us or in-person meetings at our company.
- Through photo and video shootings at seminars and events
- Seminar feedback forms filled out at seminars and events
- In business cards and registration information received during seminar and event registrations
Your personal data may be collected verbally, in writing, or electronically. Your collected personal data may be processed by PARGESOFT for the following purposes, in accordance with the basic principles stipulated by the Personal Data Protection Law and within the Personal Data Processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law:
- Planning and executing the company’s human resources policies and processes,
- To provide offers to prospective customers or clients regarding products and services offered by the company.
- Our business units carry out the necessary work and carry out the relevant business processes to ensure that relevant people benefit from the products and services offered by the company,
- Our business units carry out the necessary work and carry out the relevant business processes to install the products, configure them according to their needs, teach the use of the products or provide technical support upon request to the people who benefit from the products and services offered by the company under the contract,
- Planning and executing the activities required to recommend and promote the products and services offered by the Company to the relevant people by customizing them according to their tastes, usage habits and needs,
- Carrying out the necessary work by our relevant business units and carrying out the related business processes in order to carry out the commercial activities carried out by the Company,
- Planning and execution of the company’s commercial and/or business strategies,
- It is collected to ensure the legal, technical and commercial-business security of the Company and the relevant persons who have a business relationship with the Company.
Your personal data collected is collected in order to provide our services in line with the purposes stated above, in accordance with the nature of the data, and to fulfill our contractual and legal responsibilities in this context in a complete and accurate manner, and to fulfill the obligations imposed on us by the provisions of the legislation, particularly the Turkish Commercial Code No. 6102, the Tax Procedure Law No. 213, the Consumer Protection Law No. 6502, and the Personal Data Protection Law No. 6698.
In this context, the legal grounds for collecting your personal data collected are processed in accordance with the nature of the data; explicit consent, it is clearly stipulated in the laws, data processing is mandatory for the performance of the contract, it is mandatory for the fulfillment of our legal obligations, data processing is mandatory for the legitimate interests of the data controller.
| Processed Personal Data | Legal Reason for Processing |
| Name, Surname, TR ID Number, Address | In case of purchase of goods or services from us, it is processed because it is mandatory in accordance with Articles 230 and following of Tax Procedure Law No. 213 and Article 82 of Turkish Commercial Code No. 6102. (Law No. 6698 Art. 5/2-a) If you become a member of the websites we own although no goods or services have been purchased from us, it is processed because data processing is mandatory for the performance of the contract for the purpose of performing the relevant membership contract and the services linked to the membership contract. (Law No. 6698 Art. 5/2-c) |
| Email, telephone and other contact information | In cases where you receive service from us, it is processed for the purposes of providing the necessary information regarding the goods and services you have received, establishing communication between the parties, renewal of licenses, etc., because the processing of personal data belonging to the parties to the contract is necessary for the performance of the contractual relationship. (Law No. 6698, Article 5/2-c) If you become a member of the websites we own, although you have not received service from us, it is processed because data processing is mandatory for the performance of the contract for the purpose of performing the relevant membership agreement and the services linked to the membership agreement. (Law No. 6698, Article 5/2-c) If you subscribe to our newsletters, it is processed only due to the explicit consent you have given. (Law No. 6698, Article 5/1) |
| Credit card information | It is processed only in the case of mail order purchases, as it is mandatory for the performance of the contractual relationship established between the User and Pargesoft. (Law No. 6698, Art. 5/2-c) |
| Voice recording | The telephone conversations you have with us are recorded and processed for a short time, for the purposes of ensuring customer satisfaction, resolving potential disputes and ensuring security, provided that the fundamental rights and freedoms of the relevant person are not violated, and because data processing is mandatory for the legitimate interests of the data controller. (Law No. 6698, Article 5/2-f) |
| Camera recording | Camera recordings are taken to ensure security at our locations. These recordings are processed because data processing is necessary for the legitimate interests of the data controller, provided that it does not violate the fundamental rights and freedoms of the data subject. (Law No. 6698, Article 5/2-f) |
How Long Is Your Personal Data Retained?
Unless longer periods are stipulated by law, your personal data is retained for a maximum of 10 (ten) years in accordance with Article 182 of the Turkish Commercial Code and Article 146 of the Turkish Code of Obligations. Camera recordings are retained for a maximum of 2 years.
What Rights Do You Have Over Your Personal Data?
In accordance with the Personal Data Protection Law No. 6698, everyone can apply to the data controller and get information about themselves;
- Learning whether personal data is being processed,
- To request information regarding the processing of personal data,
- To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
- Knowing the third parties to whom personal data is transferred, either domestically or abroad,
- To request correction of personal data if it is processed incompletely or incorrectly,
- Requesting the deletion or destruction of personal data if the reasons requiring processing of personal data are eliminated,
- To request that the operations carried out in accordance with clauses (d) and (e) be notified to third parties to whom personal data has been transferred,
- To object to the emergence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
- In case of any damage caused by the unlawful processing of personal data, the person has the right to demand compensation for the damage.
- Pargesoft has the right to request the removal of images obtained from photo and video shootings made at events we have previously worked with or organized, from the media specified in 1.4c.
To exercise these rights, you can complete our application form and hand-deliver your request with a wet signature to Ihlamurkuyu Mah. Gümüşsuyu Cad. Meral Plaza No:5/9 Ümraniye 34771 – Istanbul, or send it with a secure electronic signature to [email protected]. Alternatively, if you have previously provided us with an email address and registered in the Pargesoft system, you can also submit the application form to [email protected] using this registered email address.
In your request, the right/demand you wish to exercise must be clearly stated along with your identity information, and all necessary explanations must be made by attaching all information and documents subject to your request.
Requests submitted to us that meet the required qualifications will be finalized within 30 (thirty) days, depending on the nature of the request, and the result will be notified to you in writing or electronically, in accordance with the feedback method you have chosen in your request.
Revision Tracking
8.1 Change Record
| Date | Writer | Approved by | Version | Change Reference |
| December 16, 2019 | Selim Uluç / Murat Tali | Kaan Altunterim | V 1.0 | First Published |