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Contact Form Clarification Text

CONTACT FORM CLARIFICATION TEXT

(Pursuant to the Law No. 6698 on the Protection of Personal Data)

This clarification text has been prepared by Ularte Sınai Yapı ve Ticaret A.Ş. (“Company”), which acts as the data controller within the scope of the Law No. 6698 on the Protection of Personal Data (“Law”) and relevant secondary regulations, in order to inform the data subjects pursuant to Article 10 of the Law, regarding the processing of personal data collected through the contact form available on the Company’s corporate website at https://galpan.com/.

1. Data Controller

The information of our Company, acting in the capacity of data controller, is provided below:
Title: Ularte Sınai Yapı ve Ticaret A.Ş.
Address: Büyükdere Cad., No:160, 1. Levent, 34330 İstanbul / Türkiye
Phone: +90 212 281 99 05
Fax: +90 212 281 99 06
E-mail: kvkk@ularte.com

2. Processed Personal Data

The following data submitted by the relevant person through the contact form are processed by our Company:
• Name-surname,
• E-mail address,
• Any requests, suggestions, complaints or statements contained in the message content.

3. Purposes of Processing Personal Data

The personal data collected are processed in accordance with the principles set forth in Article 4 of the Law and limited to the following purposes:
• Evaluation and response to the communication request of the relevant person,
• Management of the application process,
• Internal correspondence and processing regarding the subject of the request,
• Archiving for use as evidence before official authorities when necessary.

4. Legal Basis

Such data are processed on the basis of the following legal grounds set forth in Article 5(2) of the Law:
• (c) Where it is necessary for the establishment or performance of a contract directly related to the data subject,
• (e) Where it is necessary for the establishment, exercise or protection of a right,
• (f) Where it is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

In cases where the data processing activity requires explicit consent, no processing shall be carried out without first obtaining the explicit consent of the data subject.

5. Method of Collection and Legal Ground

Personal data are collected electronically and by non-automated means through the completion of the contact form on the website by the data subject, and are processed on the basis of the legal grounds specified in Article 5 of the Law.

6. Transfer of Personal Data

The personal data collected may be transferred, limited to the purposes of processing and when necessary:
• To legally authorized public institutions and organizations,
• To judicial authorities,
• To the Company’s technical service providers and IT infrastructure suppliers,

in accordance with Articles 8 and 9 of the Law.

7. Retention Period

Personal data are retained for the duration required by the purpose of processing and in any event, for a maximum of 3 years from the conclusion of the relevant request. At the end of this period, the data shall be deleted, destroyed, or anonymized.

8. Rights of the Data Subject

Pursuant to Article 11 of the Law, data subjects may apply to the Company to:
• Learn whether personal data is being processed,
• Request information if personal data has been processed,
• Learn the purpose of data processing and whether data is used in accordance with such purpose,
• Know the third parties to whom personal data is transferred domestically or abroad,
• Request the rectification of incomplete or inaccurate data,
• Request deletion or destruction of personal data under Article 7 of the Law,
• Request notification of such transactions to third parties to whom personal data has been transferred,
• Object to results that are to your detriment arising from the analysis of personal data exclusively through automated systems,
• Request compensation if you suffer damage due to unlawful processing of your personal data.

9. Method of Application

The data subject may submit requests regarding the above-mentioned rights, together with identity-verifying information and documents, in writing or by sending an e-mail to kvkk@ularte.com. Applications shall be evaluated and concluded within 30 days in accordance with Article 13 of the Law.

This clarification text has been made available to the public to clarify the Company’s personal data processing activities concerning communication requests submitted via its website and to fulfill the obligation of disclosure under Article 10 of the Law.