Fescom Privacy Policy

At fescom.net, we place great importance on the security of your personal data. Your personal data is processed and stored in accordance with the Law on the Protection of Personal Data No. 6698 (KVKK).

Processing of Your Personal Data

Pursuant to Law No. 6698, the personal data you share with fescom.net may be processed by us in whole or in part, by automatic means or non-automatic means provided that it is part of any data recording system, through obtaining, recording, storing, altering, reorganizing — in short, through any processing performed on data. All such processing activities are deemed as “processing of personal data” under the KVKK.

Purposes and Legal Grounds for Processing Your Personal Data

Your personal data may be processed for the following purposes in compliance with the KVKK and related secondary regulations:

• To fulfill the requirements of the services we provide to our customers in accordance with the contract and technological necessities and to improve our products and services;

• To provide information to prosecutors’ offices, courts, and relevant public officials upon request and in accordance with the legislation, for matters concerning public safety and legal disputes;

• To offer a wide range of opportunities to our members or to share such opportunities with individuals or institutions within legal frameworks;

• To analyze advertising preferences.

Information on Third Parties or Organizations to Which Your Personal Data May Be Transferred

For the above-mentioned purposes, your personal data shared with fescom.net may be transferred to:

• Our main shareholders and affiliates,

• Advertisers,

• Direct or indirect domestic or foreign subsidiaries,

• Member companies using the fescom.net infrastructure,

• Relevant individuals and organizations related to the services provided,

• Third parties and organizations we receive services from as Data Processors, we collaborate with, or are program partners with, either domestically or abroad.

Our regulations regarding cookies to be used for advertising purposes are included in the “fescom.net Cookie Policy”, which forms a part of this “Privacy and Personal Data Protection Policy”.

Method of Collecting Personal Data

Your personal data may be collected in the following ways:

• Through forms on the fescom.net website and mobile applications, including data such as name, surname, address, phone number, business or private email address, as well as preferences and IP records of actions performed on logged-in pages, browser-collected cookie data, navigation times and details, and location data;

• From individuals who share their personal data with fescom.net for purposes such as establishing a commercial relationship, applying for a job, making an offer, via business cards, resumes, or other methods, either in physical or virtual environments, face-to-face or remotely, verbally, in writing, or electronically;

• Indirectly obtained from other channels, such as websites, blogs, contests, surveys, games, campaigns, and similar web-based uses, and social media; data from publicly available databases, open profiles and data shared on social media platforms; reading or clicking behaviors on e-newsletters.

Personal Data Obtained Before KVKK Came into Effect

fescom.net was not in publication before the effective date of the KVKK (April 7, 2016), thus no personal data was stored prior to this date.

Transfer of Your Personal Data

Your personal data collected through any of the above methods, whether processed in Turkey or intended to be stored/processed outside of Turkey, may be transferred to service providers located in countries accredited by the Personal Data Protection Board and deemed to provide adequate protection in accordance with KVKK, provided it complies with the law and serves contractual purposes.

Your personal data may be transferred to:

• Our business partners with whom we collaborate or receive services for the provision and promotion of products and services;

• Authorized institutions for location tracking in emergency call situations;

• Regulatory and supervisory authorities, courts, enforcement offices, and other official institutions authorized to request personal data;

• Legal entities in commercial relationships with fescom.net who have your phone number.

Storage and Protection of Personal Data

fescom.net is responsible, under Article 12 of the KVKK, for preventing the unlawful processing of personal data, unauthorized access, and ensuring the safekeeping of such data by taking software measures (such as hash, encryption, transaction logging, access management) and physical security measures. If personal data is obtained illegally by others, the situation will be reported promptly and in writing to the Personal Data Protection Board, in accordance with legal regulations.

Keeping Personal Data Accurate and Up to Date

According to Article 4 of the KVKK, fescom.net is obliged to keep your personal data accurate and up to date. Therefore, our members are required to share accurate and up-to-date information or update it via our website/mobile application to fulfill fescom.net’s obligations under the applicable legislation.

Rights of the Personal Data Owner Under KVKK

As per Article 11 of the KVKK, which came into force on October 7, 2016, Personal Data Owners have the following rights:

By applying to fescom.net, a Personal Data Owner may:

• Learn whether personal data is being processed,

• Request information if personal data has been processed,

• Learn the purpose of processing personal data and whether it is used in accordance with that purpose,

• Know the third parties to whom personal data is transferred within or outside the country,

• Request the correction of personal data if it is incomplete or incorrectly processed,

• Request the deletion or destruction of personal data within the scope of Article 7 of the KVKK,

• Request that transactions made as per above be notified to third parties to whom the data has been transferred,

• Object to any unfavorable outcome resulting from the analysis of processed data exclusively through automated systems,

• Request compensation for damages in case of unlawful processing of personal data.

Contact and Application Method

Personal Data Owners may submit their questions, opinions, or requests via e-mail to info@fescom.net.

fescom.net will respond to submitted requests within 30 days, either positively or negatively, with a reasoned explanation, via written or digital means. Requests are generally free of charge. However, if the process incurs a cost, fescom.net reserves the right to request a fee based on the tariff set by the Personal Data Protection Board in accordance with Article 13 of the Law.

By sharing your personal data on our website, applications, and other channels, you confirm that you accept our Personal Data Policy, including the methods of data processing, transfer, and sale, and other related matters stated therein. You also declare, with explicit consent, as defined in KVKK as a statement made based on information, concerning a specific subject, and given with free will, that:

• You consent to the use of data shared with a social media application such as fescom.net on the website, applications, and social media platforms,

• You agree that notifications and suggestions may be made and,

• If deemed beneficial to members, your data may be shared commercially with third parties,

• And that you will first contact fescom.net to exercise your legal rights.