Policy on Protection and Processing of Personal Data

ININAL POLICY ON PROTECTION AND PROCESSING OF PERSONAL DATA
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As ininal Payment and Elektronik Para Hizmetleri A.Ş (“Company”), we pay utmost attention to the security of your personal data. Based on this responsibility, we attach great importance to the processing of all kinds of personal data of all real persons in relationship with the Company including real persons using our products and services, in accordance with the Personal Data Protection Law No. 6698 (“KVK Law”). With the awareness on this responsibility and as “Data Controller” as described in KVK Law, we process your personal data as described below and subject to limits specified in the legislation.

1.Collection, Processing of Personal Data and Purposes of Processing

Your personal data may vary depending on the services provided by our Company. Your data may be collected verbally, in writing or electronically with automated or non-automated methods, Group Companies and functions, internet site, social media, mobile applications and similar other channels. As long as you benefit from the products and services offered by our Company and Group Companies, your personal data may be processed. In addition, your personal data may be processed when you use our call centers or website to use the services of our Company or Group Companies, visit our Company offices or website, and attend training, seminars or organizations organized by our Company. Your personal data shall be processed for the purposes described below in accordance with data processing conditions and objectives described under articles 5 and 6 under the Law No. 6698.

2. Recipients and Purposes of Transferring Processed Personal Data

For the reasons explained under article 1 of this text, your personal data may be transferred to Group companies, business partners, suppliers, authorized representatives of our Company, shareholders, legally competent public organizations and private persons in accordance with conditions and purposes of personal data processing specified in Articles 8 and 9 of KVK Law.

3. Method and Legal Reason of Collecting Personal Data

Your personal data is obtained in order to provide the products and services offered by our Company in any verbal, written or electronic environment, in line with the reasons stated above, and to fulfil our Company’s contractual and legal obligations in a complete and accurate manner. Your personal data collected for this legal reason can also be processed and transferred within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law for the reasons specified in the articles (1) and (2) of this text.

4. Rights of the Data Subjects that are listed in Article 11 of the Law on KVK

As data subjects, if you submit your requests regarding your rights to our Company by the methods set out below in this Information Text, our Company will process the request free of charge latest within thirty days. However, if a fee is stipulated by the Personal Data Protection Board, the fee determined by our Company will be charged. Accordingly, data subjects are entitled to

5.Events Not Requiring Consent

Pursuant to paragraph 2, Article 5 of the Personal Data Protection Law No. 6698, Company is entitled to process personal data without obtaining express consent of the relevant person in the following cases:

6. Remedies Applicable to Data Subjects

Pursuant to paragraph 1 of Article 13 of the KVK Law, your request containing your explanations in connection with the exercising of your rights specified in Article 11 of KVK Law and information required to verify your identification should be send to the following address upon completing the form at ininal.com address with signature:

As ininal, we undertake to update this Information Text in case of any amendment to the Law No. 6698 on the Protection of Personal Data.