KVKK Policy

I. INTRODUCTION

A. PURPOSE OF THE POLICY

ANFECA Yazılım ve Danışmanlık Limited Şirketi Board of Directors and all personnel, in line with the Personal Data Protection and Processing Policy, undertake to comply with the principles and rules introduced by the Constitution of the Republic of Turkey, the Personal Data Protection Law No. 6698 (KVKK) and other legislation regarding the protection of personal data and to protect the rights of the relevant persons. For this purpose, it has adopted a written personal data protection policy and system to be implemented and developed.

The purpose of the Personal Data Protection Policy is to ensure that ANFECA Yazılım ve Danışmanlık Limited Şirketi establishes and implements its own standards in the management of personal data; determination and support of organizational goals and responsibilities, establishment of control mechanisms in accordance with ANFECA Software and Consulting Limited Company's acceptable risk level; fulfillment of the responsibilities to which ANFECA Software and Consulting Limited Company is subject in accordance with international agreements, the Constitution, laws, agreements and professional rules in the field of protection of personal data and protection of the interests of individuals in the best way.

B. SCOPE OF THE POLICY

This policy has been prepared for ANFECA Software and Consulting Limited Company and covers the services provided within the institution. The policy provisions cover all information systems and sub-information, contracts, environmental and physical areas and all systems and regulations produced for these, which are included in the processing of personal data in the fields of activity and work of ANFECA Software and Consultancy Limited Company. This policy covers the Board of Directors of ANFECA Software and Consultancy Limited Company, all departments, directorates, employees of companies providing all kinds of services, interns and contract personnel. Any violation of KVKK or this policy action is evaluated within the scope of the relevant legislation and sanctions are applied accordingly.

ANFECA Software and Consulting Limited Company’s solution partners, public institutions, insurance companies and all third parties working with ANFECA Software and Consulting Limited Company that have access or are likely to access personal data are invited to read this policy and comply with it. Third parties must ensure the protection of personal data with a system that is at least as strong and has sufficient standards as ANFECA Software and Consulting Limited Company in terms of the protection of personal data. Third A written confidentiality agreement will be made between the parties and ANFECA Yazılım ve Danışmanlık Limited Şirketi, which includes the obligations within the scope of the protection of personal data and the right to audit them. Third parties cannot access personal data processed by ANFECA Yazılım ve Danışmanlık Limited Şirketi without signing a confidentiality agreement. The data security principles adopted by ANFECA Yazılım ve Danışmanlık Limited Şirketi will be made sustainable together with the Personal Data Protection and Processing Policy.

C. OBJECTIVE OF THE POLICY

ANFECA Software and Consultancy Limited Company Policy aims to create the necessary systems in line with the goal of creating awareness on the legal processing and protection of personal data within the company and to establish the necessary order to ensure compliance with the legislation. In this context, the Policy aims to guide the implementation of the regulations set forth by the Personal Data Protection Law and relevant legislation.

D. DEFINITIONS and ABBREVIATIONS

Company: ANFECA Software and Consulting Limited Company (ANFECA)

Explicit Consent: Consent given on a specific subject, based on information and free will, with no room for hesitation, and limited only to that transaction.

Anonymization: Making personal data in no way associable with an identified or identifiable real person, even by matching it with other data.

Employee: Company personnel.

Relevant Person: Real person whose personal data is processed.

Personal Data: Any information relating to an identified or identifiable natural person