KVKK Clarification Text

Depending on the nature of the service provided by ALTIN ATLAS and the user's operations on the site, the following personal data may be processed:

• Identity and contact data: name surname, email address, phone number
• Customer transaction data: order information, purchase records, test access information, report delivery information
• Finance / payment transaction data: records related to the payment transaction, collection information, data related to the invoicing/payment process
• User transaction data: user account information, account movements, account deletion requests
• Test and evaluation data: answers given to inventory questions, reports and assessment outputs created based on these answers
• Transaction security data: IP address, device information, session/log records, site usage records
• Support and communication data: information shared within the scope of support requests sent via email and phone calls
• Cookie and analytics data: usage and traffic data obtained through Google Analytics and similar tools

It is understood that there are no fields that allow open-ended text entry by you, and special categories of personal data such as health, religion, political opinion, trade union membership are not requested.

Your personal data may be processed for the following purposes:

• Operating and managing the website
• Creating and managing the user account
• Providing access to the purchased test
• Administering the tests
• Preparing a report based on test answers and delivering it to the user
• Conducting payment, collection and order processes
• Meeting user support requests
• Ensuring system security and service continuity
• Detecting abuse, irregular transactions, technical faults and security risks
• Fulfilment of accounting, record, evidence and obligations arising from the legislation
• Measuring, analyzing and improving site performance

Your personal data are collected through:

• Your membership/account creation via the website,
• Your purchase of tests,
• Your payment transaction,
• Your completion of the test,
• Your support request,
• Your contact via phone or email,
• Your visit to the site and your use of cookie preferences

Your personal data are collected electronically.

Your personal data may be processed on the basis of the legal grounds set forth in Article 5 of KVKK. These may include, especially depending on the specific processing activity:

• Being directly related to the establishment or performance of a contract
• Being necessary for the data controller to fulfil its legal obligation
• Being necessary for the establishment, exercise or protection of a right
• Being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person
• The existence of the relevant person's explicit consent when necessary

According to the KVKK guide, the legal basis must also be explicitly stated in the clarification text.

Your personal data may be transferred to the following recipient groups to the extent necessary for the purposes specified in this Clarification Text:

• Payment service provider
• Email/communication infrastructure providers (SMTP services)
• Persons and institutions providing accounting / financial advisory services
• Attorneys / legal advisors when necessary
• Authorized public institutions and organizations in cases required by the legislation or requested by the competent authorities

Within the scope of the clarification obligation, it is mandatory to specify the purposes of transfer and the recipient groups to be transferred.

Due to the servers used for website infrastructure and technical hosting services being located abroad, your personal data may technically be hosted and processed on servers located abroad. In addition, due to some tools used within the scope of analytics and technical services, it is possible that data may come into contact with systems connected abroad.

In this framework, your personal data may be transferred abroad in accordance with Article 9 of the KVKK and in accordance with the procedures and assurances stipulated in the relevant legislation. The KVKK guide on transfer abroad clearly provides that in cases where there is no adequacy decision, appropriate safeguards and legal conditions must be additionally evaluated.

Cookies and similar technologies may be used on the website. In this context, analyses may be made in areas such as site traffic, usage intensity, page performance and user experience, especially through Google Analytics.

It is understood that a cookie banner/consent mechanism based on user preference is operated for analytical cookies. Details regarding the use of cookies and preferences may be regulated separately in the Cookie Policy text.

Your personal data may be stored for:

• As long as your user account is active
• Until the account is deleted
• To the extent that statutory retention obligations arising from the relevant legislation continue
• As long as necessary within the scope of possible disputes, proof and audit needs

If the user deletes his account through the panel, the data and reports associated with the account may be removed from the system; however, data within the scope of statutory retention, record and proof obligations may be retained additionally to the extent of the relevant legal obligation.

Users under the age of 18 can also benefit from the services through ALTIN ATLAS. However, issues such as legal transaction capacity due to minority, parental/legal representative consent requirement and similar issues are evaluated separately within the framework of the relevant legislation.

Currently, there is no specific parental approval flow; however, this situation can be updated when necessary. The KVKK practices emphasize that higher diligence should be shown in data processing activities concerning children.

As the relevant person under Article 11 of the KVKK, you have the right to apply to the data controller and:

• Learn whether your personal data is processed or not
• Request information if it has been processed
• Learn the purpose of processing and whether it is used in accordance with its purpose
• Know the third parties to whom it is transferred domestically or abroad
• Request correction if it has been processed incompletely or incorrectly
• Request deletion or destruction within the framework of the conditions stipulated in KVKK
• Request notification of the transactions made pursuant to correction or deletion to third parties to whom the data has been transferred
• Object to the occurrence of a result against you by analyzing the processed data exclusively through automatic systems
• Request compensation if you suffer damage due to unlawful processing

you have these rights.

You may submit your requests under KVKK to the data controller together with information that proves your identity via the following channels:

Data Controller / Brand: ALTIN ATLAS Address: Samandağ / Hatay / Türkiye Email: support@altinatlas.com

Applications are evaluated in accordance with KVKK and the relevant legislation and finalized within the legal period.

This Clarification Text has been prepared for the purpose of general information regarding the processing of personal data and may be revised in line with changes in legislation, changes in the scope of services or updates in technical infrastructure. The current text becomes effective as of the date it is published on the website.