Cloud Bilgisayar Limited Company

Clarification Text on Processing of Personal Data

Last Updated: April2024

Data Controller Information

Data Controller: Cloud Computer Informatics Limited Company
Trade Registry No.: Antalya Trade Registry Directorate - 118553
Telephone: +90 537 867 82 50
Address: Guzeloba Mah. 2211 Sk. Çapa Residans Sitesi No: 3A Interior Door No: 16 Muratpaşa / Antalya
Web: https://eng.cloudbilgisayar.com
MERSIS No: 0211135742400001

This clarification text has been prepared within the scope of the Personal Data Protection Law No. 6698 ("Law"), in cases where Cloud Bilgisayar Bilişim Limited Şirketi ("Cloud Bilgisayar" or "Company") acts as a data controller, in accordance with Article 10 of the Law. The aim of this text is to provide information about the process, form and purposes of collecting, processing, storing, protecting and destroying personal data of real persons ("Data Owner"), and their rights and methods of exercising their rights in accordance with the Law.

Detailed information regarding the processing of your personal data by our Company can be found in Cloud Bilgisayar Bilişim Limited Company Personal Data Protection and Processing Policy ("Policy") available at https://eng.cloudbilgisayar.com/privacy.

For What Purposes and Legal Reasons Do We Process Your Personal Data?
As the Data Controller, we collect and process your personal data collected for the purposes set out below and based on the personal data processing conditions to which they relate.

Based on the legal ground that the processing of personal data of the parties to a contract is necessary, provided that it is directly related to the conclusion or performance of the contract:
▪ Delivering products and services,
▪ Payment and collection of product, service and service fees, selection of collection method,
▪ Negotiation, conclusion and performance of contracts,
▪ Updating customer and membership information and making user definitions to the systems specific to the products and services offered (Creating a User account in the systems of cloud product providers whose services we represent as a reseller),
▪ The establishment or performance of a sales contract due to your purchase of our Company's products and services,
▪ Evaluating and responding to all questions, requests, suggestions, complaints and applications submitted in writing, verbally or electronically, including those related to personal data.

Based on the legal reason that it is clearly stipulated by law and that it is mandatory for the data controller to fulfill its legal obligation:
▪ Fulfillment of official institution requests,
▪ Providing information to authorized institutions due to legislation,
▪ Ensuring compliance with the custody obligations stipulated in the legislation,
▪ Management of judicial/administrative processes, fulfillment of legal obligations in accordance with legal regulations, resolution of legal disputes,
▪ Responding to relevant person applications in accordance with the legislation and taking necessary actions.

Based on the legal reason that data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject:
▪ Customizing the products and services offered in accordance with the demands; updating and developing them due to customer needs, legal and technical developments,
▪ Identification of users into the systems, specific to the products and services offered,
▪ Providing call center and remote support services, tracking the number and content of calls,
▪ Announcing new or existing products, services and campaigns, conducting sales and marketing activities,
▪ Generating statistics and analyzing uses,
▪ Providing liaison/communication, sending informative e-mails such as newsletters etc.to users by e-mail,
▪ Maintaining commercial relations with collaborators, suppliers, resellers and service providers,
▪ In the event that the Operator merges with another company, is divided, or is transferred in whole or in part, to ensure the results arising from this legal transaction,
▪ Developing the company's commercial strategies and plans,
▪ Creating and tracking visitor records, making the website more functional and personalized, ensuring that the Data Owner's other preferences, except for your privacy preferences, are remembered when they re-enter the site,
▪ Ensuring the internal and environmental security of the Company and the security of the Website and Applications,
▪ Usage analysis of the Website,
▪ Creation of a personal data inventory,
▪ Follow-up and execution of legal affairs,
▪ Execution of information security processes,
▪ Conducting audit and ethics activities,
▪ Planning customer satisfaction and corporate communication activities,
▪ Retention of personal data during the general statute of limitations in order to constitute evidence in possible future disputes.


Based on the legal reason that data processing is mandatory for the establishment, exercise or protection of a right;
▪ Receiving, evaluating and finalizing your requests and complaints,
▪ Retention of personal data during the general statute of limitations in order to constitute evidence in possible future disputes.

To Whom and For What Purposes We Transfer Your Processed Personal Data?
Your personal data may be transferred to the following third parties in Turkey or abroad within the scope of the purposes stated in Article 1 above and in accordance with the provisions of the Law and other mandatory legislation in force regarding personal data:
▪ Consultants
▪ Audit Firms
▪ Service Providers (i.e. Alphabet Inc.)
▪ Cooperated Companies
▪ Customers
▪ Shareholders
▪ Company Authorities
▪ Technopark Management (Managing Company)
▪ Banks and Financial Institutions
▪ Judicial Authorities and Public Authorities

What are our Personal Data Processing Methods and Legal Reasons for Processing?
We may collect and process your Personal Data in accordance with the regulations of the Policy, the Law and other relevant legislation, in writing, verbally, electronically, through video/audio recording or by physically interviewing you.

The data collection process can take place in the following ways:
• Through digital channels including website, apps, email, recruitment portals or software,
• Through contracts, applications, forms, call center, remote support, sales and marketing unit, cookies on the Website, business cards, telephone,
• Through face-to-face interviews with the Data Owner.

What are Your Rights as a Data Subject?
Pursuant to Article 11 of the Law, as a Data Subject, you have the following rights regarding yourself by applying to our Company:
• Learn whether their Personal Data is being processed or not,
• Request information if their Personal Data has been processed,
• To learn the purpose of processing Personal Data and whether they are used in accordance with their purpose,
• To know the third parties to whom Personal Data is transferred domestically or abroad,
• To request correction of Personal Data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom Personal Data is transferred,
• Although it has been processed in accordance with the provisions of the Law and other relevant legislation, in the event that the reasons requiring its processing disappear, to request the deletion or destruction of personal data and to notify third parties to whom personal data is transferred,
• To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
• In case of damage due to unlawful processing of Personal Data, to demand compensation for the damage.

However, pursuant to Article 28, paragraph 2 of the Law on the Protection of Personal Data, you cannot use your rights listed above, except for your right to demand compensation for damages in the following cases:
▪ Processing of personal data is necessary for the prevention of crime or criminal investigation,
▪ Processing of personal data made public by the data subject himself/herself,
▪ Processing of personal data is necessary for the execution of auditing or regulatory duties and disciplinary investigation or prosecution by public institutions, organizations and professional organizations that are public institutions, based on the authority granted by the law,
▪ Processing of personal data is necessary for the protection of the economic and financial interests of the state in relation to budgetary, tax and fiscal matters.

If you want to exercise your rights, you can send your requests to privacy@cloudbilgisayar.com via your e-mail address previously notified to our Company and registered in our Company's system.

If you wish to exercise this right through your proxy, it is obligatory to send us the documents certifying your identity, the documents supporting your request, if any, and a copy of the power of attorney containing special authorization.

Your requests will be answered free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board may be charged.

In cases such as sharing incomplete or incorrect information in the application, not expressing the request in a clear and understandable manner, not submitting the documents supporting the request at all or as required, not attaching a copy of the power of attorney in applications made by proxy, we may have difficulty in meeting your requests and there may be delays in the research process. Therefore, it is important that you comply with these terms in the exercise of your rights. Otherwise, our company will not be responsible for any delays. Our company reserves its legal rights against erroneous, untrue/illegal, malicious applications.