Protection of Personal Data

CLARIFICATION TEXT WITH REGARDS TO THE PROCESSING AND PROTECTION OF PERSONAL DATA

As a principle SAMM protects the confidentiality of your personal information submitted by you while you are visiting our website. Within the scope of these “Confidentiality Principles” you are going to have the answers of questions such as what kind of information is processed by SAMM, by applying what kind of methods and within the scope of what kind of legal grounds, which third parties are being involved in sharing the data within the scope of your permission and in accordance with the Law and to inform you regarding the method of protection applied by SAMM. Also, you might have an explanation regarding how to increase the security of your payments and how to change your preferences regarding receiving electronic commerce messages. Services offered by SAMM shall be referred to as “Service” in short.

DATA CONTROLLER and REPRESENTATIVE

SAMM Teknoloji İletişim San ve Tic A.Ş.

Gebze Chamber of Commerce 22448

Address: Gebze Organize Sanayi Bölgesi (GOSB) İhsandede Cd. 800. Sok No: 802, 41400 Gebze-Kocaeli, Turkey

e-mail: telecom@samm.com

Call Center : 444 17 26

PURPOSE OF PROCESSING THE PERSONAL DATA

Your personal data are being processed to realize liabilities imposed especially by the provisions of the legislation such as Turkish Code of Commerce No. 6102 and Tax Procedure Law no. 213.

Your personal data are being processed for the purposes of offering the best service requested from SAMM, providing customized products from both of our domestic and foreign suppliers, to make your profile record ready for your next visit etc. Also, your personal data are being processed to improve SAMM’s services, to offer high level services, to draw your attention to our site, our products and services as well as increasing their quality, to realize your payments, to update your information, manage and maintain your account, to provide third parties to realize technical, logistics and similar other functions as a service provider on behalf of SAMM. Demographic information is used for guiding our customers according to their field of interest and for segmentation.

Personal information might also be used to deliver bulletins, presentations, advertisements or offers, to inform you about campaigns and special opportunities and for other marketing means by having your approval and by providing means to you to withdraw your approval at any time.

SCOPE OF THE CONFIDENTIALITY PRINCIPLE

As a part of the offered service SAMM has the right to obtain and transfer your confidential information within the scope of these “Confidentiality Principles”. This type of information transfer is carried out in accordance with conditions specified by third parties and in accordance with existing agreements with third parties and with legal regulations in force. These “Confidentiality Principles” are not reflecting the confidentiality applications of third parties and SAMM is not responsible for third party’s confidentiality policies or practices. These “Confidentiality Principles” are not covering practices beyond the control of SAMM, information collected by platforms and web sites that belong to third parties, information collected over links given on SAMM's website by third parties, or titles, campaigns and other commercials or publicities on third party web sites which sponsored and/or contributed by SAMM. SAMM is not responsible for operations against personal data collected, stored and used by third parties via their own web sites.

WHICH PERSONAL DATA ARE PROCESSED

Some of your personal information is being collected within the scope of Services offered on the Web Site by SAMM. Aforementioned personal information might include: Name-last name, your contact information, information directly related to your Order, information related to purchasing Products and Services and benefiting from our web site, your nationality, passport or identity number, payment information, records regarding marketing and communication preferences, IP address while visiting our Web Site, pages displayed on our site, data introducing your mobile device while you are visiting our site via your mobile device, features and geographical information; information that you clearly and in written prefer to share with us and confirm to provide us or all kinds of other information that we could obtain from third parties with this clear approval and it is also possible to record these information.

FOR WHAT PURPOSE ARE YOUR PERSONAL DATA BEING PROCESSED?

Your personal data are being processed to realize liabilities imposed especially by the provisions of the legislation such as Turkish Code of Commerce No. 6102 and Tax Procedure Law no. 213.

Your personal data are being processed for the purposes of offering the best service requested from SAMM, to make your profile record ready for your next visit etc. Also, your personal data are being processed to improve SAMM’s services, to offer high level services, to draw your attention to our site, our products and services as well as increasing their quality, to realize your payments, to update your information, manage and maintain your account, to provide third parties to realize technical, logistics and similar other functions as a service provider on behalf of SAMM. Demographic information is used for guiding our customers according to their field of interest and for segmentation.

FOR WHAT PURPOSE AND TO WHOM YOUR PERSONAL DATA ARE BEING TRANSFERRED?

Your personal data are being shared only with third parties residing domestically or abroad; realizing technical, logistics and similar other operations on behalf of us as well as banks, our providers, business and solution partners residing domestically or abroad according to the nature of the service and to be able to offer services completely without having problems. These third parties are limited to the people that have to have these information to provide related services completely and without having problems.

It is possible to transfer your personal data – limited to only related person or institution – in case of a legal/administrative order given in accordance with laws or in case it is clearly foreseen in laws, or in case it is mandatory to realize the legal obligations of SAMM.

Your personal data might be transferred to third parties that we are receiving support in the areas such as storing, archiving data, information technologies, security, call center etc.; data might also be transferred to business partners, banks, financial institutions that we are cooperating with and/or receiving support; also to consultancy firms, law offices providing support in legal issues and tax and other similar areas and to authorized institutions and organizations which data transfer is required for the protection of SAMM’s right and/or your rights and to be able to fulfill the legal obligations and only when data transfer is mandatory for the performance of these purposes.

Parts of the personal data might only be shared with advertisers in an anonymized form together with the information belongs to other users to be able to adapt the advertisement to the target group. It is not possible to match the anonymized data with our visitors/customers, and said data would not contain ID information or would not make your ID determinable. Your confidentiality is guaranteed in anonymized data.

THE METHOD OF COLLECTING PERSONAL DATA AND ITS LEGAL REASON

Your personal data are being acquired for customer interviews, written/digital applications to direct sales teams, our web site, all of our mobile applications, our call center, companies which we are acting as a mediator/agency, our business and solution partners residing domestically or abroad, social media, SMS channels, in various verbal, written or electronic mediums via automatic or non-automatic methods and to conduct our commercial activities by collecting your personal data via channels which our Company is communicating with you today or in the future; said data are being acquired to fulfill our contractual and legal liabilities and acquired data are being stored within the legal period in accordance with the legislation related to acquired personal data.

YOUR RIGHTS AS BEING A DATA OWNER

As personal data owners, your requests related to your rights are going to be finalized free of charge within maximum thirty days according to the features of the request in case you deliver your request to SAMM in written. Within this scope personal data owners has various rights such as; (i) Learning whether personal data are being processed or not, (ii) Asking for information related to the processing of their personal data (if processed), (iii) Learning the purpose of processing the personal data and learning whether or not these are being used in accordance with the purpose, (iv) Knowing the third parties which the personal data are being transferred domestically or abroad, (v) Requesting a correction in case personal data are not being processed completely or being processed inaccurately and requesting the notification of the operation carried out to third parties which personal data are transferred, (vi) Requesting the deletion or removal of personal data in case reasons that require the processing of personal data are cease to exist, even though said data are being processed in accordance with The Law on the Protection of Personal Data and provisions of other related laws, and requesting the notification of the operation carried out to third parties which personal data are transferred, (vii) Objecting an outcome to the detriment of the person by analyzing the processed data exclusively via automatic systems and (viii) Requesting the compensation of losses in case data owner incurs losses due to illegal processing of personal data.

To exercise these rights you might deliver your request by hand to Gebze Organize Sanayi Bölgesi (GOSB) İhsandede Cd. 800. Sok No: 802, 41400 Gebze-Kocaeli, Turkey address by filling out the application form given in https://telecom.samm.com/kisisel-verilerin-islenmesi-ve-korunmasi-hakkinda with wet signature or send its to samm@hs01.kep.tr e-mail address with secure electronic signature. Also, in case you notified an e-mail address to our side and in case said address is registered to SAMM Technology system, then you might forward your application form to kvkk@samm.com by using this registered e-mail address.

You need to clearly specify the right/request you need to use together with your ID information and you need to attach all information and documents to your request by providing required explanations.

Requests that are having the necessary qualifications and being delivered to our side are going to be brought to a conclusion within 30 (thirty) days according to the nature of the request and its result is going to be notified to your side in written or in electronic medium according to the method of feedback you selected in your request.

Apart from these, in case you do not want to receive a commercial e-mail related to a Service offered by SAMM, you could use your right to reject regarding this matter free of charge by posting a notice to telecom.samm@samm.com.

STORAGE PERIOD OF YOUR SAMM PERSONAL DATA

In case longer periods are not foreseen in the legislation, your personal data are going to be stored for maximum 10 (ten) years in accordance with Article 146 of Turkish Code of Obligations and Article 182 of Turkish Trade Act. Camera records shall be stored for maximum 2 (two) years.

QUESTIONS AND RECOMMENDATIONS REGARDING INFORMATION UPDATE

You might update your personal information over our web site by yourself. If you wish you might change them by means of our Customer Services. To be able to change the required information by our Customer Services; you need to go through an examination and your ID information have to be confirmed.

You might help keeping your contact information and preferences correct, complete and up-to-date over an e-mail forwarded to your upon your request or over Telecom&SAMM web site. With regards to other personal information that we are keeping at hand; you might request the correction of wrong information or you might request the deletion of information in case it is not needed to keep for legal commercial purposes or according to the law.

PAYMENT SECURITY

Our web site has SSL system which is providing the highest level of security for you to make your transactions securely. SAMM is using your “Credit Card Information” at the stage of purchasing. Credit Card Information shall not be recorded for any other operations.

COOKIE USAGE

To be able to provide better services, for the guests and members to benefit from the advantages of the membership and shopping platform and within the scope of the legal responsibilities, telecom@samm.com is going to collect your browsing information, going to process them and share with third parties and shall store them securely within the scope of purposes specified by this Confidentiality/The Policy on the Protection of Personal Data and without using beyond this scope.

Cookies are text files containing small pieces of information being stored in your computer, mobile phone or tablet and installed by your internet browser when you visit “telecom.samm.com” web site or when you realize connection from the mobile site.

For What Purposes (Which) Cookies are Being Used?

In General

- To realize the basic functions required for the functioning of the Site. For example, members login to the Site would not need to re-enter their passwords while visiting other pages.

- To analyze the Site and to increase the performance of the Site. For example, integration of different servers which the Site is working on, to detect the number of visitors and making performance settings accordingly or make it for visitors to find what they are looking for.

- To enhance the functionality of the Site and providing ease of use. For example, realizing sharing to third party social media mediums over the Site, remembering the username information or queries of the visitor at the next visit.

- The realization of customization, targeting and advertising activities. For example, displaying advertisements related to the areas of interest of visitors over displayed pages and products.

In accordance with Article 5 and 8 of Personal Data Protection Law and/or in case of availability of exceptions within the scope of the related legislation your personal data might be processed in accordance with the legislation, otherwise in line with aforementioned purposes without having your consent. As SAMM we might share your personal data with third parties, affiliated companies, joint ventures and group companies which our Company is benefiting from the services in accordance with the legislation and limited to the realization of aforementioned purposes. We would like to indicate that said parties might keep your personal data in servers residing anywhere around the world.

Cookies Used by our Site

You might examine various types of cookies used by our site below. Both first party cookies (inserted by the visited site) and third party cookies (inserted by servers apart from the site visited) are used by our Site.

Types of cookies used by the Web Site are shown below:

Session Cookies

Session cookies are temporary cookies used only during the session and deleted after closing the browser. The primary objective of using these types of cookies is to provide the proper functioning of the Web Page throughout its usage.

Persistent Cookies

Persistent cookies are the type of cookies used to enhance the functionality of the Web Site, to offer faster and better services to users. This kind of cookies are used to remind your preferences and stored in your device via browsers. Some types of persistent cookies are offering customized suggestions by evaluating matters such as your usage purposes of the Web Site. When you visit the web site by the same device, by means of persistent cookies Web Site and your device would recognize each other. By this means you would have a better service experience.

How Could I Control and/or Stop the Cookie Usage?

You might block the cookie usage according to your browser type by means of below mentioned connections:

Adobe Analytics

http://www.adobe.com/uk/privacy/opt-out.html

AOL

https://help.aol.com/articles/restore-security-settings-and-enable-cookie-settings-on-browser

Google AdWords

https://support.google.com/ads/answer/2662922?hl=en

Google Analytics

https://tools.google.com/dlpage/gaoptout

Google Chrome

http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647

Internet Explorer

https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox

http://support.mozilla.com/en-US/kb/Cookies

Opera

http://www.opera.com/browser/tutorials/security/privacy/

Safari

https://support.apple.com/kb/ph19214?locale=tr_TR

Matching and usage related to cookies shall remain only within the scope and purposes specified via this Confidentiality/The Policy on the Protection of Personal Data and Communication Consent.

If you reject persistent cookies and session cookies, then you might keep on using the web site or mobile application; however, you might not have access to all functions of the web site and mobile application or you might experience a limited access.

SAMM Teknoloji İletişim San ve Tic A.Ş.