CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

The Law on the Protection of Personal Data No. 6698 entered into force upon its publication in the Official Gazette dated 07.04.2016 and numbered 29677. The Law, prepared by taking into account international documents, comparative legal practices, and the needs of our country, aims to process and protect personal data in accordance with contemporary standards. In this context, the purpose of the Law is to regulate the conditions for processing personal data, the protection of fundamental rights and freedoms of individuals in the processing of personal data, and the obligations, procedures, and principles to be followed by real and legal persons processing personal data.

Our Company is obliged to comply with the Law on the Protection of Personal Data No. 6698, and all personal data processed within our operational processes are within the scope of this law.

As POLİTAK SAVUNMA SANAYİ TİCARET A.Ş. (Headquarters Address: Karlıktepe Mahallesi, Ayabakan Sok. No:17/3, 34870 Kartal / İstanbul, MERSİS No: 0732193394300001), we act in the capacity of Data Controller and take the necessary measures regarding the protection of personal data.

1. General Principles in Processing Personal Data Our Company acts in accordance with the general principles set forth by Law No. 6698 in the processing of personal data. Our general principles in processing personal data are as follows:

  1. Compliance with the law and rules of good faith (fairness),

  2. Being accurate and, when necessary, up to date,

  3. Processing for specific, explicit, and legitimate purposes,

  4. Being connected, limited, and proportionate to the purpose for which they are processed,

  5. Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

Although your personal data may vary depending on the service, product, or commercial activity provided by our Company, it may be collected verbally, in writing, or electronically by automatic or non-automatic methods, through our Company's and our member merchants' offices, branches, dealers, call centers, websites, social media channels, mobile applications, and similar means.

Furthermore, your personal data may be processed when you call our call center with the intention of using our Company's services, visit our website, or participate in trainings, seminars, organizations, and meetings organized by our Company.

2. Categories of Processed Personal Data The following categories of personal data are processed within the scope of our activities:

  • Identity Information: Name, surname, etc.

  • Contact Information: Phone number, e-mail address, residence address, etc.

  • Customer Transaction Information: Requests, complaints, order information, etc.

  • Financial Information: Bank account information, payment information, etc.

  • Transaction Security Information: IP address, log records, etc.

  • Visual/Audio Recordings: Camera images and voice recordings (For detailed information, see "Camera and Voice Recording Clarification Text")

  • Marketing Information: Campaign participation information, commercial communication consent information, etc.

  • Other: Records required to be kept pursuant to relevant legislation.

3. Purposes and Legal Reasons for Processing Personal Data Your personal data is obtained in any verbal, written, or electronic environment for the purposes stated above, in order to provide the products and services offered by the Company within the determined legal framework and, in this context, for our Company to fulfill its contractual and legal responsibilities completely and accurately. Your personal data collected for this legal reason may also be processed and transferred for the purposes specified in this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK (Law on Protection of Personal Data).

Personal data is used by our Company for the following purposes:

  • Improving the services offered, developing new services, and providing information regarding these,

  • Regarding commercial electronic message approval for existing and potential customers; promotion and marketing of campaigns and services,

  • Resolving customer problems and complaints,

  • Conducting statistical assessments and market research,

  • Determination and implementation of the Company's commercial and business strategies,

     

     

  • Managing relationships with member merchants and business partners,

     

     

  • Follow-up of accounting and payment transactions,

     

     

  • Legal processes and compliance with legislation,

     

     

  • Responding to information requests from administrative and judicial authorities,

     

     

  • Planning of internal reporting and business development activities,

  • Performing financial controls and reporting, and making legal notifications,

  • Managing internal control and audit activities,

  • Ensuring information and transaction security and preventing malicious use,

  • Making necessary arrangements to ensure that processed data is up-to-date and accurate, and carrying out activities related to all these listed processes.

4. Methods of Collection of Personal Data Your personal data is collected by automatic or non-automatic means through methods such as offices, branches, dealers, websites, social media, call centers, mobile applications, e-mails, written forms, camera and voice recording systems, etc.

5. Transfer of Personal Data Stored data may be transferred within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law on the Protection of Personal Data No. 6698 ("KVKK"). Your personal data may be transferred;

  • Domestically: To partners, suppliers, banks, financial institutions, legal advisors, authorized public institutions, independent audit firms, Payment and Securities Settlement Systems, Payment Services, and Electronic Money Institutions within the framework of the provisions of Articles 8 and 9 of the KVKK.

  • Internationally: If the transfer is to be made to countries where there is no adequate protection, your explicit consent will be obtained.

     

     

Records and documents regarding transactions carried out by our Company with its customers may be stored for a certain period within the scope of legal regulations. In case you request the deletion of your personal data, this request will be fulfilled at the end of the legal periods; during this process, your personal data will not be processed except for legal obligations and will not be shared with third parties. Our Company takes the necessary technical and administrative measures within the framework of the legislation and is responsible for violations committed by third parties after the transfer only to the extent required by the legislation.

 

 

6. Retention Periods Your personal data will be stored for the period stipulated in the relevant legislation or for the period necessary for the processing purposes. Retention periods are specified below:

  • Accounting records: 10 years

  • Camera recordings: 30 days

  • Commercial communication permission records: Until permission is withdrawn

Before the legal retention period expires, deletion or anonymization of your personal data may not be possible due to technical or legal reasons. Our Company takes all necessary technical and administrative measures to protect your personal data and process it in accordance with the legislation.

 

 

7. Technical and Administrative Measures Within the scope of Article 12 of the KVKK, our Company takes measures such as access control, data masking, encryption, logging, personnel training, and network security measures.

 

 

 

 

8. Rights of the Data Subject (KVKK Art. 11) As personal data owners, if you submit your requests regarding your rights to our Company through the methods set out below in this Clarification Text, our Company will conclude the request free of charge within thirty days at the latest, depending on the nature of the request. However, if a fee is foreseen by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged. Personal data owners have the right to:

  • Learn whether personal data is processed,

  • Request information if personal data has been processed,

  • Learn the purpose of processing personal data and whether they are used in accordance with their purpose,

  • Know the third parties to whom personal data is transferred domestically or abroad,

  • Request correction of personal data in case of incomplete or incorrect processing,

  • Request the deletion/destruction of personal data if the reasons for processing have disappeared,

  • Object to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,

  • Demand compensation for damages in case of damage due to unlawful processing of personal data.

Pursuant to paragraph 1 of Article 13 of the KVKK, you may submit your request regarding the exercise of your above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any specific method at this stage, you are required to submit your application to our Company in writing in accordance with the KVKK. In this framework, the channels and procedures through which you will submit your written application to our Company within the scope of Article 11 of the KVKK are explained below.

9. Application Methods To exercise your rights stated above, you may submit your letter containing your explanations regarding the right you request to exercise among the rights specified in Article 11 of the KVKK, together with the necessary information to identify your identity and other requested information, to our company headquarters address shared below by hand with documents identifying your identity, send it via registered mail with return receipt, send it via notary public or other methods specified in the KVKK, or send the relevant documents to the KEP address shared below with a secure electronic signature.

You may submit your applications to [Company Address: Karlıktepe Mahallesi, Ayabakan Sok. No:17/3 34870 Kartal / İstanbul] and [KEP Address: politak.savunma@hs01.kep.tr] together with documents certifying your identity via the following methods:

  • Hand delivery

  • Registered mail with return receipt

  • Notary Public

  • info@politak.com

  • KEP (with secure electronic signature)

10. Enforcement and Updates This Clarification Text entered into force on 11.08.2025. Our Company may update the text in line with legal changes. You can access the current text on our website.

Last Update Date: 11.08.2025

POLİTAK SAVUNMA SANAYİ TİCARET A.Ş.

Headquarters: Karlıktepe Mah. Ayabakan Sok. No:17/3, 34870 Kartal / İSTANBUL KEP Address: politak.savunma@hs01.kep.tr MERSİS No: 0732193394300001 Switchboard: (216) 353 0002 pbx Fax: (216) 353 0533 E-Mail: info@politak.com