Disclosure Text

A ÖDEME VE ELEKTRONİK PARA HİZMETLERİ A.Ş. 

ENLIGHTENMENT TEXT ON THE PROTECTION OF PERSONAL DATA

We, as A ÖDEME VE ELEKTRONİK PARA HİZMETLERİ A.Ş. (“Morpara”), in the capacity of the data controller, process your personal data within the scope of the Law on the Protection of Personal Data No. 6698 (“KVKK” or “Law”) and the Communiqué on the Procedures and Principles to be Followed in Fulfillment of the Obligation to Inform (“Communiqué”), and other relevant legislation. At the same time and make our best efforts to protect the data we process by taking the technical and administrative measures stipulated by law. 

With this text, we would like to fulfill the enlightenment obligation specified in Article 10 of the KVKK as the data controller and in this way, we would like to inform you in detail about the purpose for which your personal data will be processed, to whom and for which purpose your personal data may be transferred, the method and legal reason for collecting your personal data, and your rights listed in Article 11 of the Law. 

1. PERSONAL DATA PROCESSED BY MORPARA

2. METHOD OF COLLECTING YOUR PERSONAL DATA 

Your personal data is collected and processed for the following reasons: 

• It is explicitly stipulated in the law. 

• It is necessary to process the personal data of the parties subject to the contract provided that it is directly related to the drawing up or performance of a contract. 

• It is mandatory for Morpara, the data controller, to fulfill its legal obligation, • It is mandatory for the establishment, use or protection of a right. 

• It is mandatory for the legitimate interests of Morpara, the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned. 

Based on the legal grounds of your explicit consent, for the following purposes; 

• The information you provide through the Morpara Director General, Director General Units, and Agencies, 

• Also, Morpara’s subsidiaries, support service organizations, natural and legal persons with whom it cooperates/ receives services and provides/has business relationships, companies with which we conduct activities as intermediaries/agents, correspondent/addressee banks, contracted dealers, customer interviews, applications to direct sales teams, member establishments and POS, market intelligence, scanning of judicial records, SSI records, PTT, 

• If you visit the website; the cookies contained on the website, customer satisfaction survey, job application form, and the information filled out on the Website are received by us via ‘kvkk@morpara.com’ email address,

• All kinds of systems that are opened for Morpara used by public institutions and organizations such as Identity Sharing System, Address Sharing System, Trade Registry Gazette, Land Registry and Cadastral Information System, Risk Center, Credit Registration Bureau, electronic pledge, 

• National and international authorities/institutions, 

• Opened for Morpara use by public institutions and organizations; Identity Sharing System, Address Sharing System, Trade Registry Gazette, Land Registry and Cadastral Information System, Risk Center, Credit Registration Bureau, Electronic Pledge systems, 

• Payment tools, websites, media, social media, call center, branch and representative office, • Phones, computers and cameras belonging to the Headquarters Units, 

• Registered electronic mail, electronic notification, electronic mail, mail, fax, text message, 

• All kinds of notifications, applications and interviews made to Morpara are processed by collecting them in written, verbal, electronic or other means, in whole or in part, automatically or non-automatically. 

3. THE PURPOSE OF PROCESSING YOUR DATA 

Personal data collected by Morpara in accordance with 1st and 2nd Articles of the KVKK and personal data listed in detail in Article 1 of this Enlightenment Text, may be processed in accordance with the personal data processing conditions and purposes specified in Articles 5, 6 and 8 of the KVKK and the purposes stated below by natural and legal persons including Morpara and/or its Agencies with whom Morpara cooperates with or has given authorization, and may also be transferred and stored in accordance with the 5, 6, and 8 Articles 1 of the KVKK. 

• Performance and execution of the services and business activities offered by Morpara and carrying out the necessary tasks and business processes in order to ensure that the relevant persons benefit from these services, 

• Planning and execution of operational activities necessary to ensure that Morpara services and activities are carried out in accordance with the Company's procedures and/or relevant legislation, 

• Sharing information about the services offered by Morpara, where current campaigns and payment instruments can be used, especially information that will be useful for Customers to use electronic money services more widely and effectively, 

• Ensuring the legal, technical and commercial job security of Morpara and the related persons who are in a business relationship with it, 

• Communication with the relevant persons within the scope of other contractual or commercial relations, 

• Planning and/or execution of all kinds of audit activities with information and documents requested by the BRSA, MASAK, CBRT, Revenue Administration and related public legal entities, including but not limited to them, 

• Providing information to authorized organizations based on legislation,

• Ensuring the security of the payment operations of Morpara, 

• Planning, supervision and execution of information security processes, • Creation and management of information technology infrastructure, 

• Monitoring of processes related to finance, accounting and/or billing, • Follow-up of legal processes, fulfilment of legal obligations, 

• Realization of communication and correspondence with official institutions, • Tracking of customer requests and/or complaints, 

• Follow-up of contract processes and/or legal requests, 

• Execution of customer relationship management processes, 

• Execution of the processes of managing relationships with agencies, providers and/or other business partners, 

• Planning and/or execution of access authorizations of agencies, providers and/or other business partners, 

• Planning and provision of customer satisfaction activities, 

• Ensuring that the data is accurate and up-to-date 

• Keeping of the system records related to the services provided and realization of the reports • Planning and/or execution of analyses related to business activities, 

• Planning and/or execution of occupational health and safety processes, • Ensuring business continuity planning and/or execution of activities, 

• Planning and/or execution of human resources processes and needs, 

• Managing the processes related to personnel employment, 

• Planning and/or execution of benefits and advantages for employees, 

• Planning and/or monitoring of employee performance evaluation processes, • Planning and/or execution of access authorizations of employees, 

• Ensuring the security of the company's premises, fixtures and resources, • Execution of all other operational activities that may occur.

4. THE PERSONS TO WHOM YOUR PERSONAL DATA IS TRANSFERRED AND THE PURPOSE OF THE TRANSFER 

Based on the legal reasons stipulated in Article 5 of the Law as “Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract”, “Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject”, and “it is necessary for compliance with a legal obligation which the controller is subject to”, your personal data may be transferred to the following persons; 

• In order to be able to fulfil our legal obligations; to relevant official institutions such as regulatory and supervisory institutions and court and enforcement directorates and other public institutions or organizations authorized to request your personal data, provided that it is in accordance with the law and procedure, 

• In order to fulfil your requests that you have sent to your surrogates and representatives; to your authorized proxy and agencies, 

• In order to conduct our business processes in accordance with the law and our other legitimate interests, to exercise our right to defense in a possible judicial process; to lawyers, auditors, tax consultants and other third parties for whom we receive consulting services, 

• Persons or organizations authorized by the provisions of Law No. 6493 and other legislation; • BRSA, MASAK, CBRT and related public legal entities, including but not limited to them. • Our main shareholders, 

• Our direct/indirect domestic subsidiaries, 

• To the program partner organizations that we cooperate with, where we receive services to carry out our electronic money issuance activities, 

• Upon request, the judicial authorities, or the relevant law enforcement authorities, 

• Within the scope of research conducted before and after advertising, before and after launch, to third parties providing services for this task by Morpara, provided that the explicit consent of the relevant person is obtained for this purpose, 

• The permissions required to be obtained within the scope of commercial electronic messages sent/to be sent by Morpara for marketing goods and services; to be stored in a secure environment, to be able to make approval and rejection notifications by recipients, to be able to use the right of complaint to the Message Management System, which is a subsidiary of The Union of Chambers and Commodity Exchanges of Turkey, 

• Abroad, (in compliance with your explicit consent) due to the fact that the servers used in the Morpara’s technical infrastructure for electronic mail services are located abroad, 

• Within the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK.

5. YOUR RIGHTS WITH REGARD TO YOUR PERSONAL DATA You have the following rights regarding your personal data; 

• To be informed about whether your personal data has been processed or not, • If your personal data has been processed, to request information about it, 

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

• To be informed about the third parties to whom your personal data is transferred domestically or abroad, 

• To request correction of your personal data in case of incomplete or incorrect processing, 

• To request the deletion or disposal of personal data within the framework of the conditions stipulated in Article 7 of the KVKK, 

• Pursuant to the11th Article of the KVKK, to request that the transactions made in accordance with subparagraphs(d) and (e) of the article be notified to the third partiesto whom the personal data are transferred, 

• Objecting to the occurrence of a negative consequence against you by analyzing your processed data exclusively through automated systems, 

• If you suffer damage due to the unlawful processing of your personal data, you have the right to request compensation for your damage. 

Within the scope of your specified rights, you can submit your requests by registered letter, in person, in written by notary, by registered electronic mail (KEP) address, secure electronic signature, mobile signature or by using your electronic mail address if you have an electronic mail address that you have previously notified to us and registered in our system, or by contacting us via a software or application developed for the purpose of application. Your requests will be finalized free of charge within thirty days at the latest from the date of delivery to us via the specified ways. As stated in the “Communiqué on the Principles and Procedures for Request to the Data Controller” published by the Personal Data Protection Authority in the Official Gazette dated March 10, 2018 and numbered 30356, your requests contained in your application will be answered free of charge; however, if the answer to your application is provided in a written way, 1 TL for each page on the first ten pages is charged and if the answer is provided in a recording medium such as CD, flash memory, a fee that will not exceed the cost of the recording medium may be requested by you. If your application is processed by a mistake on our part, the fee will be refunded to you. Your application will be answered in accordance with the relevant provisions provided for in the KVKK, and Morpara may be able to request some confirmatory information from you in order to confirm that the applicant is the correct person; this information will be requested only in order to determine who the real data owner is and to share the application results with the correct person.

6. CONTACT INFORMATION  

A ÖDEME VE ELEKTRONİK PARA HİZMETLERİ A.Ş. 

Data Controller: A Ödeme ve Elektronik Para Hizmetleri Anonim Şirketi Phone Number: +90 (212) 215 32 42 

E-mail: kvkk@morpara.com 

KEP (Registered Electronic Mail) Address: aodeme@hs03.kep.tr Web Address: www.aodeme.com and www.morpara.com  

Address: Esentepe Mh. Büyükdere Cd. No:127 İç Kapı No: 63 – Şişli/İSTANBUL