Privacy Policy

Informational Text Regarding Processing of Personal Data

Data Controller : SAG Veri Teknolojileri A.Ş.

Levazım Mah. Yazgülü Sok. No: B1/1 Beşiktaş, 34340 İstanbul

We, SAG Veri Teknolojileri A.Ş. (“Sanction Trace” or “company”); care about protection the personal data of our business partners and the people who visit our website. In this context, we would like to enlighten you within the scope of Law No. 6698 on the Protection of Personal Data (“KVKK”).

This informational text regarding processing of personal data (“informational text”) will be valid as of the date it is published by company. Informational text can always be changed by company if necessary. Informational text regarding processing of personal data of the employees and interns of company has been published in intranet.

Detailed information about cookies can be checked via Cookie Policy Personal data processed through cookies are explained in this informational text.

CUSTOMERS / CUSTOMERS’ REPRESENTATIVES

ID INFORMATION
Personal Data Processed	Purpose of Processing
· Name · Surname · ID Number/Tax ID Number · Signature/Signature Circulars	Execution of finance and accounting, goods/services sales and contract processes. Execution of activities align with the legislation.
Legal Reason of Collection
KVKK article 5/2-a “it is expressly provided for by the laws” KVKK article 5/2-c “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” KVKK article 5/2-ç “it is necessary for compliance with a legal obligation to which the data controller is subject”
The Methods of Collection
The above – mentioned personal data have been collected through business cards, contracts, face-to-face or online meetings and electronic forms.
CONTACT INFORMATION
Personal Data Processed	Purpose of Processing
· Address · E-mail Address · Phone Number	Execution of finance and accounting, goods/services sales and contract processes.
Legal Reason of Collection
KVKK article 5/2-a “it is expressly provided for by the laws” KVKK article 5/2-c “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”
The Methods of Collection
The above – mentioned personal data have been collected through business cards, contracts and electronic forms.
LEGAL TRANSACTION INFORMATION
Personal Data Processed	Purpose of Processing
· Contracts · Case / Execution Files · Correspondence with Judicial / Administrative Authorities	Execution of activities align with the legislation. Monitoring and execution of legal affairs. Execution of goods/services sales and contract processes. Providing information to authorized persons, institutions and organizations.
Legal Reason of Collection
KVKK article 5/2-a “it is expressly provided for by the laws” KVKK article 5/2-c “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” KVKK article 5/2-ç “it is necessary for compliance with a legal obligation to which the data controller is subject”
The Methods of Collection
The above – mentioned personal data have been collected through contracts and official letters and electronic documents from judicial and administrative authorities.
CUSTOMER TRANSACTION INFORMATION
Personal Data Processed	Purpose of Processing
· Invoice Details · Order and Request Information · Current Account Information · Bank Account Information	Execution of activities align with the legislation. Execution of finance and accounting, goods/services sales. Providing information to authorized persons, institutions and organizations.
Legal Reason of Collection
KVKK article 5/2-a “it is expressly provided for by the laws” KVKK article 5/2-ç “it is necessary for compliance with a legal obligation to which the data controller is subject”
The Methods of Collection
The above – mentioned personal data have been collected through printed / electronic documents, invoices, e-mails and ERP/CRM programs.
Transfer of Personal Data
By taking necessary technical and organizational measures, the personal data of customers/customers’ representatives can be transferred to authorized persons, institutions and organizations align with legislation in order to fulfill our obligations and can be recorded in our programs and systems that are provided by our infrastructure suppliers in the field of technology.

POTENTIAL CUSTOMERS / POTENTIAL CUSTOMERS’ REPRESENTATIVES

ID INFORMATION
Personal Data Processed	Purpose of Processing
· Name · Surname	Execution of communication activities. Execution of contract offer and negotiation processes.
Legal Reason of Collection
KVKK article 5/2-c “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” KVKK article 5/2-f “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”
The Methods of Collection
The above – mentioned personal data have been collected during participation in a meeting or an event and / or via printed / electronic forms.
CONTACT INFORMATION
Personal Data Processed	Purpose of Processing
· E-mail Address · Phone Number	Execution of communication activities. Execution of contract offer and negotiation processes.
Legal Reason of Collection
KVKK article 5/2-c “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” KVKK article 5/2-f “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”
The Methods of Collection
The above – mentioned personal data have been collected during participation in a meeting or an event and / or via printed / electronic forms.
MARKETING INFORMATION
Personal Data Processed	Purpose of Processing
·Information obtained through marketing activities	Execution of marketing processes of goods/services. Execution of marketing analysis activities.
Legal Reason of Collection
KVKK article 5/1 “explicit consent of data subject”
The Methods of Collection
The above – mentioned personal data have been collected through marketing activities.
Transfer of Personal Data
By taking necessary technical and organizational measures, the personal data of potential customers/ potential customers’ representatives can be transferred to authorized persons, institutions and organizations (when they demand) align with legislation in order to fulfill our obligations and can be recorded in our programs and systems that are provided by our infrastructure suppliers in the field of technology.

WEBSITE VISITORS

ID INFORMATION
Personal Data Processed	Purpose of Processing
· Name / Surname	Execution of newsletter subscribing processes.
Legal Reason of Collection
KVKK article 5/1 “explicit consent of data subject”
The Methods of Collection
The above – mentioned personal data have been collected through newsletter form.
CONTACT INFORMATION
Personal Data Processed	Purpose of Processing
· E-mail Address	Execution of newsletter subscribing processes.
Legal Reason of Collection
KVKK article 5/1 “explicit consent of data subject”
The Methods of Collection
The above – mentioned personal data have been collected through newsletter form.
MARKETING INFORMATION
Personal Data Processed	Purpose of Processing
· Cookie Records	Execution of marketing processes.
Legal Reason of Collection
KVKK article 5/1 “explicit consent of data subject”
The Methods of Collection
The above – mentioned personal data have been collected through cookies.
TRANSACTION SECURITY INFORMATION
Personal Data Processed	Purpose of Processing
· IP Address · Website Login/Logout Information	Execution of information security processes. Execution of activities align with the legislation. Providing information to authorized persons, institutions and organizations.
Legal Reason of Collection
KVKK article 5/2-a “it is expressly provided for by the laws” KVKK article 5/2-ç “it is necessary for compliance with a legal obligation to which the data controller is subject” KVKK article 5/2-f “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”
The Methods of Collection
The above – mentioned personal data have been collected through internet applications, information systems and electronic devices (telecommunications infrastructure, computers, mobile devices etc.)
Transfer of Personal Data
By taking necessary technical and organizational measures, the personal data of website visitors can be transferred to authorized persons, institutions and organizations align with legislation in order to fulfill our obligations and can be recorded in our programs and systems that are provided by our infrastructure suppliers in the field of technology.

STORAGE of PERSONAL DATA

If a period is specified in the legislation for the storage of personal data, it must be kept for at least this period. If a period for storage of personal data has not been regulated in the legislation, personal data has been stored for reasonable periods determined being relevant with, limited to and proportionate to the purposes of processing.

THE RIGHTS of DATA SUBJECT

a) to learn whether his personal data are processed or not,

b) to request information if his personal data are processed,

c) to learn the purpose of his data processing and whether this data is used for intended purposes,

ç) to know the third parties to whom his personal data is transferred at home or abroad,

d) to request the rectification of the incomplete or inaccurate data, if any,

e) to request the erasure or destruction of his personal data under the conditions laid down in Article 7 of KVKK

f) to request notification of the operations carried out in compliance with subparagraphs (d) and (e) to third parties to whom his personal data has been transferred,

g) to object to the processing, exclusively by automatic means, of his personal data, which leads to an unfavorable consequence for the data subject,

ğ) to request compensation for the damage arising from the unlawful processing of his personal data.

METHODS of APPLICATION REGARDING THE RIGHTS of DATA SUBJECT

Data subjects can apply our company via,

Using application form and sending it to our address with a wet signature and a copy of the ID
Applying personally with a valid ID
By sending an e-mail from your e-mail address which is previously notified to our company and registered in our system.

In the evaluation of the applications, the provisions of the “Notification on the Procedures and Principles of Application to the Data Controller” shall be applied.

In the application to be made, the request must be clear and the documents related to the application must be attached to the application.

If the application is made on behalf of someone else, the applicant must be specifically authorized in this regard and be documented.

Your claims regarding your personal data are answered within 30 days at the latest from date they reach our company.

Türkçe Versiyon için Tıklayınız

Method	Channel / Address	Information to be Specified
In-person	Levazım Mah. Yazgülü Sok. No: B1/1 Beşiktaş, 34340 İstanbul	“Information Request Under the Law on Protection of Personal Data” shall be written on the application form or petition.
By post/notary	Levazım Mah. Yazgülü Sok. No: B1/1 Beşiktaş, 34340 İstanbul	“Information Request Under the Law on Protection of Personal Data” shall be written on the envelope
Via e-mail (previously notified to our company and registered in our company’s system)	info@sanctiontrace.com	“Information Request Under the Law on Protection of Personal Data” shall be written in the subject.

Name
Surname
ID Number
Phone Number
E – Mail
Address
Address

Applicant Name / Surname
Date
Signature