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Privacy Policy

The general framework for how we handle your information.

This is a translation provided for convenience. In case of any discrepancy, the Turkish version of this document prevails.

We, Gökkuşağı Yazılım ve Danışmanlık (the “Company”), take the security of your personal data and our legal responsibilities in this regard extremely seriously. For this reason, pursuant to Law No. 6698 on the Protection of Personal Data (the “KVKK”), we attach great importance to the processing and protection of the personal data of all natural persons who have a relationship with our Company.

I. About the Policy

The purpose of this Policy is to explain the rights that the Data Subject holds under both the KVKK and the applicable secondary legislation in force, in order to protect the fundamental rights and freedoms of natural persons — in particular the privacy of personal life — in the processing and transfer of personal data belonging to natural persons with whom our Company establishes a relationship in the course of its commercial activities.

This Policy further aims to explain the purposes and legal grounds for processing personal data, together with the methods of transfer and collection, within the scope of Law No. 6698 on the Protection of Personal Data and the relevant secondary legislation.

Our Company reserves the right to amend its Personal Data Processing Purposes, Legal Grounds, Data Collection and Transfer Methods, and its Personal Data Protection and Processing Policy.

Should this Policy be amended — for example, but not limited to, in order to meet newly enacted legal requirements — the most current version of the relevant text will be published on our website.

II. Definitions

The definitions and terms used in this Policy shall have the meanings ascribed to them in Law No. 6698 on the Protection of Personal Data and in the relevant secondary legislation issued thereunder. In this context:

  • Explicit Consent: consent relating to a specific matter, based on information and declared with free will,
  • Data Subject: the natural person whose personal data is processed,
  • Personal Data: any information relating to an identified or identifiable natural person,
  • Processing of Personal Data: any operation performed on data such as obtaining, recording, storing, retaining, altering, reorganising, disclosing, transferring, taking over, making obtainable, classifying or preventing the use of personal data, wholly or partly by automated means, or by non-automated means provided that it forms part of a data filing system,
  • Data Processor: the natural or legal person who processes personal data on behalf of the data controller, based on the authority granted by the controller,
  • Data Controller: the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data filing system.

III. Data Subjects

The Company may collect or process personal data from the following persons:

  • Our customers, shareholders, suppliers, business contacts and potential customers (and / or the natural persons associated with them) and our other business partners;
  • Natural Persons whose personal data we obtain within the scope of the professional services we provide to our customers (for example, our customers’ employees, customers and suppliers, our customers’ contact persons at public institutions, and the Data Subject’s other references);
  • Our employees, former employees, our employees’ family members and job applicants;
  • Visitors to our website and our social media accounts.

IV. Data Controller

The Company, acting in the capacity of Data Controller, may process, record, retain and reorganise your personal data, and may transfer it domestically or abroad, to the extent permitted by the KVKK and within the scope of our commercial or business relationships — also seeking the Data Subject’s consent where explicit consent is required.

V. Personal Data Collection Methods and Legal Basis

We may collect or obtain personal data because you provide it to us, or because third parties provide that data to us (for example, our customers may give us information about their employees, customers or other Data Subjects whose personal data they collect, or about the Data Subject’s other references; public institutions or third-party service providers from whom we receive support in fulfilling our contractual obligations may supply such data); or because you connect to our Wi-Fi network, through our website or social media accounts, or because it is publicly available.

Due to the fulfilment of legal requirements, the performance of our contractual obligations, our Company’s legitimate interests and the other purposes and grounds set out in detail below, we may collect the personal data we request from you or that you choose to share with us directly, by automated or non-automated methods and sources, and retain it for the periods permitted by law:

  • Meetings between all service units of our Company and you;
  • Applications made to our Company verbally, in writing or electronically;
  • Affiliates, subsidiaries and third-party persons and organisations with which we have a close relationship;
  • Meetings and congresses;
  • Public institutions;
  • Third-party service providers we use to conduct our Company’s activities;
  • Applications made over the internet, SMS channels, social media;
  • Other companies from which support services are received;
  • Natural and / or legal persons with whom we transact under any legislation or contract;
  • Records shared with the PTT, the SGK and insurance companies within the scope of private health insurance;
  • Publicly available information.

In addition, if you use our website and give your consent, we also collect your personal data through the cookies on our website in accordance with our Cookie Policy (see Section XI “Cookie Policy”).

VI. Personal Data Processed

The personal data collected and processed by our Company may vary according to your commercial and legal relationship with our Company.

That said, we may indicate the following data categorisation by way of example: your identity information, contact information, financial information, special categories of personal data, educational and visual data, and data concerning your family members may be processed within the framework of the purpose requiring such processing, in a manner connected with, limited to and proportionate to that purpose, kept up to date where necessary, and in accordance with the conditions set out in Articles 5 and 6 of Law No. 6698:

Identity Information

Name, surname, date of birth, age, country of birth, city of birth, gender, marital status, nationality, Turkish ID card details, previous surname, ID photocopy, etc.

Contact Information

Telephone number, full address, e-mail address, Company telephone number, extension, Company e-mail address, social media account contact details, etc.

Special Categories of Personal Data

Where obtained, information qualifying as special categories of personal data under the definition in Law No. 6698. In certain services or activities, in line with our legal obligations or with the explicit consent of the data subject, we may also collect special categories of personal data.

Visual and Audio Data

Photographs, images, camera recordings, voice recordings, etc.

Financial Information

Invoices showing the financial outcome of transactions carried out by the data subject, credit card debt, interest rate, tax amount, debts and outstanding receivables, IBAN details, other account details, etc.

Electronic Data

Membership records, internet passwords, IP address, transaction security information, log records, etc.

Customer Information

The customer’s requests, orders, instructions, complaints, product basket, preferences, cookie records, customer number, occupation, educational background, etc.

Marketing Information

Statistical, evaluation and reporting activities carried out in line with the data subject’s preferences and areas of interest, surveys, customer satisfaction forms, and data obtained within the scope of promotional and marketing activities, etc.

Legal Records

Data contained in court or administrative authority decisions and enforcement office documents.

Security Information

Workplace entry-exit records, meeting records, visit times and details, camera recordings, etc.

Candidate Information

CV, interview notes, test results, habits, etc.

Other Data

Records and documents required to be submitted within the scope of audit activities, etc.

VII. Purposes of Processing Personal Data

The Company may process personal data for the following purposes, subject to the statutory periods:

A. Fulfilment of Our Legal Requirements

  • Complying with any statutory provision, legislation or the professional body of which we are a member;
  • Like all other professional service providers, we are subject to laws, regulations and professional obligations. We are required to keep certain records to demonstrate that our services are provided in accordance with these obligations, and those records may contain personal data.
  • Complying with the orders of judicial, administrative and legal authorities and enforcement offices;
  • Conducting audit services for the Company.

B. Performance of Our Contractual Obligations

Providing the broad range of professional services we offer. We process personal data in order to provide these products and services to our (potential) customers, being the Data Subject personally, the Data Subject’s employer, or a party with whom the Data Subject has entered into a contract.

C. Our Company’s Legitimate Interests

  • The management, administration and development of our activities and services;
  • We process personal data in order to manage our relationship with our customers, fulfil our administrative, accounting and corporate obligations, send service proposals containing our employees’ identity details to potential customers, maintain and use our IT systems, develop our business and services, host various events, manage our systems and applications, and conduct our business including the headings below;
  • Processing personal data relating to our suppliers and subcontractors and the natural persons associated with them, in order to manage the relationship, manage the contract, receive services from our suppliers and, where necessary, provide professional services to our customers;
  • Ensuring that personal data is kept up to date;
  • Protecting our own information and that of our customers, and providing security, quality and risk management within the scope of internal quality and risk analysis;
  • Evaluating customer satisfaction and service quality;
  • Communicating for the purposes of celebration and congratulation;
  • Conducting processes and transactions, software, ERP, CRM, financial record operations, communications, market research and procurement activities (request, quotation, evaluation, order, budgeting, contracts) in order to determine and implement the Company’s business strategies.

D. Establishing the Legal and Commercial Security of Persons in a Business Relationship with Our Company

  • Fulfilling our obligation to provide information to authorised bodies arising from legislation;
  • Carrying out legal proceedings;
  • Identity checks of visitors for the purposes of security and the issue of visitor cards.

E. Communication and Communication-Related Operations

  • Communicating with data subjects;
  • Ensuring that data subjects’ data is kept up to date.

F. Conducting Human Resources Policies

  • Collecting data for recruitment purposes, which includes CVs sent to the Human Resources Department by e-mail or through various social media channels;
  • Completing the recruitment process;
  • Evaluating potential candidates;
  • Carrying out human resources activities in accordance with Human Resources policies and fulfilling obligations within the framework of Occupational Health and Safety;
  • Fulfilling our obligations (towards company employees) arising from employment contracts and / or legislation.

G. Entrepreneurship, Sustainability, Social Responsibility, Innovation, Confidentiality, Risk Monitoring, Modelling, Reporting, Scoring, Security and Evaluation Activities

  • Evaluating, planning and conducting sales and marketing activities relating to our products and services;
  • Implementing our sustainability efforts;
  • Diversifying the range of services within our Company;
  • Improving customer relationship management;
  • Planning and conducting sustainability and social responsibility projects.

H. Direct Marketing

Promoting and developing our services, presenting information we believe may be of interest to you, and sending invitations to our events.

VIII. Transfer of Personal Data

In order for our Company to fulfil its obligations arising from the relevant legislation — including but not limited to the Code of Obligations, the Commercial Code, the Tax Procedure Law, the Identity Notification Law and the Law on the Protection of Personal Data — your personal data may be transferred to third parties within the framework of the applicable statutory provisions and on the basis of the conditions set out in Articles 8 and 9 of the KVKK.

Under the conditions set out in Articles 5 and 6 of the KVKK, it is possible to transfer data without obtaining explicit consent. Provided that it complies with the KVKK and other relevant legislation, Gökkuşağı Yazılım ve Danışmanlık may transfer personal data to third parties in Türkiye and to Group companies, taking all security measures specified in the regulations and — unless there is a provision to the contrary in the law, the relevant legislation or any contract signed with the Data Controller — also seeking the data subject’s consent where required.

In addition — seeking your consent where explicit consent is required — we may transfer your personal data to companies and manufacturers, by transferring security camera recordings in order to ensure the confidentiality, accessibility, integrity and resilience of the hardware and software of data processing equipment or to protect our company’s physical security, as well as to intermediary service providers such as telecommunications services, postal / shipping services, maintenance and user support services, data carriers and IT system maintenance companies; and, where necessary for administrative purposes or in order to provide professional services to our customers, to other member firms of Gökkuşağı Yazılım ve Danışmanlık (for example when providing services involving Gökkuşağı Yazılım ve Danışmanlık member companies in different countries); or during visitor / employee entry-exit controls in the fields of building management, legal services and legal support.

Your personal data may be transferred abroad only where your explicit consent exists or, where your explicit consent does not exist, within the framework prescribed by the Law — where adequate protection is available in the country of transfer as determined by the Personal Data Protection Board. Where adequate protection is not available, the transfer may be carried out provided that our Company and the Data Controller in the relevant foreign country undertake in writing to provide adequate protection and the Board’s permission is obtained in this regard. When we transfer your information, we ensure adequate protection for the transfer of your personal information to recipients in those countries by signing data transfer agreements based on provisions meeting KVKK standards with the relevant recipients.

IX. Retention of Processed Data

We will keep your personal data in our systems for the longest of the following periods:

  • (i) the period necessary for the purpose for which it was collected;
  • (ii) any requirement or retention period required by law; or
  • (iii) the expiry of the limitation period during which proceedings or investigations arising from our services may be brought.

Once the relevant retention periods expire, personal data will be destroyed or anonymised.

X. Data Security

Pursuant to Article 12 of the KVKK, we ensure that appropriate technological and organisational controls are carried out in order to protect your personal data against loss, misuse, alteration or inadvertent destruction.

Our personnel who have access to your personal data have been trained to protect the confidentiality of this information. They are permitted to access your personal data only to the extent that they need this information in order to perform their duties properly. Persons who may access your data are also subject to strict professional confidentiality rules.

Our security defence measures are regularly monitored and tested to ensure they remain effective against the latest threats. For details of the technical and organisational measures we apply, see our Information Security page.

XI. Cookie Policy

Browsing our website may result in cookies being sent to your computer. Cookies are small text files placed on your computer by the websites you visit. For further information, please review our Cookie Policy.

XII. Your Rights

Pursuant to Law No. 6698 on the Protection of Personal Data, by applying to the Data Controller you may exercise the following rights:

  • To learn whether your personal data is processed,
  • To request information if your personal data has been processed,
  • To learn the purpose of processing your personal data and whether the data is used in accordance with that purpose,
  • To know the third parties to whom personal data is transferred domestically or abroad,
  • To request the rectification of personal data if it has been processed incompletely or inaccurately,
  • To request the erasure or destruction of personal data within the framework of the conditions set out in Article 7 of the Law; to request that rectification, erasure, destruction or anonymisation operations be notified to the third parties to whom the personal data has been transferred; to object to an outcome arising against you as a result of the analysis and processing of your data exclusively by automated systems; and to request compensation for damages where you suffer loss due to the unlawful processing of personal data.

Pursuant to the KVKK or the provisions of the relevant secondary legislation, the Company will handle all of your applications concerning your rights as a Data Subject. If you wish to exercise any of your rights as a Data Subject, please contact us at satis@jetcp.com.tr with the subject line “Personal Data Application Request Form”; when doing so, please use the e-mail address you have previously notified to us and which is currently registered in our system, or use your electronic or mobile signature as defined under Electronic Signature Law No. 5070. For details of the application routes and time limits, see our KVKK page.

XIII. Children and Our Website

The Company is particularly aware of the importance of protecting children’s privacy in the online environment. Our sites are not designed for children. Our policy is not to knowingly collect or retain information about anyone under the age of 18 through our websites. If you are under 18, you must obtain the consent of a parent or guardian in order to send information through our website. Please ask them to review this information before contacting us.

Contact

  • E-mail: satis@jetcp.com.tr
  • Phone: 0541 763 98 57
  • Address: Gökkuşağı Yazılım ve Danışmanlık, İçerenköy Mah. Eryılmazlar Sk. No:2 Kemal Bey İş Merkezi Kat:4 Daire:18 Ataşehir/İstanbul

Policy version and last updated: V.1.2 – April 2026