Denge İzmir Bağımsız Denetim ve Yeminli Mali Müşavirlik A.Ş.

General Privacy Notice Regarding the Processing of Personal Data

Denge İzmir Bağımsız Denetim ve Yeminli Mali Müşavirlik A.Ş. (“Denge”) processes certain personal data obtained through automatic or non-automatic means, verbal, written, or electronic methods within the scope of its primary activities, including independent auditing and sworn financial consultancy services, as well as activities related to its commercial operations and the management of information society services. As the data controller, Denge prioritizes the protection of the confidentiality of personal data.

Within the framework of the Regulation on the Working Procedures and Principles of Certified Public Accountants and Sworn-in Certified Public Accountants, professionals and their employees are obligated to maintain the confidentiality of information and secrets acquired during their professional activities. However, with the issuance of this notice, our aim is to ensure complete compliance with the legislation regarding the processing and protection of personal data, as a Data Controller according to Law No. 6698. Furthermore, it is our goal to safeguard all rights of personal data owners as stipulated in the legislation on personal data.

This text has been prepared by Denge to notify individuals whose personal data are processed in compliance with Law No. 6698 on the Protection of Personal Data (“Law”) and related legislation.

The Denge website currently only provides the “General Clarification Text on the Processing of Personal Data.” This general privacy notice offers general information about the data processing activities conducted for each group of data subjects whose personal data is processed by us, as outlined within the specified purposes and scopes.

Specific and detailed privacy notices concerning the processing of personal data for each group of data subjects have been prepared separately. If you wish to receive the detailed privacy notice relevant to your request, please reach out to us via email at [email protected], and we would be pleased to furnish it upon your request.

Even if users do not directly share data with us through our website and/or other communication channels, we encourage them to refer to our cookie policy for information on data that may be collected through cookies during their website visit.

Processing of Personal Data for Relevant Person Groups: Purpose and Legal Basis

1. Our Website Visitors

The IP addresses of visitors to our website are processed to categorize and analyze user data, improve the website, and enhance user experience. This processing is conducted in accordance with the Law, which states “Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract,” or, “Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.”

Our website features links to our social media accounts. By clicking on these links, users are directed to our respective social media platforms, where their personal data may be collected and processed. Please note that we do not have control over or assume responsibility for such data processing activities. We advise visitors to review the privacy statements and terms of use provided by the relevant social media organizations when accessing our social media accounts.

2. Our Customers

The personal data of our customers, and at times the personal data of individuals associated with our customers (such as employees or representatives), are processed within the scope of the services we provide and related processes. This processing is carried out for legal reasons directly linked to the establishment or performance of a contract, as outlined in accordance with the Law.

Furthermore, the personal data of our customers and associated individuals are processed for legal reasons necessitated by the protection of our legitimate interests. This processing is conducted in compliance with the Law, ensuring it does not infringe upon fundamental rights and freedoms. The purpose of such processing is to facilitate our business relations, maintain communication, and provide information about legislative developments and innovations in our field.

3. Our Business Partners

The personal data of our business partners, suppliers, their representatives, authorities, and employees are processed for legal reasons directly linked to the establishment or performance of contracts, in accordance with the Law. This processing is conducted for the purpose of concluding and fulfilling necessary contracts with our business partners and suppliers.

Additionally, the personal data of our business partners and associated individuals are processed for legal reasons pertaining to the protection of our legitimate interests, as outlined within the Law. This processing is essential for managing our business relations and establishing effective communication channels.

4. Our Prospective Customers

The personal data of prospective customers and their representatives, officials, and employees who reach out to us for services, request quotations, or whose data we acquire in compliance with legal regulations from various events and publicly available sources, along with the personal data of our execution assistant, academics, and colleagues, are processed for legal reasons aimed at protecting our legitimate interests. This processing is conducted within the framework of the Law, ensuring it does not infringe upon fundamental rights and freedoms. The primary purpose is to manage our business relations and establish effective communication channels.

5. Job Applicants

In our efforts for job application and recruitment, we process the personal data provided by job applicants through our website’s career platform, email submissions, or via third-party recruitment agencies. This data processing activity strictly adheres to legal regulations, ensuring fairness, proportionality, and fundamental principles.

The personal data of job applicants is processed to manage recruitment processes, including application review, evaluation, and other general recruitment activities. Information collected may be utilized to identify potential job opportunities suitable for the applicant’s qualifications. Additionally, we may periodically reach out to potential candidates regarding relevant job opportunities.

If provided by the job applicant, we may contact references or gather further personal information from relevant person who recommend the candidate or from publicly available sources for recruitment purposes.

In accordance with the Law, the personal data of employee candidates are processed based on the legal ground that such processing is necessary for the protection of our legitimate interests, while ensuring that fundamental rights and freedoms are preserved.

In instances where personal data processing relies on the explicit consent of the prospective employee, as stipulated by the Law, individuals reserve the right to withdraw this consent at any time, provided there is no other legal basis for processing.

Regardless of the legal basis for processing, personal data of prospective employees will be retained for a maximum period of one year. Upon expiry, data will be securely destroyed in accordance with legislative requirements.

In Case of Dispute

Personal data obtained in accordance with legislation may be utilized, to the extent necessary, for legal disputes or potential disputes involving Denge. In such cases, this data may be shared with authorized institutions and organizations. Within this context, personal data may be processed without explicit consent as required by law, for the purpose of fulfilling Denge’s legal obligations and safeguarding Denge’s rights.

Transfer of Personal Data

To achieve the stated purposes of processing personal data, Denge may share your personal data with domestic third parties and authorized public institutions solely for the realization of these purposes, while taking the utmost measures required by confidentiality and legislation.

Our computer systems and infrastructures are maintained on an in-house server, with adequate technical measures in place to safeguard your personal data. There is no transfer of your personal data abroad. However, it should be noted that communication activities conducted through foreign applications may result in the transfer of personal data abroad, as the application servers of foreign origin are located overseas.

Collection of Personal Data

Your personal data is collected verbally, in writing, or electronically, through documents and information that you transmit to us electronically or physically, via automated or non-automated means.

What Are Your Rights Regarding Your Personal Data?

In accordance with Article 11 of the Law, data subjects possess the following rights:

• To ascertain whether your personal data is being processed and to request information concerning the processing thereof,
• To comprehend the purpose of processing your personal data and whether it is being utilized accordingly,
• To identify the third parties to whom your personal data is transferred,
• To request the rectification of your personal data in cases of incomplete or incorrect processing, and to request that such rectification be communicated to third parties to whom your personal data has been disclosed, should you exercise this right,
• To request the erasure or destruction of your personal data in the event that the reasons for its processing cease to exist, and to request that such erasure or destruction be communicated to third parties to whom your personal data has been disclosed, should you exercise this right,
• To object to decisions made about you based on the analysis of information obtained through automated systems, and to seek compensation if you suffer damages.

As Denge, without prejudice to our obligations arising from legislation, we assure you that you can exercise your rights at any time and in the manner that best suits you. You can contact us via the provided contact information below to exercise your rights or to obtain more detailed information, such as specific and detailed disclosure texts, policies, and others.

Denge İzmir Bağımsız Denetim ve Yeminli Mali Müşavirlik A.Ş.

1456 Sokak Punta İş Merkezi No:10/1 Kat:13 Alsancak/İZMİR

Tel: 0 (232) 421 26 00

Faks: 0 (232) 421 26 01

E-Mail: [email protected]