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Legal

KVKK Privacy Notice

This “Privacy Notice on the Protection and Processing of the Personal Data of Netsipp Users” has been prepared in order to fulfil the disclosure obligation pursuant to Article 10 of Law No. 6698 on the Protection of Personal Data (the “Law”) and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Disclosure Obligation, in relation to the processing of your personal data shared by the Customer benefiting from our service or by the User who uses Netsipp on behalf of the Customer, or obtained directly by Netgsm İletişim ve Bilgi Teknolojileri A.Ş. (the “Company” or “NETGSM”), whose identity is set out below. The company that receives the Netsipp service is referred to as the “Customer”; the persons who use Netsipp on behalf of the Customer are referred to as the “User”.

Last updated: August 2026
1

Purpose and Identity of the Data Controller

Personal data obtained by NETGSM, whose registered address is Batı Blv. A.T.B. İş Merkezi G Blok No:194 Yenimahalle / ANKARA, is processed by NETGSM in its capacity as data controller, and the personal data that the User has provided to the Customer is processed by NETGSM in its capacity as data processor. Pursuant to the Law, your personal data may be processed within the framework of the purposes listed below, in a manner connected, limited and proportionate to those purposes, in the form in which it reaches us, by automated means, while preserving the accuracy and currency of the personal data, and to the extent explained below.

Trade NameNETGSM İLETİŞİM VE BİLGİ TEKNOLOJİLERİ A.Ş.

AddressBatı Blv. A.T.B. İş Merkezi G Blok No:194 Yenimahalle/ANKARA

Phone Number0850 303 0 303

E-mail Address[email protected]

Registered Electronic Mail (KEP)[email protected]

2

Purposes of Processing Personal Data

Within the scope of our Company's activities, the personal data that the User has shared with the Customer in relation to the service provided to the Customer, or that is collected by the Company through automated means, may be processed by the Company for the purposes explained below, in accordance with the fundamental principles set out in the Law and within the personal data processing conditions specified in Articles 5 and 6 of the Law. In addition, subject to your explicit consent, your data will also be processed for the purposes of direct marketing, online behavioural advertising and location-based advertising carried out on the basis of profiles created by making use of the information you have shared with NETGSM as well as information obtained by tracking behaviour such as third-party pages viewed and links and advertisements clicked through the use of tracking technologies (cookies, web beacons, etc.); the details are set out in the Cookie Policy available at https://netsipp.com.

The personal data processed within the scope of this Privacy Notice, the purposes of processing and the personal data categories are explained in detail in the table below.

Personal Data CategoryPersonal Data ProcessedPurpose of Processing
Identity DataFull name, Turkish ID number (T.C. Kimlik No), job title
  • Responding to demo, price quotation, contact form or sales meeting requests
  • Where you subscribe to the e-newsletter and marketing communications, sending content based on your past preferences
  • Managing event/webinar registrations
  • Setting up the account on the Netsipp panel, defining users/administrators, identity verification (including 2FA)
  • Providing functions such as cloud PBX, call routing, IVR, call recordings, messaging/SMS, live chat and reporting
  • Carrying out subscription fees, usage-based charges and payment transactions
  • Managing support requests, fault records and complaints
  • Determining/verifying the identity of the customer and of the ultimate beneficial owner and carrying out risk assessment within the scope of electronic communications legislation
Contact DataTelephone number, e-mail address
  • Responding to demo, price quotation, contact form or sales meeting requests
  • Where you subscribe to the e-newsletter and marketing communications, sending content based on your past preferences
  • Managing event/webinar registrations
  • Setting up the account on the Netsipp panel, defining users/administrators, identity verification (including 2FA)
  • Providing functions such as cloud PBX, call routing, IVR, call recordings, messaging/SMS, live chat and reporting
  • Carrying out subscription fees, usage-based charges and payment transactions
  • Managing support requests, fault records and complaints
  • Determining/verifying the identity of the customer and of the ultimate beneficial owner and carrying out risk assessment within the scope of electronic communications legislation
Transaction Security DataIP address, session and access logs, device/browser information, cookie records
  • Detecting/preventing fraud, unauthorised access and misuse, and keeping log records
  • Carrying out information security processes
  • Carrying out marketing activities
  • Carrying out product promotion processes
  • Carrying out advertising activities
  • Carrying out goods/service sales processes
  • Carrying out customer relationship management processes
  • Carrying out activities aimed at customer satisfaction
  • Carrying out / auditing business activities and ensuring their continuity
  • Carrying out contract processes
  • Following up requests / complaints
User Transaction DataAccount configuration data, call detail/recording records (CDR), called/calling number, call duration and status, voice recordings (if enabled)Providing functions such as cloud PBX, call routing, IVR, call recordings, messaging/SMS, live chat and reporting.
3

Parties to Whom Your Personal Data Is Transferred and Purposes of Transfer

Your collected personal data may be transferred to third parties within the scope of the purposes stated below, in accordance with the fundamental principles set out in Law No. 6698 and within the conditions specified in Articles 8 and 9 of the Law.

Personal Data CategoryPersonal Data ProcessedDomestic TransferTransfer Abroad
Identity DataFull name, Turkish ID number (T.C. Kimlik No), job titleThe Customer and, upon request, judicial authoritiesNo transfer abroad is carried out.
Contact DataTelephone number, e-mail addressThe Customer and, upon request, judicial authoritiesNo transfer abroad is carried out.
Transaction Security DataIP address, session and access logs, device/browser information, cookie recordsThe Customer and, upon request, judicial authoritiesNo transfer abroad is carried out.
User Transaction DataAccount configuration data, call detail/recording records (CDR), called/calling number, call duration and status, voice recordings (if enabled)The Customer and, upon request, judicial authoritiesNo transfer abroad is carried out.
4

Method of Collection and Legal Grounds of Your Personal Data

Your personal data is obtained and processed by your Employer and by NETGSM on the basis of the conditions set out in Articles 5 and 6 of the Law and, in the absence of any of those conditions, within the scope of your explicit consent.

Personal Data CategoryPersonal Data ProcessedMethod of CollectionLegal Ground
Identity DataFull name, Turkish ID number (T.C. Kimlik No), job titleShared by the Customer and the User.
  • Article 5/1: Explicit consent
  • Article 5/2 (c): Necessary for the establishment or performance of a contract
  • Article 5/2 (ç): Mandatory in order for the data controller to fulfil its legal obligations
  • Article 5/2 (e): Data processing is mandatory for the establishment, exercise or protection of a right
  • Article 5/2 (f): Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject
Contact DataTelephone number, e-mail addressShared by the Customer and the User.
  • Article 5/1: Explicit consent
  • Article 5/2 (c): Necessary for the establishment or performance of a contract
  • Article 5/2 (ç): Mandatory in order for the data controller to fulfil its legal obligations
  • Article 5/2 (e): Data processing is mandatory for the establishment, exercise or protection of a right
  • Article 5/2 (f): Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject
Transaction Security DataIP address, session and access logs, device/browser information, cookie recordsShared by the Customer and the User.
  • Article 5/1: Explicit consent
  • Article 5/2 (c): Necessary for the establishment or performance of a contract
  • Article 5/2 (ç): Mandatory in order for the data controller to fulfil its legal obligations
  • Article 5/2 (e): Data processing is mandatory for the establishment, exercise or protection of a right
  • Article 5/2 (f): Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject
User Transaction DataAccount configuration data, call detail/recording records (CDR), called/calling number, call duration and status, voice recordings (if enabled)Arises during use of the Service.
  • Article 5/1: Explicit consent
  • Article 5/2 (ç): Mandatory in order for the data controller to fulfil its legal obligations
  • Article 5/2 (e): Data processing is mandatory for the establishment, exercise or protection of a right
  • Article 5/2 (f): Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject
5

Retention Period of the Data

Your personal data is retained for as long as required by the purpose for which it is processed and for as long as the relevant legal ground continues to exist:

  • Data based on the performance of a contract is retained for the duration of the contractual relationship and throughout the relevant statutes of limitation.
  • Data based on a legal obligation (e.g. tax/accounting records, traffic records within the scope of Law No. 5651) is retained for the minimum retention periods prescribed in the relevant legislation.
  • Data based on a legitimate interest is retained for as long as the relevant legitimate interest continues to exist.
  • Data based on explicit consent is deleted if you withdraw your consent. Withdrawal of consent does not affect the lawfulness of processing carried out up to the moment of withdrawal. Where the same data is also processed on another legal ground, your withdrawal of consent may not mean that the data is deleted entirely.

Data whose retention period has expired is deleted, destroyed or anonymised in accordance with the personal data retention and destruction policy.

6

Your Rights as a Personal Data Owner and the Exercise of These Rights

Pursuant to Article 11 of the Law, and without prejudice to the exceptions set out in Article 28 thereof, we hereby inform you that as data owners you have the following rights:

  • to learn whether your personal data is being processed,
  • to request information if your personal data has been processed,
  • to learn the purpose of processing your personal data and whether it is used in accordance with that purpose,
  • to know the third parties in Türkiye or abroad to whom your personal data is transferred,
  • to request the rectification of your personal data if it has been processed incompletely or inaccurately, and to request that the action taken in this respect be notified to the third parties to whom your personal data has been transferred,
  • to request the erasure or destruction of your personal data where the reasons requiring its processing have ceased to exist, even though it has been processed in accordance with the Law and other relevant statutory provisions, and to request that the action taken in this respect be notified to the third parties to whom your personal data has been transferred,
  • to object where a result to your detriment arises from the analysis of the processed data exclusively by automated systems,
  • to request compensation for the damage in the event that you suffer damage due to the unlawful processing of your personal data.

With regard to your requests concerning the rights listed above, for the personal data you have shared with NETGSM in its capacity as data controller, you may submit your request petition containing the minimum requirements set out in the Communiqué on the Procedures and Principles of Application to the Data Controller in writing and bearing your wet signature by delivering it in person to Batı Blv. A.T.B. İş Merkezi G Blok No:194 Yenimahalle/ANKARA, where the head office of NETGSM is located, by sending it through a notary public, by sending it with an electronic signature via the registered electronic mail (KEP) address [email protected] belonging to NETGSM, or, if your e-mail address is registered in NETGSM's systems, by submitting it to NETGSM via the e-mail address [email protected]. Since NETGSM acts in the capacity of data processor in respect of the processing of the personal data you have shared with your Employer, you must contact your Employer in order to have such data deleted.

7

Changes to This Notice and Language

Netgsm may update and amend this Notice from time to time. In the event of a material change, we will publish the updated text on our website and/or through other channels we deem appropriate; we may also inform you by e-mail or by other means.

The Turkish version of this Notice prevails. Where translated versions are provided, in the event of any inconsistency between a translated version and the Turkish version, the Turkish version shall apply.

The Turkish version of this Notice prevails; in the event of any inconsistency between the translated versions and the Turkish version, the Turkish version shall apply.

Data controller: NETGSM İLETİŞİM VE BİLGİ TEKNOLOJİLERİ A.Ş., Batı Blv. A.T.B. İş Merkezi G Blok No:194 Yenimahalle/ANKARA. For requests relating to your personal data you may contact us at [email protected], via the registered electronic mail (KEP) address [email protected], or by telephone on 0850 303 0 303.