Hereby the clarification text has been prepared to inform you about your rights as the data owner by Netcad Yazilim A.S ("Netcad") whose corporate office address is BilkentCyber Plaza, B Blok, No:409 Cyberpark 06800 Cankaya, Ankara, as the data controller regarding the use of personal data obtained from the relevant person in relation to the www.netcad.com.tr website ("Website") and e-mail, pursuant to the Article 10 titled "Obligation of Disclosure of Data Controller" of the Personal Data Protection Law No.6698 ("KVKK") and further pursuant to the Article 11 titled "Rights of the Related Person", within the framework of processing purposes of your personal data to whom and for what purposes your processed data can be transferred and of the method of data collection and its legal reason.
The following terms hereinafter will refer to the below definitions:
Netcad endeavors to process your personal data by storing them within the conditions and purposes required for the purpose for which they are processed or stipulated in the relevant legislation, within the scope of the processing conditions and purposes specified in the KVKK, in accordance with the law and the rules of honesty, by maintaining the accuracy and the most up-to-date state of your personal data, for specific, clear and lawful purposes, in a limited and measured manner, and performs audits for this purpose.
Your name and surname, e-mail address and your communication subject explanations are processed by us in the event that you want to contact us on the Netcad web page; and in case that you want to benefit from support services, your user name and password are processed by us within the framework of your previously created membership.
Your personal data is processed by Netcad for the purposes of company management and representation, managing human resources processes, concluding contracts with customers and suppliers within the framework of company activities and fulfilling obligations arising from contracts, providing and developing our products and services, solving systemic problems, providing technical support, providing communication limited to the activity purposes, ensuring the fulfillment of legal obligations as obliged or required by legal regulations, fulfilling the obligation to provide the necessary information in line with the demands and inspections of regulatory and supervisory institutions and official authorities, fulfilling obligation to prove as evidence in future legal disputes, continuing marketing and sales activities provided that your prior consent has been obtained, obtaining statistical information by contacting and anonymizing new product and service campaigns for marketing purposes, subjecting them to market reviews and evaluations.
Within this context, Netcad can process your personal data based on the reasons of legal obligations, establishment and execution of contracts, the fulfillment of legal obligations, your personal data being public by yourself, mandatory processing of data objectively for the legitimate interests of Netcad in a way that does not harm your fundamental rights and freedoms, pursuant to the Article 5 of KVKK. Beyond this, in cases where the above-mentioned processing conditions are not available, Netcad may also process your personal data by obtaining your explicit consent in accordance with Article 5/1 of the KVKK in order to carry out additional activities to support its activities. In all cases where data processing is based on explicit consent, you have the right to withdraw your consent at any time.
Your personal data are collected, processed and shared with 3rd parties within the framework of Articles 8 and 9 of the KVKK in a manner that is related to the purpose of processing and is limited and measured for this purpose.
The personal data we collect and process from you may vary depending on the relationship you have with Netcad, the service you receive and/or the scope of the contract you have concluded. Such personal data can be collected, processed and transferred verbally, in writing or electronically, directly from you or via www.netcad.com.tr or via e-mail, call centers, online forms, camera recordings for the purposes specified in this Clarification Text, within the scope of Personal data processing conditions specified in Articles 5 and 6 of KVKK. In addition, you may be asked for your personal data during your visit to our website and to use the opportunities on our website.
Legal reasons for collecting and processing personal data are as follows:
i. Retention of personal data directly related to the establishment and execution of contracts,
ii. Retention of personal data for the purpose of establishing, using or protecting a right,
iii. It is imperative that personal data be retained for the legitimate interests of the company, provided that it does not harm the fundamental rights and freedoms of individuals,
iv. Retention of personal data in order for the company to fulfill any legal obligation,
v. Stipulation of the retention of personal data in the legislation expressly,
vi. Presence of explicit consent of data subjects in terms of retention activities that require the explicit consent of data subjects.
Your personal data excluding your health data may be transferred to SSI, tax office, banks, business partners, relevant units within the company, suppliers for the purposes of managing human resources processes, management and representation of the company, fulfilling the requested services, performing payment transactions and to law enforcement and police forces, judiciary and Turkey Statistical Institute and the related public institutions and organizations in accordance with the responsibilities and legal obligations of Netcad arising from the laws and to law firms and lawyers in case of legal dispute and to financial advisors, certified public accountants and financial consultancy and auditing companies in order to fulfill financial audit and legal obligations.
Your personal data are transferred to third parties in the country in a limited and measured manner, in connection with the purpose for which they are processed, without your explicit consent, in cases where it is required by law and/or mandatory for the performance of the contract and/or in order to fulfill its legal obligations, by taking adequate measures based on the 8/2 (a) provision of the KVKK.
Personal data such as identity and contact belonging to customers can be transferred to Netcad's suppliers that provide advertising and marketing services based on explicit consent in accordance with Article 8/1 of KVKK. Data owners can always withdraw their consent for the transfer of their personal data to third parties for marketing purposes.
Netcad e-mail network is working on Microsoft Office 365 program. In this case, all e-mail communication conducted over Netcad workplace e-mail address is encrypted and stored on Microsoft servers at www.office.com, based on your explicit consent in accordance with the provision of Article 9/1 of KVKK.
Personal data are kept within the Company as accessible only to limited persons. At the end of the processing period, this personal data shall be deleted, destroyed or anonymized as specified in the Company's Personal Data Protection and Destruction Policy."
Personal data collected through this website shall be stored for 10 years. Apart from this, special informative texts (clarification text) prepared for each data subject group contain separately the appropriate storage periods of the personal data of each data subject group. Your personal data shall be deleted, destroyed or anonymized during the first destruction period following the said storage periods. Camera recordings are kept for 15 days from the date of recording and are destroyed at the end of this period.
You have the following rights as the data owner pursuant to the prevailing legislation:
i. to request information about whether and how your personal data is processed (art. 11/(a), (b)),
ii. to be informed about the purpose of processing your personal data and whether they are used for their intended purpose (art. 11/c),
iii. to know the third parties to whom your personal data has been transferred (art. 11/ç)
iv. to request correction of your personal data (art.11 / d),
v. to request the deletion or destruction of your personal data in case the reasons requiring its processing are eliminated (art. 7, art.11/e),
vi. to request the relevant transactions to be notified to third parties to whom your personal data has been transferred in case of correction and deletion (art. 11/ f),
vii. to object to the results obtained as a result of analyzing your personal data (art. 11/g),
viii. to request to limit the processing of your personal data (art. 7),
ix. to claim compensation in case of damage due to unlawful processing of your personal data.
The applications to be made to our company, which is the data controller, regarding these rights, in accordance with the first paragraph of Article 13 of the KVKK shall be submitted to us in written and signed form, by sending it to the following mail and/or e-mail address. After your request is received by Netcad, a reply shall be sent in writing or electronically within thirty (30) days at the latest.
DATA CONTROLLER : Netcad Yazilim Anonim Sirketi
MERSIS NO : 0889005402100018
ADDRESS : Bilkent Cyber Plaza, B Blok, No:409 Cyberpark 06800 Cankaya, Ankara
PHONE : 0312 265 05 10
E-MAIL : email@example.com
KEP : firstname.lastname@example.org
WEBSITE : www.netcad.com.tr
Please contact us via e-mail.
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Data is collected through via devices through which you access browsers. This information collected is specific to the device. It can be deleted by the user at any time and access to information can be closed. There is no cookie/cookie tracking prepared by us on our website by Netcad. However, some statistics are shared by service providers within the scope of services such as Google and Hotjar, which are integrated with our web system. At this point, we would like to point out that we do not have information that is definite and/or identifiable from the statistics shared.
Your privacy is important to us, your privacy and security rights are our basic principle.
In this context, you can find our clarification text on the protection of personal data here.
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The purpose of the Anti-Bribe and Anti-Corruption Policy is to ensure the compliance of Netcad Yazilim A.S. with anti-bribe and anti-corruption legal regulations, professional principles and universal rules in line with ethical rules.
Anti-bribe and anti-corruption policy involves;
All Netcad Yazilim A.S employees, including Netcad Yazilim A.S Board of Directors,
Companies and employees from whom we obtain goods and services, persons and organizations (business partners) working on behalf of Netcad Yazilim A.S., including suppliers, consultants, lawyers, external auditors.
This policy is an integral part of,
Ethical principles adopted by the board of directors and all employees,
The principles we commit to comply by participating in the United Nations Global Compact,
Human Resources Applications
Corruption is the misuse of the authority held due to the position, directly or indirectly, to obtain any kind of gain.
Bribery refers to providing, offering or promising benefits directly or through intermediaries in order for a person to do, to get done, not do, accelerate, decelerate a work related to the performance of his duty; to request or acceptance; providing benefits to himself or to the party requesting this or another person due to this relationship within the framework of an agreement with another person in order to act contrary to the requirements of his duty by means of mediating them.
Bribery and corruption can be realized in many different ways, including:
Political or other donations,
The implementation and updating of the Anti-Bribe and Anti-Corruption Policy is under the authority, duty and responsibility of the Board of Directors. In this context;
It is necessary to ensure that the policies and strategies are written down by the Board of Directors and that the necessary systems are established,
Senior management is required to assess their risks and establish necessary control mechanisms in accordance with the principles to be determined by the Board of Directors,
Each unit supervisor is required to follow up whether the activities of Netcad Yazilim A.S. are carried out in accordance with the safe and legal regulations in their field of duty,
In case of failure to comply with policies, rules and regulations, notification, inspection and sanction mechanisms should be determined and operated.
In addition, all Netcad Yazilim A.S employees are responsible for;
Complying with the policies determined by the Board of Directors,
Effectively managing the risks related to their field of activity,
Working in accordance with the relevant legal regulations and Netcad Yazilim A.S applications,
Notifying the Board of Directors in case of encountering an act, activity or practice contrary to the Policy.
Companies and business partners from which goods and services are purchased and sold are obliged to comply with the principles of the Policy and other relevant legal regulations, and the works with individuals and organizations that do not comply with them are terminated.
5.1 Selection of Companies and Business Partners
At the stage of selection of companies and business partners from which goods and services are purchased and sold, criteria such as experience, financial performance, technical competence, ethical levels and a positive history in this field are also taken into consideration by the senior management. Companies or business partners that have negative intelligence about bribery or corruption are not worked with, even if they meet other criteria. In this context, the responsibility of making the necessary research and evaluations before entering into any business relationship is primarily on the board of directors.
5.2 Making an Agreement with the Company and Business Partners
The following terms are included in the agreements and contracts to be made with companies and business partners that have positive intelligence and meet other criteria;
Full compliance with the principles specified in the policy and other relevant regulations,
Employees' assimilation of these principles and acting accordingly,
Ensuring that employees receive Policy-related training periodically,
Reminding its employees regularly about their notification obligations and encouraging them to notify in case of such situations
. In the event that these are not complied with or there is a situation contrary to the Policy, there are provisions stating that the work and the contracts in force will be terminated for just cause.
6.KEY RISK AREAS FOR BRIBERY AND CORRUPTION ACTIONS
The company always aims to comply fully with the relevant laws, regulations and principles and does not tolerate any act of bribery and corruption, regardless of its purpose.
The business relationship with third parties who want to get or request service from the Company by bribery is terminated.
The main risk areas where bribery and corruption can occur are described in detail below:
6.1 Bribery and Corruption
Netcad Yazilim A.S is against all kinds of bribery and corruption. Receiving, giving or offering bribes for whatever purpose is unacceptable.
Business relations with third parties who want to do business with Netcad Yazilim A.S. through bribery or corruption should not be continued.
A gift is a product that does not require any monetary payment and is generally given by people or customers with whom we have business relations as a thank you or business courtesy.
Any gift offered or given to third parties by Netcad Yazilim A.S. must be offered in good faith and unconditionally.
The same principles apply to the acceptance of a gift, and gifts must not be accepted except for the symbolic gifts with low material value, which are included in these principles. In addition, even if it is within this scope, gift acceptance must not be frequent, and a notification should be made to the Board of Directors of the company through the first supervisor by the acceptor regarding the accepted gifts.
6.2.1 Gifts from Suppliers or Service Providers
Netcad Yazilim A.S. is an important customer for suppliers, service providers (hereinafter referred to as "Suppliers"). All employees, especially those responsible for purchasing, may receive unethical and inappropriate offers from Suppliers.
Suppliers can only be selected on a competitive basis. Suppliers' efforts to influence the purchasing decisions of Netcad Yazilim A.S.'s employees with gifts, aids or donations must not be tolerated. Such initiatives may be in favor of an individual or a third party. Suppliers should be advised not to affect company employees in this way and should be warned if they themselves violate such term. Suppliers that seriously violate or continue to violate this rule must be reported to Netcad Yazilim A.S Human Resources Department. If the violation is serious or repeated, the business relationship must be terminated.
Netcad Yazilim A.S. employees are prohibited from directly or indirectly receiving gifts, gaining unfair advantage or receiving valuable items (credit, commission, share of valuable securities or other property, recruitment, exemption or being exempted from any debt or other liability, any other profitable service, etc.).
6.2.2 Gifts to Employees of Customers or Other Business Partners
Netcad Yazilim A.S. does not want the purchasing decisions of its customers or other business partners' employees to be affected by personal gifts. For this reason, invitations and other donations to employees of customers or other business partners are limited and such donations are prevented from possibly affecting the customer's purchasing decision. Donations other than promotional gifts and invitations to regular business dinners are permitted only if the customer or business partner is notified to the employee's supervisor or authorized body and has received approvals for gifts. These rules apply equally to persons or other third parties who have a close relationship with the employee of the customer or business partner.
6.2.3 Gifts to Public Authorities and Government Officials
Employees of the company and its subsidiaries should avoid that a promotional gift to a government official could influence the decisions of that person in the performance of their official duties. For this reason, all employees are prohibited from taking any action or taking any precaution that may put such pressure. It is forbidden in principle to give, offer, promise or authorize any government or government officials, money or equivalents, or gifts, aids or donations. Exceptions are subject to prior approval from the company official and ethics representative. Invitations to regular business dinners for government officials require the prior approval of the employee's supervisor. Making payments or providing non-cash equivalents, invitations, gifts, donations or grants (also known as expedition payments) to secure or expedite the routine transactions of government officials or private sector employees are always prohibited.
6.3 Hospitality Policy
Hospitality is an event or activity sponsored by a person outside the company or another company. Hospitality events / activities include:
The company may offer hospitality to third parties in order to improve its business relationships and to establish normal business communication networks. These third parties include customers, consultants, lawyers, auditors and other related companies (including their employees, family and friends) that have business relationships with the firm. The firm offers its hospitality publicly, in good faith and unconditionally. The same principle applies to accepting hospitality offers on behalf of personal or connected persons (family members, friends, close relationships, etc.). When a high-value hospitality offer that may not comply with the company principles is received, approval must be obtained from the head of the unit. Even if it complies with the issues specified in the policy, situations that may lead to conflict of interest or perceived in this way should not be caused, and hospitality offers should not be offered or accepted in such cases.
6.4 Facilitation Payments
Facilitation payments can not be offered to individuals and organizations covered by this Policy to secure or expedite a routine transaction or process (obtaining permits and licenses, obtaining documents, etc.) with government agencies.
Certain restrictions have been imposed on donations and aids within the framework of the legal legislation that the company is subject to. However, Netcad Yazilim A.S employees' support to charities with the amounts they collect independently from their jobs is not considered within this scope.
7. Error-free Registration
The issues that Netcad Yazilim A.S. has to comply with regarding the accounting and registration system are regulated by legal regulations. Accordingly;
It is required that all kinds of accounts, invoices and documents related to relations with third parties (customers, suppliers, etc.) must be reliably registered and kept in full, accurate and correctness,
The accounting or similar commercial registrations regarding any transaction must not be falsified and the facts must not be distorted.
7. TRAINING AND CONTACT
Anti-Bribe and Anti-Corruption Policy has been announced to the employees of Netcad Yazilim A.S. and is continuously and easily accessible. Training is an important instrument to increase the awareness of employees. In this context, the company designs information programs that require the participation of all employees, together with the supervisors of all units.
8. POLICY VIOLATIONS AND SANCTIONS
All Netcad Yazilim A.S employees are obliged to comply with this Policy, relevant legal regulations and all applicable anti-corruption laws. In the event that the employees act against the rules in this Policy, disciplinary penalties that may lead to the termination of the employment contract, depending on the nature of the incident, come into question. In addition, there may be criminal liability for those who do not comply with the relevant legal regulations and the anti-corruption laws in force. It is unacceptable for any employee to be subjected to ill-treatment for the reasons of refusing to participate in a bribery or corruption incident, notifying Netcad Yazilim A.S. Human Resources Department regarding the violation of the principles in this Policy, expressing his concerns about possible future corruption actions.
In cases that are or are likely to be contrary to the policy, the subject is examined by the Board of Directors and necessary sanctions are applied in case of detecting inappropriate behavior.
In contracts made with companies where goods and services are purchased and sold or with persons and organizations working on behalf of Netcad Yazilim A.S., in case it is determined that there is an act, attitude or activity contrary to the policy, there are provisions stating that the works/contracts in force will be unilaterally terminated by Netcad Yazilim A.S. for just cause and in the event of a policy violation, these provisions are applied without exception.
This Policy is regularly reviewed and necessary updates are made and announced on the website of Netcad Yazilim A.S