INFORMATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA UNDER THE PDPL

This information text has been prepared by Sumsa Medical Products Manufacturing & Export Ltd. Co. (“Sumsa” or the Company) as the data controller, within the scope of Article 10 of the Law on the Protection of Personal Data No. 6698 (“Law”) and the Communiqué on the Principles and Procedures to Be Followed in Fulfilling the Obligation to Inform. Your personal data may be processed by the Company within the scope explained below in accordance with the Law.

Method of Collecting Personal Data and Purposes of Processing

Your personal data may be collected within the scope of our business relationship with you or through our website, call center, or other communication channels.

What Personal Data Do We Process?

We process your name, surname, mobile phone, email address, address, IP data, voice recording if you speak with our call center, payment information, information contained in correspondence with authorized persons, institutions, and organizations, data in legal and enforcement files, and legal information request records.

Purposes and Legal Grounds for Processing Your Personal Data

Your personal data will be processed for the purposes of fulfilling our services to customers in accordance with contracts and technological requirements, providing post-sale support services for products and services, managing our customer relations processes, responding to your requests and complaints, conducting necessary activities by our relevant business units for the realization of commercial activities carried out by our Company, and executing related business processes. This processing will be carried out in accordance with the personal data processing conditions specified in Articles 5 and 6 of the Law.

Apart from this information, anonymous statistical data that does not contain personal information, such as frequency and timing of site visits, order times and IP addresses at the time of order, statistics of visited product pages and purchased products, will be collected and used to analyze visitor behavior and preferences. Based on your explicit consent, your data may also be processed to improve our products and services, conduct marketing activities, inform you about our campaigns, send commercial electronic messages such as advertisements and promotions, share them with companies we receive services from for sending such messages, better understand your needs and provide appropriate services, conduct marketing analyses, customize our products according to your preferences, and create user profiles.

To Whom and For What Purposes Can Your Personal Data Be Transferred?

Your collected personal data may be transferred for the purposes stated above to Sumsa's affiliated companies, service providers we work with to fulfill the services we offer to you, our business partners, dealers, suppliers, legally authorized public institutions, organizations from which we receive services, domestic and international servers, cloud service providers (domestic/international), data processors acting on behalf of the data controller, audit companies, advertising and promotion agencies, cargo companies, and private individuals within the scope of the personal data processing conditions stated in Articles 8 and 9 of the Law.

Your data may be transferred to domestic/international servers and institutions from which we receive cloud services based on your explicit consent in accordance with Article 9 of the Law.

Method and Legal Reason for Collecting Your Personal Data

Your personal data will be collected based on the legal reason of contract performance through your contact with our Company, electronic platforms such as our website, call center, mobile applications, online tools, cookies, emails, social media channels, and physical settings such as in-store shopping, via our sales and marketing departments, printed forms, membership forms, and solution partners. If you give your explicit consent, your personal data will be processed for the legal reason of customizing our products and services based on your preferences and usage habits within the scope of Articles 5 and 6 of the Law.

How Long Is Your Personal Data Processed?

Sumsa retains your personal data for the duration required by law and for the period necessary to fulfill the purpose of processing or, where applicable, to protect and use its legal rights in potential legal processes that may arise in the future.

At the end of this period, your personal data will be deleted, destroyed, or anonymized by Sumsa.

Personal data processed for the purposes specified in Sumsa’s policy will be deleted, destroyed, or anonymized by Sumsa once the reason for processing is eliminated, and the periods set by the Turkish Commercial Code No. 6102, the Regulation on Deletion, Destruction, or Anonymization of Personal Data published in the Official Gazette dated October 28, 2017 and numbered 30224, and the Turkish Penal Code No. 5237 have expired.

Storage and Protection of Personal Data

Your personal data will be stored and protected in accordance with relevant legislation. Necessary security measures will be taken to prevent unauthorized access, loss, theft, or misuse. Your personal data will be stored for the legal duration and will be destroyed at the end of this period.

Email Security

Do not include your credit card number or passwords in any emails you send to our store’s Customer Service regarding your orders. Information in emails may be visible to third parties. Our Company cannot guarantee the security of information transferred through emails.

What Are Your Rights as a Data Subject?

As a data subject, you have the following rights under Article 11 of the Law:

a) To learn whether personal data is being processed, b) To request information if personal data has been processed, c) To learn the purpose of processing personal data and whether it is used appropriately, d) To know the third parties to whom personal data is transferred domestically or abroad, e) To request correction if personal data is processed incompletely or incorrectly, f) To request deletion or destruction of personal data under the conditions specified in Article 7, g) To request notification of the actions taken pursuant to (e) and (f) to third parties to whom the personal data has been transferred, h) To object to a result against you that arises from analysis of the processed data exclusively through automated systems, i) To request compensation for damages if you suffer damage due to unlawful processing of personal data.

You may submit your applications regarding the rights listed above by visiting our company headquarters with your ID, by sending an email signed with your secure electronic signature to our registered email address via notary, or by sending an email to the addresses below from the email address you have previously provided and registered in our system.

Depending on the nature of your request, your applications will be concluded as soon as possible and within thirty days at the latest, free of charge; however, if the transaction requires an additional cost, a fee may be charged based on the tariff determined by the Personal Data Protection Board.

Our Contact Information

Registered Email Address: info@clearone.com.tr

Postal Address: Yıldırım Beyazıt Mah. Aşık Veysel Bul. 63 H Melikgazi, Kayseri, Türkiye

This text may be updated and revised when necessary. The updated version will be published on our website. We recommend that you regularly check the text to stay informed about changes and to access up-to-date information on how your personal data is processed.