16.07.2026_v3

KVKK CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA - Contact‍

‍Information and Clarification Text Regarding the Protection of Your Personal Data

‍As Efilli Yazılım Ticaret Anonim Şirketi, we value the security of the personal data you share with our Company; for this purpose, we exercise maximum care to ensure that your personal data is processed and protected in accordance with the law. In this context, this Clarification Text is provided to you as a requirement of Article 10 of the Personal Data Protection Law No. 6698 ("Law"). You become a "data subject" if you submit your opinions, complaints, and requests to us via the contact or "contact us" button on the https://efilli.com/ ("Website") website. Your personal data collected by our Company in the capacity of "data controller," the purposes for which they are collected, and other relevant matters are detailed below.
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What Is Your Personal Data?

‍Personal data refers to information that identifies you or makes you identifiable.

‍Purposes of Processing Your Personal Data In line with the following, your personal data is collected by us: a) In our capacity as data controller via website communication channels: Name, surname, e-mail address, phone number, message content. b) In our capacity as data processor, within the scope of the Cookie Management Platform (CMP), Mobile App Consent, and Digital Accessibility solutions operating on our Customers' websites and mobile applications, the following personal data may be processed: Cookie preference information (which cookie categories you have consented to/not consented to), mobile application permission and consent preferences, IP address, device information, browser type and language, operating system, application version, session records and log data, user preference history (permissions granted in previous visits), and technical usage information regarding the use of digital accessibility features (to the extent necessary for the accessibility solution to function).

‍Purposes of Processing Your Personal Data

‍a) Services are provided through this button to address your questions, opinions, or complaints regarding the product on the website, or to provide information about the product to allow our customers to gain experience with the product before purchasing. The data processing purposes for queuing and providing these requests are as follows:

Sending commercial, administrative, informative, and/or reminder e-mails regarding new and/or existing features added to our Content and Services, and/or promotions regarding the products and/or specific information and/or services and/or paid services we offer to our customers,

Executing requests for advertising and similar activities, sending information or notifications regarding the product, which is a computer program in the form of a work, via e-mail,

Answering your questions and providing an effective user experience service,
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Providing information about new services,

Contacting the User when necessary,

Conducting and developing operational activities such as business development, marketing, and communication, and providing better service by enhancing the user experience,

Operating the Services securely for the purpose of auditing and detecting illegal transactions such as fraud to ensure our users are not affected by such activities,

Protecting the legal rights of customers and third parties and preventing the commission of crimes,

Resolving technical issues and improving service quality.

b) Your personal data processed in our capacity as a data processor within the scope of the Cookie Management Platform (CMP), Mobile App Consent, and Digital Accessibility solutions used on our customers' websites and mobile applications are processed for the following purposes:

Ensuring that the products function technically correctly and securely,

Recording cookie preferences and mobile application permission preferences and remembering them during subsequent visits,

Creating, storing, and reporting the consent records provided by the user when necessary,

Supporting our customers in fulfilling their obligations under the PDPL, GDPR, and relevant data protection legislation,

Providing digital accessibility solutions and operating accessibility features,

Ensuring product security,

Performance analysis,

Error detection,

Conducting product development activities,

Conducting and developing customer relations.

‍Processing and Transfer of Personal Data

‍a) Your personal data processed via website communication channels will be transferred to necessary and authorized persons and organizations domestically, including but not limited to regulatory and supervisory authorities and other official institutions within the scope of relevant legislation, and public institutions or organizations authorized to request your personal data.

b) Your personal data processed within the scope of the Cookie Management Platform (CMP), Mobile App Consent, and Digital Accessibility solutions may be shared with:

Hosting, infrastructure, information security, and technical support providers from whom we receive services,

Legally authorized public institutions and organizations,

Legally authorized private law entities,

limited solely to the purpose of providing services and fulfilling legal obligations.

‍Method and Legal Basis for Personal Data Collection

‍a) Your personal data processed via website communication channels is collected based on the following legal grounds:

It is necessary to process data for our Company to fulfill its legal obligations,

It is necessary to process data for the establishment, exercise, or protection of a right.

b) Your personal data processed within the scope of the Cookie Management Platform (CMP), Mobile App Consent, and Digital Accessibility solutions is processed automatically in an electronic environment based on the following legal grounds:

Your explicit consent,

The establishment or performance of a contract,

Fulfillment of the data controller's legal obligation,

Establishment, exercise, or protection of a right,

Legitimate interests of the data controller.

‍Data Processed Within the Scope of Our Products

‍Efilli may act as a data processor within the scope of the Cookie Management Platform (CMP), Mobile App Consent, and Digital Accessibility solutions offered to its customers in order to provide the relevant services. Personal data processed in this context is processed only in accordance with our customers' instructions and in compliance with relevant data protection legislation. The digital accessibility solution is primarily a technical service aimed at increasing the accessibility of websites; depending on the nature of the service, it may not process personal data or may only process limited technical data necessary for the provision of the service.

‍Your Rights Regarding the Protection of Personal Data

‍In accordance with Article 11 of the Law, by applying to our Company, you have the right to: Learn whether your personal data is being processed, request information if it has been processed, learn the purpose of processing your personal data and whether it is used in accordance with its purpose, know the third parties to whom it is transferred domestically or abroad, request correction if it is processed incompletely or incorrectly, request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the Law, request that the transactions made in accordance with your rights of correction, deletion, and destruction mentioned above be notified to third parties to whom your personal data has been transferred, object to a result against you arising from the analysis of your processed personal data exclusively through automated systems, and request the compensation of your damages in case you suffer damage due to the unlawful processing of your personal data.

You may submit your requests regarding the implementation of the Law and any questions regarding your personal data in writing to the address Erzene Mah. Ankara Cad. Ege Teknopark No:172/67 Bornova/İzmir (via notary, registered mail with return receipt, etc.) or to the info@efilli.com address, along with a copy of your ID to verify your identity.

This clarification text was updated on 16.07.2026.