With this KVK policy, Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi adopts the principles stipulated by the KVK Law in comply with the Law on Protection of Personal Data No. 6698 (“KVK Law”). It fulfills the obligations regarding bringing the processing, deletion, destruction, anonymization of personal data, transferring, informing the relevant person and secure data security.

Polypus is a product of Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi and shows the same sensitivity in personal data processing. Information on processed personal data within the scope of Polypus is given below.

Purpose and Scope of the Policy

This Personal Data Protection Policy, of Polypus;

• Personal data collection methods and legal reasons,
• Which person groups' personal data are processed (Data Owner Categorization),
• Which category of personal data is relating to these groups of people (Data Categories) and sample data types,
• In which business processes and for what purposes used this personal data,
• Technical and administrative measures taken to ensure the security of personal data,
• To whose and for what purpose personal data can be transferred,
• Retention periods of personal data,
• It explains the rights of the Relevant Persons over personal data and how they can use these rights.

a) Personal Data Collection Methods and Legal Reasons

Polypus collects personal data through the website, cookies, notifications from administrative and judicial authorities and other communication channels, in aural, electronic or in writing, in accordance with the personal data processing conditions specified in the KVK Law and in regulation the legal reasons specified in this Personal Data Protection Policy.

b) Data Subject Person Group Categorization

Polypus, categorizes the data subject groups, whose personal data are processed in the personal data processing processes and activities related to these processes as follows. However, can processed personal data of other person groups in accordance with the personal data processing conditions specified in Articles 5 and 6 of the KVK Law, and in the legal reasons specified in this Personal Data Protection Policy.

• Customer
• Potential Customer
• Online Visitor
• Website Users

Data Categories and Sample Data Types

1. Customer,

• Identity Information: Name, surname,
• Contact Information: mobile phone, e-mail address, address,
• Financial Information: Tax office, invoice information
• Customer/Member Process Information: Purchased product and amount,
• Risk Management Information: IP address
• Process Security Information: Password, password information
• Marketing Information: Cookie records, targeting information, results showing habits and likes
• Legal Transaction and Compliance Information: The start and end time of the service provided, the type of service used, the commercial electronics message permission given by the Relevant Person in the electronic media, legal texts and contracts within the scope of the service provided.

2. Potential Customer

• Identity Information: Name, surname
• Contact Information: e-mail address
• Risk Management Information: IP address

3. Online Visitor

• Legal Transaction Information/Risk Management Information: IP address
• Legal Action and Compliance Information: Start and end time of the service provided, type of service used, amount of data transferred

4. Person submitting a request/complaint

• Identity Information: Name, surname
• Contact Information: e-mail address,,
• Process Information: Message subject, message content

d) In Which Business Processes And For What Purposes Used This Personal Data,

Personal data, Polypus operated by Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi;

• Processing of online visitor data in compliance with the applicable legislation,
• Performing customer transactions,
• In terms of current customers the commercial electronic message approval contact with the customer; providing special promotions, opportunities and benefits,
• Resolving of customer problems and complaints,
• Creating of customer satisfaction, loyalty and engagement ,
• Making statistical evaluations and market researches,
• Practicing and formulationing the commercial and business strategies of Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi,
• Follow-up of accounting and purchasing transactions,
• Legal process and compliance with legislation,
• Answering information requests from administrative and judicial authorities,
• Planning in-company reporting and business development activities,
• Preventing information and process security and malicious use,
• It is used to make the necessary arrangements in order to get that the data processed is actual and correct and to carry out the activities related to all these processes.

e) Technical and Administrative Measures Taken to get the Security of Personal Data

Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi undertakes to take all necessary technical and administrative measures and to exercise due diligence to get the confidentiality, integrity and security of your personal data.

Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi takes due precautions to prevent unauthorized access, misuse, unlawful processing, disclosure, alteration or destruction of personal data.

Regarding the prevention of unlawful access to the personal data processed by Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi, preventing the unlawful processing of these data and get the protection of personal data:

• All areas on the website where personal data is taken are protected with SSL,
• Creates and implements access authorization and control matrix for its employees so that the personal data collected from the website is not processed unlawfully,
• It give that personal data is not accessed unlawfully.

Despite taking the necessary information security measures, in the event that personal data is damaged as a result of attacks on the system or is in the take control unauthorized third parties, Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi immediately notifies you and the Personal Data Protection Council and takes the necessary measures.

f ) To Whose And For What Purpose Personal Data Can Be Transferred,

Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi transfers personal data to third parties only for the purposes specified in the Personal Data Protection Policy and in accordance with Articles 8 and 9 of the KVK Law.

As per above personal data subject to domestic and abroad transfer, together with technical measures to get their security ; protection of the other party of the legal relationship is a data controller or a data processor, it is also legally protected thanks to the compliance with the KVK Law included in our contracts.

g) Personal Data Retention Periods

Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi preserves the personal data it processes in accordance with the KVK Law for the periods stipulated in the relevant legislation or required by the processing purpose.

Customer records	10 years	Law No. 6098
All records related to accounting and financial transactions	10 years	Law No. 6102, Law No. 213
Traffic information about online visitors	2 years	Law No. 5651
Müşterilere ilişkin kişisel veriler	Hukuki ilişki sona erdikten sonra 10 yıl;	Law No. 6098, Law No. 213, Law No. 6502

You can review our Cookie Policy for the retention periods of personal data we obtained via cookies.

h) What are the Rights of the Related Persons on their Personal Data and How They Can Use These Rights

The rights of the Related Person on the personal data processed by Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi in accordance with article 11 of the KVK Law are listed below:

• Learning whether personal data is processed or not,
• If personal data has been processed, requesting information about it,
• Learning the purpose of processing personal data and whether they are used in accordance with the purpose,
• Knowing the third parties to whom personal data is transferred at up country or abroad,
• Requesting correction of personal data in case of incomplete or misfunction,
• Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVK Law,
• Requesting notification of the transactions made as per articles (d) and (e) stranger to whom personal data has been transferred,
• Objecting to a result from against the person himself by analyzing the processed data exclusively through automated systems,
• Requesting the compensation for the damage in case of loss due to unlawful processing of personal data.

As per article 13 of the KVK Law, you can exercise your rights by sending an e-mail to info@Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi.

2) Terms of Deletion, Destruction and Anonymization of Personal Data

Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi stores the personal data it processes through its website and mobile site for the periods stipulated by the relevant laws and/or for the required periods by the purpose of processing, as per articles 7, 17 of the KVK Law and article 138 of the Turkish Penal Code. In the event that these expire, it will delete, destroy or anonymize as per the Regulation on the Deletion, Destruction or Anonymization of Personal Data.

The deletion of personal data by Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi means the process of making personal data inaccessible and unusable for the users in any way.

Destruction of personal data by Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi means the process of making personal data inaccessible, unrecoverable and unusable by anyone in any way.

Anonymization of personal data by Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi means that personal data cannot be associated with an identified or identifiable natural person under in no case, even it is matched with other data.

Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi explains in detail the methods and the technical and administrative measures it has taken in the relevant Policy it has prepared in as per with the Regulation on the Deletion, Destruction or Anonymization of Personal Data.

3) Amendments to the Personal Data Protection Policy

Motto Ticari Yazılım ve Bilişim Sistemleri Sanayi Limited Şirketi can always make changes in this Personal Data Protection Policy. These changes will become valid immediately upon the promulgate of the new Personal Data Protection Policy. Our members will be informed about the changes in this Personal Data Protection Policy.