Data Protection Policy

WBE Digital Data Protection Policy

1. Data Controller Information

Company Name: WBE Digital Marketing Agency Address: Suadiye Neighbourhood, Bağdat Avenue, Kazım Özalp Street, No. 10, Fl. 10, Kadıköy/Istanbul Telephone: 0542 722 72 34 Email: [email protected]

2. Purpose and Scope

This policy sets out the principles governing the processing of personal data collected from WBE Digital Marketing Agency’s customers, prospective customers, suppliers, employees and website visitors. The policy has been drawn up in accordance with the Law on the Protection of Personal Data No. 6698 (KVKK) and relevant legislation.

3. Personal Data Collected and Purposes of Processing

Our company processes the following personal data for legitimate purposes and to the extent necessary:

3.1. Categories of Data Collected

• Identity Information: First name, surname, Turkish identity number (where legally required)

• Contact Details: Email address, telephone number, address details

• Customer Transaction Details: Invoice details, order history, payment details

• Marketing Information: Preferences, subscription status, campaign participation details

• Website Usage Data: IP address, cookies, browser information, page view history

3.2. Purposes of Data Processing

• The provision of digital marketing services and the fulfilment of contracts

• Management of customer relations and the execution of communication processes

• Compliance with legal and regulatory requirements

• Planning and execution of marketing activities (subject to obtaining explicit consent)

• Analysing and improving website performance

4. Data Processing Methods and Legal Grounds

Personal data is processed, whether by automated or non-automated means, as part of a data filing system. The legal grounds for our processing activities are as follows:

• Article 5(2)(c) of the KVKK: The conclusion or performance of a service contract

• Article 5(2)(c) of the Personal Data Protection Act: Fulfilment of the data controller’s legal obligations

• Article 5(2)(f) of the Personal Data Protection Act: Where it is necessary for our legitimate interests

• KVKK Article 5/1: Explicit consent (only in cases where explicit consent has been given)

5. Data Sharing and Transfer

Your personal data is shared only in the following circumstances and for the purposes specified below:

5.1. Domestic Data Transfer

• Our service providers (server hosting, software development)

• Public bodies and organisations where legally required

• Financial institutions (for payment transactions)

5.2. Cross-border data transfers

The transfer of personal data abroad is carried out provided that the conditions set out in Article 9 of the Personal Data Protection Law (KVKK) are met and the necessary security measures are in place.

6. Data Security

Our company takes the following technical and organisational measures to protect your personal data:

• Secure network infrastructure and firewalls

• Restricted access and authorisation systems

• Regular security audits and tests

• Staff training and confidentiality undertakings

• Data masking, encryption and anonymisation techniques

7. Data Retention Periods

Your personal data is retained for as long as is necessary for the purposes for which it is processed. These periods are:

• The term of the service contract and the statutory limitation periods thereafter

• Statutory retention requirements (10 years for accounting records)

• For as long as our legitimate interests persist

• Where explicit consent has been given, this will remain in force until you withdraw your consent

8. Your Rights (Article 11 of the Personal Data Protection Act)

In accordance with Article 11 of the KVKK, you have the following rights regarding your personal data:

1. Find out whether your personal data is being processed

2. If this has been edited, please request information regarding this

3. To find out the purpose of the processing and whether the data is being used in accordance with that purpose

4. Not knowing the third parties to whom data is transferred, whether within the country or abroad

5. Please request corrections if any information is missing or has been processed incorrectly.

6. Request for deletion or destruction in accordance with the conditions set out in Article 7 of the KVKK

7. Request that third parties to whom the data has been transferred be notified of the above corrections and deletions

8. You have the right to object to a decision being made solely through the automated processing of your personal data that adversely affects you

9. If you suffer loss or damage as a result of the unlawful processing of personal data, you may claim compensation for such loss or damage

9. How to Exercise Your Rights

To exercise your rights, please provide the following along with documents verifying your identity:

• Written Application: By post to our company address

• Email: By sending an email with the subject line ‘KVKK application’ to [email protected]

• Other Methods: You may apply using other methods specified by the Ministry.

Your applications will be processed free of charge within 30 (thirty) days at the latest. However, should the process incur additional costs, a fee may be charged in accordance with the tariff set by the Personal Data Protection Authority.

10. Cookie Policy

Our website uses cookies to improve the user experience. Types of cookies:

• Essential Cookies: This is essential for the website’s core functions

• Performance Cookies: For website usage statistics

• Functional Cookies: To remember user preferences

• Targeting Cookies: For marketing purposes (only with explicit consent)

You can manage your cookie preferences via your browser settings or by using the cookie management panel on our website.

11. Amendments and Updates

This policy may be updated due to legal changes or changes to company practices. The current policy will always be published on our website, and we will notify you of any significant changes.

12. Contact

For any questions, comments or requests regarding the protection of your personal data:

WBE Digital Marketing Agency Address: Suadiye Neighbourhood, Baghdad Street, Kazım Özalp Street, No. 10, Flat 10, Kadıköy/Istanbul Telephone: 0542 722 72 34 Email: [email protected]

This policy has been drawn up in accordance with the Personal Data Protection Act (KVKK) and relevant legislation; our company attaches great importance to the protection of personal data.