Datenschutz und Allgemeine Geschaftsbedingungen

We appreciate your interest in our Privacy Policy. Qontrolo takes the protection of your data very seriously. In this Policy you can find out what data Qontrolo collects when you use the website and how it is used.

This Privacy Policy applies to www.qontrolo.com (our “website”) operated by Qontrolo of [Insert Address] (“Qontrolo”, “us” or “we”) acting as the data controller in accordance with Turkeys Law No. 6698 on Protection of Personal Data (“PDPL”). As well as the EUs General Data Protection Act (“GDPR”). If you have any questions, you can reach us using our Contact Form or write to the above address.

We would like to ask you to read this policy along with our Cookie Policy and if you are a user of our services, please also refer to our Data Processing Agreement.

General Information
What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.

What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to explicitly consent to the processing.

What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

What are the legal bases of processing?
In accordance with the PDPL and GDPR, we have to have at least one of the following legal bases to process your Personal Data:

you have given your consent,
the data is necessary for the fulfillment of a contract / pre-contractual measures,
the data is necessary for the fulfillment of a legal obligation or
the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

Data we collect automatically
Log data
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

Content Delivery Network
We use a Content Delivery Network (CDN) to distribute our online content. Our CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymized and then transmitted without any personal reference. Server log files include, in particular, i) details of the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, as well as v) the date, time of all page views including the amount of data transmitted. The legal basis for processing is our legitimate interest.

Hosting
To provide our website, we use the services of HostArmada INC, who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in the PDPL and the GDPR, we need to obtain consent for the use of Non-essential Cookies. For further information on the Cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

When you watch our videos
On our website, we implement videos of the video portal “YouTube” of the company Google LLC.
Doing so, we use the “extended data protection mode” option provided by Google. When you call up a page that has an embedded video, a connection is established to Google’s servers and in the process the content is displayed on the website by notifying your browser. According to Google’s information, in “extended data protection mode” your data – in particular which of our Internet pages you have visited as well as device-specific information including the IP address – is only transmitted to the YouTube server in the USA when you watch the video. By clicking on the video, you consent to this transmission.

If you are logged in to Google at the same time, this information will be assigned to your YouTube member account. You can prevent this by logging out of your YouTube account before visiting our website.

Data we collect directly
General
We may ask you for Personal Data when you:
use our website,
request our demo, services, support, or information,
participate online or otherwise in marketing activities,
subscribe to Qontrolo`s marketing and promotional emails or other materials,
interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
contact us.

Categories of Personal Data we collect may include your name, email address, and IP addresses. We may also collect demographic data such your interests, and preferences.

In order to provide you with a more consistent and personalized user experience in your interactions with Qontrolo, data collected through one source may also be linked to other data collected by Qontrolo through other sources. This may include data that helps us identify you when you access our website through several different devices.

Contacting us
In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and Contract.

We are present on social media on the basis of our legitimate interest (LinkedIn, Instagram, XING, and YouTube). If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.

When using our services
We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfillment of our accounting and tax obligations. Your data will not be used by us for automated decision making or profiling, nor will it be shared with third parties. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations.

We ensure that access by our staff members to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our staff members and enforce privacy and protection safeguards strictly.

Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

Testimonials
Within your testimonial you may be able to display certain information, share certain details, knowledge, and insights. Content and data are publicly viewable. You have choices about the information on your testimonial. You don’t have to provide additional information and it is your choice whether to include sensitive information and to make it public. Please do not post or add personal data to your profile that you would not want to be available. The legal basis for the storage is our legitimate interest and your consent.

Principles of processing Personal Data
Storage and Retention
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

Do Not Sell
We do not sell your Personal Data.

Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.

International Transfer
We may transfer your Personal Data to other companies and/or staff members as necessary for the purposes described in this Privacy Policy. In doing so, your Personal Data may be transferred to so called third countries including India, Pakistan, Lebanon and Bangladesh. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

Third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“content”). This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:

Analytics and Tracking: Google Analytics by Google LLC
Fonts: Font Awesome by Fonticons Inc,

Your Rights and Privileges
Privacy rights
Under the PDPL, you have the following rights:
Right to be informed
Right to access
Right to rectification
Right to erasure
Right to deletion
Right to object/opt-out

Under the GDPR, you can exercise the following rights:
Right to information
Right to rectification
Right to object to processing
Right to deletion
Right to data portability
Right of objection
Right to withdraw consent
Right to complain to a supervisory authority
Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The competent data protection authority in Turkey is: The Turkish Personal Data Protection Authority, Nasuh Akar Mahallesi Ziyabey Caddesi, 1407 Sokak No:4 06520, Çankaya, Ankara Turkey (www.kvkk.gov.tr)

Changes and Questions
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise the Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. If you would like to contact us regarding our privacy practices for any reason, please contact us.

Data Processing Addendum

In order that you as a service user and data controller (referred to as “Controller” or “you” or “User”) may use or continue to use our services (the “Services”) offered by us, Qontrolo of [Tahtakale Mah. Saray patı sk.] and data processor (referred to as “Qontrolo” or “Processor”), you have agreed that these data processing terms (“Terms”) shall apply (notwithstanding any other terms and conditions applicable to the delivery of the Services to the contrary) in order to address the compliance obligations imposed upon Qontrolo and its Users pursuant to applicable Data Protection Law and in particular Turkey`s Law No. 6698 on Protection of Personal Data (“PDPL”) and the General Data Protection Regulation (“GDPR”).

These Terms shall constitute a separate agreement, or they may be incorporated by reference in the relevant Services agreement, as the case may be.
Definitions
In this Agreement, capitalised words shall have the meaning as set out below or, as the case may be, elsewhere in this Agreement:
“Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with, a party from time to time during the Term.
“Data Protection Law” means the data privacy laws applicable to the processing in connection with the Services, including, where applicable, the PDPL / GDPR or similar law, or the applicable data privacy laws of any other relevant jurisdiction.
“User” means any User of Qontrolo.
“Contractual Clauses” means the standard contractual clauses of the European Commission for the transfer of personal data across borders, as amended or replaced from time to time, or any equivalent set of contractual clauses approved for use under Data Protection Law; and
“Personal Data” means the personal data processed by Processor in connection with the Services on behalf of User during the Term and may include Personal Data, and Special Categories Data as specifically required and transferred by the User. The processing may include activities auxiliary to Qontrolo services, such as administrative and other services. This will include names and other information about data subjects included in User materials.
The words “data subject”, “personal data”, “processing” and variations, “controller” and “processor” shall have the meaning attributed to them in Data Protection Law.

Appointment
Qontrolo is designated by its Users, User Affiliates and Business Affiliates (collectively “Instructing Parties”) to provide and manage various services, including the Services on their behalf. Accordingly, Personal Data may contain personal data in relation to which User and its Instructing Parties are controllers. Qontrolo confirms that it is authorised to communicate to User any instructions or other requirements on behalf of User in respect of processing of Personal Data connection with the Services.
Processor is appointed by User to process Personal Data on behalf of User and/or the Instructing Parties, as the case may be, as is necessary to provide the Services or as otherwise agreed by the parties in writing.

Duration
The Terms shall commence on the Effective Date and shall continue in full force and effect until such time as all Services have ceased and all Personal Data in the Processor’s possession or within its reasonable control has been returned or destroyed (the “Term”).

Data Protection Compliance
In relation to its processing of Personal Data, save as otherwise required by law, Qontrolo agrees to:
process Personal Data only as required in connection with the Services and in accordance with User and its Instructing Parties documented lawful instructions from time to time;
inform User and its Instructing Parties if, in Qontrolo`s opinion, an instruction infringes Data Protection Law;
ensure that all personnel authorised by Qontrolo to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
implement appropriate technical and organizational measures to appropriately safeguard Personal Data having regard to the nature of the personal data which is to be protected and the risk of harm which might result from any Security Breach (as defined below), at a minimum the measures set out in the Schedule;
promptly inform User and its Instructing Parties of any data subject requests under Data Protection Law or regulatory or law enforcement requests relating to Personal Data. Qontrolo shall not acknowledge or otherwise respond to the subject access request except with User and its Instructing Parties prior written approval, which shall not be unreasonably withheld;
provide such assistance as User and its Instructing Parties may reasonably require in order to ensure Qontrolo’s compliance with Data Protection Law in relation to data security, data breach notifications, data protection impact assessments and prior consultations with a competent authority;
at User and its Instructing Parties choice, without delay delete or return all Personal Data to User and its Instructing Parties, and delete existing copies of all Personal Data in the Processor’s possession or within its reasonable control (including those held by a Sub processor); and
make available to User and its Instructing Parties information reasonably necessary to demonstrate Qontrolo compliance with these Terms and allow for, and contribute to, audits and inspections carried out by User and its Instructing Parties.

Sub Processors
Processor will sub-contract, outsource, assign, novate or otherwise transfer obligations under these Terms or engage any subcontractors involved in the processing of Personal Data (each a “Sub processor”) only with User’s prior written consent and subject to subclause 5.2.
When engaging a Sub processor, Processor will:
carry out reasonable due diligence;
enter into a contract on terms, as far as practicable, same as those in these Terms, and which may include Contractual Clauses to provide adequate safeguards with respect to the processing of Personal Data; and
inform User of any intended changes concerning the addition or replacement of a Sub processor from time to time. If User object`s to any such change on reasonable grounds, then acting in good faith the parties will work together to resolve such objection.
Our currently engaged Sub processor are:
HostArmada INC, 501 Silverside Rd, Wilmington, DE 19809, United States with Server Location in Frankfurt, Germany

Security Incidents
“Security Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
Processor will investigate the Security Breach and take reasonable action to identify, prevent and mitigate the effects of the Security Breach. Processor will take such further action as User may reasonably request in order to comply with Data Protection Law.
Qontrolo will notify User without undue delay if Qontrolo becomes aware of any Security Breach within 24 hours of discovering such Breach and provide User with:
a detailed description of the Security Incident;
the type of data that was the subject of the Security Incident;
the identity of each affected person, and
the steps Qontrolo takes in order to mitigate and remediate such Security Incident, in each case as soon as such information can be collected or otherwise becomes available.
Qontrolo shall use its best efforts to immediately mitigate and remedy any Security Incident and prevent any further Security Incident(s) at its sole expense.
Qontrolo agrees that User shall have the sole right to determine (i) whether notice of the Security Incident is to be provided to any individuals, regulators, law enforcement agencies, consumer reporting agencies or others as required by law or regulation, or otherwise in User’s discretion, (ii) the contents of such notice, and (iii) whether any type of remediation may be offered to affected persons, as well as the nature and extent of any such remediation.
In the event of a Security Incident involving Personal Data in Qontrolo’s possession or otherwise caused by or related to Qontrolo’s acts or omissions, and without limiting User’s other rights and remedies, Qontrolo will pay all costs and expenses of (i) any disclosures and notification required by applicable law or as otherwise determined as appropriate in User’s reasonable discretion, (ii) monitoring and reporting on the impacted individuals’ or entities’ credit records if determined in User’s reasonable discretion as reasonable to protect such individuals, and (iii) all other costs incurred by User in responding to, remediating and mitigating damages caused by such Security Incident.
Qontrolo will investigate the Security Breach and take reasonable action to identify, prevent and mitigate the effects of the Security Breach. Qontrolo will take such further action as User may reasonably request in order to comply with Data Protection Law.
Qontrolo may not release or publish any filing, communication, notice, press release, or report concerning any Security Breach (“Notices”) without User`s prior written approval; such approval shall not be unreasonably withheld.

Audit
User (or its designated representatives) may, on an annual basis or more frequently as reasonably requested by User, at User’s expense, conduct an audit to verify that Qontrolo is operating in accordance with this DPA. Such audit(s) may include a review of all aspects of Qontrolo’s performance, including, but not limited to, Qontrolo’s general controls and security practices and procedures. Qontrolo will cooperate with User in conducting any such audit, and will allow User reasonable access, during normal business hours and upon reasonable notice, to all pertinent records, documentation, computer systems, data, personnel, and areas used to Process the User Data areas as User reasonably requests to complete such audit. User will take reasonable steps to prevent the audit from materially impacting Qontrolo’s operations.
Qontrolo shall correct any deviations from Security Best Practices that are identified in any security audit as soon as practicable, but in no event more than five days after receiving notice from User outlining any deviations (provided, however, that if five days is not a practicable cure period, then Qontrolo may instead present a remediation plan to User within such five day period that sets forth an achievable and reasonable timeframe, and Qontrolo must thereafter diligently proceed to correct any deviations in accordance with such plan).

International Data Transfers
Qontrolo will ensure that no Personal Data are transferred out of either:
the by the User approved data environment; or
any territory in which restrictions are imposed on the transfer of Personal Data across borders under Data Protection Laws,
without the prior written consent of User.
Qontrolo will ensure that Contractual Clauses or other applicable transfer mechanism, are in place to ensure adequate level of data protection.

Indemnity
Notwithstanding any provisions of the relevant Services agreement to the contrary, Processor shall and hereby agrees to indemnify User and Instructing Parties and their officers, employees, agents and subcontractors (each an “Indemnified Party”) from and against any claims, losses, demands, actions, liabilities, fines, penalties, reasonable expenses, damages and settlement amounts (including reasonable legal fees and costs) incurred by any Indemnified Party as a result of any gross negligence or willful breach by Processor of these Terms.

Miscellaneous
Clause and other headings in these Terms are for convenience only and shall not affect the meaning or interpretation of these Terms.
To the extent of any conflict, these Terms shall prevail over any Services agreement or other agreement.
Nothing in these Terms will exclude or limit the liability of either party which cannot be limited or excluded by applicable law. Subject to the foregoing sentence, (i) these Terms, including any appendices, constitutes the entire agreement between the parties pertaining to the subject matter hereof and supersedes all prior agreements, understandings, negotiations and discussions of the parties relating to its subject matter; and (ii) in relation to the subject matter of these Terms neither party has relied on, and neither party will have any right or remedy based on, any statement, representation or warranty, whether made negligently or innocently, except those expressly set out in these Terms.
User shall agree any amendment to these Terms that may be required from time to time for us and Instructing Parties to comply with any amended Data Protection Laws.
All notices of termination or breach must be in English, in writing and addressed to the other party’s primary contact person or legal department. Notice will be treated as given on receipt, as verified by a valid receipt or electronic log. Postal notices will be deemed received 48 hours from the date of posting by recorded delivery or registered post.
The provisions of these Terms are severable. If any phrase, clause, or provision is invalid or unenforceable in whole or in part, such invalidity or unenforceability shall affect only such phrase, clause or provision, and the rest of these Terms shall remain in full force and effect.
These Terms are governed by the law of Turkey and the parties submit to the exclusive jurisdiction of the courts of Turkey in relation to any dispute (contractual or non-contractual) concerning these Terms save that either party may apply to any court for an injunction or other relief to protect its property or confidential information.

SCHEDULE
Security measures
Qontrolo represents, warrants, and undertakes that it has established and for so long as Qontrolo Processes Personal Data it will at all times enforce, an ongoing program of Security Policies, Security Procedures, and Security Technical Controls, which reasonably ensures delivery of Security Best Practice made available at request.
Cross Border Data Transfer Mechanisms
In the event the Services are covered by more than one Transfer Mechanism, the transfer of personal data will be subject to a single Transfer Mechanism in accordance with the following order of precedence:
Qontrolo’s binding corporate rules as set forth in this Schedule
the applicable Standard Contractual Clauses as set forth in this Schedule
other applicable data Transfer Mechanisms permitted under Applicable Data Protection Law.
Binding Corporate Rules
The parties agree that Qontrolo will process personal data within the Qontrolo Services in accordance with the data protection policies that are approved by European data protection authorities after significant consultation with those authorities and enable multinational businesses, such as Qontrolo, to make intra-organizational transfers of personal data across borders in compliance with EU data protection law.
The parties further agree that, with respect to the Qontrolo Services, the Binding Corporate Rules will be the lawful Transfer Mechanism of User Account Data, User Content, and User Usage Data from the UK, European Economic Area or Switzerland, either directly or via onward transfer, to Qontrolo in any country or recipient outside the UK, European Economic Area or Switzerland and in Particular India, Pakistan, Lebanon and Bangladesh.
Standard Contractual Clauses
The parties agree that the 2021 Standard contractual clauses for international transfers as publish and available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en will apply to personal data that is transferred via the Services from the UK, European Economic Area or Switzerland, either directly or via onward transfer, to Qontrolo in any country or recipient outside the UK, European Economic Area or Switzerland and in Particular India, Pakistan, Lebanon and Bangladesh that is:
not recognized by the European Commission (or, in the case of transfers from Switzerland, the competent authority for Switzerland) as providing an adequate level of protection for personal data and
not covered by the above Binding Corporate Rules. For data transfers from the European Economic Area that are subject to the 2021 Standard Contractual Clauses, the 2021 Standard Contractual Clauses will be deemed entered into (and incorporated into this Addendum by this reference) and completed as follows:
Module One (Controller to Controller) of the 2021 Standard Contractual Clauses will apply where Qontrolo is processing User Account Data and
User is a controller of User Usage Data and Qontrolo is processing User Usage Data.
Module Two (Controller to Processor) of the 2021 Standard Contractual Clauses will apply where User is a controller of User Content and Qontrolo is processing User Content.
Module Three (Processor to Processor) of the 2021 Standard Contractual Clauses will apply where User is a processor of User Content and Qontrolo is processing User Content.
Module Four (Processor to Controller) of the 2021 Standard Contractual Clauses will apply where User is a processor of User Usage Data and Qontrolo processes User Usage Data.
For each Module, where applicable:
Data Exporter: User.
Contact details: The email address(es) designated by User in User’s account via its notification preferences.
Data Exporter Role: The Data Exporter’s role is set forth in this Agreement.
Signature and Date: By entering into the Agreement, Data Exporter is deemed to have signed these Standard Contractual Clauses incorporated herein, as of the Effective Date of the Agreement.
Data Importer: Qontrolo.
Contact details: Qontrolo Support Team.
Data Importer Role: The Data Importer’s role is set forth in this Agreement.
Signature and Date: By entering into the Agreement, Data Importer is deemed to have signed these Standard Contractual Clauses, incorporated herein, including their Annexes, as of the Effective Date of the Agreement.
The categories of data subjects are described in this Agreement.
The Sensitive Data transferred is described in this Agreement.
The frequency of the transfer is a continuous basis for the duration of the Agreement.
The nature of the processing is described in this Agreement.
The purpose of the processing is described in this Agreement.
The period for which the personal data will be retained is this Agreement.
The Supervisory Authority shall be The Turkish Personal Data Protection Authority, Nasuh Akar Mahallesi Ziyabey Caddesi, 1407 Sokak No:4 06520, Çankaya, Ankara Turkey (www.kvkk.gov.tr)
For transfers to sub-processors, the subject matter, nature, and duration of the processing is set forth below.
The Schedule Security Measures of this Agreement serves as Annex of the Standard Contractual Clauses.
Conflict. To the extent there is any conflict between the Standard Contractual Clauses, and any other terms in this Agreement, or the Privacy Policy, the provisions of the Standard Contractual Clauses will prevail.

Questions?
If you have any questions about the processing of your Personal Data, please contact us using our Contact Form or write us to the above address.