Privacy and Data Handling Policy (KVKK and GDPR Aligned)

Effective Date: April 29, 2026
Company: AGEM BİLİŞİM YAZILIM DANIŞMANLIK EĞİTİM HİZMETLERİ LTD.ŞTİ.

1. Introduction

AGEM BİLİŞİM YAZILIM DANIŞMANLIK EĞİTİM HİZMETLERİ LTD.ŞTİ. is committed to protecting the privacy, confidentiality, and security of personal and business information processed through our services and platforms. This Privacy and Data Handling Policy explains how we collect, process, store, use, share, retain, and dispose of data.

2. Information We Collect

We may collect and process the following categories of information:

Information provided by customers and users

  • - Account and contact information
  • - Order and transaction information
  • - Product and inventory data
  • - Billing and invoicing information
  • - Support requests and communications

Information collected automatically

  • - Application usage data
  • - Log and audit data
  • - Device and technical information
  • - Security and access records

3. How We Use Information

We process information only for legitimate business purposes, including:

  • - Providing and operating our services
  • - Order and fulfillment management
  • - Invoicing and financial processing
  • - Product and inventory management
  • - Customer support
  • - Security monitoring and fraud prevention
  • - Legal and regulatory compliance
  • - Service improvement and operational analytics

4. Data Protection and Security

We implement administrative, technical, and organizational safeguards designed to protect data, including:

  • - Role-based access controls
  • - Encryption in transit and at rest where applicable
  • - Authentication and access restrictions
  • - Network and infrastructure security controls
  • - Logging and monitoring controls
  • - Secure development and change management practices

Access to data is limited to authorized personnel based on business need and the principle of least privilege.

5. Data Sharing

We do not sell customer data.

We may share data only when necessary:

  • - With authorized service providers supporting our services
  • - With logistics or fulfillment partners when required for service delivery
  • - With government authorities or regulators when legally required
  • - With authorized e-invoicing or compliance service providers where applicable

Any sharing is limited to the minimum data necessary for the intended purpose.

6. Data Retention

We retain data only as long as necessary for:

  • - Service delivery and operational needs
  • - Contractual obligations
  • - Legal, tax, and regulatory requirements

When data is no longer required, it is securely deleted, anonymized, or disposed of using appropriate methods.

7. International Transfers

Where applicable, data transfers are carried out using appropriate safeguards and in accordance with applicable laws.

8. Privacy Rights (KVKK and GDPR)

Subject to applicable laws, including the Turkish Personal Data Protection Law (KVKK) and, where applicable, the General Data Protection Regulation (GDPR), users may have rights to:

  • - Request access to personal data
  • - Request correction or update of inaccurate data
  • - Request deletion or anonymization where legally permissible
  • - Request restriction or objection to certain processing activities
  • - Request information regarding processing purposes and recipients of data
  • - Request portability where applicable under GDPR

Requests may be submitted using the contact information below.

8A. Lawful Basis for Processing

Personal data is processed based on one or more lawful grounds where applicable, including:

  • - Performance of contractual obligations
  • - Compliance with legal obligations
  • - Legitimate business interests
  • - Explicit consent where required by law

8B. Data Minimization and Purpose Limitation

We collect and process only the minimum data necessary for specified, legitimate business purposes and do not use personal data for purposes incompatible with those purposes.

8C. Cross-Border Data Transfers

Where personal data is transferred internationally, such transfers are performed subject to applicable legal safeguards under KVKK and/or GDPR.

9. Incident Response

Subject to applicable law, users may have rights to:

  • - Request access to their data
  • - Request correction of inaccurate data
  • - Request deletion where applicable
  • - Object to or restrict certain processing

Requests may be submitted using the contact information below.

We maintain security procedures designed to identify, respond to, and manage security incidents involving data.

10. Updates to This Policy

This policy may be updated periodically. Updated versions will be published on this page.

11. Data Protection Contact

For privacy, data protection, or rights requests:

AGEM BİLİŞİM YAZILIM DANIŞMANLIK EĞİTİM HİZMETLERİ LTD.ŞTİ.
Email: info@agem.com.tr
Website: https://www.agem.com.tr

If applicable, requests related to personal data rights under KVKK or GDPR may be submitted through these contact channels.

12. Contact

For privacy or data protection inquiries:

AGEM BİLİŞİM YAZILIM DANIŞMANLIK EĞİTİM HİZMETLERİ LTD.ŞTİ.
Email: info@agem.com.tr
Website: https://www.agem.com.tr