1. DATA CONTROLLER, CATEGORIES OF PERSONAL DATA AND METHODS OF COLLECTION
Pursuant to Law No. 6698 on the Protection of Personal Data (“Law No. 6698”), your personal data — in the categories of identity, contact, customer transaction, legal transaction and transaction security — is collected from you through electronic written data transfer by automatic means, and is processed by ASTOPIA TECH OÜ (“Company”), acting as data controller, within the scope detailed below.
2. PURPOSES AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
The personal data we collect is processed based on the following purposes and legal grounds:
| Purpose of Data Processing | Data Category | Legal Ground |
| Carrying out activities in compliance with legislation | Transaction Security | Art. 5/2-a of Law No. 6698 — Explicitly provided for by law. Art. 5/2-ç — Mandatory for the data controller to fulfill its legal obligation. |
| Carrying out information security processes | Transaction Security | (same as above) |
| Carrying out sales and after-sales support activities for goods/services | Identity, Contact, Customer Transaction, Legal Transaction | Art. 5/2-c — Necessary for the processing of personal data of the parties to a contract, provided it is directly related to the establishment or performance of the contract. |
| Carrying out goods/services production and operation processes | Identity, Contact, Customer Transaction, Location, Personnel, Transaction Security | (same as above) |
| Carrying out contract processes | Identity, Contact, Customer Transaction | (same as above) |
| Carrying out communication activities | Identity, Contact, Customer Transaction, Marketing | Art. 5/1 — Explicit consent of the data subject |
| Carrying out advertising and marketing activities | Identity, Contact, Customer Transaction, Marketing | Art. 5/1 — Explicit consent of the data subject |
| Carrying out customer satisfaction processes | Identity, Contact, Customer Transaction | Art. 5/2-f — Necessary for the data controller’s legitimate interests, provided this does not harm the fundamental rights and freedoms of the data subject. |
| Carrying out retention and archiving activities | Identity, Contact, Transaction Security, Customer Transaction | Art. 5/1 — Explicit consent; Art. 5/2-ç — Mandatory for legal obligation. |
3. TRANSFER OF PERSONAL DATA
Your personal data may be transferred to third parties under the following conditions:
| Legal Ground for Transfer | Purpose of Transfer | Party to Whom Transferred |
| Art. 8/2-a — Mandatory for the data controller to fulfill its legal obligation | Carrying out activities in compliance with legislation | Competent Public Institutions and Authorized Private Parties |
| Art. 8/2-a — Necessary for the data controller’s legitimate interests, provided this does not harm the fundamental rights and freedoms of the data subject | Transfer of information necessary for carrying out goods/services production and operation processes to our business partners | Business Partners |
| Art. 8/2-a — Necessary for the processing of personal data of the parties to a contract, provided it is directly related to the establishment or performance of the contract | Transfer of information necessary to fulfill our obligations under your service agreement to our business partners | Business Partners |
4. APPLICATION PROCEDURES AND PRINCIPLES
As a data subject, you may submit your requests relating to your rights under Article 11 of Law No. 6698 to us by completing the Application Form Regarding the Protection of Personal Data available on our website, or by submitting an application that meets the minimum conditions stipulated by the Communiqué on the Procedures and Principles for Application to the Data Controller, via the methods listed below. As the Company, we will conclude your application free of charge, as soon as possible and, in any event, within thirty days at the latest, depending on the nature of your request.
However, if the transaction requires an additional cost, a fee determined by the Personal Data Protection Board will be charged by the Company.
| Application Method | Application Address |
| Electronic message sent via Registered Electronic Mail (KEP) | orfeteknoloji@hs03.kep.tr |
| Message sent from your e-mail address registered in our system, or via secure electronic signature or mobile signature | support@astopia.com |
| Written application submitted in person or through a notary public | Ahmet Yesevi Mah. Kerem Sok. No:9 İç Kapı No:203 Pendik/İstanbul |