1. How Your Personal Data May Be Processed

Pursuant to KVKK No. 6698, the personal data you share with vemilac.com may be obtained wholly or partially by automated means or non-automated means as part of a data recording system; recorded, stored, altered, reorganized—in short, subjected to any kind of processing by us. Under KVKK, any action performed on data is considered “processing of personal data.”

2. Purposes and Legal Grounds for Processing Your Personal Data

The personal data you share may be processed in order to:

• Fulfill the requirements of our services in accordance with contractual and technological needs and improve our products/services,
• Provide information to public prosecutors, courts, and relevant public officials upon request and as required by law in matters of public security and legal disputes,
• Offer our members a wide range of opportunities or share these opportunities with persons/institutions within the legal framework,
• Analyze advertising preferences.

These purposes are carried out in compliance with KVKK No. 6698 and the relevant secondary regulations.

3. Third Parties or Organizations to Which Your Personal Data May Be Transferred

For the purposes above, your personal data may be shared with our principal shareholders, shareholders, advertisers, our direct/indirect domestic or foreign affiliates; member companies using the infrastructure of vemilac.com; persons and institutions to whom we provide services/regarding the services we provide; organizations from which we receive services or with which we cooperate and partner; domestic/overseas organizations; and other third parties.

Our arrangements regarding advertising cookies are set forth in the “vemilac.com Cookie Policy,” which forms part of this Policy. Please see the Cookie Policy for details.

4. Method of Collecting Your Personal Data

• Forms on the vemilac.com website and mobile applications (name, surname, address, phone, e-mail, etc.), preferences on pages accessed with username/password, transaction IP logs, cookie data, browsing durations/details, location data,
• Data shared for purposes such as establishing a commercial relationship with vemilac.com, applying for a job, or submitting a proposal—via business cards, résumés (CVs), offers, etc. (physical/virtual, face-to-face/remote, verbal/written/electronic),
• Data obtained from websites, blogs, contests, surveys, games, campaigns, micro-sites, and social media; e-newsletter read/click behaviors; publicly available databases; and shareable profiles/data on social media platforms (Facebook, Twitter, Google, Instagram, Snapchat, etc.).

5. Personal Data Obtained Before KVKK Took Effect

Since vemilac.com did not commence publication before April 7, 2016, there are no personal data stored prior to the effective date of KVKK. (If your website collected data before this date, how such data were processed and preserved should be additionally specified.)

6. Transfer of Your Personal Data

Personal data collected by the methods listed above may be processed in Türkiye or transferred abroad for storage and processing, provided that it remains within the scope of KVKK and is in line with contractual purposes. Transfers may be made to countries and service providers deemed to have adequate protection by the Personal Data Protection Board.

Where necessary, your personal data may be transferred to:

• Our business partners with whom we collaborate and/or from whom we receive services to provide/promote products and services,
• Authorized authorities who may determine your location in case of an emergency call,
• Regulatory/supervisory bodies, courts, enforcement offices, and other public institutions/organizations authorized to request personal data,
• Legal entities in a commercial relationship with vemilac.com that have your phone number.

7. Storage and Protection of Personal Data

In accordance with Article 12 of KVKK, vemilac.com implements administrative/technical measures—such as hashing, encryption, transaction logging, and access management on the software side, and physical security measures on the organizational side—to prevent unlawful processing, unauthorized access, and to ensure secure storage of personal data. If it is learned that personal data are obtained by others through unlawful means, the situation will be promptly reported to the Personal Data Protection Board in accordance with legal regulations.

8. Keeping Personal Data Accurate and Up to Date

Pursuant to Article 4 of KVKK, vemilac.com has an obligation to keep your personal data accurate and up to date. Accordingly, our members are required to share accurate and current data or update them via the website/mobile application so that we can fulfill our legal obligations.

9. Rights of the Data Subject Under KVKK

As of October 7, 2016, the data subject’s rights under Article 11 of KVKK include, in summary:

• To learn whether personal data are processed,
• If processed, to request information regarding such processing,
• To learn the purpose of processing and whether data are used in line with that purpose,
• To know the third parties to whom personal data are transferred domestically or abroad,
• To request correction if personal data are incompletely/incorrectly processed,
• To request deletion/destruction of personal data within the framework of Article 7 of KVKK,
• To request that these transactions be notified to third parties to whom the data have been transferred,
• To object to a result to the detriment of the person arising from analysis of the data exclusively through automated systems,
• To claim compensation for damages incurred due to unlawful processing of personal data.

10. Contact and Application Method

The Data Controller Representative to be appointed by vemilac.com will be announced in the Data Controllers Registry and on the web page where this document is located, once the legal framework is provided.

Data subjects may send their questions, opinions, and requests to info@vemilac.com.

vemilac.com will respond to submitted requests with a reasoned positive/negative reply in writing or electronically (within 30 days at the latest). Processing is principally free of charge; however, if a cost arises, a fee may be requested according to the tariff set out in Article 13 of KVKK.

By sharing your personal data through our website, applications, and other channels, you declare that you have been informed about the processing purposes, methods, transfer/sale, and other matters stated in this Policy; that the data shared with vemilac.com may be used on web, application, and social media channels; that they may be commercially shared with third parties provided it benefits members; and that you will first apply to vemilac.com before exercising your legal rights—thereby giving your explicit consent as defined in KVKK.