Protection and Processing of Personal Data Policy and KVKK Clarification Text The purpose of this Personal Data Protection and Processing Policy (“Policy”) is to use the platform (“Platform”) operated by Radamon Yazılım Anonim Şirketi (“Radamon”) and accessed via www.kyrr.io and Radamon Mobile Applications. is to determine the terms and conditions regarding the use of personal data that are shared with Radamon and/or obtained in other ways by persons who are registered as (“User”). This Policy is an annex and inseparable part of the User Agreement, and the definitions in the User Agreement will be taken into account when interpreting the terms that are not defined here. The User declares that he has been informed about the processing of his personal data with this Policy and that he consents to the use of his personal data as specified here. ISSUES REGARDING THE PROCESSING OF PERSONAL DATA 1. Definition of Personal Data Any information relating to an identified or identifiable natural person is Personal Data. (“Personal Data”) Data related to race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data are special personal data. carries. (“Special Quality Personal Data”) 2. Legal basis for the processing of personal data The Law on the Protection of Personal Data No. 6698 includes other provisions regarding the determination of data that qualify as personal data, the processing or protection of personal data. Likewise, the Turkish Penal Code No. 5237 establishes a protection mechanism for personal data by envisaging certain sanctions regarding the processing and confidentiality of personal data. As Radamon, we need the personal data of the User to be processed in order to provide you with the best service, to ensure the security of the Platform served, to properly manage the work and services provided to you, and to fulfill the relevant legal obligations. 3. The method used in the processing of personal data Radamon attaches great importance to the security of your User\'s information and works with the most advanced technology tools to ensure this. In order to ensure the security of the Platform, all kinds of physical, electronic and administrative measures have been taken in secure environments. All information is stored and backed up on secure servers. So, Radamon aims to produce statistical information through the Platform, to make the Platform more effective by observing User behaviors, and to obtain the data it needs in the development of the Platform. In order for third-party providers, including Google, to display Platform ads in the banner areas of publisher sites on the internet, they are required to collect information about ads, optimize and publish ads based on visitors\' past visits to the Platform. For the above-mentioned purposes, first-party cookies, which are technical communication files, and three-party cookies are used together by third-party providers, including Radamon and Google. As mentioned above, Radamon may use cookies to collect information and in this context, it will be able to process data and transmit it to third parties for the purpose of processing within the scope of analysis services offered by third parties, only to the extent required by these analysis services. The aforementioned technical communication files are small text files saved on the desktop or mobile device of the Users to determine how often the Platform is visited to be stored in the main memory. By using cookies, Radamon stores the status and preference settings of the Users about the Platform, thus facilitating the use of the Platform. Through cookies, statistical information is obtained about how many people use the Platform, for what purpose, how many times a person visits the Platform and how long they stay. In addition, cookies designed to help dynamically generate advertisements and content from specially designed user pages for Users are also used for these purposes. The cookie is not designed to retrieve any other personal data from the main memory. Most of the browsers are initially designed to accept cookies, but it is possible for the User to change the settings regarding the use of cookies via the browser. If the use of cookies is blocked as a result of these settings, it may result in the Platform not functioning as desired or the Users being unable to access the Platform. The Company can also monitor the behavior of the Users on the Platform (page viewed, duration of visit, etc.) via cookies in order to conduct online behavioral advertising and marketing. Despite the fact that it has been processed in accordance with the provisions of the KVK Law and other relevant laws, in the event that the reasons requiring its processing are eliminated, personal data is deleted, destroyed or anonymized by the data controller ex officio or upon the request of the data subject. You can delete all cookies or site data from the tools section of your internet browser, and reject all cookies from the help section. 4. Purpose of processing your personal data Radamon processes data in accordance with the provisions of the Constitution of the Republic of Turkey, the Law on the Processing of Personal Data (hereinafter referred to as KVK) and other laws it has to comply with. Aggregate statistical data that does not contain personal information, such as the frequency and times of the Platform\'s visits, the IP address, the statistics of the product pages visited and the products added to the basket, are also collected and used to analyze and understand the User\'s movements and preferences. The personal information collected on the Platform is used to inform the Users about the campaigns, to provide the services requested or authorized or to fulfill the transactions. The platform can also manage accounts within the scope of the establishment and performance of the contract; execution of orders, payment and trading transactions; Offering the company\'s products and services; providing general information about these products and services; conducting customer acquisition, customer satisfaction and customer acquisition activities; fulfillment of customer relationship management processes; evaluation of my complaints and requests; ensuring the confirmation and approval of the transactions carried out; providing the services within the scope of commercial activities to the member; Maintaining company operations and policies, performing suspicious transaction detection and audits; may use personal information to monitor fraud processes and carry out marketing activities. In order to support these uses, the Platform may use personal information to provide more effective services to our Users, to improve the site and other related Radamon products or services, to make the Platform easier to use, or to customize the Platform according to your specific preferences and interests. For research purposes, we combine data about Platform visits with anonymous demographic information and may use this information in aggregate to provide more useful content. We may combine site visit data with your personal information to provide personalized content on the Platform. 5. Institutions to which your personal data is transferred and the purpose of transfer Radamon, in order to carry out the personal data it collects, cooperates with the program partner institutions, organizations, individuals and institutions in the country / abroad from which the data is stored in the cloud environment, with various marketing activities within the scope of various marketing activities in order to provide better service to its users and to ensure visitor satisfaction, It can share it with various agencies, advertising companies, survey companies, other domestic and foreign third parties and relevant business partners. The platform uses the Remarketing & Demographics and Interest Reporting features of Google Analytics. You can opt out of Google Analytics for Display Advertising and customize your Google Display Network ads using your ad settings. Demographic information provided by Google Analytics is used to customize the Platform and the advertisements given by the Platform according to their interests. While this information is used in target audience studies, it can be shared with advertising publishers for advertising and promotional purposes, together with information about other users. This information in any way name, surname, T.C. It does not contain any personal information such as identity number, gender, age, etc., but is used to conduct studies on user trends as a group and to differentiate the target audience. Radamon\'s processing of your personal data without express consent is only possible in the limited number of cases listed in the Personal Data Protection Law No. 6698. In case of existence of one of the conditions specified within the scope of Articles 5 and 8 of the Personal Data Protection Law, Radamon will be able to process the personal data it has obtained without obtaining the User\'s separate consent and share it with third parties. The main conditions are given below: • It is clearly stipulated in the law that the Company will process the User\'s data without obtaining express consent, • It is mandatory for the protection of the life or physical integrity of the User or someone else, who is unable to express his or her consent due to actual impossibility or whose consent is not given legal validity, • It is necessary to process personal data, provided that it is directly related to the establishment or performance of any contract between the User and Radamon, • It is mandatory for Radamon to fulfill its legal obligations, • It has been made public by the User himself, • Data processing is mandatory for the establishment, exercise or protection of a right, • Data processing is mandatory for the legitimate interests of Radamon, provided that it does not harm the fundamental rights and freedoms of the User. 6. Your rights regarding your personal data As Radamon, we would like to remind you of your rights regarding your personal data, which are recognized in accordance with the Law on Protection of Personal Data No. 6698: • Learning whether your personal data is processed, • If your personal data has been processed, requesting information about it, • To learn the purpose of processing your personal data and whether they are used in accordance with the purpose, • Knowing the third parties to whom your personal data is transferred, in the country or abroad, • Requesting correction of your personal data if it is incomplete or incorrectly processed, • Requesting the deletion or destruction of your personal data in the event that the reasons for its processing are eliminated, • Requesting notification of third parties to whom your personal data has been transferred, in case of correction, deletion or destruction of your personal data, • Objecting to the emergence of a result against you by analyzing your processed data exclusively through automated systems, • Requesting the compensation of the damage in case you suffer damage due to unlawful processing of your personal data. If you want to exercise your rights that we have mentioned above, we request you to contact us through the communication channels of the Platform and under the heading Communication. Measures and Commitments Regarding Data Security As Radamon, under the conditions determined in the relevant legislation or expressed in this Policy, • Personal data is not processed unlawfully, • Personal data not to be accessed unlawfully and • Protection of personal data undertakes to take the necessary technical and administrative measures to ensure the appropriate level of security and to carry out the necessary inspections. Radamon cannot disclose the personal data obtained about the User to others in violation of the provisions of this Policy and the Personal Data Protection Law and cannot use it for purposes other than processing. In case of linking to other applications on the platform, Radamon does not bear any responsibility for the privacy policies and contents of the applications. Within the scope of the Illumination Text; Fulfillment of legal obligations; managing my accounts within the scope of the establishment and performance of the contract; ensuring my membership on the site; confirmation of my membership; execution of my instructions, payment and trading transactions; Offering the company\'s products and services; providing general information about these products and services; conducting customer acquisition, customer satisfaction and customer acquisition activities; improving service quality; fulfillment of customer relationship management processes; evaluation of my complaints and requests; ensuring the confirmation and approval of the transactions I have performed; the provision of services within the scope of commercial activities; sending a monthly newsletter; Maintaining company operations and policies, performing suspicious transaction detection and audits; my identity information (name, surname, TCKN, date of birth, place of birth); Fulfillment of legal obligations; managing my accounts within the scope of the establishment and performance of the contract; ensuring my membership on the site; confirmation of my membership; execution of my instructions, payment and trading transactions; Offering the company\'s products and services; providing general information about these products and services; conducting customer acquisition, customer satisfaction and customer acquisition activities; improving service quality; fulfillment of customer relationship management processes; evaluation of my complaints and requests; ensuring the confirmation and approval of the transactions I have performed; the provision of services within the scope of commercial activities; my contact information (address, residence, ID, e-mail, telephone) for the purposes of sending a monthly newsletter; Fulfillment of legal obligations; managing my accounts within the scope of the establishment and performance of the contract; ensuring my membership on the site; confirmation of my membership; execution of my instructions, payment and trading transactions; Offering the company\'s products and services; providing general information about these products and services; conducting customer acquisition, customer satisfaction and customer acquisition activities; improving service quality; fulfillment of customer relationship management processes; evaluation of my complaints and requests; ensuring the confirmation and approval of the transactions I have performed; the provision of services within the scope of commercial activities; my contact information (address, residence, ID, e-mail, telephone) for the purposes of sending a monthly newsletter; Fulfillment of legal obligations; managing my accounts within the scope of the establishment and performance of the contract; execution of my instructions, payment and trading transactions; Offering the company\'s products and services; providing general information about these products and services; conducting customer acquisition, customer satisfaction and customer acquisition activities; fulfillment of customer relationship management processes; evaluation of my complaints and requests; ensuring the confirmation and approval of the transactions I have performed; the provision of services within the scope of commercial activities; Maintaining company operations and policies, performing suspicious transaction detection and audits; my financial information (bank/investment institution account information, invoice, IBAN); Managing my accounts within the scope of establishment and performance of the contract; execution of my instructions, payment and trading transactions; fulfillment of customer relationship management processes; ensuring the confirmation and approval of the transactions I have performed; the provision of services within the scope of commercial activities; Maintaining company operations and policies, performing suspicious transaction detection and audits; My title information for the purposes of tracking fraud processes and carrying out marketing activities; Fulfilling the obligations arising from the law, my legal information (correspondence with judicial authorities and case / enforcement file information); Fulfillment of legal obligations; managing my accounts within the scope of the establishment and performance of the contract; execution of my instructions, payment and trading transactions; Offering the company\'s products and services; providing general information about these products and services; conducting customer acquisition, customer satisfaction and customer acquisition activities; improving service quality; fulfillment of customer relationship management processes; evaluation of my complaints and requests; ensuring the confirmation and approval of the transactions I have performed; the provision of services within the scope of commercial activities; Maintaining company operations and policies, performing suspicious transaction detection and audits; my transaction security information (device information, IP address information, log records) for the purposes of tracking fraud processes and conducting marketing activities; Fulfillment of legal obligations; managing my accounts within the scope of the establishment and performance of the contract; execution of my instructions, payment and trading transactions; Offering the company\'s products and services; providing general information about these products and services; fulfillment of customer relationship management processes; evaluation of my complaints and requests; ensuring the confirmation and approval of the transactions I have performed; the provision of services within the scope of commercial activities; performing suspicious transaction detection and audits; my customer transaction information (crypto money/e-money address information, customer ID information, crypto money/e-money wallet information) in order to monitor fraud processes and carry out marketing activities; Fulfillment of legal obligations; managing my accounts within the scope of the establishment and performance of the contract; my other information (professional information, registered professional association registration number, education information and authorization information) Within the scope of fulfilling the obligations arising from the Law No. 5651 on the Regulation of Broadcasts Made on the Internet and Combating Crimes Committed Through These Broadcasts (Law No. 5651) and its secondary regulations, I agree with my free will that the infrastructure and information systems used by Radamon are processed and transferred abroad in connection with the aforementioned purposes, in a measured and limited manner. Providing the products and services offered by Radamon to its customers under the best conditions, providing products or services in a reliable and uninterrupted manner and maximizing customer satisfaction, fulfilling various transactions regarding the services in question, conducting and developing operations, realizing financial transactions, identification information, address information, which are directly or indirectly related to the purposes of promotion, marketing, advertising, campaign and survey activities of the products and services or different products and services, informing customers about opportunities, campaigns and other services, and fulfilling the requirements of the agreements concluded with the customers. , e-mail address, postal address, phone number, bank account information and cookies to be collected are legally available to company employees, officials, domestic and foreign group companies (Radamon and/or business partners, shareholders), Authorized public institutions and organizations, in order to carry out their activities, within the framework of legal obligations and legal limitations, to domestic independent audit companies, survey companies, domestic / foreign information technology support servers, hosting companies, programs, electronic environments such as cloud computing, services to be provided to me. and/or to the business partners and service providers that Radamon receives services or works with for the execution of activities, physically or electronically, it can be securely stored, transferred, processed or the use of data can be prevented; I accept and declare that I have been informed by Radamon regarding the above-mentioned issues and that I have given my express consent within the framework of the KVK Law. All of my personal data received by Radamon, subject to the above-mentioned purposes, by Radamon; Providing business development services, providing statistical and technical services and conducting customer relations, establishing, developing and maintaining technical and administrative infrastructure and electronic systems (web site), keeping customer data, taking necessary security measures for archiving and storage, and transferring them to processing here. can be processed and stored. In order to maintain the services related to the management of the call center processes, the company employees, officers, foreign/international group companies (Radamon and/or its business partners, shareholders), legally authorized public institutions and organizations, in order to carry out their activities, in the framework of legal obligations and legal limitations, international independent auditing companies, survey companies, servers, hosting and infrastructure providers that receive information technology support abroad, electronic environments such as software and cloud computing, business partners that Radamon receives services or works with for the execution of services and/or activities to be provided to me, I accept and declare that it can be transferred to service providers and in this context, I expressly consent to the transfer of my personal data abroad. Also, that the personal data I have shared with Radamon is correct and up-to-date; I agree and declare that if there is a change in this information, I will notify Radamon of the changes. 7. Changes to the Policy Radamon may change the terms of this Policy at any time. The Current Policy becomes effective on the date it is published on the Platform.