Privacy Agreement

1 - Parties

This Membership Agreement ("Agreement") is entered into between Respanet Information Technologies Trade Limited Company ("Company"), located at Deliktaş Mahallesi 1989 SK NO: 54/A Denizli / Pamukkale with tax ID number 6250895879, and the individual or legal entity ("Member") using the services ("Services") offered under the brand ("Respanet") and on the ("Site"). This Agreement defines the terms and conditions of usage.

By accepting this Membership Agreement, the parties undertake to act in accordance with the terms set forth below.

2 - Definitions

2.1 Agreement: The Service Agreement and its annexes concluded between the parties, defining their rights and obligations.

2.2 Company: Respanet Information Technologies Trade Limited Company, located at Deliktaş Mahallesi 1989 SK NO: 54/A Denizli / Pamukkale with tax ID number 6250895879.

2.3 Respanet: The brand under which the Company provides Services.

2.4 Site: The website operated under the Respanet brand at https://respanet.com.tr.

2.5 Services: All services provided under the Respanet brand and the Site.

2.6 Member: The individual or legal entity registered to benefit from the Services under the Respanet brand.

2.7 Law: The Turkish Personal Data Protection Law No. 6698 and related regulations governing the parties' rights and obligations.

3 - Legal Nature and Scope

In accordance with Article 10 "Obligation to Inform the Data Subject" of the PDPL, persons whose personal data are processed must be properly informed when consent is obtained. Under this law, personal data refers to any information related to an identified or identifiable individual (“Personal Data”). Special Categories of Personal Data include data about race, ethnic origin, political views, philosophical beliefs, religion, attire, association memberships, health, sexual life, criminal convictions, security measures, biometric and genetic data (“Special Categories”). The explanations provided in this Privacy Agreement regarding your Personal Data also apply to your Special Categories of Personal Data.

Under Article 3(1)(ı) of the PDPL, Respanet is recognized as the “Data Controller.” Accordingly, it is mandatory to inform data subjects of the identity of the data controller, purposes of data processing, recipients and purposes of transfers, legal grounds, and their rights such as updating, erasure, or anonymization under Article 11 of the PDPL.

As Data Controller, Respanet informs and clarifies to data subjects that it processes personal data within the limits and conditions prescribed by the law through this Privacy Agreement and Article 10 of the PDPL.

This document clarifies that Respanet may act as a “data processor” or “sub-processor” in the context of its services, but this Agreement does not cover data processing activities carried out in the capacity of processor.

4 - Data Controller and Representative

As per Article 3(1)(ı) of the PDPL, the Data Controller is the real or legal person determining the processing purposes and means, and responsible for establishing and managing the data registry system. In this context, the Data Controller is the following entity:

Entity Name: Respanet Information Technologies Trade Limited Company
Address: Deliktaş Mahallesi 1989 SK NO: 54/A Denizli / Pamukkale
Email: hukuk@respanet.com.tr
Phone: +90 258 220 2870

5 - Data Processor

Under Article 3(1)(ğ) of the PDPL, a “Data Processor” is a real or legal person processing personal data on behalf of the Data Controller based on authorization. Sub-processors are those who perform delegated processing activities on behalf of both the controller and processor.

6 - Categories of Processed Personal Data

Our Company processes the following personal data categories:

• First Name,
• Last Name,
• Date of Birth,
• Gender,
• Email Address,
• Phone Number,
• Postal Address,
• Turkish ID Number,
• IP Address,
• Details of Services Used,
• Financial Information and Details,
• Support Request Texts,
• Customer Service Call Recordings.

7 - Purposes of Data Processing

Your Personal Data is processed in accordance with principles in the PDPL for the following purposes:

• To inform customers about products and services and enhance their use,
• To improve service quality, customer satisfaction, and loyalty through customization based on needs and habits, and to implement marketing, sales, and post-sales processes,
• To notify customers about expiring services,
• To assist in safeguarding and managing customers’ digital assets and rights,
• To ensure the highest level of data security via appropriate infrastructure and measures,
• To enable customers to perform online transactions,
• To allow customers to access and manage online services,
• To authenticate and manage user identities,
• To plan and execute corporate partnerships and strategies,
• To maintain company operations and strategic planning,
• To conduct necessary business processes in our operational units,
• To ensure legal, commercial, and physical security for the company and partners, including public security disclosures when legally required,
• To procure, allocate, update or renew services from foreign suppliers when service delivery requires it (e.g. domain registration, SSL allocation, server provisioning, licensing),
• To develop web and online services, respond to inquiries and complaints, fix errors, and ensure compliance with the Privacy Policy within legal and commercial frameworks and highest security standards.

These data are processed under legal grounds and conditions in Articles 5 and 6 of the PDPL for the stated purposes.

8 - Principles of Processing Personal Data

As Respanet, we adhere to the following principles:

• Processing data in a lawful and fair manner,
• Ensuring accuracy and currency of data,
• Processing data for clear and legitimate purposes,
• Limiting data processing to what is necessary and proportional,
• Retaining data only as long as legally required or necessary.

9 - Recipients and Purposes of Data Disclosure

Personal Data collected and processed in compliance with PDPL may be disclosed within confidentiality agreements for the following purposes:

• To our authorized business partners and payment/collection intermediaries,
• To domestic and foreign solution partners, data processors, and subprocessors,
• To legal counsel for legal proceedings,
• To public authorities to fulfill legal obligations.

10 - Methods and Legal Grounds for Data Collection

Personal Data may be collected automatically or manually via customer services, website, customer panel, social media, mobile applications, and similar channels, based on services and commercial activities, in compliance with Articles 4, 5, and 6 of the PDPL.

These data are necessary to provide services legally and fulfill contractual obligations. They may be processed and disclosed under legal grounds in Articles 5 and 6 of the PDPL for stated purposes.

11 - Data Subject Rights

As data subjects, you may exercise your rights under Article 11 of the PDPL. If you submit a request through methods described in this Agreement, it will be processed free of charge within 30 days. However, fees prescribed by the Personal Data Protection Board may apply. Requests must be made by the data subject, or by a guardian in the case of minors or dependents.

You have the following rights via Respanet’s portal:

• To learn whether your Personal Data has been processed,
• To request information if data has been processed,
• To learn the purpose and compliance with that purpose,
• To learn domestic or international data recipients,
• To request correction and notification to third parties if data is inaccurate or incomplete,
• To request deletion or anonymization and notification of third parties if legal grounds for processing no longer exist,
• To object to analysis by automated systems resulting in adverse outcomes,
• To claim compensation if unlawful processing causes damage.

12 - Submitting Requests

Under Article 13(1) of the PDPL, data subject requests under Article 11 can be submitted via your registered KEP or email address to [----], or in writing in person, via notary, or by registered mail.

Your request should include:

• Your full name and signature,
• Your Turkish ID number or passport/residence permit number if foreign,
• Your postal address for notifications,
• Your email, phone, and fax (if any),
• Information and documents relevant to your request.

13 - Data Security

Respanet takes necessary technical and administrative measures to protect collected Personal Data from unauthorized access. This includes compliance of software with standards, careful selection of third parties, and adherence to our Privacy Policy within the company.

Main measures include:

• Encryption: Data is stored securely using encryption methods.
• Access Controls: Only authorized personnel can access data.
• Data Masking: Masking methods are used to preserve data confidentiality.

14 - Final Provision

Stamp duty arising from this Agreement shall be borne by the Member. This Agreement consists of 14 main articles and sub-clauses and has been read and understood by the parties. It may be executed electronically or physically, and both forms are legally valid. Respanet reserves the right to add, remove, or modify articles or sub‑clauses. The Member irrevocably declares acceptance of these changes, which become effective upon publication on Respanet’s website.