KVKK Aydınlatma Metni (Clarification Text)

1. Purpose

This text explains, under Article 10 of Law No. 6698 on the Protection of Personal Data, how HUBLİNKLY AI YAZILIM VE TEKNOLOJİ LİMİTED ŞİRKETİ processes personal data.

2. Categories of data processed

Identity, contact, customer transaction, finance, transaction security, audit and marketing data, and — where the employer enables the Clock application — attendance and location data of that employer’s staff.

3. Purposes of processing

Delivering the subscription service, account management, billing and legal record-keeping, security and fraud prevention, support, and — with consent — marketing communications.

4. Legal grounds (Articles 5 and 6)

• Necessary for the performance of a contract
• Necessary for compliance with a legal obligation
• Necessary for our legitimate interests, without prejudice to your fundamental rights
• Explicit consent, where relied on — marketing, and [cross-border transfer, if that is the chosen mechanism]

5. Transfers

Personal data is processed outside Türkiye. The recipients, their purpose and their location are the ones named on the Sub-processor List; the principal ones are:

The transfer mechanism relied on under Article 9 is to be confirmed. This is stated as unknown rather than asserted: the choice between an undertaking approved by the Personal Data Protection Board, standard contractual clauses notified to the Board, and explicit consent is a legal determination about this company, and naming one before it has been made would be the error the rest of this document exists to avoid.

6. Method of collection

Electronically, through the website, the applications, email and support channels.

7. Your rights under Article 11

Under Article 11 of Law No. 6698 you may apply to us and:

• learn whether your personal data is being processed;
• request information about it, if it has been processed;
• learn the purpose of processing and whether the data is used in accordance with that purpose;
• know the third parties, in Türkiye or abroad, to whom your personal data has been transferred;
• request that incomplete or inaccurate data be corrected;
• request that your personal data be erased or destroyed, within the conditions set out in Article 7;
• request that a correction, erasure or destruction made under the two rights above be notified to the third parties to whom the data was transferred;
• object to a result reached to your detriment by analysis of your data carried out solely by automated systems;
• claim compensation if you suffer damage because your personal data has been processed unlawfully.

There is no charge for making an application. We answer within thirty days of receiving it at the latest, as the law requires. Where answering carries a cost, we may charge no more than the tariff set by the Personal Data Protection Board.

8. Application

Written application to our registered address (Vadistanbul Park, 7C Blok, No: 7D/15, Ayazağa Mah., Kemerburgaz Cad., Sarıyer / İstanbul, Türkiye), or through our KEP address (hublinkly@hs01.kep.tr), or from the email address held in our systems.