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KVKK Privacy Notice

INTRODUCTION

In accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK / Law”), J Start, acting as the Data Controller, has adopted certain fundamental principles to ensure the confidentiality and security of personal data. In this regard, this Personal Data Protection Privacy Notice (“Privacy Notice”) has been prepared for informational purposes pursuant to Article 10 of the KVKK, in order to inform data subjects about personal data processing activities and the rights arising from the Law.

Personal data are processed in line with the fundamental principles set out in the Law, for the purposes and legal grounds specified below, and are securely stored for the retention periods determined in accordance with these purposes.

This Privacy Notice applies to the following real persons:

Potential Entrepreneurs: Entrepreneurs and startup companies that apply to receive investment from J Start prior to the execution of investment-related agreements.

Entrepreneurs: Entrepreneurs and startup companies that have received investment from J Start.

DATA CONTROLLER

Pursuant to the KVKK, your personal data are processed and transferred by J Start, acting as the Data Controller, within the scope of this Privacy Notice. The information regarding the Data Controller is provided below:

J Start Danışmanlık Anonim Şirketi

Address:
Trade Registry Number:
MERSIS Number:

DEFINITIONS

Explicit Consent
Consent given freely, based on adequate information, and relating to a specific subject.

Data Subject
The real person whose personal data are processed.

KVKK
Law No. 6698 on the Protection of Personal Data.

Personal Data
Any information relating to an identified or identifiable real person.

Processing of Personal Data
Any operation performed on personal data, whether fully or partially automated or non-automated provided that it forms part of a data recording system, such as collection, recording, storage, preservation, alteration, reorganization, disclosure, transfer, acquisition, making available, classification, or prevention of use.

Transfer of Personal Data
The transfer of personal data carried out verbally, in writing, electronically, or by other means by the parties.

Data Controller
The real or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

CATEGORIES OF PERSONAL DATA PROCESSED AND COLLECTION METHODS

The categories of personal data processed by the Data Controller and the methods of collection are set out below:

For Potential Entrepreneurs:

Data Category | Source Channel | Collection Method
Identity Information | Applications submitted via the website and email through the website at [.] | Partially Automated Methods
Contact Information | Applications submitted via the website and email through the website at [.] | Partially Automated Methods

For Entrepreneurs:

Data Category | Source Channel | Collection Method
Identity Information | In addition to the channels specified above, directly from the data subject via investment documents, in hard copy and via email | Partially Automated and Non-Automated Methods
Contact Information | In addition to the channels specified above, directly from the data subject via investment documents, in hard copy and via email | Partially Automated and Non-Automated Methods

PURPOSES OF PROCESSING PERSONAL DATA AND LEGAL GROUNDS

Personal data are processed by the Data Controller for the purposes and legal grounds specified below:

For Potential Entrepreneurs:

Pursuant to Article 5(2)(c) of the Law, based on the legal ground that “processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract,” the purposes of processing personal data are as follows:

  • Carrying out communication activities

  • Evaluating business opportunities

For Entrepreneurs:

Pursuant to Article 5(2)(a) of the Law, based on the legal ground that “processing is explicitly stipulated by law,” or pursuant to Article 5(2)(ç), based on the legal ground that “processing is mandatory for the data controller to fulfill its legal obligations,” the purposes of processing personal data are as follows:

  • Conducting activities in compliance with legislation

  • Providing information to authorized public institutions and organizations

Pursuant to Article 5(2)(c) of the Law, based on the legal ground that “processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract,” the purposes of processing personal data are as follows:

  • Managing contract processes

  • Carrying out communication activities

Pursuant to Article 5(2)(f) of the Law, based on the legal ground that “processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject,” the purposes of processing personal data are as follows:

  • Carrying out audit and ethics activities

  • Following up and managing legal affairs

  • Conducting storage and archiving activities

In addition to the personal data processing activities specified above, personal data of Entrepreneurs such as name and surname and [.] data are processed based on explicit consent for the purpose of conducting application and promotional activities for investments, and are publicly published via the website with the [.] domain extension and J Start’s social media accounts. The relevant Explicit Consent Text prepared within this scope is submitted to the approval of the Entrepreneurs.

TRANSFER OF PERSONAL DATA / TRANSFER ABROAD

Personal data may be transferred by the Data Controller for the purposes and to the parties specified below:

Personal data of Potential Entrepreneurs are not shared with third parties.

Personal data of Entrepreneurs may be shared with:

Authorized Public Institutions and Organizations: Personal data may be shared with the Capital Markets Board, Revenue Administration, other administrative authorities upon request, and judicial authorities for the purpose of providing information to authorized persons, institutions, and organizations.

Suppliers: Personal data may be shared with law firms for the purpose of following up and managing legal affairs, with financial advisors and banks for the purpose of conducting finance and accounting activities.

DATA SUBJECT RIGHTS UNDER ARTICLE 11 OF THE KVKK

If you submit your requests regarding your rights through the communication channels specified below, the Data Controller will conclude your request free of charge as soon as possible and no later than thirty (30) days. However, if the transaction requires an additional cost, the fee determined by the Personal Data Protection Board may be charged.

Pursuant to Articles 11 and 13 of the KVKK, your rights include:

  • Learning whether your personal data are processed

  • Requesting information if your personal data have been processed

  • Learning the purpose of processing your personal data and whether they are used in accordance with that purpose

  • Knowing the third parties to whom your personal data are transferred domestically or abroad

  • Requesting correction of incomplete or inaccurate personal data and requesting notification of such correction to third parties to whom the data have been transferred

  • Requesting deletion or destruction of personal data if the reasons requiring processing no longer exist, even though the data have been processed in accordance with the KVKK, and requesting notification of such action to third parties to whom the data have been transferred

  • Objecting to a result arising against you due to the analysis of your data exclusively through automated systems

  • Requesting compensation for damages if you suffer damage due to unlawful processing of personal data

If you wish to submit a request regarding your personal data within the scope of the KVKK, you may submit your application by using one of the methods below:

  • Via registered electronic mail (KEP), secure electronic signature, or mobile signature, or by using the email address previously notified to J Start and registered in J Start’s systems, by sending an email to [.]@com

Your application must be submitted in accordance with Article 13 of the KVKK and Article 5 of the Communiqué on the Procedures and Principles of Application to the Data Controller published in the Official Gazette No. 30356 dated 10.03.2018.

This Privacy Notice may be updated in order to comply with changing conditions and legal regulations. Any updates made by the Data Controller will be notified to the Data Subject.