COMMERCIAL ELECTRONIC MESSAGE
DISCLOSURE AND CONSENT TEXT

Dear customer; on the ground of obtaining your explicit consent regarding sending a commercial electronic message and processing personal data within this context, this disclosure and explicit consent text is prepared and submitted for your information by “MINDOSHERE INCORPORATION” and “UDE KURUMSAL VE BİREYSEL GELİŞİM HİZMETLERİ ULUSLARARASI TİC. LTD. ŞTİ.” (“Mindturtle”) in order to fulfill the obligation to inform and to obtain your explicit consent to send a commercial electronic message, pursuant to the Law on Personal Data Protection No 6698 (“KVKK”), the Law on Regulation of Electronic Commerce No 6563 (“ETK”) and the General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”).

As subjected to the term and provision of this informing, by marking the checkbox stating that “I would like to receive e-mails from Mindturtle including customized suggestions, campaigns, consultancy tips, consultancy updates and reports developed to improve me and my business within the scope of the Disclosure and Consent Text.”, the related person accepts that Mindturtle can process his/her personal data and commercial electronic messages such as e-mail, short messages (SMS), automatic calls, phone calls, push notifications and other messages can be sent through a computer, phone, fax, e-mail, social media and another online advertisement network, other wireless network and other electronic media to himself/herself related with a presentation, advertisement promotion, sale, marketing of any product/service, the issues about celebration, wishes by Mindosphere Incorporation and license holder company “Ude Kurumsal ve Bireysel Gelişim Hizmetleri Uluslararası Tic. Ltd. Şti.” pursuant to provisions of the GDPR, CCPA, KVKK, ETK and other related laws. Also, Mindturtle accepts, declares and undertakes that it will act in compliance with the GDPR, CCPA, KVKK, ETK and any regulations which are enacted or will be enacted based on these regulations, and fulfill any legal obligations.

1. Your Personal Data Processed:

Your personal data given below is processed by Mindturtle in the context of your consent;

• ID Information: Name, Surname, and Country
• Contact Information: E-mail Address
• Occupational Information: Sector and Title

2. The Methods and Legal Grounds of Processing Personal Data

Your personal data such as ID, Contact or Occupational Information collected in the process of being a member on the website, www.mindturtle.com,  or of the fulfillment of the form for updating membership information or accessed through the link in the short message/e-mail sent to you, is obtained by marking checkbox (opt-in)stating that by marking the checkbox regarding that you give your explicit consent for your personal data is processed on the purpose of sending a commercial electronic message as short message or e-mail, stating that “I would like to receive e-mails from Mindturtle including customized suggestions, campaigns, consultancy tips, consultancy updates and reports developed to improve me and my business within the scope of the Disclosure and Consent Text”.


3. The Purpose of Processing of Your Personal Data

Your Personal Data is processed in the context of the purposes given as follows;

• To plan and/or enforce the activity for sale and marketing of the product/service
• To announce general or special opportunities regarding products/services
• To send developments and reports regarding the consultancy
• To send a message related to celebration, wishes, greetings
• To operate activity increasing the user experience by monitoring movement of the customer
• To plan related process in order to obtain the maximum benefit of provided product/service
• To manage customer service and relationships
• To plan and enforce the activity of customer satisfaction
• To plan and enforce the process of creating product loyalty and increasing it
• To fulfill obligations imposed by the Ministry of Trade and Custom and other public institutions and organizations
• To access statistical information in order to more effectively operate our Company’s financial and administrative business and for taking ads/correct technical analysis/reporting/ personal targeting.

Your personal data indicated in this disclosure text can be processed in the context of your explicit consent, under the purpose given above upon your confirmation of this disclosure text.

 
4. Transfer of Your Personal Data (Abroad/Domestic)

Based on your explicit consent as per article 5(1) of the KVKK and according to the relevant provisions of the GDPR and CCPA, your personal data can be processed, transfer abroad/domestic in the context of purposes and legal grounds given here, shared to Mindosphere Inc. and Ude Kurumsal ve Bireysel Gelişim Hizmetleri Uluslararası Tic. Ltd. Şti., IT firms providing service or in cooperation with our Company, independent auditing firms, our business partners in the telecommunication or communication sector, the server hosting providers, the data centers, the cloud platforms, the authorities which are entitled to ask customer information like Ministry of Custom and Trade, legally authorized public institutions in compliance with the GDPR, CCPA, and purpose and conditions processing of personal data stipulated under article 8 and 9 of the KVKK on the purpose of planning and enforcing the marketing and business strategy of Mindturtle, carrying out necessary practices by the related department in order to enforce sale and advertisement activities operated by Mindturtle and managing business process depended on it, providing legal, technical and commercial business safety of “Ude Kurumsal ve Bireysel Gelişim Hizmetleri Uluslararası Tic. Ltd. Şti.” which is in cooperation with us and other third people.

 
5. The Period of Processing of Your Personal Data

Your personal data is processed for the period, if available, laid down by relevant legislation, or the period required for the purpose for which the personal data is processed. In the case of expiration of related period your personal data will be erased, destructed or anonymized ex officio or upon your request, your personal data will be erased, destructed or anonymized in compliance with “the Regulation on Erasure, Destruction or Anonymisation of Personal Data”.


6. As A Data Subject, Your Rights

In the context of the GDPR, CCPA, KVKK and other related regulations in force, you have rights:

i. to learn whether his/her personal data is processed or not,
ii. to demand for information as to if your personal data has been processed,
iii. to learn the purpose of the processing of your personal data and whether these personal data is used in compliance with the purpose,
iv. to know the third parties to whom your personal data is transferred in-country or abroad,
v. to request the rectification of the incomplete or inaccurate data, if any,
vi. to request the erasure or destruction of your personal data under the conditions given by the law,
vii. to request reporting of the operations carried out pursuant to sub-paragraphs (v) and (vi) to third parties to who your data have been transferred,
viii. to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,
ix. to claim compensation for the damage arising from the unlawful processing of your personal data.

With the documents identifying your ID, in regard to the use of these rights you can (i) deliver by hand your request with a wet-ink signature to our Company located at the addressNidakule Göztepe, Merdivenköy Mh. Bora Sk. No:1 Kat:7 Kadıköy İstanbul or (ii) submit via notary to our Company located atNidakule Göztepe, Merdivenköy Mh. Bora Sk. No:1 Kat:7 Kadıköy İstanbul or (iii) send it with a secure electronic signature, mobile signature or through registered mail to legal@mindturtle.com.

Informed explicit consent can be withdrawn without any excuse. If you would not like to receive commercial electronic messages anymore, commercial electronic messages can be stopped without an excuse, anytime you follow the transaction (or through the IYS which runs from 1 June 2020) defined in the short message or e-mail sent to you.