UPLASS PACKAGING USER INFORMATION TEXT

UPLASS AMBALAJ USER CLARIFICATION TEXT

Ensuring the security of our users' personal data is one of our foremost principles. Based on this principle, as UPLASS AMBALAJ SANAYİ VE TİCARET A.Ş. in our capacity as the Data Controller, we process the personal data of users who visit our website within the scope of our activities in the plastic packaging sector, in accordance with the Personal Data Protection Law No. 6698 (“KVKK”) and the relevant legislation.

With this Uplass Ambalaj Clarification Text, we would like to explain to you:

The identity of Uplass Ambalaj as the Data Controller,
The purposes for which your personal data is collected (processed) by Uplass Ambalaj,
To whom and for what purposes we may transfer your personal data,
How we obtain your personal data and the legal grounds for doing so,
And finally, what your rights are regarding your personal data.

Before sharing this information with you, here are some points that need to be clarified:

a. What is personal data? All kinds of information that serves to determine the identity of a natural person constitutes personal data. For example; individuals' first name, last name, phone number, and graduation information are some examples of personal data.

b. What is a Data Processing activity? It means any operation performed on personal data, whether or not by automated means—meaning via information systems or manually—such as obtaining, recording, storing, preserving, transferring, classifying, or preventing the use of data. For example, sharing your personal data with us when purchasing an Uplass Ambalaj product is a data processing activity carried out by us.

c. Who is the Data Controller? It is the natural or legal person who determines the purposes and means of the processing of personal data. In this respect, our Company is a data controller.

Our company, with the commercial title UPLASS AMBALAJ SANAYİ VE TİCARET A.Ş. and Tax Identification Number 1250360139, will be briefly referred to as “Uplass Ambalaj” in this text.

Uplass Ambalaj operates at its headquarters located at “Ömerli Mah. Doğanyurt cd. No:6/1 Arnavutköy/İstanbul” and its branch located at “1. OSB Mah.8. Cad. No:2 Yeşilyurt/Malatya”. For more detailed information about our company, you can visit the Contact section of our website at www.uplass.com.tr.

In light of the explanations above, our disclosures regarding the processing of your personal data within the scope of this Clarification Text are as follows:

1. Which of Your Personal Data is Processed If You Review the Uplass Ambalaj Website and E-Catalog, and Subsequently Purchase a Product?

From your identity information: First name, last name,
From your contact information: Phone number, city information, e-mail address,
From your customer transaction data: Call records, order information, payment method and details, invoices, Uplass Ambalaj specialist/consultant notes created for you, your work calendar,
From your transaction security data: IP address, User ID, device information (brand, model, technical specifications, and operating system information regarding the device used), username and password, approval logs of legal texts, entry and exit logs to the Uplass Ambalaj website, your log records, statistics of your test-taking and lesson-watching activities within Uplass Ambalaj,
From your Financial Information: Bank account information, IBAN number: TR39 0006 4000 0011 2840 2259 46 TL,
Marketing: Data containing program browsing durations and details, cookie records, survey responses,
Other: In-app feedback, rating, comment and opinion information, Product/Service Usage Information, Request/Complaint Management Information, Instagram username information.

2. Purposes of Processing Personal Data, Legal Grounds for Data Processing, and Methods of Collecting Personal Data During Your Review of the Uplass Ambalaj Product via E-Catalog and Purchase via Communication Channels

Processed Personal Data	Purposes of Processing	Legal Grounds	Collection Methods
First name-last name, e-mail, phone number, information contained in the CV, order information, payment method and details, IBAN information, invoice	To carry out the sales transaction of the product you reviewed via the e-catalog and subsequently wish to purchase through communication channels, to fulfill the requirements of the distance sales contract, and to issue and send the e-invoice/e-archive invoice to you.	It is necessary for the performance of our services if you review the e-catalog on the Uplass Ambalaj website and subsequently purchase the product through communication channels (KVKK Art. 5/2-c); it is mandatory to fulfill our legal obligations arising from the legislation related to the execution, security, and audits of the application (KVKK Art. 5/2-ç); data processing is mandatory for the establishment, exercise, or protection of a right (KVKK Art. 5/2-e); and finally, it is mandatory for our legitimate interests, provided that it does not harm the fundamental rights and freedoms of our users (KVKK Art. 5/2-f).	Your visit to the Uplass Ambalaj website, information systems and electronic devices, online electronic forms during the provision of the contract service, other printed forms, e-mail, and documents declared by the data subject.
First name-last name, e-mail, CV, phone number, log records, IP address, User ID, address, payment method and details, voice recordings of conversations with representatives (call records), order information, invoice	To provide post-sales technical support services following your visit and purchase, to ensure in-app security and audit, to resolve any potential disputes, to ensure your safety, the safety of Uplass Ambalaj employees, and other related third parties against any acts, crimes, or behaviors contrary to relevant laws and regulations; to fulfill our obligations arising from laws and regulations, and to exercise all kinds of lawsuit, defense, and objection rights against authorized and assigned private/public institutions and organizations; to conduct negotiation and settlement processes regarding disputes; to provide the necessary information to you in the event that you request information from us or make an application within the scope of legal rights; to prevent usage contrary to the contract, law, or regulations, and to detect suspicious transactions and unlawful usages.	It is necessary for us to fulfill our services if you purchase the product you reviewed on the Uplass Ambalaj website (KVKK Art. 5/2-c); it is mandatory to fulfill our legal obligations arising from the legislation related to the execution, security, and audits of the application (KVKK Art. 5/2-ç); data processing is mandatory for the establishment, exercise, or protection of a right (KVKK Art. 5/2-e); and finally, it is mandatory for our legitimate interests, provided that it does not harm the fundamental rights and freedoms of our users (KVKK Art. 5/2-f).	Your visit to the Uplass Ambalaj website, contacting us via the support line, requesting technical support after the purchase, reporting a problem with the Uplass Ambalaj digital product, calling Uplass Ambalaj representatives, or communicating with authorized persons via WhatsApp; information systems and electronic devices, online electronic forms during the provision of the contract service, other printed forms, e-mail, and documents declared by the data subject.
IP Address, User ID, Log Records, program login/logout information, username and password information	Ensuring transaction security.	Your personal data is processed for the realization of the stated purposes based on the legal grounds specified in Article 5 of the KVKK: "explicitly provided for in the laws" and "data 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."	Collected through information systems and electronic devices.
Problems and comments you report in the "Contact and Career" sections within the Uplass Ambalaj website (in-app feedback)	Identifying and fixing problems within the system, conducting Customer Satisfaction Activities, conducting Customer Relations Management Processes, tracking Requests / Complaints.	Your personal data is processed for the realization of the stated purposes based on the legal ground specified in Article 5 of the KVKK: "having been made public by the data subject themselves."	Your visit to the Uplass Ambalaj website, collected through information systems and electronic devices.
First name, last name, e-mail address, mobile phone information, IP address, User ID, usage (browsing) information obtained during your visit to our Uplass Ambalaj website, cookie information (advertising identifier/ID information, information of the city you live in)	Offering special opportunities and deals to you, organizing general or personalized campaigns, advantages, promotions, advertisements, and other events, performing profiling, reporting, marketing, and analysis studies, conducting Uplass Ambalaj advertisements and marketing/communication activities within the Application, Site, or other 3rd party environments (sending special or general notifications within the Application, targeted advertising/promotions, and ensuring an effective user experience, customizing the user screen, special campaigns offered to you, surveys), conducting studies to improve your user experience and strategic planning, analysis, and business development regarding operational processes, performing statistical studies regarding usage.	Processed within the scope of marketing, segmentation, and analysis studies based on the legal ground of your “explicit consent” (KVKK Art. 5/1) regarding personal data processing processes and commercial communication activities.	Your visit to the Uplass Ambalaj website, participating in Uplass Ambalaj surveys, and submitting opinions, suggestions, and ratings; collected through information systems and electronic devices.
Approval logs of legal texts (Clarification Text, Explicit Consent Text)	Fulfilling our burden of proof arising from the law.	Your personal data is processed for the realization of the stated purposes based on the legal grounds specified in Article 5 of the KVKK: "it is mandatory for the fulfillment of our legal obligations arising from the legislation related to the execution, security, and audits of the application (KVKK Art. 5/2-ç)" and "data processing is mandatory for the establishment, exercise, or protection of a right (KVKK Art. 5/2-e)."	Collected through information systems and electronic devices.
Information regarding your suggestions, opinions, and ratings made through any channel	Creating statistical data for the purpose of improving and developing services, Uplass Ambalaj studies aimed at improving your user experience.	Your personal data is processed for the realization of the stated purposes based on the legal ground specified in Article 5 of the KVKK: "it is mandatory for our legitimate interests, provided that it does not harm the fundamental rights and freedoms of our users (KVKK Art. 5/2-f)."	Your visit to the Uplass Ambalaj website, participating in Uplass Ambalaj surveys, and submitting opinions, suggestions, and ratings; collected through information systems and electronic devices.

3. To Whom and For What Purposes Do We Transfer Your Personal Data?

Your personal data may be transferred to the relevant authorities within the framework of KVKK Art. 28/1 upon request, without an obligation to clarify and without seeking your explicit consent. Apart from this, in unforeseen circumstances, your personal data may be transferred to public institutions specified in the laws (such as administrative authorities like Ministries) upon request, within the scope of the purposes and limitations provided in the law.

Apart from our legal obligations that do not require an obligation to clarify and your explicit consent, within the framework of the conditions specified in Article 8 of the law, we transfer your data to:

Uplass Ambalaj partners and solution partners for the purposes of performing services and improving services,
Logistics companies for the delivery of orders, banks for financial processes, and abroad for marketing purposes, subject to your explicit consent,
Authorized and assigned private or public institutions and organizations (such as tax offices, the Ministry of Family and Social Policies) and judicial authorities and official institutions/organizations, in order to fulfill our obligations regarding providing information, documents, conducting our activities in accordance with the legislation, and other related obligations, and to exercise our legal rights such as the right to sue and respond,
Contracted financial consultancy and law firms for the purposes of conducting activities in accordance with the legislation and executing contract and accounting processes,
Domestic and international business partners, suppliers, and service providers (such as electronic communication service providers, call centers, those who collect personal data through devices, marketing/advertising/analysis service providers, database and server service providers, infrastructure maintenance and support, and software licensing service providers, e-invoice/e-archive invoice service providers, independent audit service providers, archiving and cloud service providers) from whom we receive information technologies, marketing/advertising/analysis activities, or expertise-requiring consultancy, etc., within the scope of the services provided and the purposes stated above, for the purpose of fulfilling the service activities of Uplass Ambalaj, provided that you give your consent.

4. Retention Periods of Your Personal Data

Your personal data is stored for the periods stipulated in the legal legislation or required by the purpose of processing. At the end of the period, it is subjected to periodic destruction processes.

5. What Are Your Rights Regarding Your Personal Data?

We would like to remind you that pursuant to Article 11 of the Personal Data Protection Law, you have the following rights:

To learn whether your personal data is processed or not,
To request information if your personal data has been processed,
To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
To know the third parties to whom your personal data is transferred at home or abroad,
To request correction of your personal data if it is incomplete or incorrectly processed, and to request that the operation performed within this scope be notified to the third parties to whom your personal data has been transferred,
To request the deletion or destruction of your personal data despite being processed in accordance with the provisions of the KVKK and other relevant laws, in the event that the reasons requiring its processing cease to exist, and to request that the operation performed within this scope be notified to the third parties to whom your personal data has been transferred,
To object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems,
To request compensation for damages in the event that you suffer damage due to the unlawful processing of your personal data.

Uplass Ambalaj runs the necessary systems within administrative and technical capabilities, in accordance with the Law, to enable our users to exercise their personal data rights.

You can always submit your requests regarding your rights in writing, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, or by using a registered electronic mail (KEP) address, secure electronic signature, mobile signature, or the electronic mail address you previously notified to us and is registered in our system, to the addresses specified below. If you wish, you can submit your application to our Company using the methods specified in the UPLASS AMBALAJ SANAYİ VE TİCARET A.Ş. “Data Subject Application Form”. Your request will be concluded free of charge as soon as possible and within thirty days at the latest, depending on its nature. However, if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board may be charged.

Data Controller: UPLASS AMBALAJ SANAYİ VE TİCARET A.Ş

E-mail: info@uplass.com.tr

KEP Address: avvplastik@hs01.kep.tr

Address: Ömerli Mah. Doğanyurt cd. No:6/1 Arnavutköy/İstanbul

Necessary explanations regarding the processing activities of your personal data are included in this Clarification Text. Nevertheless, if you request more detailed information on this matter, you can review our Personal Data Processing and Protection Policy on our website at www.uplass.com.tr or call us.