Privacy Statement

1. Introduction

Cerebra is dedicated to adhering to the principles and rules introduced by Law No. 6698 on the Protection of Personal Data (“Law”) and other relevant legislation concerning the protection of personal data and ensuring the protection of the rights and freedoms of individuals whose data are processed.

Within the scope of the Law, personal data refers to any information relating to an identified or identifiable natural person (“Personal Data“) and Personal Data of Special Nature, which is a special type of this, refers to data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or trade union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data (“Personal Data of Special Nature“). In this context, the definition of Personal Data also includes your Sensitive Personal Data.

2. Method of Collection of Personal Data and Legal Reasons for Processing

Your Personal Data is collected in connection with the transactions with Cerebra and for the purpose and scope specified in Section 4 below, by automatic or non-automatic means, verbally, in writing or electronically and through the following methods and third parties. In this respect, the methods and means of personal data collection are as follows:

  1. Through the information provided verbally and/or in writing within the scope of the processes carried out regarding the services provided by Cerebra,
  2. Through the suggestions, requests and complaints submitted through the Cerebra’s website,
  3. Through customer cards, business cards and similar documents provided within the scope of customer relations,
  4. Through the closed circuit camera system located at the premises of Cerebra,
  5. Through third parties from whom Cerebra receives services in relation to its customers and with whom Cerebra has a business relationship.

The legal reasons specified in Articles 5 and 6 of the Law regarding the processing of Personal Data are as follows:

  1. Your explicit consent,
  2. Explicitly stipulated in the laws,
  3. It is necessary for the protection of the life or physical integrity of the person who is unable to disclose his/her consent due to actual impossibility or whose consent is not legally valid,
  4. Processing personal data in relation to the conclusion or performance of a contract,
  5. It is mandatory for the fulfilment of our legal obligations,
  6. It has been publicised by the person concerned,
  7. Data processing is mandatory for the establishment, exercise or protection of a right and
  8. It is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms.

3. Your Personal Data Collected

The Personal Data we collect from you are your data that we process in proportion to the processing purposes specified in Section 4 below.

4. Purposes of Processing Your Personal Data

Your Personal Data is processed by Cerebra for the following purposes based on your explicit consent or in other cases legally permitted under the Law:

  1. Invoicing customers after the sale of services, fulfilment of tax and other legal obligations (identity, contact, finance, customer transaction information) within the scope of carrying out activities in accordance with the legislation,
  2. Carrying out customer relationship management processes and ensuring the follow-up of customer requests/complaints in this context (identity information, contact information, customer transaction information, transaction security information, financial information, request/complaint management information),
  3. Archiving business cards of customers within the scope of conducting customer relations (identity, contact, occupational information),
  4. Ensuring physical space security (physical space security knowledge),
  5. Follow-up and execution of legal affairs (identity, contact, customer transaction, legal transaction, financial information),
  6. Providing information (identity, contact, customer transaction, financial, physical space security information) to authorised persons, authorities and institutions in the context of the fulfilment of legal obligations and requests of competent administrative and judicial authorities.

5. To whom and for what purpose personal data can be transferred

Cerebra may transfer your Personal Data, based on your explicit consent and in other cases permitted by law (as outlined in Section 4) to group companies located domestically, business partners and/or service providers both domestically and internationally, who collaborate with and/or provide services to Cerebra; to third parties who provide support in areas related to law, information technology, and other activities of Cerebra (including firms providing storage, information processing, backup, software, cloud computing support such as Microsoft 365, Drive servers); and to competent authorities and law enforcement agencies upon request, for the resolution of legal disputes, and to fulfill obligations arising from regulations.

6. Your rights

As a personal data owner, you can request the following rights from Cerebra, which is the data controller, at any time in accordance with Article 11 of the Law.

The rights you have in this context are as follows:

  1. To learn whether personal data is being processed,
  2. Request information if personal data has been processed,
  3. To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
  4. To know the third parties to whom personal data are transferred domestically or abroad,
  5. To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this framework to third parties to whom personal data is transferred,
  6. To request the deletion, destruction or anonymisation of such data within 30 (thirty) days in accordance with the provisions of the Regulation on the Deletion, Destruction or Anonymisation of Personal Data in the event that the reasons requiring its processing disappear, although it has been processed in accordance with the Law and other relevant provisions of the law, and to notify the third parties to whom the personal data has been transferred,
  7. To object to the emergence of a result to the detriment of the person himself/herself by analysing the processed data exclusively through automated systems,
  8. In case of damage due to unlawful processing of personal data, to demand compensation for the damage.

The above-mentioned requests shall be submitted to Cerebra as the data controller in writing or by other methods to be determined by the Personal Data Protection Board (”Board”).

In this context, you may submit your request regarding your above-mentioned rights to our e-mail address given below, which may change from time to time, via your registered electronic mail (KEP) address, with secure electronic signature, mobile signature or by using your electronic mail address previously notified by you to Cerebra and registered in the Cerebra’s system (by attaching documents identifying your identity) or you may hand-deliver a wet-signed petition with documents identifying your identity to our postal address below, which may change from time to time, or send it through a notary public.

In the application that you have as a personal data owner and that you will make in order to exercise your rights mentioned above and that includes explanations regarding the right you request to exercise; the matter you request must be clear and understandable, the subject you request must be related to your person or if you are acting on behalf of someone else, you must be specifically authorised in this regard and this authorisation must be documented, the application must contain your identity and address information.

Cerebra shall finalise the requests included in the application free of charge as soon as possible and within thirty days at the latest (if there is no cost) depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff to be determined by the Board may be charged.

The provisions of this Policy may be amended or renewed at any time and for any reason without notice. The amended provisions become effective on the date of publication on our website.

Data Controller : Cerebra

Postal address : Büyükdere Cad. Quasar No:76 /172 Şişli / İstanbul 34394 Türkiye

E-mail address : [email protected]

* Cerebra Danışmanlık Hizmetleri Limited Şirketi & Cerebra Denetim Serbest Muhasebeci Mali Müşavirlik Anonim Şirketi