PRIVACY POLICY

The identity and contact information of our Company, which holds the title of data controller in accordance with the KVKK, is as follows:

Within the scope of this Notice;

"KVKK"

"KVKK" means Law No. 6698 on the Protection of Personal Data,

"Personal Data"

"Personal Data" means any information relating to an identified or identifiable natural person,

"Sensitive Personal Data"

"Sensitive Personal Data" means data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, dress code, association, foundation or union membership, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data,

"Processing"

"Processing" means any operation performed on personal data such as collection, recording, storage, preservation, alteration, reorganization, disclosure, transfer, acquisition, making accessible, classification, or prevention of use, whether wholly or partially by automatic means or by non-automatic means provided that it is part of a data recording system,

"Data Controller"

"Data Controller" means the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system,

"Data Processor"

"Data Processor" means the natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller,

"Data Subject"

"Data Subject" means the natural person whose personal data is processed,

"Explicit Consent"

"Explicit Consent" means consent that is related to a specific subject, based on information, and freely given,

"Board"

"Board / Personal Data Protection Board" means the decision-making body established pursuant to Law No. 6698 and performing the duties assigned by the Law,

"VERBIS"

"VERBIS" means the Data Controllers Registry Information System maintained for the purpose of entering information about personal data processed by data controllers

shall mean.

In accordance with the KVKK and relevant legal regulations, the categories of personal data that may be processed by our Company within the scope of the purposes and legal reasons stated in this Notice are as follows:

Your personal data may be processed for the following purposes within the personal data processing conditions specified in Article 5 of the KVKK, in accordance with the principles stipulated in the KVKK:

• Execution of product and service provision, development, and delivery processes
• Evaluation of demo, quote request, and contact applications regarding products/services and software solutions
• Execution of customer relationship management processes
• Execution of activities aimed at customer satisfaction
• Follow-up of requests/complaints
• Execution of goods/services sales processes
• Execution of goods/services after-sales support services
• Execution of advertising/campaign/promotion and marketing processes
• Execution of communication activities
• Measurement of online visitor traffic and improvement of user experience
• Execution of information security processes
• Execution of business continuity activities
• Execution of storage and archiving activities
• Execution of activities in compliance with regulations
• Providing information to authorized persons, institutions, and organizations

Personal data processing activities carried out by the Company are performed within the framework of the KVKK and related secondary regulations, based on the following legal reasons within the scope of Article 5 of the KVKK:

• Explicitly stipulated by law
• Necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract
• Necessary for the data controller to fulfill its legal obligations
• Necessary for the establishment, exercise, or protection of a right
• Necessary for the legitimate interests pursued by the data controller, provided that this does not harm the fundamental rights and freedoms of the data subject

Your personal data is processed within the scope of software products and SaaS (Software as a Service) services offered by our Company; creating user records, providing product and panel access, establishing and performing service contracts, license/subscription management, meeting technical support and customer requests, performing systemic performance and security monitoring, improving user experience, and for the Purposes specified in this Notice.

In this context, your data may be collected through automatic and/or non-automatic methods via website membership/contact/support forms, email, telephone, software usage logs, cookies, customer support systems, and similar digital channels.

Your collected personal data may be transferred, based on legitimate interest, to our domestic dealers, branches, consultants and technical service providers located domestically and/or abroad who process personal data on behalf of our Company for IT infrastructure services, our lawyers and consultants within the scope of confidentiality obligations for legal process follow-up, and other legally authorized public/private institutions and organizations, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK, in order to fulfill the above-mentioned Purposes.

Your personal data will not be shared with third parties or transferred abroad except in the cases listed above.

The Company will delete, destroy, or anonymize the personal data covered by this Notice, as regulated in Article 138 of the Turkish Penal Code and Article 7 of the KVKK, in accordance with the relevant legal provisions, upon the Company's own decision or upon request of the personal data subject, when the reasons requiring its processing no longer exist, even though it has been processed lawfully.

As a data subject within the scope of Article 11 of the KVKK, you have the right to:

You have these rights.

As a data subject, if you have a request regarding your rights under Article 11 of Law No. 6698; with a message that meets the minimum conditions stipulated by the Communiqué on the Procedures and Principles of Application to the Data Controller:

• Via email to contact@orceus.com from your email address registered in our system or with a secure e-signature
• In writing to our Company address, in person or through a notary

you can submit your application. As the Company, we will conclude your application free of charge as soon as possible and within thirty days at the latest, depending on the nature of your request. However, if the process requires an additional cost, the fee determined by the Personal Data Protection Board will be charged by the Company.

The Company reserves the right to reject your application if it is found to be incorrect, unauthorized, lacking a valid basis, or intended for misuse.