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PERSONAL DATA PROCESSING DISCLOSURE STATEMENT IN ACCORDANCE WITH THE PERSONAL DATA PROTECTION LAW
ADGAGER ARAŞTIRMA HİZMETLERİ A.Ş. (“ADGAGER”) takes utmost care to protect all kinds of personal data of our website or mobile application visitors, customers, and members (“GAGER”) at https://www.adgager.com/.

Therefore, we inform you with this “Disclosure Statement” regarding the collection, processing, purpose of processing, transfer of personal data, and the rights of the personal data owner, in accordance with our Constitution, International Agreements, and relevant legislation, particularly the Personal Data Protection Law No. 6698 (“KVKK”).

1. DATA CONTROLLER

Your personal data may be processed within the scope specified below by ADGAGER ARAŞTIRMA HİZMETLERİ A.Ş., located at ARI 4 Binası No: 2/50/6 Reşit Paşa Mah. Katar Cad. No:4 34467 Sarıyer / İSTANBUL, as the data controller in accordance with the “KVKK”.

2. COLLECTION, PROCESSING, PURPOSE OF PROCESSING, AND TRANSFER OF PERSONAL DATA

Personal data refers to any information relating to an identified or identifiable natural person. The processing of personal data involves any operation performed on data such as obtaining, recording, storing, retaining, altering, rearranging, disclosing, transferring, taking over, making available, classifying, or preventing its use by automatic or non-automatic means, provided that it is part of any data recording system.

Your personal data may be processed as follows:

1. a) In accordance with the law and principles of honesty,
2. b) Accurately and, where necessary, kept up to date,
3. c) For specific, explicit, and legitimate purposes,
4. d) Processed in a manner relevant, limited, and proportionate to the purpose for which they are processed,
5. e) Kept for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

Adgager, as a comprehensive market research industry and idea evaluation platform, is an online data collection company (excluding special categories of personal data) focused on providing high-quality data. Within the scope of our “Privacy Policy,” the collected data is aggregated and reported about groups rather than individuals.

As the data controller, Adgager retains your personal data for purposes in line with the management and execution of research and reporting services, which will be specified below:

– Creating databases, listing, reporting, verifying, analyzing, and making evaluations, producing statistical information, and sharing them with experts when necessary.

– Contacting you through communication channels you have directly shared with us for informational purposes.

– Using them in the processes necessary for recruitment to our company.

– Utilizing them in digital and print media for communication activities, news, developments, and informational purposes related to our company.

– Processing for purposes other than those stated above, as required by law and regulations.

Your personal data is processed and stored in any verbal, written, or electronic medium in line with the specified purposes to provide the products and services offered by our company within the legal framework and to fulfill our company’s contractual and legal obligations fully and correctly.

Participation in our panel and research is voluntary. You can become a member by filling out our registration form on our website or mobile application at https://www.adgager.com/ or by clicking links on the websites of our partners who collect some personal and general consumer information about you. By registering, you agree to share your personal information with ADGAGER A.Ş., a company based in Turkey, and that this information will be stored on Adgager A.Ş.’s servers located in the United States and Turkey. Adgager collects personal information when an individual registers to become a member of one of our panels. Participation in any of our panels or research is voluntary. After registration, we ask panel members to provide us with more personal information to be invited to suitable surveys. To become a panel member, we ask you to fill out a registration form to collect a certain amount of personal information and general consumer information. To send you email invitations to participate in upcoming research, we ask for your email address and mobile phone information. Other information such as your name, address, gender, birth date, and employment status is used to match you with suitable market research projects. Your birth date is used to automatically update your age so we can target marketing groups based on age. We ask for this information to see if you are eligible for specific projects. Emails from Adgager will be sent to the primary email address you provided during registration or, if you prefer, to your mobile phone. If you become a panel member, your information (name, address, city, state, and postal code) will also be used for incentive purposes. This information is necessary to ensure that we can send your reward to the correct address when GAG incentives are credited to your account, and you wish to redeem them. Sometimes, third parties may be used for the organization of sweepstakes or the delivery of prizes; your personal information will be used solely for the purpose of sending your prize.

After registration, we ask panel members to provide us with more personal information to be invited to suitable research. In some cases, Adgager may ask you to inform us about your sensitive personal information; if we are not legally permitted to process such special information, we will seek your explicit consent. Generally, sensitive information that may be collected by Adgager includes race or ethnic origin, political opinions, physical or mental health or condition, and sexual life. This information is not shared with third parties unless required by law or as part of the transfer of Adgager’s operations.

If you participate in research or provide us with your personal information without being a panel member, the personal information we will retain is limited to your email address, gender, age, ethnicity, postal code, machine ID, and IP address. We do this to communicate with you if you win a prize or qualify for an incentive, to direct you to suitable research, and to improve the user experience. If you are not selected to become a member of the Adgager panel, we will not contact you for any reason except to inform you that you have won a prize or qualified for an incentive. If you qualify for a prize or incentive, we will collect and retain your personal information as required by law or regulations.

Our website does not offer public logs or community forums and operates on a closed system.

Your personal data may be shared with authorities such as Ministries and the Social Security Institution, judicial authorities, and similar authorized public institutions and organizations, and Private Health Insurance companies, to fulfill our company’s legal obligations.

Adgager may transfer personal data to third parties (third-party companies, institutions, group companies, third natural persons) in line with lawful personal data processing purposes by taking necessary security measures. Adgager acts in accordance with the regulations stipulated in articles 8 and 9 of the KVKK. The information may be retained domestically or transferred abroad to achieve the purposes mentioned here by taking necessary security measures.

As regulated in Article 138 of the Turkish Penal Code and Article 7 of the KVKK, although it has been processed in accordance with the relevant legislation, personal data will be deleted, destroyed, or anonymized ex officio by our institution or upon the request of the personal data owner when the reasons for processing no longer exist.

3. RIGHTS OF THE PERSONAL DATA OWNER

As personal data owners, you may apply to the data controller, Adgager, to:

1. a) Learn whether your personal data is being processed,
2. b) Request information if your personal data has been processed,
3. c) Learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
4. d) Know the third parties to whom your personal data is transferred, domestically or abroad,
5. e) Request correction if your personal data is incomplete or incorrectly processed,
6. f) Request deletion or destruction of your personal data,
7. g) Request notification of the actions taken in accordance with (e) and (f) to the third parties to whom your personal data has been transferred,
8. h) Object to the occurrence of any result that is to your detriment by analyzing the processed data exclusively through automated systems,
9. i) Request compensation for the damages if you suffer damage due to unlawful processing of your personal data.

4. EXERCISE OF RIGHTS AND APPLICATION

In accordance with the “KVKK,” you can submit your requests regarding the exercise of the above-mentioned rights together with documents verifying your identity through our website https://www.adgager.com/, mobile application, Registered Electronic Mail Address, secure electronic signature, mobile signature, mail, notary, or other methods specified in the “KVKK.”

The application must include:

1. a) Name, surname, and if the application is in writing, signature,
2. b) For citizens of the Republic of Turkey, T.C. identification number, for foreigners, nationality, passport number, or identity number if any,
3. c) Residence or workplace address for notification,
4. d) Notification email address, telephone, and fax number, if any,
5. e) Subject of the request.

Applications will be concluded free of charge as soon as possible and within a maximum of thirty days. However, if the process requires an additional cost, a fee of 1 (one) Turkish Lira may be charged for each page over ten pages. The response to the application may be provided on CD, Flash Memory.