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Privacy Statement

SABANCI VENTURES WEBSITE PRIVACY STATEMENT

This Sabancı Ventures Website Privacy Statement provides information on the principles followed by Hacı Ömer Sabancı Holding Anonim Şirketi (“Sabancı Holding”) while processing personal data as per the Law No. 6698 on Personal Data Protection Law (“KVKK”) and how to use your rights under the Article 11 of KVKK.

1. Purposes of Use of Data, Legal Reasons and Collection Methods

As per the principles of Article 4 of the KVKK and in connection with the purposes and legal reasons stated below, Sabancı Holding collects data through essential and non-essential cookies, application form, newsletter registration form and other areas of the Web Site and further process (automated and non-automated means), stores and secures the data in Sabancı Holding’s physical and electronic systems.

1.1. Sabancı Ventures Parties

Personal Data Category 

Purpose of Processing

Legal Reasons 

Information provided on the Application Form (“Application Form Information”) either filled out directly by yourself or one of your team members while registering the Sabancı Ventures database (“Program”)

Evaluation of applications, maintenance of investment process, communication purposes

Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement (Article 5/2-c KVKK).

 

Name-surname, contact information (e-mail, mobile phone) startup name

Public entities and authorities who are legally authorized to get information.

It is a legal requirement for performance by Sabancı Holding of its legal obligations (Article 5/2-ç KVKK).

Application Form Information and other information you would like to share with Sabancı Holding during the Program (requests, questions, suggestions, and other personal information)

Assessment of the startup and management of investment process.

The anonymized data is used for statistical purposes for improvement. 

 

Data processing is necessary for the establishment, exercise or protection of any right (Article 5/2-e KVKK).

Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK).

 

Application Form Information and other personal data which are necessary for the transactions following the Program.

Execution and completion of legal proceedings (such as company establishment, share transfer, partnership agreement) if you are awarded an investment from Sabancı Holding.

Preventing disputes, taking necessary legal actions, providing necessary information and documents in case of being involved in legal processes.

Processing is expressly provided for by the laws (Article 5/2-a KVKK).

Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement (Article 5/2-c KVKK).

Data processing is necessary for the establishment, exercise or protection of any right (Article 5/2-e KVKK).

 

Third-party personal data provided on the Application Form will also be processed under this Privacy Statement. Applicants should inform these third parties before registering for the Program. It is your responsibility to share the personal data of these third parties with Sabancı Holding in accordance with KVKK.

Sabancı Ventures may obtain services from external suppliers within the scope of the Program. In such cases where the data transfer is not made directly by Sabancı Holding, external suppliers may process, store and transfer your personal data abroad. Accordingly, external suppliers are responsible to take actions such as providing Privacy Statement or collecting explicit consent in accordance with KVKK.  

 Website Visitors

Personal Data Category 

Purpose of Processing

Legal Reasons 

Web traffic (IP address, port number, start and end time of the service provided, type of service used, amount of data transferred, member identification information).

Law No. 5651 on Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publication

Processing is expressly provided for by the laws (Article 5/2-a KVKK).

It is a legal requirement for performance by Sabancı Holding of its legal obligations (Article 5/2-ç KVKK).

2. Transfer of Personal Data

2.1. Sabancı Ventures Parties

Transferees

Personal Data Transferred

Purpose

Legal Reasons

Omtera Bilişim Teknolojileri ve Ticaret Şirketi (Asana Solutions Partner) 

Name-surname, contact information (e-mail, mobile phone) 

 

Data is transferred for the purpose of monitoring and managing the Program processes.

Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK).

Luckeye Bilgisayar Tanıtım Hizmetleri Yayıncılık ve Ticaret A.Ş.

Name-surname, contact information (e-mail, mobile phone)

 Data is transferred for registering applications. 

Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK). 

Advisory Board members, Consultants, Sabancı Group Companies (“Business Partners”).

Application Form Information and other information you would like to share with Sabancı Holding during the Program (requests, questions, suggestions, and other personal information)

Data is transferred for the purpose of effective execution and management of the Program processes, website functioning, evaluation of your startup. 

 

Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK).

Public entities and authorities

Application Form Information and other information you would like to share with Sabancı Holding during the Program (requests, questions, suggestions, and other personal information)

Preventing disputes, taking necessary legal actions, providing necessary information and documents in case of being involved in legal processes.

Receiving information/document requests from public entities and authorities. 

It is a legal requirement for performance by Sabancı Holding of its legal obligations (Article 5/2-ç KVKK);

Data processing is necessary for the establishment, exercise, or protection of any right (Article 5/2-e KVKK).

2.2. Website Visitors

Transferees

Personal Data Transferred

Purpose

Legal Reasons

Advisory Board members, Consultants, Sabancı Group Companies (“Business Partners”).

Application Form Information and other information you would like to share with Sabancı Holding during the Program (requests, questions, suggestions and other personal information)

Data is transferred for the purpose of effective execution and management of the Program processes, website functioning, evaluation of your startup. 

 

Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK).

Your rights under the Personal Data Protection Law

You may exercise your rights under Article 11 of the KVKK.

You may withdraw your explicit consent at any time.

To exercise your rights under Article 11 of the KVKK, you may use one of the methods given below as per the Communique on the Principles and Procedures for the Request to Data Controller (“Communique”):

By written application to the following application address: H.Ö. Sabancı Holding A.Ş. 4. Levent, 34330 Istanbul/Türkiye, with reference to the Legal and Compliance Department

ii By an e-mail sent to kvkk@sabanci.com>kvkk@sabanci.com from your e-mail address that you have provided to the Company and have been registered in the Company systems or

iii By an e-mail sent from your registered email address to the following registered e-mail address: sabanci@sabanci.hs02.kep.tr

Where the process requires additional costs, we may charge the fees laid down Article 7 of the Communique.

We may update this Privacy Statement in line with the new personal data processing activities that may occur from time to time. We recommend that you visit our website regularly so that you may follow the changes in this Privacy Statement.

Regards,

Data Controller

Hacı Ömer Sabancı Holding Anonim Şirketi

Sabancı Center 34330 4. Levent, İstanbul, Mersis No: 0454001967900016

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