TouchThink Smart Privacy Statement

Last Updated: March 2024

Your privacy is important to us. This privacy statement explains what personal data TouchThink Smart Co., Ltd.and its affiliates(en lo sucesivo denominado “TouchThink Smart”) collects from you (including but not limited to employee, customer, supplier and any third party who use the service of TouchThink Smart ), through our interactions with you and through our products, and how we use that data.

TouchThink Smart offers a wide range of products, from server products used to help operate enterprises worldwide, devices you use in your company, software for engineers use at factory, and services developers use to create and host what’s next. References to TouchThink Smart products in this statement include TouchThink Smart services, websites, software, servers and devices.

Please read the product-specific details in this privacy statement, which provide additional information about some of TouchThink Smart products. This statement applies to TouchThink Smart’s interactions with you and the TouchThink Smart products listed below, as well as other TouchThink Smart products that display this statement.

Official Platform: MyTouchThink Smart, TouchThink Smart official website, eStore, Live Chat, Return merchandise authorization (RMA) website, CRM system, IoT Academy, WISE PaaS Forum, AIM Forum.
TouchThink Smart Software WebAccess : WISE-PaaS/EdgeLink, Intelligent wards (iWards), UFleet+ and WISE-iService solutions
Third Party Platforms : Hubspot, Siebel, SalesForce.com, Live Chat, Workday

Agenda
Personal Data We Collect
How We Use Personal Data
Reasons We Share Personal Data
How to Access & Control Your Personal Data
Lawful Basis for Processing Your Personal Data
How Long Do We Keep Your Personal Data
Your Information and Countries Outside Europe
Protection Of Privacy
Your Rights
How to Contact Us
Privacy Notice for California Consumers
KVKK Personal Data Protection Policy
KVKK Clarification Text on the Contact Form Process
KVKK Confidentiality Agreement and Term of Use
Privacy Notice for Japan Consumers

1. Personal Data We Collect
TouchThink Smart collects data to operate effectively and provide you the best experiences with our products. You provide some of this data directly, such as when you create an TouchThink Smart account, administer your organization’s licensing account, submit a search query to resources center, register for an TouchThink Smart event, subscribe to marketing emails, purchase an TouchThink Smart product, use eStore and RMA services, sign up for MyTouchThink Smart, or contact us for support. We get some of it by recording how you interact with our products by, for example, using technologies like cookies, and receiving error reports or usage data from software running on your device.

We also obtain data from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time, but have included:

Data brokers from whom we purchase demographic data to supplement the data we collect.
Social networks when you grant permission to an TouchThink Smart product to access your data on one or more networks.
Service providers that help us determine a location based on your IP address in order to customize certain products to your location.
Partners with which we offer co-branded services or engage in joint marketing activities, y
Publicly-available sources such as open government databases or other data in the public domain.
You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature.

The data we collect depends on the context of your interactions with TouchThink Smart, the choices you make, including your privacy settings, and the products and features you use. The data we collect can include the following:

A. Name, identity and contact data
We collect your first and last name, ID Card number, passport number, email address, postal address, phone number, and other similar contact data.

B. Credentials
We collect passwords, password hints, and similar security information used for authentication and account access.

C. Demographic data
We collect data about you such as your age, gender, country, and preferred language.

D. Payment data
We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.

E. Device and Usage data
We collect data about your device and how you and your device interact with TouchThink Smart and our products. For example, we collect:

Product use data. We collect data about the features you use, the items you purchase, and the web pages you visit. This data includes your voice and text search queries or commands to TouchThink Smart official website, MyTouchThink Smart, eStore, Live Chat and RMA website. This also includes the settings you select and the software configurations you use most.
Device, connectivity and configuration data. We collect data about your device and the network you use to connect to our products. It includes data about the operating systems and other software installed on your device, including product keys. It also includes IP address, device identifiers (such as the registration ID and phone numbers), and regional and language settings.
Error reports and performance data. We collect data about the performance of the products and any problems you experience with them. This data helps us to diagnose problems in the products you use, and to improve our products and provide solutions. Depending on your product and settings, error reports (sometimes called “crash dumps”) can include data such as the type or severity of the problem, details of the software or hardware related to an error, contents of files you were using when an error occurred, and data about other software on your device.
Troubleshooting and Help Data.When you engage TouchThink Smart for troubleshooting and help, we collect data about you and your hardware, software, and other details related to the incident. Such data includes contact or authentication data, the content of your chats and other communications with TouchThink Smart, data about the condition of the machine and the application when the fault occurred and during diagnostics, and system and registry data about software installations and hardware configurations.
F. Interests and favorites
We collect data about your interests and favorites, such as the products you interested in, the Business application area you prefer, the Solution topic you track in TouchThink Smart website, or the favorite product you add to eStore shopping cart. In addition to those you explicitly provide, your interests and favorites may also be inferred or derived from other data we collect.

GRAMO. Contacts and relationships
We collect data about your contacts and relationships if you use an TouchThink Smart product to manage contacts, for example MyTouchThink Smart, or to communicate or interact with other people or organizations, for example Live Chat and worldwide trade show.

H. Location data
For products with location-enhanced features, we collect data about your location, which can be either precise or imprecise. Precise location data can be Global Navigation Satellite System (GNSS) data (e.g., GPS), as well as data identifying nearby cell towers and Wi-Fi hotspots, we collect when you enable location-based products or features. Imprecise location data includes, for example, a location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postal code level.

I. Content
We collect content of your files and communications when necessary to provide you with the products you use. For example, if you transmit a file using Live Chat, we need to collect the content of that file to display it to you and the other user as you direct. If you receive a data using Live Chat, we need to collect the content of that data to deliver it to your inbox, display it to you, enable you to reply to it, and store it for you until you choose to delete it. Other data we collect to provide communication services to you include the:

subject line and body of an email,
text or other content of an instant message,
audio and video recording of a video message, y
audio recording and transcript of a voice message you receive or a text message you dictate.
J. Video
If you enter TouchThink Smart headquarters, office buildings or other facilities, or attend an TouchThink Smart event, your image may be captured by our security cameras.
If you use eStore and MyTouchThink Smart, at your direction, we may also collect payment card information, receipt data, or financial transaction data, to provide the service.
If you use Enterprise Online Services, WebAccess, Intelligent wards (iWards), UFleet+ and WISE-iService solutions , TouchThink Smart collects Customer Data (including content), Support Data, and Administrator Data, defined below in the Enterprise and Developer Products section.
We also collect information you provide to us and the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide for customer support. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
Product-specific sections below describe data collection practices applicable to use of those products.

TouchThink Smart will not collect any personal data about you (e.g. your name, address, telephone number or e-mail address), unless you voluntarily choose to provide us with it (e.g. by registration, surveys, etc.). TouchThink Smart is the sole owner of the information collected on our web sites. Under no circumstances will we share your customer information with anyone other than those directly involved with the purchase and shipment of your order, unless you explicitly give us permission to do so. We may use your e-mail address to notify you of special offers and promotions that you are eligible to participate in as a registered customer. You may decline this service.

K. Non-Personal Data Collected Automatically
When you access our Web site, we may automatically (i.e., not by registration) collect non-personal data (e.g. type of Internet browser and operating system used, IP address, domain name of the Web site from which you came, number of visits, average time spent on the site, pages viewed). We use this data to monitor web interaction, analyses trends improve performance and content and study the needs of customers more closely. This will be performed in accordance with the applicable data privacy protection legal framework.

*Cookies
Most TouchThink Smart Sites use “cookies,” small text files that can be read by a web server in the domain that put the cookie on your hard drive. We may use cookies to store your preferences and settings; help with sign-in; provide targeted ads; and analyze site operations.

L. EU-U.S. & Swiss-U.S. Privacy Shield
TouchThink Smart adheres to the principles of the EU-U.S. and Swiss-U.S. Privacy Shield frameworks.

2. How We Use Personal Data
TouchThink Smart uses the data we collect for three basic purposes, described in more detail below: (1) to operate our business and provide (including improving and personalizing) the products we offer, (2) to send communications, including promotional communications, y (3) to show advertising, whether in our own products supported by advertising like eDM and Campaign, or in products offered by third parties. The proportion of customer information used in (2) & (3) is currently about 32.97%, and it is carried out with the consent of the customers.

In carrying out these purposes, we combine data we collect to give you a more seamless, consistent and personalized experience. For example, MyTouchThink Smart and eStore can use information about the products and services you use to make personalized Solution Ready Packages recommendations. However, to enhance privacy, we have built in technological and procedural safeguards designed to prevent certain data combinations. For example, we store data we collect from you when you are unauthenticated (not signed in) separately from any account information that directly identifies you, such as your name, email address or phone number.

A. Providing and improving our products. We use data to provide and improve the products we offer and perform essential business operations. This includes operating the products, maintaining and improving the performance of the products, developing new features, conducting research, and providing customer support. Examples of such uses include the following:
Providing the Products. We use data to carry out your transactions with us and to provide our products to you. Often, those products include personalized features and recommendations that enhance your productivity and enjoyment, and automatically tailor your product experiences based on the data we have about your activities, interests and location.
Customer support. We use data to diagnose product problems, repair customers’ devices, and provide other customer care and support services and joining events we host.
Product activation. We use data—such as device and application type, location, and unique device, application, network and subscription identifiers—to activate software and devices that require activation.
Product Improvement. We use data to continually improve our products, including adding new features or capabilities. For example, we use error reports to improve security features, search queries and clicks in Bing to improve the relevancy of the search results, usage data to determine what new features to prioritize, and audio recordings from voice input features to improve speech recognition accuracy.
Security, Safety and Dispute Resolution. We use data to protect the security and safety of our products and our customers, to detect and prevent fraud, to confirm the identity of individual and validity of software licenses, to resolve disputes and enforce our agreements. Our security features and products can disrupt the operation of malicious software and notify users if malicious software is found on their devices.
Business Operations. We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.
B. Communications
We use data we collect to communicate with you and personalize our communications with you. For example, we may contact you by phone or email or other means to inform you when a subscription is ending, discuss your licensing account, let you know when security updates are available, remind you about items left in your online shopping cart, update you or inquire about a service or repair request, invite you to participate in a survey, or tell you that you need to take action to keep your account active. Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications from TouchThink Smart by email, SMS, physical mail, and telephone. For information about managing your contact data, email subscriptions and promotional communications, please visit the Access and Controls section of this privacy statement.

C. Advertising
TouchThink Smart does not use what you say in email, chat, video calls or voice mail, or your documents, photos or other personal files to target ads to you.

We use data we collect through our interactions with you, through some of our products and on third-party web properties, to show advertising. For example:

TouchThink Smart may use your data to select and deliver some of the ads you see on TouchThink Smart web properties, such as touchthink.net, MyTouchThink Smart and eStore.
When the advertising ID is enabled in touchthink.net as part of your privacy settings, TouchThink Smart apps can access and use the advertising ID (much the same way that websites can access and use a unique identifier stored in a cookie) to select and deliver ads.
We may share data we collect with third parties, such as Siebel, Salesforce, and Google Analytics so we can service you better and target our marketing messages to your preferences. Nevertheless, we will ensure that those third parties comply with the data protection legislation applicable.
Advertisers may choose to place our web beacons on their sites in order to allow TouchThink Smart to collect information on their sites such as activities, purchases and visits; we use this data on behalf of our advertising customers to help target their ads. We also share data directly with service providers, such as Live Chat to permit them to provide services on our behalf or to partner with us in selecting and serving ads for our advertising partners.
The ads that you see may be selected based on data we process about you, such as your interests and favorites, your location, your transactions, how you use our products, your search queries, or the content you view.

The ads that you see may also be selected based on other information learned about you over time using demographic data, location data, search queries, usage data from our products and sites, as well as the sites and apps of our advertisers and partners. We refer to these ads as “interest-based advertising” in this statement. For example, if you view gaming content on touchthink.net, you may see offers for gaming on TouchThink Smart’s marketing emails. To provide interest-based advertising, we combine cookies placed on your device using information that we collect (such as IP address) when your browser interacts with our websites. If you opt out of receiving interest-based advertising, data associated with these cookies will not be used.

Further details regarding our advertising-related uses of data include:

Children and Advertising. We do not deliver interest-based advertising to children whose birthdate in their TouchThink Smart account identifies them as under 16 years of age.
Data Retention. For interest-based advertising, we retain data for no more than 12 months, unless we obtain your consent to retain the data longer.
Data Sharing. In some cases, we share with advertisers reports about the data we have collected on their sites or ads.
Data Collected by Other Advertising Companies. Advertisers sometimes include their own web beacons (or those of their other advertising partners) within their advertisements that we display, enabling them to set and read their own cookie. Additionally, TouchThink Smart partners with third-party ad companies to help provide some of our advertising services, and we also allow other third-party ad companies to display advertisements on our sites. These third parties may place cookies on your computer and collect data about your online activities across websites or online services. These companies may also be members of the NAI or DAA, which each provide a simple way to opt out of ad targeting from participating companies.

3. Reasons We Share Personal Data
We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. For example, we share your content with third parties when you tell us to do so. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.

In addition, we share personal data among TouchThink Smart-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.

Finally, we will access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to:

comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
protect our customers, for example to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone;
operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks; or
protect the rights or property of TouchThink Smart, including enforcing the terms governing the use of the services – however, if we receive information indicating that someone is using our services to traffic in stolen intellectual or physical property of TouchThink Smart, we will not inspect a customer’s private content ourselves, but we may refer the matter to law enforcement.
Please note that some of our products include links to products of third parties whose privacy practices differ from TouchThink Smart’s. If you provide personal data to any of those products, your data is governed by their privacy statements.

4. How to Access & Control Your Personal Data
You can view, edit, or delete your personal data online from many of TouchThink Smart’s websites. You can also make choices about TouchThink Smart’s collection and use of your data. How you can access or control your personal data will depend on which Websites you use. For example:

TouchThink Smart Account (My TouchThink Smart and eStore). If you wish to access, edit, or remove the profile information and payment information in your TouchThink Smart account, change your password, add security information or close your account, you can do so. From here, you can also access controls for other TouchThink Smart products.
TouchThink Smart Store. You can access your TouchThink Smart Store profile and account information, and clicking on “View account” or “Order history”
touchthink.net You can access and update your profile on touchthink.net
If you cannot access certain personal data collected by TouchThink Smart via the links above or directly through the TouchThink Smart websites you use, you can always contact TouchThink Smart by visiting our Contact us page. We will respond to requests to access or delete your personal data within 30 days

A. Your Communications Preferences
You can choose whether you wish to receive promotional communications from TouchThink Smart by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to opt out, you can do so by following the directions in that message. You can also make choices about the receipt of promotional email, telephone calls, and postal mail by signing in with your personal TouchThink Smart account, and viewing your communication permissions where you can update contact information, manage TouchThink Smart-wide contact preferences, opt out of email subscriptions, and choose whether to share your contact information with TouchThink Smart partners. If you do not have a personal TouchThink Smart account, you can contact us to find more assistance.

B. Your Advertising Choices
You may opt out of receiving interest-based advertising from TouchThink Smart by visiting here (Please click “Usuario” in upper right corner then click “My Profile” and you will be able to update your preference). When you opt out, your selection will be stored in Customer Relationship Management (CRM) system as a basis for sending advertisements.

C. Browser-Based Controls
Cookie Controls. Relevant browser-based cookie controls are described in the Cookies section of this privacy statement.
Tracking Protection. Internet Explorer (versions 9 and up) has a feature called Tracking Protection that will block third-party content, including cookies, from any site that is listed in a Tracking Protection List you add. By limiting calls to these sites, the browser will limit the information these third-party sites can collect about you.
Browser Controls for “Do Not Track.” Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, TouchThink Smart services do not currently respond to browser DNT signals. TouchThink Smart continues to work with the online industry to define a common understanding of how to treat DNT signals. In the meantime, you can use the range of other tools TouchThink Smart provides to control data collection and use, including the ability to opt-out of receiving interest-based advertising from TouchThink Smart as described above.

D. Cookie
What sort of cookies does the TouchThink Smart use?

Generally, our cookies perform up to three different functions:

Essential Cookies: Some cookies are essential for the operation of our website. For example, some cookies allow us to identify subscribers and ensure they can access the subscription only pages. If a subscriber opts to disable these cookies, the user will not be able to access all of the content that a subscription entitles them to.
Performance Cookies: We utilise other cookies to analyze how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website.
Functionality Cookies: We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you access the site, and recall your customization preferences, such as which regional edition of the website you want to see when you log in.
We also use functionality cookies to provide you with enhanced services such as allowing you to watch a video online. We also use or allow third parties to serve cookies that fall into the four categories above. For example, like many companies, we use Google Analytics to help us monitor our website traffic. We may also use third party cookies to help us with market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions and copyright policy.

Can a website user block cookies?
As we’ve explained above, cookies help you to get the most out of our websites. However, if you do wish to disable our cookies then please follow the instructions below from main browser providers:

Instructions for Microsoft Internet Explorer -Click here.
Instructions for Mozilla Firefox -Click here.
Instructions for Google Chrome -Click here.
Instructions for Apple Safari -Click here.
Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly.

E. We track whether users open our emails?
Our emails may contain a single, campaign-unique “web beacon pixel” to tell us whether our emails are opened and verify any clicks through to links within the email. We may use this information for purposes including determining which of our emails are more interesting to users, to query whether users who do not open our emails wish to continue receiving them.

5. Lawful Bases for Processing
We will only collect and process personal data about you where we have lawful bases. Lawful bases include:

A. Legitimate interest of TouchThink Smart
We will rely on legitimate interests as a basis for data processing where the processing of your data is not overridden by your interests or fundamental rights and freedoms. TouchThink Smart may process your personal data for the purposes of our legitimate interests or for the legitimate interests of third parties (e.g. your employer). For example, TouchThink Smart may process your personal data to enable TouchThink Smart to carry its business, such as:

conclusion and execution of agreements with your employer, supplier or business partners;
to record and financially settle delivered Services and Products;
sales, marketing and promotions;
account management;
customer service, finance and accounting;
investigación y desarrollo;
purchasing;
internal management and control;
quality control, consolidated reporting;
corporate transactions, such as a sale of a business or a part of a business to another company, or any reorganization, merger, joint venture, or other disposition of TouchThink Smart’s business, assets, or stock (including in connection with any bankruptcy or similar proceeding)
understand and improve our business or customer relationships generally
Please note that where we rely on legitimate interests, you have the right to object to the processing of your data.

Compliance with legal obligations to which TouchThink Smart is subject to;
Protect you, TouchThink Smart or others from threats (such as security threats or fraud)
Contract where processing is necessary for the performance of a contract with you (e.g. to deliver the Products or Services you have requested). Where we rely on contract, we will ask that you agree to the processing of personal data that is necessary for entering into or performance of your contract with TouchThink Smart.
If none of the criteria listed in a)-d) above applies or if consent is required by the applicable local legislation, TouchThink Smart shall obtain consent from you before processing your data. Where we process data based on consent, we will ask for your explicit consent. When seeking for consent, TouchThink Smart shall inform you;
Of the purpose of the processing for which consent is requested and;
Any other relevant details to seek to ensure legal processing.
Of the purpose of the processing for which consent is requested and
Any other relevant details to seek to ensure legal processing.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.

6. How long do we keep your personal data?
We keep your Personal Data for the period necessary to fulfill the purposes for which it has been collected and we may retain and use your personal data.

The criteria used to determine our retention periods include:

Are we subject to a legal, contractual, or similar obligation to retain the personal data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve personal data relevant to an investigation, or personal data that must be retained for the purposes of litigation;
do we have a contract in place with your employee or a business partner or are we engaged with you in any negotiation for the conclusion of a contract or any other operation or transaction;
Do you have an account with us? In this case we will keep the personal data while your account is active or for as long as needed to provide services to you. However, if you haven’t logged onto our website for 10 (ten) years we will delete your information from our systems provided that there are no other reasons including but not limited to prevention of fraud and abuses, enforce the contract we have with you or your employer, legal or regulatory requirements, resolve disputes, when we may also keep hold of some of your information as required, even after you have closed your account or it is no longer needed to provide the services to you.
Have you consented that we can retain your personal data?

7. Your information and countries outside Europe
Due to its international position, TouchThink Smart may need to transfer your personal data outside the European Union or European Economic Zone, including but not limited to Taiwan. Taiwan is not a country in respect of which there is a European Commission decision of adequacy, but we have put in place adequate measures to protect your privacy and your rights through the use of the European Commission’s standard data protection clauses.

You may also obtain a copy of these measures by contacting TouchThink Smart at info@touchthink.net

8. Protection of Privacy
With TouchThink Smart’s Privacy Policy and relevant regulations, TouchThink Smart takes appropriate technical and organizational security measures in accordance with the law to prevent any person’s privacy from being accidentally or deliberately damaged, lost, tampered with, unauthorized disclosure, and unauthorized access and other illegal or unauthorized processing. The aforesaid security measures including firewalls, anti-virus systems and other related information security equipment and necessary security protection measures, to protect the website and your personal data. Only authorized personnel can access your personal data, and all relevant personnel have signed a confidentiality agreement.

TouchThink Smart adopts a zero-tolerance policy for violations of privacy rights and personal information protection. If it is found through investigation that there is indeed a violation of this policy or related laws and regulations on privacy and personal information protection, TouchThink Smart will punish those involved in violations in accordance with relevant norms. , where necessary and will be pursued or retroactively pursued in accordance with applicable regulations.

Privacy and personal data protection are one of TouchThink Smart’s important risk management aspects and internal controls. TouchThink Smart also has an internal audit mechanism, which conducts audits on related topics at least once every two years, continuously improves related systems, and TouchThink Smart also irregularly entrusts external professional organizations to ensure the implement of privacy protection.

Secure Shopping
TouchThink Smart takes all precautions to protect your data. When you submit data through our website, your information is protected both online and offline. When order forms, login pages, and/or registration pages require users to input sensitive information (such as credit card numbers), that information is encrypted and protected using industry-leading encryption software – SSL
In addition, we use VeriSign as our certification authority. When on secure pages (such as order form), the lock icon at the bottom of browsers like Netscape Navigator and Microsoft Internet Explorer changes to a locked state, while in normal, non-secure use, it is unlocked or open. While we use SSL encryption to protect sensitive data online, we also take every possible measure to protect users’ personal information offline. All user data within our office (not just the sensitive information mentioned above) is restricted. Only employees who require the data to perform specific tasks (such as our treasurer or customer service representatives) are granted access to personal information.
9. Your Rights
You have the following rights relating to your personal data:

(i) The right to be informed about how your personal information is being used (an example of information is this policy)
(ii) The right to access the personal data we process about you
(iii) The right to request the correction of inaccurate personal information we process about you (although you can probably do most of this through your account)
(iv) The right to request that we delete your data, or stop processing it or collecting it, in some circumstances
(v) The right to stop direct marketing messages and to withdraw consent for consent-based processing at any time
(vi) The right to request that we transfer or port elements of your data either to you or another service provider, in case we collect personal data based on your consent.
(vii) The right to complain to your data protection regulator.
* California Residents – Please see Section 10: Privacy Notice for California Consumers of this policy for more details on your additional rights.

A. Secure Shopping
This website takes every precaution to protect our users’ information. When users submit sensitive information via our website, your information is protected both online and off-line. When our order form, log-in page, and/or registration page asks users to enter sensitive information (such as credit card number), that information is encrypted and is protected with the best encryption software in the industry – SSL.

In addition, VeriSign is used as our certifying authority. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, in normal non-secure use. While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information off-line. All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information.

10. How to Contact Us
A. Questions and Comments
TouchThink Smart will respond to reasonable requests to review your personal data and to correct, amend or delete any inaccuracies. If you have any questions or comments about TouchThink Smart Web Security and Privacy Policy (e.g. to review and update your personal data), please click on ” Contacts” in the upper right-hand corner of this page, and select your location to check our contact numbers or click Email us. As the Internet matures, so will our Web Security and Privacy Policy. We will post changes to our Web Security and Privacy Policy on this page. Please check this page regularly to keep up-to-date.

B. Consent
By visiting TouchThink Smart’s website, you consent to the practices described in the Privacy notice and your visit and any dispute over privacy is subject to this notice.

We always want to hear from our customers. If you:

Have any questions or feedback about this policy
Would like us to stop using your personal data
Want to exercise any of your rights as set out above, or have a complaint
please don’t hesitate to contact our team, who will be happy to answer any questions you may have.

You can contact our privacy team by dropping us a line at info@touchthink.net

11. Privacy Notice For California Consumers
This section provides more information about your rights under the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.). The CCPA provides rights to California consumers to be informed about the collection and use of their personal information, request access to their personal information, request for the deletion of their personal information, and to not be discriminated against for exercising such rights.

TouchThink Smart does not sell your personal information and has not sold your information in the last 12 months. You can request access to or deletion of your personal information by using the online DO NOT SELL INFORMATION form [Link to form]. If you request the deletion of your personal information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such deletion. Your information may also remain within our systems and other records where necessary for compliance with applicable law.

The chart below outlines the categories of Personal Information (which are defined by the CCPA, not us) that we have collected and/or disclosed for a business purpose in the preceding twelve months. The examples of Personal Information provided for each category are taken from the CCPA and are included to help you understand what the categories mean. The examples are not meant to indicate what we actually collect or disclose.

Category We Collect We Disclose We Sell
A. Identifiers
Yes Yes No
Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
B. Categories of Personal Information in Cal. Civ. Code 1798.80(e)
Yes Yes No
Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
C. Characteristics of Protected Classifications under California or Federal Law
No No No
Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.
D. Commercial Information
Yes Yes No
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric Information
No No No
Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
F. Internet or Other Electronic Network Activity Information
Yes Yes No
Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.
GRAMO. Geolocation Data
Yes Yes No
Example: Precise physical location.
H. Sensory Information
No No No
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information
No No No
Examples: Job application or resume information, past and current job history, and job performance information.
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
No No No
Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.
K. Inferences Drawn from Personal Information
Yes Yes No
Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Use of Personal Information
The CCPA defines various business and commercial purposes for collecting, using, and disclosing Personal Information. While we collect, use, and disclose Personal Information pursuant to our Privacy Policy as a whole, we wanted to clarify out that this includes Personal Information in accordance with the specific CCPA business and commercial purposes below:

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to auditing compliance with this specification and other standards.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use.
Contracting with service providers to perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
For other purposes for which we provide specific notice at the time the information is collected.
Your California Privacy Rights
If you are a California resident, you may exercise the following rights;

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected or disclosed by us; (2) purposes for which categories of Personal Information are collected by us; (3) categories of sources from which we collect Personal Information; y (4) specific pieces of Personal Information we have collected about you during the past twelve months.
Right to Delete. Subject to certain exceptions, you have the option to delete Personal Information about you that we have collected from you.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Shine the Light. We do not rent, sell, or share your Personal Information with nonaffiliated companies for their direct marketing purposes, unless we have your permission.
To exercise your rights under the CCPA, you (or your authorized representative) can OPT-Out by completing the form on TouchThink Smart’s DO NOT SELL MY PERSONAL INFORMATION page.

12. KVKK Personal Data Protection Policy
In accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), your personal data, as Data Controller, will be processed by being used, recorded, stored, updated, transferred and/or classified within the framework described below, depending on business purposes. In this context, in accordance with the Laws and Regulations issued by our Company to protect the fundamental rights and freedoms of individuals, especially the privacy of private life, and to protect personal data, our Company maintains the appropriate level of security in order to prevent unlawful processing of your personal data, to prevent unlawful access and to ensure its preservation and takes all technical and administrative measures to assurance.

The target group of this text is all natural persons whose personal data are processed by our Company, excluding our Company employees or employee candidates who have applied for a job in our Company.

Our company collects data to work efficiently and to provide you with the best experiences about our products. Some of this data is collected while creating an TouchThink Smart account, registering for an TouchThink Smart event, subscribing to eDM, purchasing an TouchThink Smart product or service, registering with MyTouchThink Smart, or contacting the Company for support. We obtain some of this data through cookies or software running on your device.

We also collect data from third parties. We also process data obtained from third parties within the scope of the purposes described in this policy and protect it according to the specified measures. These third-party resources may change over time, but includes:

Data brokers that we purchase demographic data to support the data that we collect,
Social networks that you allow,
Service providers who help us locate based on your IP address in order to customize certain products for your location,
Business partners with whom we offer co-branded services or engage in co-marketing activities; y
Government data-based resources accessible to the public.
You have choices in terms of the data we collect. When you do not want your personal data to be processed, you can exercise your right of refusal. However, we would like to remind you that the use of a product or feature may be disrupted as a result of using your right of refusal.

The personal data processed as the data controller are given below, but not limited to the ones stated here;

Name, surname, Turkish Republic ID number, address, postal number, age, gender, Country name, phone number, e-mail address, signature, physical location/security footage, call center/quality of service audio recording, credit card number, bank account number, IP addresses , username and password, device data, MyTouchThink Smart, eStore and Live Chat voice and text search queries or commands, favorite product information added to the eStore shopping cart, chats conducted over My TouchThink Smart or Live Chat, location data, file contents sent over devices, video and picture records, cookie records.

Purposes and legal reasons for processing personal data;
Your personal data shared by you;

Carrying out necessary studies, including, but not limited to, the determination and implementation of our Company’s commercial and business strategies, marketing activities, business development and planning activities, in order to benefit you and/or the institutions and organizations you represent, from the products and services offered by our company,
Execution of administrative operations for communication carried out by our company,
Execution of promotion and campaign activities,
Ensuring the physical security and control of our company’s locations in use,
Establishing business partner/customer/supplier (authorized or employees) relations,
Ensuring contractual requirements and financial reconciliation regarding products and services offered with our business partners, suppliers or other third parties,
Execution of our company’s human resources policies,
Acting in accordance with the legal obligations to which the Company is subject,
Fulfillment of contractual obligations,
Processing personal data based on this policy and your express consent,
Calling our company’s call center or using the website and/or
It will be processed for the purpose of participating in training, seminars or organizations organized by our company.
ROLE AND RESPONSIBILITIES
Human Resources is responsible for the oversight of the determination and operation of notification, review and sanction mechanisms in case of non-compliance with this Policy, rules and regulations.

This Policy has been approved by TouchThink Smart Management, and the Human Resources Department is the authorized approval mechanism for the creation, implementation and, if necessary, updating of the Policy. TouchThink Smart departments and employees are responsible for taking the necessary measures for the compliance of the outsourcing companies with the Policy, examining the issues in order to determine the issues contrary to the Policy and reporting them to the TouchThink Smart Management, involved in the activities with the employees in charge.

The internal distribution of the prepared document is in the responsibility of the Human Resources Department.

Protection of Personal Data Within the framework of this Policy, it is responsible for carrying out the Company’s public disclosure practices in a transparent manner to all concerned simultaneously. It is the responsibility of TouchThink Smart Marketing Department to publish the prepared document on the website.

Method of collection and storage of personal data;
Your personal data that you share with our company, through automatic or non-automatic methods, offices, branches, call center, website, social media channels, MyTouchThink Smart, eStore, CRM, official website, Hubspot, Siebel, SalesForce.com, Live Chat, WISE-PaaS It can be collected orally, in writing or electronically through Intelligent wards (iWards), UFleet+ ,WISE-iService solutions , mobile applications and similar means. Your personal data will be stored in electronic and/or physical media. Necessary business processes are designed and technical security infrastructure developments are implemented in order to prevent your personal data provided and stored by our company from being exposed to unauthorized access, manipulation, loss or damage in the environments where they are stored.

Your personal data will be processed by taking all necessary information security measures, provided that it is not used outside of the purposes and scope notified to you, and will be stored and processed during the legal retention period or, if such a period is not foreseen, for the period required by the processing purpose. When this period expires, your personal data will be removed from our Company’s data streams by deletion, destruction or anonymization methods.

Keeping personal data for the period stipulated in the legislation or for the period required for the purpose for which they are processed.
We keep personal data for as long as required by the purpose of processing personal data and within the scope of our Personal Data Retention and Destruction Policy, without prejudice to the storage periods stipulated in the legislation.

We retain your personal data for as long as your company account is active or necessary to provide you with services. However, if you have not logged into the Company website for 10 (ten) years, your account will be deleted.

In cases we process personal data for more than one purpose, the data is deleted, destroyed or anonymized and stored if all the purposes of processing the data disappear or, upon the request of the Relevant Person, if there is no obstacle to the deletion of the data in the legislation. In matters of destruction, deletion or anonymization, the provisions of the legislation and the decisions of the KVK Board are complied with.

Measures we take regarding the storage of personal data
Technical Measures

We establish technical infrastructures and related control mechanisms for the deletion, destruction and anonymization of personal data.
We take the necessary measures for the safe storage of personal data
We employ employees with technical expertise
It creates business continuity and emergency plans against possible risks and develops systems for their implementation.
We establish security systems in accordance with technological developments regarding the storage areas of personal data.
Administrative Measures

We raise awareness by informing our employees about the technical and administrative risks related to the storage of personal data.
In the case of cooperation with third parties for the storage of personal data, we include provisions regarding taking necessary security measures in order to protect and securely store the transferred personal data in the contracts signed with the companies to which the personal data is transferred.
Transfer of Personal Data;

Your personal data, within the scope of Laws and other legislation and for the purposes explained; TouchThink Smart company and its subsidiaries,
Companies that we have authorized, operating on behalf of and on behalf of our Company, to our representatives,
Regulatory and supervisory authorities, public institutions or organizations that are authorized to explicitly request your personal data in their applicable laws,
Business partnerships, supplier and contractor companies, banks, credit risk and financial institutions and other real or legal persons within the scope of the stated purposes,
Tax and similar consultants, obligatory persons related to legal proceedings, institutions and organizations and third parties, including auditors, including but not limited to, business partners, third parties from whom services are received, authorized persons for the above-mentioned purposes, at home and abroad. and organizations.

Due to its international location, the Company may be required to transfer your personal data outside of the European Union or the European Economic Area, including but not limited to Taiwan. Taiwan is not the country with a European Commission qualification decision, but we are committed to taking adequate measures to protect your privacy and rights using the European Commission’s standard data protection clauses. For more information, you can contact the Company.

DELETING, ANONYMIZATION AND DESTRUCTION OF THE PERSONAL DATA
Personal data;

The complete termination of our processing purposes or
In case of the request of the Related Person Personal data will be deleted, destroyed or anonymized.
The deletion, destruction and anonymization processes in question are made within the scope of our Personal Data Retention and Disposal Policy, without prejudice to the provisions of the relevant legislation.

While your personal data is being deleted, destroyed or anonymized, the security measures in this Policy are taken.

Records of the transactions made for the deletion, destruction or anonymization of personal data are kept for at least 3 years, without prejudice to the provisions of other laws and regulations.

TouchThink Smart chooses the appropriate method of deleting, destroying or anonymizing personal data, unless otherwise specified by the KVK Board. If requested by the Relevant Person, the appropriate method is chosen by explaining the reason.

SECURITY OF PERSONAL DATA
Our obligations regarding the security of personal data As TouchThink Smart;

To prevent the unlawful processing of personal data,
To prevent unlawful access to personal data, y
To ensure that personal data is kept in accordance with the law, we take administrative and technical measures according to technological possibilities and implementation costs.
Measures we take to prevent unlawful processing of personal data;
Carries out and has the necessary inspections made within the company,
We train and inform our employees about the legal processing of personal data,
In cases where cooperation is made with third parties for the processing of personal data, we include provisions regarding taking the necessary security measures in the contracts made with companies that process personal data.
In case of unlawful disclosure of personal data or data leakage, we notify the Relevant Person and the KVK Board, carry out the investigations stipulated by the legislation in this regard and take the relevant measures.
Technical and administrative measures taken to prevent unlawful access to personal data
To prevent unlawful access to personal data;

We employ employees with technical expertise,
We update and renew the technical measures periodically,
We create access authorization procedures within the company,
We determine the procedures for reporting the technical measures and audit processes we take,
We create the data recording systems used in the company in accordance with the legislation and we audit them at regular intervals,
We create emergency aid plans against possible risks and develop systems for their implementation,
We train and inform our employees about accessing and authorizing personal data,
In contracts with companies that provide access to personal data, in cases where cooperation is made with third parties for activities such as processing and storing personal data; We include provisions regarding taking the necessary security measures by persons who access personal data,
We establish security systems within the scope of technological developments in order to prevent unlawful access to personal data.
Measures we take in case of unlawful disclosure of personal data

We take administrative and technical measures to prevent the unlawful disclosure of personal data and update them in accordance with our relevant procedures. If we detect that personal data has been disclosed without authorization, we establish the necessary systems and infrastructures to notify the Related Person and the KVK Board.

In case of an unlawful disclosure despite all the administrative and technical measures taken, this situation may be announced on the website of the KVK Board or by any other method, if deemed necessary by the KVK Board.

RIGHTS OF THE RELATED PERSON
Within the scope of our obligation to inform, we inform the Related Person and establish the necessary systems and infrastructures for this information. We make the necessary technical and administrative arrangements for the Relevant Person to exercise their rights regarding their personal data.

Your rights in accordance with Article 11 of KVKK; By applying to our company, your personal data;

Learning whether it is processed or not,
Requesting information if processed,
Learning the purpose of processing and whether it is used in accordance with its purpose,
Knowing the third parties to whom it was transferred in the country / abroad,
Requesting correction if it is incomplete / incorrectly processed,
Requesting deletion / destruction within the framework of the conditions stipulated in Article 7 of the KVKK,
Requesting notification of the transactions made in accordance with subparagraphs (e) y (f) above, to the third parties to whom it has been transferred,
Objecting to the emergence of a result against you due to the analysis exclusively by automated systems,
You have the right to demand the compensation of the damage in case you suffer damage due to unlawful processing.
Pursuant to paragraph 1 of Article 13 of the KVK Law, you may submit your request regarding the exercise of your above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board.

Utilisation of rights regarding personal data

In order to exercise your above-mentioned rights, you can personally deliver your petition with the necessary information identifying your identity, send it through a notary public or other methods determined by the Personal Data Protection Board, or send it to alitek@hs01.kep.tr with secure electronic signature.

Although the subject of the request must be related to the person of the applicant, if acting on behalf of someone else, the applicant must be specifically authorized in this regard and this authority must be documented (special power of attorney).

In addition, the application must include identity and address information, and documents proving identity must be attached to the application.

Requests made by unauthorized third parties on behalf of someone else will not be considered.

Evaluation of the Application
Respondence time of the application

Requests regarding personal data are concluded as soon as possible and in any case within 30 (thirty) days at the latest, free of charge, or against the fee in the tariff in case the conditions in the tariff to be published by the KVK Board are met.

Additional information and documents may be requested during the application or while the application is being evaluated.

Our right to refuse the application

Applications regarding personal data may be rejected in the following cases, including but not limited to:

Processing personal data for purposes such as research, planning and statistics by making them anonymous with official statistics,
Processing of personal data for artistic, historical, literary or scientific purposes or within the scope of freedom of expression, provided that it does not violate the privacy or personal rights of the Relevant Person or constitute a crime,
Processing of personal data made public by the Relevant Person,
The application is not based on a just cause,
The application contains a request contrary to the relevant legislation and
Failure to comply with the application procedure
Evaluation procedure of the application

Applications must be duly submitted in order for the response period specified in this Policy to begin.

If the request is accepted, the necessary procedures are applied and the applicant is notified in writing or electronically. In case of rejection of the request, the applicant is notified in writing or electronically by explaining the reason.

Right to complaint to the Personal Data Protection Board

In cases where the application is rejected, the answer given is insufficient, or the answer is not given in a timely manner; The applicant has the right to complain to the KVK Board within 30 (thirty) days from the date of learning the answer and in any case within 60 (sixty) days from the date of application.

Access and Control of Your Personal Data

For many products or services, you can view, edit or delete your personal data online. You can also make choices about the Company’s collection and processing of your data. How you can access or control your personal data depends on the products you use. E.g:

TouchThink Smart Account (My TouchThink Smart and eStore) If you want to access, edit or remove profile information and payment information in your TouchThink Smart account, change your password or close your account, you can access it here.
TouchThink Smart Store . You can access your TouchThink Smart Store profile and account information, here you can click “View account” or “Order history”.
You can access and update your profile on touchthink.net. If you are unable to access some personal data collected by TouchThink Smart from the links above or through the TouchThink Smart products you use directly, you can always contact us.
Your Communication Preferences

You can choose whether you want to receive communication services from the Company via e-mail, SMS, mail or telephone. If you receive e-mails or SMS regarding promotions/campaigns from us and you want to be excluded from the scope, you can opt out by following the instructions in the relevant e-mail/message. You can also edit the communication consent option about promotions, e-mails, phone calls and written mail by logging into your personal TouchThink Smart account. These methods do not apply to the Company’s mandatory service communications or surveys and other information communications with special unsubscribe methods.

PUBLICATION AND STORAGE OF THE POLICY
This Policy is stored in two different media, printed paper and electronic media.

Wet signed copies and controlled copies are kept in the Human Resources Department and destroyed when necessary with the written approval of TouchThink Smart management.

UPDATE FREQUENCY
This Policy is reviewed at least once a year without notice and updated as needed. Therefore, it is recommended that you periodically review this Policy.

EFFECTIVE DATE
This Policy is deemed to have entered into force after its approval by the Company’s Board of Directors.

REVOCATION
If it is decided to repeal this Policy, old copies of the Policy with wet signatures are canceled and signed by the Human Resources Department (with a cancellation stamp or written cancellation) with the written approval of the TouchThink Smart Board of Directors and are kept by Human Resources for a period of 5 years.

13. KVKK Clarification Text on the Contact Form Process
After you fill out this contact form, your data will be recorded/processed in the TouchThink Smart COMPANY (“TouchThink Smart/Company”) sistema. This form has been prepared in order to respond completely within the legal time to your application within the scope of any opinion, suggestion and related requests you may send to the Company in a correct. TouchThink Smart processes personal data regarding name, surname, telephone, e-mail of related persons who want to contact Company during the related process. Your personal data processed by TouchThink Smart are shared with the departments and units authorized to evaluate the application at the Company limited to this personal data processing process, and are not shared with any third party or company.

Your personal data mentioned above can be processed automatically through electronic media based on the legal reasons of Article 5 of the Law on the Protection of Personal Data as “processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfilment of that contract, data processing is mandatory for the establishment, exercise or protection of any right, it is mandatory for the legitimate interests of the controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject”. You can choose whether you want to receive communication services from the Company via e-mail, SMS, mail or telephone. If you receive e-mails or SMS regarding promotions/campaigns from us and you want to be excluded, you can opt out by following the instructions in the relevant e-mail/message. You can also sign in to your personal TouchThink Smart account and edit the communication consent option about promotions, e-mails, phone calls and text mails. These methods is not valid for the Company’s mandatory service communications or surveys and other information communications with special unsubscribe methods. You have the right to learn whether your personal data are processed or not, to request information if your personal data are processed, to learn the purpose of your data processing and whether this data is used for intended purposes, to know the third parties to whom your personal data is transferred at home or abroad, to request the rectification of the incomplete or inaccurate data, if any, to request correction of your personal data if it is incomplete or incorrectly processed, to request the deletion or destruction of your personal data in case the reasons requiring processing disappear, to request that your personal data be notified to third parties in case of correction, deletion or destruction of your personal data, to object to the processing, exclusively by automatic means, of your personal data, which leads to an unfavourable consequence for the data subject, to request compensation for the damage arising from the unlawful processing of your personal data pursuant to article 11 of the Law.

Your requests regarding the above rights provided by the Law to you, should be sent to TouchThink Smart company [Seyrantepe, İbrahim Karaoğlanoğlu Cd. No: 71-73/2, 34418 Kağıthane/İstanbul ] in accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller”.

14. KVKK Confidentiality Agreement and Term of Use
You can find legal information about the TouchThink Smart website here.

As TouchThink Smart Turkey Teknoloji Anonim Şirketi (“TouchThink Smart” or “Company”), we approach this issue with precision, as we care about the privacy of your personal data and accept that the information you share with us is personal and confidential.

All intellectual and industrial property rights on the website named www.touchthink.net.tr and the content, visual and audio elements and their arrangement on this website belong to TouchThink Smart, unless expressly stated otherwise. The information cannot be distributed, rented, reproduced, modified or used for commercial purposes without the written consent of TouchThink Smart. However, it can be quoted by showing the source.

Under no circumstances TouchThink Smart can be held responsible for the content and the false information presented by the visitor, including but not limited to errors or omissions in the content or any loss or damage that may arise from the use of the content on the website.

On the TouchThink Smart website, advertisements and promotions regarding the services of TouchThink Smart or third parties may be displayed. On our website, other websites that do not belong to TouchThink Smart and are not related to their activities can be redirected. If the visitor visits any of these websites, TouchThink Smart is not responsible for the policies and practices of these websites, which are used and owned by third parties.

The presence of any logo, sign, etc.. of TouchThink Smart on a site not managed by TouchThink Smart does not mean that this Policy is valid for that site. While sharing personal data with such sites, you must make sure that the site in question is a site owned by TouchThink Smart in order to benefit from the assurances in this Policy.

The information provided on this website is provided “as is”, “as available”. TouchThink Smart provides the visitor with implied, implied warranties, including, but not limited to, warranties of ownership, merchantability, accuracy, reliability, accuracy, fitness for a particular purpose, and/or virus-freeness, including the information on the website, including those about third parties. makes no legal guarantees.

Direct or indirect damage resulting from any performance failure, error, deficiency, interruption, defect, delay in operation and/or transfer, computer virus and/or line and/or system failure that may occur during or after the use of this website, TouchThink Smart and/or its employees shall not be liable for any loss or damage, including but not limited to loss and expense, even if they have been informed of the possibility of such damage and loss.

TouchThink Smart reserves the right to change all products and services, pages, information, visual elements and content on this website without prior notice.

Please read our Clarification Text for detailed information about the processing of your personal data by TouchThink Smart within the scope of Personal Data Protection Law, about your rights regarding your personal data and the technical and administrative measures we take to protect your personal data.

If you are requested to enter personal information on the TouchThink Smart website, your personal information (name, surname, identity number, address, postal code, age, gender, country name, telephone number, e-mail address, signature, physical place/ security video recording, call center/quality of service audio recording, credit card number, bank account number, IP addresses, username and password, device data, MyTouchThink Smart, eStore and Live Chat voice and text search queries or commands, favorite added to eStore shopping cart product information, chats conducted over My TouchThink Smart or Live Chat, location data, file contents sent over devices, video and picture records, cookie records) will be used by TouchThink Smart only for the purpose of sending informational messages and will not be shared with third parties or institutions except for legal obligations or your permission.

If you do not want to receive direct marketing messages by TouchThink Smart, you can send this request to us via the “unsubscribe” extension under each message sent to you, or you can make a request by contacting us via our contact information.

Data Collected on our Website
Personal Data Collected Through Contact Forms
We collect the following information through communication forms that enable you to convey your information and requests to us.

Name, Surname,
Correo electrónico,
Phone number,
Postal Code,
Country, City, Address,
Subject and message.
Device Information

When using our Device Information Services, the IP address of your electronic devices (computers, tablets, smart phones, smart televisions, etc.) you use, etc.. information is collected.

We may also send you instant notifications via our website(s). You can refuse to receive these messages.

Data Collected Through Cookies

Cookies are small text files that are stored in the visitor’s device (such as a computer or phone) and can contain data in name-value format when a website is visited. On this occasion, various information about the device on which the visit to the website (s) is made and the related user can be obtained. Cookies are used on our website.

Types of Cookies

Cookie Type Explanation
Mandatory Cookies Cookies are mandatory to use in order for the website to function properly, to benefit from the features of the website and the services provided.
Functional and Analytical Cookies Cookies that contain data about how you use the site, such as remembering your preferences, using the website effectively, and optimizing the site to respond to your requests. Due to their nature, such cookies may contain your personal data. For example, cookies that record your display language preference are functional cookies.
Targeting Cookies Tracking cookies are primary and third-party cookies created during your visit to our website and third-party domains. It can be used by companies to profile your interests and show relevant ads on other sites. They do not store personal information directly, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
We also allow third parties to use the above cookies. For example, like many companies, we use Google Analytics to help us track the progress of our website. We may also use third-party cookies to assist us with market research, improving site functionality, and monitoring compliance with our terms and conditions and copyright policy.

As we explained above, cookies help you get the most out of our websites. However, if you want to disable cookies, please follow the instructions below from your main browser providers:

Instructions for Microsoft Internet Explorer
Instructions for Mozilla Firefox
Google Chrome instructions
Instructions for Apple Safari
If you choose to disable cookies, we would like to remind you that certain parts of our website may not work properly.

Data We Collect Automatically When You Access Our Servers

If you use our website, device log records, etc., in order to meet our customers’ individual or corporate demands and needs, to improve and control our technical infrastructure, to develop our hardware and software technologies and other services, and to fulfill our legal obligations. we may collect personal data.

Links to Third Party Websites

Our site may contain links to third party websites, such as private employment agencies. In such cases, it is beyond our responsibility to collect, process, share or transfer data by third parties. Your use of third party sites and data sharing with these sites are subject to the privacy policy and terms of use on these sites and are outside the scope of this Policy. We recommend that you read the privacy policies of the websites you visit before sharing your personal data.

The provisions of this Policy may be changed or renewed in part or in full on the date it is published on our website.

We recommend that you check our website periodically in order to follow the changes in the policy.

Your questions, reservations or complaints regarding the interpretation or application of this Policy; you can forward to marketing.ATR@touchthink.net.tr .