Privacy Statement for Sestek

This Privacy Statement (“Statement”) describes the personal data that Sestek collects, how we use it, and when we share it, as we interact with you, deliver our products and services, and conduct our business operations. This Statement applies to Sestek Ses ve Iletisim Bilgisayar Teknolojileri San. ve Tic. A.S., its affiliates, and any wholly-owned subsidiaries worldwide referred to in this Statement as “Sestek.” When we refer to Sestek products, we mean all Sestek products and services.

Hereby with this statement, as a data controller SESTEK will be fulfilled its obligation to data subjects regarding their right to be informed under Article 10 of the Turkish Personal Data Protection Law No. 6698 regarding personal data, Law on Regulation of Publications on The Internet, and Combating Crimes Committed By Means of Such Publication No. 5651 and Law on The Regulation Of Electronic Commerce No. 6563. This Statement contains references to other key SESTEK policies and processes relevant to data protection, including information security policies.

What personal information do we collect from the people?

We collect your personal information in order to provide and continually improve our products and services.

Here are the types of personal information we collect:

• Identity information such as name, surname when you submit by engaging with Sestek for marketing purposes, such as by expressing interest in Sestek’s Products through a web form, creating a new user through a support site, attending to marketing events, or filling an employment application form.
• Contact information such as phone number, email address when you submit by engaging with Sestek for marketing purposes, such as by expressing interest in Sestek’s Products through a web form, creating a new user through a support site, attending to marketing events, or filling an employment application form.
• Professional experience information such as the name of the organization, job title when you submit by engaging with Sestek for marketing purposes, such as by expressing interest in Sestek’s Products through a web form, creating a new user through a support site, attending to marketing events or filling an employment application form.
• Operation security information such as IP address, user name, password, session id, session token, preferred language, last session time, last process time, security stamp information that is collected automatically when you engage with Sestek’s WEB and support site.
• Physical space security such as indoor camera records that are collected when you visit our offices is processed for ensuring physical space security.
• Finance information such as IBAN number, account information when the vendors propose the quotation.
• Other data about your interaction with our sites and data collected from our use of cookies and similar tracking tools.

Through our Products, we may collect personal data directly in the following situations:

• When you use Sestek speech recognition technology, whether by using Sestek’s own Products or by using third-party products that employ Sestek speech recognition technology, we may capture your voice and the words that that is not associated with a particular person.
• We may also collect other electronic data derived from your use of our Products. This data may include your IP address, usage data, and data showing your registration, installation, and use of Sestek software Products. Except for IP address and unique device identifiers, we generally collect this data on an aggregate and non-identifying basis.

How do we use your information?

The personal information processed by SESTEK which has mentioned above is under Article 4 of Turkish Personal Data Protection Law No. 6698 which concerns General Principles Relating to Processing of Personal Data. Therefore, the processing by SESTEK will be performed lawfully, fairly and in a transparent manner in relation to the data subject; adequate, accurate, relevant, and limited to what is necessary for relation to the purposes for which they are processed, collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes where necessary, kept up to date. Furthermore, every reasonable step is taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay by the Erasure, Destruction, Anonymisation and Privacy Policy of SESTEK.

It is important to mention that during your engagements with SESTEK’s products, the data that you have shared with us to provide the best service for speech and artificial intelligence technologies under the article 5 and 6 of the Turkish Personal Data Protection Law No. 6698.

• We use contact information to market, sell, and service Sestek’s Products, subject to your consent where required by law. We allow recipients of marketing messages and collateral to opt-out of receiving further communications from Sestek at any time without detriment.
• We use your financial or payment information, and your contact details, to support, establish, and conduct customer relationships as necessary for the performance of our terms of service with you (including, for example, completing purchase transactions, the fulfillment of an order, order confirmations, responding to requests for information about products and services, and the provision of purchased products and services). If you fail to provide the personal data we need, we may be unable to complete your transaction.
• We use personal data from employment applications where necessary to support our legitimate interest in processing your application and to contact you if future opportunities arise.
• We use personal data of individuals associated with proposed resellers and distributors to conduct reference and background checks ahead of entering into a contract and as necessary for compliance with legal obligations to which we are subject.
• We use the personal data that is processed within our solutions, such as voice data within speech recognition products, personal data processed in communications products, and any personal data contained within product usage data we collect, to deliver our products under applicable terms and for our legitimate interests in tuning, maintaining, enhancing, and developing our solutions and products. We never use this data, referred to as sensitive data, for marketing purposes and we never sell or transfer your data to third parties for the third party’s marketing purposes.
• We use aggregated, non-identifying, electronic data collected from the use of our Sites and Products to operate, analyze, improve, and develop our Sites and Products. This information is not used to inform decisions about specific individuals; rather, it is processed to understand how different categories of users interact with our Sites and Products so that we can consistently improve our Products.

How do we protect your information?

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all personal information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information. We provide the website’s security by monitoring and updating continuously and protect with an anti-virus program.

Do we use ‘cookies’?

Yes, we use cookies for tracking purposes as described in our Cookie Policy.

If you turn cookies off, some features will be disabled that make your site experience more efficient and may not function properly.

When We Share Personal Data?

It may be transferred within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of Turkish Personal Data Protection Law No. 6698. In this context, your personal data are stored by using Cloud Information Technologies.

• We may share personal data with our affiliates, subsidiaries, resellers, suppliers, sub-contractors, and distributors, and with vendors acting on our and their behalf, to service our customers and perform any contract we enter with you.
• We may share personal data derived from Site usage (excluding Product Personal Data), with analytics and search engine providers that assist us in the improvement of our Sites, subject to the cookie section of this Privacy Statement. Our Sites may use Google Analytics. The way Google collects and processes data when delivering Google Analytics is described here: https://policies.google.com/technologies/partner-sites
• We may share personal data from employment applications with vendors acting on our behalf who help us in recruitment, background check, and human resources matters.
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• We may also share personal data to comply with the law and legal process, to respond to governmental inquiries and lawful requests from public authorities (including to meet national security or law enforcement requirements), and to protect life, property, or the security of Sestek or its customers. If Sestek enters any merger, acquisition, or asset sale of all or any part of its business, personal data held by Sestek may be transferred to a buyer or successor entity.

Third-party links

This Website contains links to other sites that are owned or controlled by Sestek. Please be aware that all privacy policy is valid for the other sites.

Third-Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, which may result in the compliant processing of personal information. Our appointed data processors include:

(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877. Their Data Protection Officer can be emailed at: dpo@sopro.io.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

Your Rights

In accordance with Article 11 of the Turkish Personal Data Protection Law No. 6698, as a data controller we guarantee that every user is entitled to the following data protection rights:

The Right to Information: You have the right to request information on your personal data processed by SESTEK. This Privacy Statement shall serve this purpose. In case you have any remaining questions, you may send an e-mail to the contact indicated at the end of this statement.

The Right to Access: You may demand access to the personal data processed SESTEK. We will provide the required data to you via e-mail.

The Right to Rectification: You may demand from SESTEK the rectification of inaccurate personal data concerning you.

The Right to Erasure: You may demand from SESTEK erasure of your personal data. SESTEK is going to comply with your request unless legal requirements oppose deletion, or we have to process the data in order to fulfill our contractual obligations. In that case, we will contact you and provide alternative solutions to your request (e.g. anonymization of your data).

The Right to Data Portability: At your request, SESTEK will provide you with your data in a suitable format, and (if technically possible) we will transmit your data to another responsible controller upon your request.

The Right to Object and to Restrict: Furthermore, you may demand from us to end the processing of your personal data at any given time or to restrict your consent to the processing activities.

You can also exercise the rights listed above, or write to us with any complaints, at any time by contacting us, specifying the nature of your request by filling the “Personal Data Owner Application Form”, sending an email to privacy@sestek.com. Your application will be responded to under the provisions of the Turkish Personal Data Protection Law No. 6698 and in order to confirm your application, SESTEK may request further information for authentication purposes.

Sestek never sells or transfers your data to third parties for the third party’s marketing purposes. You can object to receiving further marketing from Sestek at any time without detriment. You can change your preferences to opt-out of marketing communications at any time by contacting us at marketing@sestek.com. Alternatively, please follow the opt-out instructions in the relevant communication. If you opt-out, we will retain your email address to confirm that we do not send you further communications.

How to contact us

Sestek Ses ve Iletisim Bilgisayar Teknolojileri San. ve Tic. A.S.

Address: Vadistanbul Bulvar Ayazaga Mah. Cendere Cad. 109B 1B Ofis Blok No:4  Sariyer / Istanbul / Turkey

Telephone: +90 212 2862545

E-mail: privacy@sestek.com

Changes to This Privacy Statement

We may update this Privacy Statement from time to time by publishing an updated version on Sestek’s Sites. Each updated version will include the date the statement was last updated. Please review the latest version of this Privacy Statement periodically to keep current with Sestek’s use of personal data.

Updated: November 17th, 2020.