Personal Data Protection

Last updated: March 2026

1. Data Controller

This disclosure text has been prepared by Pragma Global Bağımsız Denetim A.Ş. ("Pragma" or "the Company") in its capacity as data controller, pursuant to Article 10 of the Law on Protection of Personal Data No. 6698 ("KVKK").

2. Personal Data Processed and Collection Methods

Pragma may process the following categories of personal data:

• Identity data: First name, surname.
• Contact data: E-mail address, phone number, postal address.
• Transaction security data: IP address, log records (in connection with website visits).
• Business relationship data: Company name, title, service requests and correspondence content.

Personal data is collected through our website, e-mail, telephone or written communication channels, by automated or non-automated means.

3. Purposes of Processing

Your personal data may be processed for the following purposes:

• Managing service proposals and contractual processes,
• Planning and carrying out communication activities,
• Sending newsletters and professional content,
• Operating the website securely and efficiently,
• Fulfilling legal obligations,
• Conducting legal proceedings and protecting rights.

4. Legal Bases for Processing

Personal data is processed on the following legal grounds set out in Article 5 of the KVKK:

• Processing is necessary for the establishment or performance of a contract,
• Processing is necessary for the Company to fulfil its legal obligations,
• Processing is necessary for the establishment, exercise or protection of a right,
• Processing is necessary for the legitimate interests of the Company, provided that the fundamental rights and freedoms of the data subject are not prejudiced,
• Your explicit consent (solely for processing activities based on consent).

5. Transfer of Personal Data

Your personal data may be shared with the following parties to the extent necessary to fulfil the purposes set out above, and in accordance with Articles 8 and 9 of the KVKK:

• Competent public authorities and judicial bodies where required by law,
• Suppliers and business partners engaged for service delivery (on a need-to-know basis),
• Lawyers and advisors in the context of legal proceedings.

Your personal data is never sold to third parties.

6. Retention of Personal Data

Personal data is retained for as long as necessary to fulfil the purpose for which it was collected and in accordance with applicable statutory retention periods. Upon expiry of such periods, personal data is deleted, destroyed or rendered anonymous.

7. Your Rights under the KVKK

Pursuant to Article 11 of the KVKK, you have the right to:

• Learn whether your personal data is being processed,
• Request information if your data has been processed,
• Learn the purpose of processing and whether data is used in accordance with that purpose,
• Know the third parties to whom data has been transferred, domestically or abroad,
• Request correction if data is incomplete or inaccurate,
• Request deletion or destruction under the conditions set out in the KVKK,
• Request that correction and deletion operations be notified to third parties to whom data was transferred,
• Object to a result that is to your detriment arising solely from automated analysis,
• Claim compensation for damages arising from unlawful processing of your personal data.

8. How to Submit a Request

To exercise your rights under the KVKK, you may contact us through the following channels:

• Written application: In person with identity verification, or via notary, to Gülbahar Mahallesi Avni Dilligil Sokak Çelik İş Merkezi No:7 K:11, 34394 Şişli / İstanbul,
• E-mail: To info@pragma-global.com with a secure electronic signature.

Requests will be concluded within a maximum of 30 (thirty) days depending on the nature of the request. Where processing involves an additional cost, the tariff set by the Personal Data Protection Board shall apply.

9. Changes

Pragma reserves the right to update this disclosure text in line with changes in applicable legislation. The current version will always be published on this page.