- Privacy Policy and Data Protection Notice- 1. Overview - This Privacy and Data Protection Notice (“Notice”) explains how Ekin Smart City Teknoloji A.Ş. (“Ekin”, “we”, “us”, or “our”) collects, uses, stores and protects personal data provided to us, as well as the reasons for processing, the parties to whom such data may be transferred and your rights in relation to that processing. - This Notice has been prepared for our customers who purchase specific products manufactured and sold by Ekin, such as Automatic License Plate Recognition (ALPR) systems, speed enforcement devices or surveillance cameras, as well as potential customers and visitors to our website located at www.ekin.com (“Website”). 
 Additional privacy notices or policies may apply to other products, services ordata processing activities carried out by Ekin.- 2. Identity and Contact Information of the Data Controller - Ekin Smart City Teknoloji A.Ş. - Gediz Sokak No:7 34450 Sarıyer / İstanbul,Türkiye - Tel: +90 (0212) 425 26 24 
 E-Mail: info@ekin.com- In certain circumstances, the data controller responsible for your personal data may not be Ekin but another company under the same ownership or control. If you are in direct contact with another company owned or controlled by the same person or entity as Ekin, unless stated otherwise in this Notice, that company is the data controller - 3. Collection of Personal Data - 1. Information You Provide to Us - We may collect certain personal information you provide in the following situations: - - When you complete a contact form, demo request or event registration, - - When you subscribe to our newsletter, - - When you contact us via e-mail, phone or in person, - - When you apply for a business partnership or a career opportunity. - The types of personal data collected inthese cases may include: 
 - Identity information such as name and surname,
 - Professional details such as company name and title,
 - Contact information such as e-mail address and phone number,
 - Country information,
 - Request or complaint details contained in your message.- 2. Information Collected Automatically - We use cookies on our Website to enable functionality, analyze performance and improve visitor experience. The types of cookies used include: - Necessary cookies: These cookies are essential for the basic functionality of the website. They are required for the proper operation and intended use of the website. If necessary cookies are disabled, certain parts of the Website may not function properly. These cookies enable features such as enhancing security, saving searches, logging in or performing similar core functions. They are not used for marketing purposes. - Analytical cookies: These cookies help us understand how visitors use the Website. Also referred to as performance cookies, they are used to improve the way the website operates. They do not collect information that identifies individual visitors. Instead, they provide aggregated information about how users interact with the Website, for example, whether they encounter error messages on web pages. 
 When you visit the website, certain information may be automatically collected through cookies, including:
 - IP address,
 - Browser type and version,
 - Operating system,
 - Referring URLs and access times,
 - Pages visited and session duration.
 You can manage your cookie preferences through your browser settings.-  
 The data collected through cookies are used solely for analytical, security and technical purposes and are not associated with an identifiable individual, except where required by law or in response to official requests from the public authorities.- 4. Purposes of Processing - Ekin processes personal data in line with the principles of necessity, proportionality and legitimacy set out in the Personal Data Protection Law numbered 6698 (the “Law”) mainly for the following purposes: 
 Ensuring Information Security Processes
 - Ensuring the security of the website and preventing or detecting incidentssuch as fraud, unauthorized access or misuse.
 - Operating and improving the website and diagnosing technical issues.- Ensuring Compliance with Legal and Regulatory Requirements 
 - Maintaining the website security and preventing misuse.
 - Complying with legal obligations.- Carrying Out and Supervising Business Operations 
 - Operating and improving the website.
 - Diagnosing and resolving technical problems.
 - Responding to customer inquiries and requests.- Managing Customer Relations, Handling Requests / Complaints and Conducting Communication Activities 
 - Responding to customer inquiries.
 - Providing information, demos or support related to our products upon request.
 - Evaluating customer feedback regarding our products or services.- Conducting Marketing, Advertising, Campaign and Promotional Activities 
 - Sending news, updates or event invitations about Ekin and its products incases where customers have provided their consent.- Carrying Out Risk Management Processes 
 - Preventing and detecting fraud, unauthorized access or misuse on the Website.- Providing Information to Authorized Persons, Institutions and Authorities 
 - Fulfilling legal obligations.
 - Responding to requests from competent authorities.- 5. Legal Basis for Processing - Personal data are processed based on one or more of the following legal bases provided under Article 5 of the Law: - Article 5/2(a): where the processing is expressly required by law, - Article 5/2(c): where the processing is necessary for the establishment or performance of an agreement - Article 5/2(ç): where the processing is necessary for the data controller to fulfill its legal obligations, - Article 5/2(f): where the processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject and where required, based on your explicit consent under Article 5/1 of the Law. - 6. Data Retention - Your personal data are retained only for as long as necessary to fulfill the purposes set out above and for the duration required by the reason for their collection. - However, we may also retain your personal data for the duration o fEkin’s legitimate interests, such as to exercise our right of defense against potential legal claims. - Where your personal data are subject to statutory retention obligations, they are stored for the periods required by the applicable laws. Once the purpose for processing no longer exists your personal data are securely destroyed. - 7. Data Security - We implement the necessary technical and administrative security measures to ensure the security of your personal data and prevent unauthorized access, disclosure, alteration, or unlawful processing. - These measures include, among others: - HTTPS encryption - Firewalls and access control systems - Regular audits and monitoring - Employee confidentiality agreements - However, data transmission via electronic networks may not always be completely risk-free. Our company takes all necessary technical and administrative steps to minimize such risks, yet users should remain aware ofthese potential risks when sharing personal data. - By accessing the website, you acknowledge that you are using asecure information system. 
 Access and transaction logs may be recorded, limited to purposes such as systemsecurity, performance monitoring and usage analysis.- 8. Data Transfers - Our company may transfer your personal data to third parties located in Turkey in accordance with the fundamental principles set out under the Lawand limited to the purposes described in this Notice, as permitted by Article 8 of the Law. 
 Accordingly, your personal data may be shared only to the extent necessary and with appropriate security measures in place with our business partners and suppliers as well as with authorized public authorities and judicial bodies.- Your personal data may also be transferred abroad, provided that such transfers comply with the general principles of the Law, our processing purposes and one of the appropriate conditions specified in Article 9 of the Law regarding cross-border data transfers. 
 As Ekin operates on a global scale, your personal data may, where necessary, be transferred to our business partners located abroad or to other companies under common ownership or control as Ekin. For such data transfers, appropriate safeguards, such as Standard Contractual Clauses may be implemented.- 9. Information Regarding Data Processing through Certain Ekin Products - Some of Ekin’s products, such as Automatic License Plate Recognition (ALPR) systems, speed enforcement devices or surveillance cameras may involve the limited processing of certain personal data depending on their intended use. Such personal data generally include vehicle license plate numbers,vehicle type or model, visual recordings and device location information. - The personal data obtained through these devices are processed solely by our customers who operate them. Ekin does not determine the purposes or means of such processing and does not have any access to, control over or authority to intervene in these data. - The personal data collected through these devices are processed exclusively by our customers for purposes they determine, such as ensuring traffic and public safety or conducting urban planning projects. Accordingly, Ekin bears no responsibility for the processing of personal data carried outthrough these devices. - 10. Your Rights Regarding Personal Data - Depending on your location, you may have rights under applicable data protection laws such as the GDPR (EU/EEA) or the Personal Data Protection Law (Turkey), including:- The right to access and obtain a copy of your data, - - The right to request correction ordeletion, 
 - The right to object to processing,
 - The right to withdraw consent (for marketing communications),
 - The right to submit a complaint with the competent authority.- Under the Personal Data Protection Law you have certain rights that you may exercise by applying to the data controller, as set out in Article 11 of the Law. - You may submit your requests regarding your rights under Article 11 through one of the following methods: - 1) By sending a signed written request together with a copy of a valid identity document to the address: Gediz Sokak No:7, 34450 Sarıyer/İstanbul, Türkiye, - 2) By submitting your request in person, accompanied by a valid identity document, - 3) By sending your request via your registered electronic mail (KEP) address, using a secure electronic signature, to our KEP address: ekinteknoloji@hs01.kep.tr - 4) By sending an e-mail from thee-mail address previously provided to Ekin and registered in our system to: contact@ekin.com. - Your request should clearly state which rights you wish to exercise under Article 11 of the Law and must include information sufficient to verifyyour identity. Ekin reserves the right to request additional information ordocumentation from the applicant in order to confirm whether the applicant is indeed the data subject and to clarify any details related to the request. Yourapplication will be processed and responded to as soon as possible and in anycase within thirty (30) days. - 1. Linked Sites 
 Our website may contain links to third-party websites. Ekin is not responsible for the content or privacy practices of such external sites. Please review the privacy policies of those websites when visiting them.- 2. Changes to This Notice -  
 Ekin may update this Notice from time to time. The “Last Updated” date indicates when it was most recently revised. Please visit this page from time to time to keep up to date with our practices.- Ekin Smart City Teknoloji A.Ş. 
- Terms of Use- Ekin Europe GmbH. (“Ekin”) and/or Ekin Website (“the Website”), creators of every kind of content in this Website, workers of the company, personnel or institutions authorized by Ekin shall not have any legal or penal responsibility in the future for any claim regarding moral or material damage irrespective of your reading or not reading this terms herein. - In no event shall Ekin have any legal, penal and/or personal responsibility for any content which is not within the responsibility or authority of Ekin due to the structure of the internet according to general inclinations, and Website visitors hereby agrees and declares these terms once they visit the Website. - All information, statistical graphics and values are acquired and collected from sources having reliability within general trends and their correctness and sufficiency is not guaranteed under any circumstances by Ekin. - Ekin shall not have any legal or penal responsibility in the future for direct or indirect any moral and/or material, any positive and/or negative damages or any other damages or costs arising from the usage of information, evaluation, comment or statistical graphic or values. Contents, graphics, pictures, information, shapes, values, comments and other material content (all together referred to as \”Content\”) herein are only for information purposes. - Ekin or Content providers are not responsible for any decisions taken by users based on the Content in the Website. - Ekin is not responsible for any disruption, delay or error in the published contents and for any damage due to these reasons. - Content (in whole or in part) cannot be duplicated or distributed, used by referring for commercial reasons and transferred to other computer systems under any format without prior permission of Ekin. - Ekin is entitled to change and update unilaterally the provisions and terms herein at any time without prior notification requirement. - It is assumed and agreed by you that you have read aforespecified warnings and notifications before entering to the Website. -  
- Imprint- DISCLAIMER - The content and information contained in this Web Site has been compiled with the greatest possible care and are intended for general marketing purposes. Changes may be made by Ekin during the development and in line with the needs; models, designs, technical spesifications, visiuls or any other information on this Web Site are always subject to change without notice. This Web Site is a guide only and does not constitute an offer or contract, no rights may be derived in any way whatsoever from the content of this Web Site. For detailed information in respect of the content herein, it is suggested to contact us via legal@ekin.com. -  
- GDPR- Ekin Europe GmbH Personal Data Security & GDPR - As Ekin, we are aware of our obligations as the enabler of safe city technologies under the GDPR- General Data Protection Regulation which came into effect on May 25th, 2018 in European Union and remain committed to helping to support our clients all around the world for GDPR compliance. - What is GDPR? - GDPR lays down rules relating to the protection of natural persons with regard to the processing of personal data and rules relating to the free movement of personal data. GDPR is planned to make natural persons and their rights be centralized. - What is personal data? - Personal data means any information relating to an identified or identifiable natural person. Here is a list of personal data types - Biographical information or current living situation, including dates of birth, Social Security numbers, phone numbers and email addresses - Looks, appearance and behavior, including eye color, weight and character traits - Workplace data and information about education, including salary, tax information and student numbers - Private and subjective data, including religion, political opinions and geo-tracking data - Health, sickness and genetics, including medical history, genetic data and information about sick leave - Pseudonymization & Anonymization - “Anonymization” of data means processing it with the aim of irreversibly preventing the identification of the individual to whom it relates. - “Pseudonymization” of data means replacing any identifying characteristics of data with a pseudonym, or, in other words, a value which does not allow the data subject to be directly identified. - The legal distinction between anonymized and pseudonymized data is its categorization as personal data. Pseudonymous data still allows for some form of re-identification, while anonymous data cannot be re-identified. Both pseudonymization and anonymization are encouraged in the GDPR and enable its constraints to be met. - Ekin Product Processes related with Personal Data - Number Plate Recognition - Face Recognition - Surveillance - GDPR Principles - 1. Certain Personal Identified Information (PII) description – Any information about a natural person means personal data. - 2. Lawfulness, fairness and transparency – Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject. - 3. Data minimization – Minimization of data acquisition: Data collection level must be equal to requirements of products or systems. - 4. Purpose limitation – Personal data can be collected for a specific purpose that related person knows totally. - 5. Accuracy – Personal data shall be accurate and keep up to date where necessary. Personal data are erased or rectified without delay when they are inaccurate in regard to purpose that they are processed. - 6. Storage limitation – Personal data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes. - 7. Data Masking – Pseudonymization or anonymization is an obligation to keep data for some specific purposes. - 8. Integrity and confidentiality – Personal data shall be processed in a manner that ensures appropriate security of the personal data. - 9. Accountability – The controller shall be responsible for and be able to demonstrate compliance with all matter about personal data. - Ekin’s Attitudes - 1. All information about any natural human obtained from Ekin systems – face photo, number plate info, age and gender details etc.- is named as personal data. - 2. Ekin products collect data with the obvious legal issue such as number plate recognition and speed control in order to detect traffic infringement. - 3. Ekin products obtains as much as data only needed for its main functions. - 4. Any personal data gathered by Ekin products is about just a specific purpose. Different authorization levels for different users can be set and access without a permission will not be provided. - 5. Ekin products collect correct and update data to operate systems. - 6. Ekin gathers personal data and keeps them only during necessary time. - 7. Ekin decrypts personal data by using a special method in other words anonymizes every single data about a natural person. - 8. Ekin preserves all data including personal data with high-tech encryption method named anonymization. Ekin is inclusive safe city guard include you and your personal data. - 9. Ekin has the optimum level sense of responsibility to provide correct personal data and its analysis; accordingly, Ekin products include sensitive processor with high processing power for compliance - Ekin products are designed in a manner that neither Ekin nor any unauthorized third party can access to the records and data obtained by this product. The responsibility for the usage of the Ekin product in accordance with the terms of the personal data protection laws and relevant legislation as well as storage, handling, usage, process of the records and data obtained by the Product, in accordance with the terms of the personal data protection laws and relevant legislation belong to the user of the Product. The user of the Ekin product is also responsible for notifying the owners or relevant parties of the personal data and, for obtaining required permission from them. -  
- Quality Policy- Ekin Smart City Technologies is committed to delivering reliable and seamless products and services by employing advanced technology and modern engineering solutions, supported by an expert management team and technical staff. We operate in alignment with our vision, values, policies, and all relevant regulations. - All members of Ekin Smart City Technologies play a crucial role in upholding the quality of our products, processes, and services, and in creating value for our customers. - Our Quality Policy is to: - Prioritize customer satisfaction as our primary goal across all departments by meeting applicable requirements and standards. - Adhere to the ISO 9001:2015 Quality Management System standard, ensuring compliance and continuously improving its effectiveness. - Implement a culture of continuous improvement and development to achieve excellence in everything we do. - This policy reflects our dedication to maintaining the highest standards of quality in all aspects of our operations. -  
- Environmental Policy- Our company is committed to sustainable practices and upholding the highest standards in environmental responsibility. We adhere to the following principles: - Compliance and Continuous Improvement: We ensure compliance with all applicable legal requirements and customer expectations related to environmental aspects, while striving for continuous improvement in our environmental performance. - Sustainable Technology and Resource Conservation: We prioritize the use of technologies that minimize environmental impact, within the scope of technical and economic feasibility. By reducing raw material consumption, we contribute to the preservation of natural resources. - Environmentally Conscious Design: We integrate environmental considerations into the design of our facilities and processes to mitigate potential impacts. - Enhanced Environmental Management: Our environmental management system is continuously developed to improve our environmental performance and achieve our sustainability goals. - Awareness and Participation: We foster awareness of our environmental responsibilities among employees and stakeholders, encouraging active participation in our sustainability initiatives. - Waste Reduction and Recycling: We seek to minimize waste generated from production, transportation, storage, operations, treatment, and maintenance. Where possible, we explore recycling and reuse alternatives to optimize resource efficiency. -  - Information Security Policy- While EKİN provides services in the field of security technologies, it aims to establish and operate an Information Security Management System in accordance with the requirements specified in ISO/IEC 27001:2022, in order to implement the objectives and policies it has defined within the scope of Information Security. - To this end, EKİN commits to complying with the Information Security Management System, allocating the necessary resources for the system to operate efficiently and to achieve its goals, continuously improving its effectiveness, and ensuring that this is understood by all employees. As a result of this commitment, EKİN organizes information security awareness programs across the organization and continues its infrastructure investments. - Managers assist by assigning responsibilities to lower-level employees on security matters and by setting an example. A security mindset that begins at the top levels and is implemented must reach all the way down to the lowest-level employees of the organization. Therefore, managers in the organization support employees involved in security-related work by complying with security procedures both in writing and verbally, and by participating in security-related efforts. 

