KVKK Disclosure Text

1. Data Controller

In accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”), your personal data is processed by the following data controller:

1.1. Affiliates

The affiliates of Sporara Teknoloji Ticaret Anonim Şirketi also act as data controllers within the scope of this disclosure text. This disclosure text also applies to your personal data processed by our affiliates.

2. Purposes of Processing Personal Data

Your personal data is processed for the following purposes:

2.1. Service Delivery

• Planning, delivering and managing corporate sports organization services
• Event organization and coordination
• Venue booking and logistics services
• Equipment supply and technical support
• Providing referees and a technical team
• Tournament and competition organization
• Team-building activities
• Organizing corporate events

2.2. Contract Management

• Establishing, performing and terminating service contracts
• Preparing and presenting quotes
• Order management and tracking
• Invoicing and accounting operations
• Payment tracking and collection
• Customer account management

2.3. Communication and Customer Relations

• Evaluating and responding to customer requests
• Customer support services
• Complaint and suggestion management
• Customer satisfaction surveys
• Sending information and announcements

2.4. Marketing and Communication Activities

• Informing about new services and campaigns (with explicit consent)
• Sending newsletters (with explicit consent)
• Marketing activities and promotions (with explicit consent)
• Customer segmentation and analysis
• Customer experience improvement work

2.5. Fulfilling Legal Obligations

• Compliance with the Tax Procedure Law and relevant legislation
• Accounting and audit obligations
• Compliance with occupational health and safety legislation
• Fulfilling court decisions and requests from administrative authorities
• Compliance with legal regulations

2.6. Security and Risk Management

• Taking security measures
• Preventing unauthorized access
• Preventing fraud and abuse
• Risk analysis and assessment
• Internal audit and compliance activities

3. Categories of Personal Data Processed

Personal data in the following categories is processed through the contact and quote-request forms offered on our website:

3.1. Data Collected via the Contact Form

The following personal data is collected through the contact form:

• Full Name: The first and last name provided in the contact form
• Email Address: The email address used for communication
• Subject: The subject of the message (optional)
• Message: The message content provided in the contact form

3.2. Data Collected via the Quote-Request Form

The following personal data is collected through the quote-request form:

• First Name: The first name provided in the quote-request form
• Last Name: The last name provided in the quote-request form
• Phone Number: The phone number used for communication
• Email Address: The email address used for communication
• Number of Participants: The number of participants planned for the event
• Service Category: The requested service category
• Sub-Service Category: The requested sub-service category (optional)
• Message: The project details and special requests provided in the quote-request form

3.3. Technical and Automatically Collected Data

The following data is collected automatically for the technical operation and security of our website:

• IP address
• Browser type and version
• Operating system information
• Device information
• Cookie data
• Website usage statistics
• Page view history
• Click data
• Session information

4. Legal Grounds for Processing Personal Data

Your personal data is processed on the basis of one or more of the following legal grounds set out in Articles 5 and 6 of the KVKK:

4.1. Explicit Consent

On specific matters (marketing activities, sending newsletters, processing of special categories of personal data, etc.), your data is processed by obtaining your explicit consent. You can withdraw your explicit consent at any time.

4.2. Establishment or Performance of a Contract

Data necessary for the establishment, performance and termination of the service contract is processed.

4.3. Legal Obligation

Data is processed to fulfil obligations under the Tax Procedure Law, the Turkish Commercial Code, the Labor Law and other legal regulations.

4.4. Legitimate Interest

Data is processed within the framework of our legitimate interests in conducting our business activities, improving service quality, ensuring security and business-development activities.

4.5. Vital Interest

Data may be processed to protect vital interests in emergencies (health problems, accidents, etc.).

4.6. Public Interest

Data may be processed in cases requiring public interest (statistics, research, etc.).

5. Transfer of Personal Data

Your personal data may be transferred to third parties in the following cases:

5.1. Domestic Transfers

• Service Providers: Business partners, suppliers and service providers we work with to deliver our services (hosting, payment systems, logistics companies, email service providers, etc.)
• Affiliates: Data may be shared with our affiliates.
• Legal Obligations: Transfers may be made to public institutions and organizations (tax office, social security institution, courts, etc.) as required by legal regulations.
• Professional Service Providers: Firms providing legal, financial, accounting and consultancy services
• Insurance Companies: Where necessary for insurance transactions

5.2. International Transfers

In accordance with Article 9 of the KVKK, your personal data may be transferred abroad in the following cases:

• Transfer to countries with adequate protection (countries designated by the KVKK Board)
• Transfer to countries without adequate protection by obtaining a written undertaking
• Transfer with explicit consent

International transfers may be made with our service providers (cloud storage, analytics tools, payment systems, etc.).

6. Retention Period of Personal Data

Your personal data is retained for the period required by the processing purposes and within the framework of legal retention periods:

Data Category	Retention Period
Contract and Transaction Records	Contract term + 10 years (Tax Procedure Law)
Financial and Accounting Records	10 years (Tax Procedure Law)
Communication Records	3 years
Marketing Permissions	Until the permission is withdrawn
Website Usage Data	2 years
Legal Obligations	Periods specified in the relevant legislation

When the retention period ends, your personal data is deleted, destroyed or anonymized in accordance with Article 7 of the KVKK.

7. Security of Personal Data

Our Company takes the following technical and administrative measures to ensure the security of your personal data:

7.1. Technical Measures

• SSL/TLS encryption technologies
• Secure server infrastructure and data centers
• Access control and authorization systems
• Firewalls and intrusion detection systems
• Data loss prevention (DLP) systems
• Regular security audits and penetration tests
• Backup and disaster recovery plans
• Secure data deletion methods

7.2. Administrative Measures

• Staff training and awareness programs
• Confidentiality agreements
• Authorization matrices
• Regular audits
• Security policies and procedures
• Incident response plans

8. Your Rights Under the KVKK

In accordance with Article 11 of the KVKK, you have the following rights regarding your personal data:

9. How to Exercise Your Rights

To exercise your rights under the KVKK, you can use one of the following methods:

9.1. Written Application

9.2. Electronic Means

9.3. Application Form

You can submit your application by filling out the KVKK application form on our website.

10. Cookies

Cookies are used on our website to improve the user experience, analyze site performance and carry out marketing activities. For detailed information about the use of cookies, please review our Privacy Policy.

11. Changes

This Disclosure Text may be updated due to changes in legal regulations, updates to our services or changes in our business processes. Updates take effect on the date they are published on our website. In the event of significant changes, you will be notified by email or through the website.

12. Contact

You can contact us with your questions, opinions and requests regarding the KVKK Disclosure Text and the processing of your personal data: