KVKK Privacy Notice

Last Updated: March 11, 2026

1. Data Controller

Within the scope of the Turkish Personal Data Protection Law No. 6698 ("KVKK"), your personal data may be processed by Mega Communication Center Inc. (Mega Iletisim Merkezi A.S.) ("Company") as the data controller, within the framework explained below.

Information	Details
Data Controller	Mega Iletisim Merkezi A.S. (Mega Communication Center Inc.)
Address	Mega Plaza, Bornova Cad. No:16-A, Isikkent - Bornova / Izmir, Turkey
Phone	+(90) 232 388 08 08
Email	info@megailetisim.com.tr
KVKK Contact	kvkk@megailetisim.com.tr
KEP Address	megacagri@hs01.kep.tr
Field of Activity	Professional Call Center Services
Operation Centers	Bornova, Odemis, Konya, Mardin

2. Categories of Personal Data Processed

Our Company may process the following categories of personal data within the scope of call center operations, customer services, payroll management, consultancy, field services, seat leasing, and third-party integration services:

Data Category	Description	Example Data
Identity Information	Data that identifies an individual	Name, surname, Turkish ID number, date of birth, gender, nationality
Contact Information	Data used to reach an individual	Phone number, email address, residential address, fax number
Customer Transaction Information	Data obtained within the scope of call center services	Call records, request and complaint information, transaction history, customer number
Voice Recordings	Audio data from call center conversations	Phone call recordings, IVR interaction records
Job Applicant Information	Data collected within the scope of job applications	Resume information, educational background, work experience, reference information
Employee Information	Data processed within the scope of employment relationship	Social security number, bank account information, salary details, leave records, performance evaluations
Financial Information	Data related to payment and invoicing processes	Invoice details, payment records, bank account information
Physical Space Security	Data related to the security of company premises	Security camera footage, entry-exit records, visitor logs
Legal Transaction Information	Data related to legal proceedings	Lawsuit and enforcement file information, legal correspondence
Transaction Security Information	Data related to security in digital environments	IP address, log records, session information, device information
Marketing Information	Data used in marketing activities	Purchase history, survey results, campaign preferences, cookie records

3. Purposes of Processing Personal Data

Your personal data collected is processed in accordance with the personal data processing conditions specified in Articles 5 and 6 of KVKK for the following purposes:

3.1 Within the Scope of Call Center Operations

• Managing inbound and outbound calls through customer representatives
• Recording and tracking customer requests, complaints, and suggestions
• Monitoring, evaluating, and improving call quality
• Measuring and reporting customer satisfaction
• Providing IVR (Interactive Voice Response) services
• Conducting outbound calling campaigns
• Analyzing call center performance metrics

3.2 Within the Scope of Customer Services and Consultancy

• Providing professional consultancy services to our clients and business partners
• Conducting customer relationship management (CRM) activities
• Improving service quality and conducting process improvement studies
• Ensuring compliance of services provided to clients' customers with quality standards

3.3 Within the Scope of Payroll and Human Resources

• Creating and managing employee personnel files
• Calculating and paying salaries, bonuses, and fringe benefits
• Making notifications in compliance with Social Security Institution (SGK) and tax legislation
• Fulfilling occupational health and safety obligations
• Managing personnel attendance control systems
• Conducting recruitment processes and candidate evaluations
• Planning and implementing training and development programs

3.4 Within the Scope of Field Services

• Coordinating and tracking field operations
• Assigning field personnel and route planning
• Creating and managing field visit reports

3.5 Within the Scope of Seat Leasing and Third-Party Integrations

• Planning and providing seat leasing services
• Implementing and managing third-party system integrations
• Conducting API and data exchange processes securely
• Monitoring and reporting integration performance

3.6 General Purposes

• Executing contractual processes and fulfilling legal obligations
• Providing information and documents to official institutions and organizations as required by relevant legislation
• Conducting internal audit, reporting, and business development activities
• Managing information security processes
• Ensuring physical space security
• Conducting communication activities
• Managing finance and accounting operations
• Providing information to authorized persons, institutions, and organizations

4. Transfer of Personal Data

Your personal data collected may be transferred to the following parties in accordance with the personal data transfer conditions specified in Articles 8 and 9 of KVKK and for the realization of the purposes stated above:

Receiving Party	Purpose of Transfer
Business Partners and Client Companies	Sharing necessary information within the scope of call center services provided to client companies; conducting field services and seat leasing operations
Suppliers and Service Providers	Providing technology infrastructure, software, hardware, telecommunications, and third-party integration services; conducting payroll and accounting services
Authorized Public Institutions and Organizations	Fulfilling legal obligations as required by relevant legislation (Social Security Institution, Revenue Administration, Turkish Employment Agency, Courts, etc.)
Legal Advisors and Audit Firms	Conducting legal consultancy, audit, and reporting activities
Banks and Financial Institutions	Processing salary payments, invoice collections, and financial transactions
Group Companies	Coordinating business processes between operation centers (Bornova, Odemis, Konya, Mardin) and providing joint services

5. Method of Personal Data Collection and Legal Basis

Your personal data is collected by our Company through the following methods:

5.1 Collection Methods

• Phone calls: Inbound and outbound calls conducted within the scope of call center operations
• Websites: Forms, cookies, and digital interactions on the megailetisim.com.tr website
• Email: Correspondence through corporate email addresses
• Physical environment: Through security cameras and visitor forms during visits to operation centers (Bornova, Odemis, Konya, Mardin)
• Job application forms: Online or physical career application forms
• Contracts: Within the scope of contracts signed with business partners and clients
• Third-party integrations: Automatic data transfer from business partner systems through APIs and web services
• Social media platforms: Interactions through the Company's social media accounts

5.2 Legal Bases

Your personal data is processed within the scope of the following legal bases specified in paragraph 2 of Article 5 of KVKK:

• Explicit consent (KVKK Art. 5/1) - For marketing activities, campaign notifications, and satisfaction surveys
• Expressly provided by law (KVKK Art. 5/2-a) - Obligations under the Labor Law, social security legislation, Tax Procedure Law, and other relevant legislation
• Establishment or performance of a contract (KVKK Art. 5/2-c) - Fulfillment of service agreements, employment contracts, and commercial contracts
• Fulfillment of the data controller's legal obligation (KVKK Art. 5/2-d) - Compliance with legal regulations
• Establishment, exercise, or protection of a right (KVKK Art. 5/2-e) - Management of legal proceedings
• Legitimate interests of the data controller (KVKK Art. 5/2-f) - Conducting business processes, quality control, and service improvement activities

6. Rights of Data Subjects (KVKK Art. 11)

In accordance with Article 11 of KVKK, as a data subject, you have the following rights:

1. To learn whether your personal data is being processed,
2. To request information regarding the processing if your personal data has been processed,
3. To learn the purpose of processing your personal data and whether they are used in accordance with their intended purpose,
4. To know the third parties to whom your personal data is transferred domestically or abroad,
5. To request correction of your personal data if it has been processed incompletely or inaccurately,
6. To request deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of KVKK,
7. To request notification to third parties to whom your personal data has been transferred regarding the operations carried out pursuant to paragraphs (5) and (6) above,
8. To object to the occurrence of a result against you through the analysis of your processed data exclusively by automated systems,
9. To claim compensation for damages in the event that you suffer losses due to the unlawful processing of your personal data.

7. Application Method

You may submit your requests regarding the above-mentioned rights to our Company through the following methods:

Application Method	Details
Written Application	You may apply in person or through a notary with identity verification documents to our address: Mega Plaza, Bornova Cad. No:16-A, Isikkent - Bornova / Izmir, Turkey.
Email Application	You may apply via your registered electronic mail (KEP) address or the email address you have previously provided to our Company to kvkk@megailetisim.com.tr.
Contact Form	You may submit your KVKK application through the form on our Contact page. Please write "KVKK Information Request" in the subject field.

8. Data Retention Periods

Your personal data is retained for the duration necessary for the purposes for which it is processed and for the statute of limitations periods stipulated in the relevant legislation. Upon expiration of the retention period, your personal data is deleted, destroyed, or anonymized in accordance with KVKK and relevant legislation.

Data Type	Retention Period	Legal Basis
Call Voice Recordings	3 years	Service agreement and legitimate interest
Customer Transaction Records	10 years	Turkish Commercial Code Art. 82
Employee Personnel Information	10 years from the end of the employment relationship	Labor Law, Social Security legislation
Payroll and Salary Records	10 years	Social Security legislation, Tax Procedure Law
Job Application Information	2 years (for candidates not hired)	Labor Law and legitimate interest
Contracts and Commercial Records	10 years	Turkish Commercial Code Art. 82, Code of Obligations
Security Camera Footage	90 days	Legitimate interest and private security legislation
Internet Access Logs	2 years	Law No. 5651
Cookie Data	30 days - 2 years depending on cookie type	Explicit consent and legitimate interest
Accounting and Finance Records	10 years	Tax Procedure Law Art. 253

9. Update Information

This privacy notice may be updated in accordance with the Turkish Personal Data Protection Law No. 6698 and relevant legislative changes. Any amendments will be published on our Company's website (www.megailetisim.com.tr) and will become effective upon publication.

Our Company continuously reviews its policies on the protection of personal data and makes necessary updates. We recommend that you monitor the updates to this privacy notice regularly.

Mega Communication Center Inc. (Mega Iletisim Merkezi A.S.)
Mega Plaza, Bornova Cad. No:16-A, Isikkent - Bornova / Izmir, Turkey
Phone: +(90) 232 388 08 08 | Email: kvkk@megailetisim.com.tr