Version: 1.0  |  Effective Date: 2026

1. Purpose Of The Policy

This personal data processing policy (“policy”); the law on protection of personal data No. 6698 (“KVKK”) and related secondary legislation within the framework of Useroam Technology Company Limited (“Useroam”) performed by the basic principles of personal data processing activities, the rights of data owners and Useroam’s obligations to provide was prepared.

2. The ID Of The Principal Of The Data

Useroam Technology Company Limited, KVKK under “Data Manager” title.

• Title: Useroam Technology Company Limited
• Address: Yenimahalle Mah. Audio Sk. Weasel Apt. No: 3 Inner Door No: 10 Bakırköy / Istanbul
• The pep Address: useroamteknoloji@hs01.kep.tr
• Reference KVKK e-mail: kvkk@useroam.com
• Web site: useroam.com

Useroam, useroam the cloud service and its customers under his capacity as the responsible for the data processing activities of personal data in terms of “process data” has the title. Liabilities in this context, data processing agreements concluded with customers (DPA), and this policy is regulated by’s beyond the scope.

3. Scope Of Policy

This policy Useroam’s data committed in his capacity as responsible for in respect of personal data applies. In this context, the owners of the processed data (“contacts”) consists of the following groups:

• useroam.com and bayi.useroam.com visitors to the site
• Customer representatives and representatives
• Dealer representatives and representatives
• Supplier representatives and representatives
• Useroam employees, employee candidates and interns
• People who apply for jobs
• Dialog, demo or would like to communicate with people who franchise application form through the Useroam

4. Basic Principles In Relation To The Processing Of Personal Data

Useroam, 4 KVKK when processing personal data. shall act in accordance in accordance with the following principles:

• Being in accordance with law and the rules of honesty
• To be updated as and when necessary correct
• Specific, explicit and legitimate purposes are processed for
• In connection with the purpose they are processed, limited and being restrained
• Stipulated in the relevant legislation or for the purpose they are processed up until the time that is required to be kept

5. The Categories Of Personal Data Processed

According to the groups of the data processed by the primary contact useroam categories are:

6. Purpose Of Processing

Useroam personal data works within the following purposes:

• Contract processes and customer/dealer relationship, the execution of
• The execution of commercial activities (billing, collection, accounting)
• Respond to the communications request a demo of the process execution.
• The evaluation of applications for business processes and human resources
• The obligations of the legislation (tax, trade, employment law, KVKK)
• Responding to Information requests from competent public institution in the future
• Execution of information security processes
• Website performance analysis

7. Legal Reasons

Useroam personal data (KVKK 5. item is included in one or more of which works on the basis of the following legal grounds:

• The law clearly the prediction (m.5/2-a)
• To be directly related with the formation or performance of a contract (ft.5/2-c)
• Data required to fulfil the legal obligation of the principal to be (ft.5/2-C)
• Data processing is mandatory for the use or protection of a right of property (m.5/2-e)
• Data processing is mandatory for the legitimate interests of the data principal (ft.5/2-f)
• Explicit consent (m.5/1) — data that cannot be used for processing activities based on the above reasons only

8. Transfer Of Personal Data

Useroam personal data specified below will only be one group of recipients, KVKK 8. and 9. transfers in accordance with the provisions of Article:

• The competent public authorities (Tax Office, court, prosecution, BTK, KVKK Institution, etc.) — in order to respond to the demands of the legislation
• Accountant / accounting service provider — for the purpose of fulfillment of financial obligations
• Infrastructure and cloud service providers (Google, workspace, server hosting provider — service presentation for the purpose of
• Banks and payment institutions — for the purpose of carrying out financial transactions
• Legal advisors and auditors — to the extent necessary, under an obligation of confidentiality

Within the scope of Google Analytics, website analytics (Google LLC) over cookie-based data processing takes place. In this context, the transfers, the visitor's cookie policy is made in accordance with the details and cookie preferences’s are described in the.

9. Storage Times

And for a period prescribed in the legislation needed for the purpose of processing personal data can be stored. The summary of this period is as follows:

10. Data Security Measures

Useroam, KVKK 12. processing in the context of the item and the nature of the activity implements technical and administrative security measures commensurate with the level of risk. These measures between authorized access control, encryption, security logs, backups, periodic review, and awareness work includes works that are employee privacy responsibilities.

11. The rights of the person concerned (KVKK m.11)

KVKK 11. as related in the context of the person the item you have the following rights:

• If your personal data has been processed learning
• Your personal data is processed, to request information in relation to it
• Purposes of the processing of your personal data and whether they are used according to the purpose of learning
• Knowing your personal data is transferred within or outside the country in the third person
• Missing or incorrectly processed and request correction of your personal data
• KVKK require to be processed is processed in accordance with the provisions of the reasons that despite the fact that in the event of the disappearance request your personal data erased or destroyed
• Correction, deletion, or destruction of the process data is transmitted to third parties where a request to be notified
• Exclusively a result of analysis by means of automated systems don't argue with the emergence of a result against you
• Offset the losses you have suffered due to the unlawful processing of your personal data, we propose to

12. Reference Method

To exercise the rights mentioned above:

• Wet-written and signed application: Useroam’s the above-mentioned through by hand or by registered mail to the physical address
• PEP via: useroamteknoloji@hs01.kep.tr
• Registered in our system, e-mail: kvkk@useroam.com

KVKK your application 13. pursuant to Article not later than 30 (thirty) days and shall be concluded within is free of charge. Applications to be used in the template of the form “contact KVKK application form” with the name of useroam.com the address has been published.

13. Modifications To Policy

Useroam this policy’s also changes in legislation, business processes, or changes in reserves the right to change for improvement purposes. Current version useroam.com the effective date and shall be published at the address specified.