The manner in which the information obtained about you and the services you request during your visit to this website and while benefiting from the services we provide through it will be used and protected is subject to the terms specified in this "Privacy Policy." By visiting this website and requesting to utilize the services offered through this site, you accept the terms specified in this "Privacy Policy."

1. Purpose of the Personal Data Protection and Processing Policy

To date, Opera Management Consulting and Financial Services Inc. (Opera Consulting), considering the sensitivity of its activities, has kept data received from customers and prospective customers confidential and has never shared it with third parties. Protecting personal data is a fundamental policy of our company. Even before the enactment of any legal regulation, our company and its affiliates placed great importance on the confidentiality of personal data, adopting it as a principle of operation and issuing instructions to employees accordingly. Opera Consulting is committed to complying with all responsibilities introduced by the Personal Data Protection Law No. 6698 (KVKK). The principles related to personal data protection adopted by our company also extend to our affiliates.

2. Scope and Modification of the Personal Data Protection and Processing Policy

This Policy has been prepared by our company in accordance with KVKK, which is fully in force as of today. Data obtained with your consent or as otherwise legally permitted under KVKK will be used to enhance the quality of the services we provide and improve our quality policies. Some of the data we hold is anonymized and used for statistical purposes; such data is not subject to KVKK and our Policy. The "Opera Consulting Personal Data Protection and Processing Policy" aims to protect data obtained automatically from customers, prospective customers, employees, and the customers and employees of companies with which we have a business partnership, as well as other individuals.

Our company reserves the right to amend our policy and regulations to ensure compliance with KVKK and to improve the protection of personal data.

3. Fundamental Principles Regarding the Processing of Personal Data

• Compliance with Laws and Principles of Fairness: Opera Consulting queries the source of the data it collects or receives from other companies, ensuring that it is obtained in compliance with laws and principles of fairness. In this regard, Opera Consulting provides necessary warnings and notifications to third parties (including agencies and other intermediaries) that sell its services to ensure the protection of personal data.

• Accuracy and Timeliness: Opera Consulting prioritizes ensuring that all data held within its systems is accurate, free from errors, and promptly updated if changes are communicated.

• Processing for Specific, Clear, and Legitimate Purposes: Opera Consulting processes data only for the purposes it has explicitly obtained consent for during service provision. Data is not processed, used, or allowed to be used for purposes outside of the stated intent.

• Relevance, Limitation, and Proportionality: Opera Consulting ensures that data is processed only for purposes it is related to and used only to the extent necessary for service delivery.

• Retention for Required Duration: Opera Consulting retains data stemming from contractual obligations for the duration necessary under laws regarding dispute resolution, commercial requirements, and tax regulations. Once these purposes are no longer valid, the data is deleted or anonymized.

Regardless of whether data is collected or processed with consent or in accordance with the law, the above principles always apply to Opera Consulting.

Rights Under Article 11 of KVKK

• Under Article 11 of the KVKK, you have the following rights:

• To learn whether your personal data is being processed,

• To request information if your personal data has been processed,

• To learn the purpose of data processing and whether your data is being used in accordance with the stated purposes,

• To know the third parties, either within Turkey or abroad, to whom your personal data has been transferred,

• To request correction of incomplete or inaccurate data,

• To request deletion or destruction of data under conditions specified by law,

• To request that corrections or deletions made under clauses (d) and (e) be communicated to third parties to whom the data was transferred,

• To object to adverse outcomes arising from the exclusive analysis of processed data through automated systems,

• To claim compensation for damages incurred due to unlawful processing of personal data.

Opera Consulting respects these rights and acts in accordance with them.

Minimal Data Processing Principle (Data Economy Principle)

Under the principle referred to as the "minimal data processing principle" or "data economy principle," Opera Consulting processes only the data necessary for its systems. The purpose of data collection determines which data will be collected. Unnecessary data is not collected. Any other data received by the company is similarly processed into its systems. Excess information is not recorded in the system and is deleted or anonymized. Such data may be used for statistical purposes.

Deletion of Personal Data

When statutory retention periods expire, legal proceedings conclude, or other obligations end, personal data is deleted, destroyed, or anonymized by the company, either automatically or upon the request of the individual concerned.

Accuracy and Data Updates

Data within Opera Consulting is processed based on the declarations of the relevant individuals. Opera Consulting is not obligated to verify the accuracy of the data declared by customers or individuals who interact with the company, as this aligns with legal and operational principles. Declared data is assumed accurate. The principle of data accuracy and currency is embraced by Opera Consulting. The company updates personal data processed based on official documents or at the request of the individual and takes necessary measures to ensure its accuracy.

Confidentiality and Data Security

Personal data is confidential, and Opera Consulting upholds this confidentiality. Within the company, only authorized personnel can access personal data. Necessary technical and administrative measures are implemented to protect the personal data collected by Opera Consulting, preventing unauthorized access and safeguarding customers and prospective customers from harm. This includes ensuring software compliance with standards, carefully selecting third parties, and enforcing adherence to data protection policies within the company.

4. Purposes of Data Processing

The collection and processing of personal data by Opera Consulting will be carried out in line with the purposes stated in the clarification text. Data is collected and processed to establish contracts and provide better services to customers.

Data Collection and Processing for Customer, Prospective Customer, and Business Partner Relations

• Customer and Prospective Customer Data for Contractual Relationships: If a contractual relationship is established with our customers or prospective customers, personal data collected can be used without explicit consent, provided it is within the scope of the contract's purpose. Data is used to improve contract execution and meet service requirements. When necessary, customers are contacted for updates. For prospective customers, data they voluntarily provide is processed to deliver easier and higher-quality services in the future. If such data does not result in a contractual relationship, it is deleted upon request.

• Business Partner Data: Opera Consulting adheres to legal standards when sharing data with business or solution partners. Data is shared under confidentiality commitments and only to the extent required for the service. Partners are required to take all necessary measures to ensure data security.

Data Processing for Advertising Purposes

In accordance with the Law on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages, advertising-related electronic messages can only be sent to individuals who have given prior consent. The recipient’s explicit approval is mandatory. Opera Consulting adheres to the details of "consent" as defined in the relevant legislation. This consent encompasses all commercial electronic messages sent to the recipient’s electronic communication address for purposes such as promoting and marketing the company's goods and services, increasing awareness through congratulatory messages, or similar content. This consent may be obtained in written form, physically, or through any electronic communication tool. The key elements include a clear declaration of the recipient’s acceptance of commercial messages, along with their name, surname, and electronic communication address.

Data Processing Due to Legal Obligations or Explicit Legal Provisions

Personal data may be processed without explicit consent if the processing is explicitly stipulated by the relevant legislation or necessary to fulfill a legal obligation. The type and scope of data processing must comply with the relevant legal provisions and be limited to what is necessary for lawful processing.

Data Processing by the Company

The company processes personal data in line with its legitimate purposes and the services it provides. However, this data may never be used for unlawful activities.

Processing of Special Categories of Personal Data

Under KVKK, special categories of personal data include information about an individual's race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, clothing, association or union memberships, health, sexual life, criminal convictions, security measures, and biometric or genetic data. Opera Consulting takes the necessary precautions prescribed by the Board for processing such sensitive data.

Opera Consulting processes sensitive personal data collected with the individual’s consent solely for the purposes for which it was collected, ensuring better service delivery.

Data Processed by Automated Systems

Opera Consulting complies with KVKK when processing data via automated systems. Information derived from such data cannot be used against the individual without explicit consent. However, Opera Consulting may use data within its systems to make decisions regarding individuals it interacts with.

User Information and the Internet

When personal data is collected, processed, or used on Opera Consulting's websites or other systems/applications, individuals are informed via privacy notices and, where necessary, about cookies. Individuals are informed about the practices on our websites. All personal data will be processed lawfully.

When you visit our website, we provide the following information regarding cookies used or to be used:

Data Processed by Automated Systems

Data processed by automated systems regarding employees may be used for internal promotions and performance evaluations. Employees have the right to object to outcomes and may do so by following internal procedures. Such objections are evaluated within the company.

Functional and Analytical Cookies

These cookies are used to remember preferences, ensure effective website use, optimize the site to meet user demands, and collect data about how visitors use the site. By nature, such cookies may contain personal information such as usernames.

Third-Party Cookies

Opera Consulting's websites, mobile applications, and mobile websites work with third-party, reliable, and recognized advertising providers. These third-party service providers may place their cookies to offer personalized advertisements. Cookies placed by third parties collect, process, and analyze browsing information from visitors on the website.

Commercial Cookies

Commercial cookies enhance your user experience by presenting targeted products/content based on your interests and preferences and offering a more advanced and personalized advertising portfolio. The retention period for session, persistent, functional, analytical, and commercial cookies described above is approximately two (2) months, after which adjustments can be made via internet browser settings. These settings vary depending on the browser used.

How to Delete Cookies

Most internet browsers are set to accept cookies automatically upon installation. You can block cookies or set alerts when cookies are sent to your device by using the help or settings menu of your internet browser. For detailed information about managing cookies and adjusting browser settings, refer to your browser's instructions or help options.

Collection and Processing of Security Data at Facilities

Opera Consulting, as the data controller under KVKK, collects security camera footage during your visit to ensure both your safety and that of the company and to provide secure services.

Your personal data is not used for purposes other than those listed and is processed under the legitimate interest legal basis outlined in Article 5/2(f) of KVKK.

Collected personal data is not shared with third parties or institutions unless required to fulfill legal obligations under Article 5/2(ç) of KVKK, which involves responding to requests from authorized public institutions. Once the purpose for data collection ends, your data is destroyed.

6. Employee Data

Data Processing for Employment Relationships

Personal data belonging to employees may be processed without explicit consent when necessary for employment relationships or health insurance purposes. However, Opera Consulting ensures the confidentiality and protection of its employees' data.

Processing Due to Legal Obligations

Opera Consulting may process personal data of its employees without explicit consent when the processing is explicitly stipulated by applicable laws or necessary to fulfill legal obligations. This is strictly limited to statutory obligations.

Processing for the Benefit of Employees

Opera Consulting may process personal data without explicit consent for activities that benefit employees, such as private health insurance. Additionally, in cases of disputes arising from employment relationships, Opera Consulting may process employees' data to address such matters.

Processing of Special Categories of Personal Data

Under KVKK, special categories of personal data include information about individuals' race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, clothing, association or union memberships, health, sexual life, criminal convictions, security measures, and biometric or genetic data. Opera Consulting ensures compliance with the necessary measures prescribed by the Board when processing such sensitive data.

Sensitive personal data is processed only for the purposes for which it was collected, with the individual's explicit consent, and is used solely for that purpose. For example, sensitive data collected to provide insurance and health services to employees is processed exclusively for those purposes.

Telecommunications and Internet Usage

Computers, telephones, email, and other tools provided to employees by the company are intended solely for business use. Employees cannot use these resources for personal purposes or communication. The company reserves the right to monitor and audit all data on these resources. Employees are required to agree, from the start of their employment, that they will not store non-business-related information or data on company-provided devices, such as computers or telephones.

7. Transfer of Personal Data Domestically and Internationally

Personal data may be shared by Opera Consulting with business and solution partners to ensure the provision of services.

Opera Consulting may transfer personal data to the following parties for specific purposes:

• Business Partners: Limited to fulfilling the purposes of the partnership.

• Suppliers: Limited to services outsourced by the company and necessary for carrying out commercial activities.

• Solution Partners: Limited to commercial activities that involve the participation of Opera Consulting's affiliates.

Opera Consulting may transfer personal data domestically or internationally in compliance with the conditions specified by KVKK and with the explicit consent of the individual, where required.

8. Rights of Individuals

Opera Consulting acknowledges that individuals have the right to provide consent before their data is processed and the right to determine the fate of their data after processing.

Individuals may contact Opera Consulting through the communication channels announced on the company’s website to exercise the following rights regarding personal data:

• Learn whether their personal data has been processed,

• Request information about their processed personal data,

• Learn the purpose of data processing and whether it has been used appropriately,

• Know the third parties to whom data has been transferred domestically or internationally,

• Request correction of incomplete or inaccurate data,

• Request deletion or destruction of data under conditions specified in Article 7 of KVKK,

• Request notification of actions taken under (d) and (e) to third parties to whom data was transferred,

• Object to adverse outcomes arising from the exclusive analysis of processed data through automated systems,

• Claim compensation for damages incurred due to unlawful processing of personal data.

However, individuals have no rights regarding anonymized data within Opera Consulting.

Opera Consulting may share personal data with relevant institutions and organizations if required for business or contractual relationships, judicial duties, or the lawful exercise of state authority.

Requests Regarding Personal Data

Personal data owners can submit their requests related to the above-mentioned rights by completing the application form available on Opera Consulting's official website at https://www.operadanismanlik.com/en/contact.php, signing it with a wet signature, and sending it to the contact address below via registered mail with return receipt, along with a photocopy of their ID (only the front side for ID cards).

Applications will be responded to within the shortest possible time, but no later than 30 days after the request reaches the company. Applications must be submitted via registered mail with return receipt. Additionally, only requests related to the applicant will be answered; applications made regarding a spouse, relative, or friend will not be accepted. Opera Consulting may request additional relevant information and documents from applicants.

9. Principle of Confidentiality

Data held by Opera Consulting, whether belonging to employees or others, is confidential. No one may use, copy, reproduce, transfer, or utilize such data for purposes other than business needs without compliance with contractual or legal obligations.

10. Transaction Security

Opera Consulting implements all necessary technical and administrative measures to protect personal data collected and prevent it from falling into unauthorized hands, thereby safeguarding its customers and prospective customers from harm. These measures include ensuring compliance of software with standards, carefully selecting third parties, and adhering to data protection policies within the company. Security measures are continuously updated and improved.

11. Audits

Opera Consulting conducts necessary internal and external audits to ensure the protection of personal data.

12. Notification of Breaches

When notified of a breach involving personal data, Opera Consulting immediately takes action to address the issue, minimize the impact on the affected party, and compensate for damages. If personal data is accessed by unauthorized individuals, Opera Consulting promptly informs the Personal Data Protection Board.

Applications regarding breaches can also be submitted using the procedures specified at https://www.operadanismanlik.com/en/contact.php

Requests Made Under the Personal Data Protection Law (KVKK)

All requests must be submitted by completing the form available at https://www.operadanismanlik.com/en/contact.php, attaching a photocopy of the ID, and sending the form to the address specified via registered mail with return receipt.

Rights regarding personal data can only be exercised concerning one’s own data. Requests related to data of others, even if submitted by someone with a completed form and ID photocopy, will not be processed. Even after data deletion requests are fulfilled, data may still be shared with official authorities if requested by those authorities.

For the application form, visit: https://www.operadanismanlik.com/en/contact.php

Contact Information

For questions regarding the privacy agreement, please contact us using the following details:

Company Name: Opera Management Consulting and Financial Services Inc.
Address: Üçevler Mh. Bayraktepe Sk. Akay İş Mrk. No:7/2 Nilüfer/Bursa/Türkiye
Email Address: bilgi@operadanismanlik.com