Clarification Text and Privacy Policy

Data Controller

Softage Yazılım Anonim Şirketi ("Vega"), registered at the Istanbul Trade Registry, located at Ahmet Yesevi Mah. Kerem Sk. No:9 Teknopol Istanbul, 34903 Pendik/Istanbul, is committed to protecting personal data. This document has been prepared to inform you about the processing of your personal data under the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the EU General Data Protection Regulation ("GDPR").

Personal Data Collected and Processing Purposes

When using the Vega platform, the following personal data may be processed:

• Identity Data: Name, surname, national ID number
• Contact Data: Email address, phone number, postal address
• Financial Data: Invoice details, payment records
• Health Data: Patient records processed within the clinic management system (contractual scope only)
• Usage Data: Platform usage statistics, log records

This data is processed for purposes including service delivery, contract management, fulfillment of legal obligations, service quality improvement, and communication about campaigns and innovations.

Situations Requiring Express Consent

Your explicit consent is obtained for marketing communications, optional profiling activities, and data processing without a legal basis. You have the right to withdraw this consent at any time.

Processing Without Explicit Consent

Your data may be processed without explicit consent in the following circumstances:

• Where expressly provided for by law
• Where directly related to the establishment or performance of a contract
• Where necessary to fulfill a legal obligation
• Where within our legitimate interests, provided it does not harm your fundamental rights and freedoms

Transfer of Personal Data

Your data may be shared with authorized public authorities within legal requirements, contracted sub-processors for service delivery, and business partners only to the extent necessary. International data transfers are carried out with appropriate safeguards under Article 9 of KVKK and relevant GDPR provisions.

Data Retention Period

Your data is retained for the duration required by the processing purpose and applicable statutory retention periods. Upon expiry of these periods, your data will be deleted, destroyed, or anonymized.

Data Subject Rights Under GDPR

• Right of access
• Right to rectification
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object
• Rights related to automated decision-making and profiling

Data Subject Rights Under KVKK

• Learn whether your personal data is being processed
• Request information about the processing purpose and its compliance
• Learn about third parties to whom data is transferred domestically or abroad
• Request correction of incomplete or inaccurate data
• Request deletion when processing conditions cease to exist
• Object to results arising through automated systems that are against your interest
• Request compensation for damages caused by unlawful processing

Contact

To exercise your rights or submit inquiries, you may contact us at our address: Ahmet Yesevi Mah. Kerem Sk. No:9 Teknopol Istanbul, 34903 Pendik/Istanbul. Responses of up to ten pages are free of charge; each additional page costs 1 Turkish Lira.