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INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA

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1. Data Controller and Its Representative

With regard to the processing of your personal data, Talya Yazılım ve Bilişim Anonim Şirketi acts as the Data Controller. Your personal data is processed by the Company within the framework described below and always in compliance with Law No. 6698 on the Protection of Personal Data ("Law No. 6698").

For detailed information regarding the purposes for which your personal data is processed by us, please refer to our Privacy Policy.

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2. Purpose of This Information Notice

This Information Notice on the Processing of Personal Data ("Information Notice") has been prepared in accordance with Law No. 6698 on the Protection of Personal Data ("KVKK") and the applicable legislation, for the purpose of informing data subjects about the personal data processing activities carried out by the Company.

The Company processes the personal data of participants, invitees, visitors, employees, suppliers, business partners, and other relevant individuals in connection with events, meetings, conferences, organizations, and similar activities organized by its customers, in accordance with the principles set forth under the KVKK and applicable legislation.

The Tridisgo platform and mobile applications created through this platform may be used in events and organizations organized or conducted by the Company's customers.

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3. Purposes of Processing Your Personal Data

Depending on the nature of the activity and the relationship between the data subject, the relevant institution, and the Company, the following categories of personal data may be processed:

  • Identity Information: first name, last name, and similar information.

  • Contact Information: telephone number, email address, postal address, and similar information.

  • Employment Information: company name, title, position, and similar information.

  • User Information, User Transaction Information, and Financial Information: membership information, membership ID number, dates and times on which you use the Company's services, search terms and filtering preferences used while searching on the Site, preferences, ratings and reviews, pages visited, errors encountered during use, billing and payment information, and balance information (including copies of invoices issued to users and payment receipts received from users, invoice number, invoice amount, invoice date, and similar information).

  • Event and Organization Information: attendance information, registration information, flight and accommodation information, event preferences, and similar information.

  • Location Information: specific or approximate location information obtained while you use the Company's services, such as GPS data.

  • Transaction Security Information: login credentials, password information, operating system, device information, log records, and similar technical information.

  • Marketing Information: reports and assessments reflecting your habits and preferences, notifications, targeting information, cookie records, and similar information.

  • Complaint Management Information: complaints submitted through the Site.

  • Risk Management Information: IP address.

  • Application Usage Information.

  • Device and Technical Information: operating system, device information, log records, and similar technical information.

  • Audio-Visual Records: photographs and/or video recordings where photography or video recording is carried out as part of an event.

  • Complaint and Recommendation Records: information relating to requests, complaints, recommendations, and communication processes.

  • User-Generated Information: events created by users, event information (such as name, location, and date), event details, and shared photographs and videos.

Data that has been anonymized within the scope of Articles 3 and 7 of Law No. 6698 shall not be considered personal data pursuant to the relevant provisions of the Law. Accordingly, processing activities concerning such anonymized data shall not be subject to the provisions of this Privacy Policy.

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Collection Methods and Purposes of Processing Personal Data

Your personal data may be collected through the following means, either by automated or non-automated methods:

  • Event and organization registration forms,

  • Physical or electronic forms,

  • Websites and online registration systems,

  • The Tridisgo platform and mobile applications,

  • Email, telephone, and other communication channels,

  • Registration and check-in procedures carried out at event venues,

  • Company employees, service providers, or business partners,

  • Information provided directly by you,

  • Other methods permitted under applicable legislation.

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Purposes of Processing Your Personal Data

Your personal data collected through the aforementioned methods may be processed for the following purposes:

  • Planning and conducting events, meetings, conferences, and organizations,

  • Creating and managing event participant records,

  • Performing participant verification and check-in procedures,

  • Communicating event programs and announcements to participants,

  • Providing services offered within the scope of the event,

  • Communicating with participants,

  • Managing requests, complaints, and feedback,

  • Providing and operating mobile applications and digital services,

  • Ensuring the security of applications and services,

  • Detecting and resolving technical issues,

  • Improving the quality of services,

  • Generating statistics regarding event and application usage,

  • Conducting information security processes,

  • Fulfilling legal obligations,

  • Responding to requests from authorized public institutions and organizations,

  • Conducting the Company's legal and commercial activities,

  • Protecting the Company's legitimate interests,

  • Establishing, exercising, or protecting rights in the event of potential disputes.

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You may submit an application to obtain information as to whether your personal data is being processed.

The personal data you share with the Company may be processed for purposes including enabling you to benefit from the Site and the services provided through the Site or the Mobile Application ("Site"); completing your membership registration on the Site; updating your membership information; improving the services provided by the Company and through the Site; introducing new services and providing you with the necessary information in this regard; conducting the Company's commercial activities; determining and implementing commercial and business strategies; ensuring the legal and commercial security of the Company and persons with whom the Company has business relationships; providing you with the necessary information in this context; and fulfilling obligations arising from the nature of such activities.

Such personal information may be used to communicate with you or to improve your experience on the Site or Mobile Application, including managing communication processes and conducting satisfaction surveys. It may also be used for internal reporting and business development activities, as well as for conducting various statistical evaluations, creating databases, and carrying out market research without disclosing your identity.

For processing activities within the scope of an event that may result in the public disclosure of your information, your explicit consent is obtained separately pursuant to Article 6/1 of the Law. Such consent shall be used solely for the purpose of carrying out the relevant public disclosure activity.

The Company may process and store such information for the purposes of direct marketing, digital marketing, remarketing, targeting, profiling, and analysis; transfer such information to third parties where legally permitted; and contact you for the purposes of promoting various applications, products, and services and providing notifications regarding maintenance and support activities.

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In addition, pursuant to Articles 5 and 8 of the Law and/or where exceptions provided under applicable legislation exist, the Company may process personal data and share it with third parties without obtaining your separate consent as the Data Subject, to the extent permitted by applicable law.

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The principal circumstances under which personal data may be processed without obtaining the Data Subject’s explicit consent are set forth below:

  • Explicitly provided for by law;

  • Where it is necessary to protect the life or physical integrity of the Data Subject or another person who is unable to express consent due to actual impossibility or whose consent is not legally valid;

  • Where the processing of personal data is necessary, provided that it is directly related to the establishment or performance of a contract between the Data Subject and the Company;

  • Where processing is necessary for the Company to fulfill its legal obligations;

  • Where the personal data has been made public by the Data Subject;

  • Where data processing is necessary for the establishment, exercise, or protection of a right;

  • Where processing is necessary for the legitimate interests of the Company, provided that such processing does not adversely affect the fundamental rights and freedoms of the Data Subject.

As stated above, the Company may use cookies and, within this scope, may process data collected through cookies and transfer such data to third parties to the extent necessary for the provision of analytics services by such third parties, solely for the purposes required by those analytics services.

The aforementioned technical communication files are small text files sent by the Site to the Data Subject’s browser for storage in the main memory. These technical communication files facilitate the use of the Site by storing information regarding the status and preference settings associated with a website.

Technical communication files are designed and used to obtain statistical information, such as the number of people using websites over time, the purposes for which an individual visits a website, the frequency of such visits, and the duration of visits. They may also be used to help dynamically generate advertisements and content tailored to users through specially designed user pages.

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Technical communication files are not designed to retrieve any personal data from the main memory other than the information necessary for the purposes described above.

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Most browsers are initially configured to accept technical communication files (cookies). However, users may change their browser settings at any time to prevent such files from being received or to receive a notification when a technical communication file is sent.

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4. Method of Processing Personal Data

Your personal data is collected and processed through the Tridisgo platform and mobile applications developed by Tridisgo, either wholly or partially by automated means or by non-automated/physical means, provided that such processing forms part of a data recording system and subject to your consent to the sharing of such data.

Your personal data is processed upon obtaining your explicit consent pursuant to Article 5/1 of Law No. 6698. In addition, where the relevant conditions are met, your personal data may be processed pursuant to Article 5/2(c) of the Law for the establishment, performance, and termination of the contract to be concluded with you; pursuant to Article 5/2(ç) for the fulfillment of the Company’s legal obligations; pursuant to Article 5/2(e) for the establishment, exercise, or protection of a right; and pursuant to Article 5/2(f) within the scope of the legitimate interests of the data controller, provided that such processing does not adversely affect the fundamental rights and freedoms of the relevant data subjects.

Records relating to processing activities carried out based on your explicit consent are automatically logged in the system for the purpose of evidencing such consent. The log records maintained for this purpose are limited to the date and time on which the consent was provided, user ID information, transaction records, and IP information.

Data processed within the scope of an event is retained only for the period required by the purpose of processing and, in accordance with the KVKK, for the period necessary to fulfill the data controller’s burden of proof, depending on the duration of the processing purposes. Upon expiration of this period, such data is irreversibly deleted or anonymized.

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5. Parties to Whom Your Personal Data May Be Transferred and Purposes of Transfer

Your personal data may be shared with and transferred to business partners, intermediary service providers, natural or legal persons from whom services are received, suppliers, and consultants with whom we cooperate for purposes such as fulfilling the processing purposes specified above, sending commercial electronic communications, processing, storing, and protecting data, in accordance with Articles 8 and 9 of Law No. 6698 and for the purposes set forth above. Such sharing and transfers may be carried out within the limits prescribed by law, to the extent required by and proportionate to the nature and purpose of the relevant transaction, provided that the security of your personal data is ensured through confidentiality agreements.

Your personal data may be transferred to natural or legal persons established in Türkiye, as well as abroad for processing in Türkiye or for processing and storage outside Türkiye, provided that the requirements set forth under the KVKK are complied with, including transfers to countries providing an adequate level of protection and/or to countries that do not provide an adequate level of protection, subject to the conditions prescribed under the KVKK.

In addition, your personal data may be shared with public institutions or organizations that are legally authorized to request and receive such data where required by law.

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6. Rights of Personal Data Subjects, Personal Data Security, and Right to Apply

Your personal data is collected through physical and electronic means, including email, telephone, web services, internal systems, and other channels through which you contact us in connection with the conduct of the business relationship between you and the Company, based on the personal data processing conditions set forth under Articles 5 and 6 of the Law.

Your personal data is collected based on the following legal grounds: where expressly provided for by law; where necessary for the Company to fulfill its legal obligations; where directly related to the establishment and performance of a contract; based on legal grounds relating to the legitimate interests of our Company; and based on your explicit consent or on the fulfillment of contractual and legal obligations, where applicable.

The Company protects your personal data in accordance with all technical and administrative security controls required under information security standards and procedures. These security measures are implemented at a level appropriate to potential risks, taking into account available technological capabilities.

The Company also ensures that the same level of security procedures is maintained in accordance with the protocols concluded with our business partners and other relevant parties, and carries out the necessary controls to ensure compliance with such procedures.

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Rights of Personal Data Subjects under Article 11 of Law No. 6698

As a personal data subject, pursuant to Article 11 of Law No. 6698, you have the following rights:

  • To learn whether your personal data has been processed,

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

  • To learn the purpose of processing your personal data and whether such data is used in accordance with its purpose,

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

  • To request the correction of your personal data if it has been processed incompletely or inaccurately,

  • To request the deletion or destruction of your personal data,

  • To request that third parties to whom your personal data has been transferred be notified of any actions taken regarding the correction, deletion, or destruction of your personal data,

  • To object to the occurrence of a result against you arising from the analysis of your processed personal data exclusively through automated systems,

  • To demand compensation for damages in the event that you suffer damage due to the unlawful processing of your personal data.

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As personal data subjects, you may submit your requests concerning your rights by contacting the Company. Your requests shall be concluded as soon as possible and, in any event, within 30 (thirty) days at the latest, depending on the nature of the request.

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Data subjects may submit their requests by completing the “Application Form for Data Subjects under the Law on the Protection of Personal Data” and delivering it in person, by post or courier, or electronically via email to .

If the relevant transaction incurs an additional cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.

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7. Transfer of Personal Data

Your personal data may be transferred, in accordance with the conditions stipulated under the KVKK and applicable legislation, for the purposes of fulfilling the purposes of processing and providing the relevant services, to:

  • The Tridisgo service provider,

  • Technical infrastructure and hosting service providers,

  • Software and technology service providers,

  • Service providers involved in event organization,

  • Business partners and suppliers,

  • Email, communication, analytics, and similar technical service providers,

  • Authorized public institutions and organizations,

  • Legally authorized natural or legal persons or organizations.

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The transfer of your personal data to third parties shall only be carried out where the legal conditions stipulated under the applicable legislation are met and shall be limited to the relevant processing purpose.

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TALYA YAZILIM VE BİLİŞİM ANONİM ŞİRKETİ – TRIDISGO

UNDERTAKING FOR THE TRANSFER OF PERSONAL DATA ABROAD UNDER LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

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In this Undertaking, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo, as the data exporter, and Amazon Web Services EMEA SARL, established abroad, as the data importer, hereby undertake to fulfill and continue to fulfill the obligations set forth below pursuant to Article 9, paragraph 2(b), of Law No. 6698.

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1. Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo, as the data controller and data exporter, hereby undertakes to have fulfilled and to continue to fulfill the following obligations:

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a) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo undertakes that the personal data has been processed and transferred in compliance with Law No. 6698 and other applicable legislation.

b) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo has taken all necessary technical and administrative measures to ensure an appropriate level of security, taking into account the nature of the personal data, in order to prevent the unlawful processing of personal data, prevent unlawful access to personal data, and ensure the secure storage of personal data. It also confirms that Amazon Web Services EMEA SARL, as the data importer, has taken such measures.

c) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo has informed Amazon Web Services EMEA SARL, as the data importer, that the transferred personal data shall be processed in accordance with Law No. 6698 and the provisions of this Undertaking.

d) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo has informed Amazon Web Services EMEA SARL, as the data importer, about Law No. 6698 and other applicable data protection regulations to which it is subject.

e) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo has informed Amazon Web Services EMEA SARL, as the data importer, that it is required to notify Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo as soon as possible if the transferred personal data is unlawfully obtained by third parties. In the event of such a data breach, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall notify the relevant data subject and the Personal Data Protection Board as soon as possible.

f) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall submit to the Personal Data Protection Board any notifications received from Amazon Web Services EMEA SARL, as the data importer, in accordance with the provisions of the applicable legislation.

g) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall immediately inform the Personal Data Protection Board of any issues arising in connection with Amazon Web Services EMEA SARL’s fulfillment of the provisions set forth in this Undertaking.

h) Although Amazon Web Services EMEA SARL, as the data importer, has agreed to respond to inquiries received from data subjects and the Personal Data Protection Board, if it is unable to provide such a response, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall respond to the relevant data subject or the Personal Data Protection Board within a reasonable period of time, based on all information and documents available to it.

i) In the event that Amazon Web Services EMEA SARL, as the data importer, breaches its obligations set forth in this Undertaking, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo may suspend the transfer of personal data or terminate this Undertaking until such breach has been remedied.

j) In the event that the transfer of personal data is suspended or this Undertaking is terminated, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall notify the Personal Data Protection Board of such situation as soon as possible.

k) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo undertakes that Amazon Web Services EMEA SARL, as the data importer, has the administrative and technical capacity required to fulfill its obligations arising from these provisions.

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2. Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo, as the Data Controller and Data Importer, hereby undertakes to have fulfilled and to continue to fulfill the following obligations:

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a) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo has taken all necessary technical and administrative measures to ensure an appropriate level of security, taking into account the nature of the personal data, in order to prevent the unlawful processing of personal data, prevent unlawful access to personal data, and ensure the secure storage of personal data.

b) Where Amazon Web Services EMEA SARL has personal data processed on its behalf by another natural or legal person, it shall be jointly responsible with such persons for taking the measures specified in paragraph (a). Persons operating under the authority of Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo, including data processors, shall process personal data solely and exclusively in accordance with the instructions received from the data importer.

c) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall process personal data in accordance with Law No. 6698 and the agreement between Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo and Amazon Web Services EMEA SARL. If compliance with the Law and the agreement cannot be ensured for any reason, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall be immediately informed of the matter. In such case, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo may suspend the data transfer and terminate the agreement.

d) Amazon Web Services EMEA SARL acknowledges, represents, and undertakes that there are no national regulations applicable to the personal data to be transferred under the agreement that conflict with the provisions of the agreement. If, during the term of the agreement, any legislative change occurs that may affect the data importer’s ability to fulfill its obligations under the agreement, Amazon Web Services EMEA SARL shall immediately notify the authorized representatives of Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo. In such case, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo may suspend the data transfer and shall have the right to terminate the agreement.

e) Amazon Web Services EMEA SARL shall immediately notify Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo of any requests received from a judicial authority concerning the transferred personal data. In such case, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall have the right to suspend or terminate the agreement, depending on the nature of the request.

f) Amazon Web Services EMEA SARL shall duly respond, as soon as possible, to any inquiries submitted by Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo under the agreement and shall comply with the decisions and opinions of the Personal Data Protection Board regarding the processing of the personal data subject to the transfer.

g) Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall have the authority to conduct or have conducted audits to determine whether the undertakings and obligations set forth herein have been fulfilled, and Amazon Web Services EMEA SARL shall provide the necessary assistance and facilities in this regard.

h) In the event that this agreement is terminated or expires, Amazon Web Services EMEA SARL agrees that, at the discretion of Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo, it shall either return the personal data subject to the transfer, together with its backups, to the data exporter or completely destroy such personal data. If there are provisions under applicable legislation that prevent the data importer from fulfilling this obligation, Amazon Web Services EMEA SARL shall take the necessary administrative and technical measures to ensure the confidentiality of the personal data subject to the transfer and shall cease processing such data.

i) Amazon Web Services EMEA SARL acknowledges that it has the administrative and technical capacity required to fulfill its obligations arising from these provisions.

j) Where Amazon Web Services EMEA SARL is required to transfer the personal data subject to the agreement to a sub-processor while performing the services under the agreement, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo shall be duly and demonstrably informed and its approval shall be obtained. The agreement to be entered into between Amazon Web Services EMEA SARL and the sub-processor shall, at a minimum, contain the provisions set forth in the agreement between Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo and Amazon Web Services EMEA SARL and in this Undertaking.

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The Data Exporter, Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo, and the Data Importer, Amazon Web Services EMEA SARL, hereby undertake that:

They shall not disclose the personal data they process to any third party in violation of the provisions of Law No. 6698 and shall not use such personal data for purposes other than those for which it was processed.

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On behalf of the Data Exporter:

Full Name / Company Name:
Talya Yazılım ve Bilişim Anonim Şirketi – Tridisgo

Registered Address:
Fulya Mah. Büyükdere Cad. No: 74 D/10 Torun Center, Şişli/Istanbul, Türkiye

Contact Number:
+90 850 441 44 90

Email:

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(Any other information required, if applicable, for the agreement to be legally binding.)

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On behalf of the Data Importer:

Name / Company Name:
Amazon Web Services EMEA SARL

Registered Address:
Amazon Web Services EMEA SARL
38 Avenue John F. Kennedy
L-1855 Luxembourg
Luxembourg

Contact Number:

Email:

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(Any other information required, if applicable, for the agreement to be legally binding.)

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ANNEX 1 TO THE UNDERTAKING

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Categories of Data Subjects

The transferred personal data relates to the following category or categories of data subjects (e.g., employee data, customer data):
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Categories of Personal Data

The transferred personal data relates to the following categories of data (personal data or special categories of personal data):
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Purposes of the Data Transfer

The data transfer is carried out for the following purposes:
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Legal Basis for the Data Transfer

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Recipients and Categories of Recipients

The transferred personal data may only be shared with the following recipients:
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Technical and Administrative Measures to Be Taken by the Data Importer

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Additional Measures Taken for Special Categories of Personal Data

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Additional Useful Information

(Retention periods and other relevant information)
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Contact Details of the Contact Person

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