OMMA VQ PRIVACY POLICY

SOFTALİVE BİLİŞİM HİZMETLERİ SAN. VE TİC. A.Ş. (“Omma”) is committed to protecting the privacy of its users and being transparent regarding the protection of personal data. This Privacy Policy explains how data reflected through the Omma VQ (“VQ”) platform is processed and protected.

1. Definitions

• Omma: Refers to Softalive Bilişim Hizmetleri Sanayi ve Ticaret Anonim Şirketi A.Ş.
• Omma VQ Platform (Data Processor): The software product that enables the end user to view information regarding themselves or their commercial enterprise in video format, depending on the services provided by our customer.
• Customer (Data Controller): Refers to the company/institution that is a customer of Omma.
• End User (“You”): Refers to the real person viewing content through the VQ platform.
• Internal Data: Refers to the data belonging to the end user located within our customer’s own systems.
• External Data: Refers to non-personal information obtained from the connected device, such as location, weather, and local time, as well as anonymous responses provided during interaction.

2. Roles and Responsibilities under Data Protection Laws (KVKK/GDPR)

Within the scope of the services provided, the Customer acts as the Data Controller, responsible for obtaining necessary explicit consents and fulfilling disclosure obligations toward End Users. Omma acts as the Data Processor, processing data solely upon the Customer’s request and for the technical execution of the service.

3. Data

Two types of data are used within the scope of the Omma VQ Platform:

• Internal (Personal) Data: Data integrated with the Omma VQ Platform by the Customer, serving as the basis for content creation. This data is not recorded, stored, permanently processed, or shared with third parties by Omma. The data is processed instantaneously and is volatile (ephemeral).
• External Data: Information obtained from your device that does not constitute personal data (weather, local time, location, IP, etc.) and the end user’s survey responses. This data is used solely to generate visual content and is strictly not stored permanently or temporarily unless specifically requested by our customers.

4. Purposes of Data Processing

• Creation of personalized content and presentation to the end user.
• Technical operation of the volatile content process.
• Anonymous reporting of survey responses and tracking metrics upon the Customer’s specific request.

5. Data Storage and Security

• Omma does not store personal data belonging to the end user under any circumstances, neither temporarily nor permanently.
• Data used to generate reports is processed only in the temporary memory (RAM) of the end user’s device and is deleted when the session ends.

6. Protection of Data

• Omma acts in accordance with the Law on the Protection of Personal Data (KVKK) and relevant legislation.
• Omma does not collect, store, or transfer personal data belonging to the end user to third parties.
• Upon the Customer’s specific request, only end-user survey responses and content tracking information may be processed; this data is provided to the customer in an anonymized form.
• Unique user IDs stored in Omma systems are anonymous and non-identifying for Omma; however, if the customer matches these with their own database, they may become personal data. In such cases, the responsibility lies with the customer.

7. Data Subject Rights

In accordance with Law No. 6698 (KVKK) and relevant legislation, end users should contact the Customer (Data Controller) to exercise their rights (access, rectification, erasure, etc.). Omma will provide the technical support to the Customer for the fulfillment of these requests.

8. Amendments

Omma reserves the right to update this policy. Changes are effective as of the date of publication.