TEPENET INTERNET
Personal Data Protection and Privacy Notice
1. Data Controller
Pursuant to Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”), your personal data may be processed by:
Tepenet İnternet Telekomünikasyon İletişim Limited Şirketi,
hereinafter referred to as “Tepenet” or the “Company”,
acting as the data controller within the scope explained below.
Tepenet processes your personal data for the provision of internet access services, management of subscription procedures, provision of technical support and customer services, invoicing and payment collection, and fulfillment of legal and regulatory obligations.
2. Personal Data Processed
Depending on the nature of the service provided and the relevant transaction, the following categories of personal data may be processed:
Identity Information
First and last name
Turkish ID number
Foreigner ID number
Date of birth
Nationality
Necessary information contained in identity documents
Contact Information
Telephone number
E-mail address
Residential address
Billing address
Installation address
Notification address
Subscription and Contract Information
Subscription number
Customer number
Contract information
Subscription start and termination information
Selected internet package and service information
Transfer, assignment, cancellation and application information
Campaign and tariff information
Financial and Transaction Information
Invoice information
Payment and collection information
Receivables and outstanding debt information
Payment method
Transaction information processed through banks and payment institutions
Refund and cancellation information
Technical and Transaction Security Information
IP address
MAC address
PPPoE user information
Internet connection and session information
Traffic and connection records
Modem, ONT, ONU and similar device information
Technical support and fault records
System and transaction logs
Call center conversation recordings
Technical information relating to website and mobile application usage
Visual and Audio Data
Where applicable, video recordings may be processed in areas equipped with security cameras. Call center voice recordings may also be processed in accordance with applicable legislation.
Legal Transaction Information
Requests and complaint records
Information relating to requests received from public institutions and authorities
Information and documents relating to legal proceedings
Information required for disputes, enforcement and collection proceedings
3. Purposes of Processing Personal Data
Your personal data may be processed for the following purposes:
Establishing and managing internet subscriptions,
Preparing and performing subscription agreements,
Providing internet services,
Installation and activation of Fiber, VDSL, WiFi and other internet services,
Carrying out transfer, assignment, cancellation and modification procedures,
Providing customer services,
Managing technical support and fault resolution processes,
Managing network and connectivity services,
Preparing and sending invoices,
Processing payments and collections,
Managing subscription and customer accounts,
Managing campaigns and tariffs,
Evaluating customer requests and complaints,
Improving service quality,
Managing information security processes,
Ensuring the security of systems and information technology infrastructure,
Preventing fraud, misuse and unauthorized access,
Managing legal and administrative processes,
Responding to requests from authorized public institutions and authorities,
Maintaining records required under Law No. 5651 and applicable legislation,
Fulfilling obligations under electronic communications legislation,
Making mandatory notifications to the Information and Communication Technologies Authority (BTK) and other competent authorities,
Fulfilling legal retention and archiving obligations,
Conducting and auditing the Company's business activities.
4. Legal Grounds for Processing Personal Data
Your personal data is processed in accordance with the personal data processing conditions set forth under Articles 5 and 6 of KVKK.
Accordingly, your personal data may be processed based on the following legal grounds:
Explicitly provided for by law,
Directly related to the establishment or performance of a contract,
Necessary for the data controller to fulfill its legal obligations,
Necessary for the establishment, exercise or protection of a right,
Necessary for the legitimate interests of Tepenet, provided that this does not adversely affect your fundamental rights and freedoms,
Your explicit consent, where required.
5. Transfer of Personal Data
Your personal data may be transferred, subject to the necessary security and confidentiality measures, to the following persons and organizations for the purposes of providing services and fulfilling Tepenet's legal obligations:
Information and Communication Technologies Authority (BTK),
Other authorized public institutions and authorities,
Türk Telekomünikasyon A.Ş. and other electronic communications operators from which infrastructure services are obtained,
Banks and payment institutions,
Payment and collection service providers,
Information technology and software service providers,
Call center and customer service providers,
Technical service and field service providers,
Accounting and financial service providers,
Legal, financial consultancy and advisory service providers,
Audit organizations,
Competent judicial and administrative authorities,
Other persons and organizations legally authorized to request information.
Your personal data shall not be transferred to third parties except where permitted or required by applicable legislation.
6. Methods of Collection of Personal Data
Your personal data may be collected electronically or physically through:
Tepenet website,
Online subscription and application forms,
Mobile application,
Call center,
E-mail,
Physical applications and contract documents,
Electronic contract systems,
Authorized sales channels,
Technical service and field teams,
Payment and collection channels,
Public institutions and authorized organizations,
Cookies and similar technologies.
7. Internet and Technical Records
Within the scope of electronic communications services, IP addresses, connection, session, traffic and technical records may be retained to the extent required by applicable legislation.
Such records may be processed for:
Providing the service,
Ensuring network and system security,
Detecting and resolving technical problems,
Preventing misuse,
Detecting unauthorized access,
Fulfilling legal and regulatory obligations.
Such records may be retained for the periods prescribed by applicable legislation.
8. Retention Period of Personal Data
Your personal data is retained for the periods required by applicable legislation or for as long as necessary for the purposes for which it is processed.
Once the applicable retention period expires or the legal basis requiring processing ceases to exist, your personal data will be deleted, destroyed or anonymized in accordance with applicable legislation.
Retention periods for records maintained within the scope of electronic communications services are determined in accordance with applicable sector-specific legislation and regulations issued by competent authorities.
9. Your Rights Under KVKK
Under Article 11 of KVKK, you have the following rights as a data subject:
To learn whether your personal data is being processed,
To request information regarding the processing of your personal data,
To learn the purpose of processing your personal data and whether it is used in accordance with such purpose,
To know the third parties to whom your personal data is transferred within or outside Türkiye,
To request correction of your personal data if it is incomplete or incorrectly processed,
To request deletion or destruction of your personal data under the conditions specified in KVKK,
To request notification of correction, deletion or destruction to third parties to whom your personal data has been transferred,
To object to the occurrence of a result against you arising from the analysis of your personal data exclusively through automated systems,
To request compensation for damages if you suffer damage due to unlawful processing of your personal data.
10. Right to Apply
You may submit your requests under KVKK to Tepenet in writing or through other methods determined by the Personal Data Protection Board.
Applications may be submitted to:
Tepenet İnternet Telekomünikasyon İletişim Limited Şirketi
Address: Kuzey Mah. Türkeli Cad. No:20 D:1 Kocaeli/Körfez, Türkiye
E-mail: info@tepenet.com.tr
KEP: tepenet@hs01.kep.tr
Your application should clearly state your name, surname, subject of the application and request.
Applications will be evaluated in accordance with the procedures and principles specified under KVKK and the relevant secondary legislation.
11. Processing Requiring Explicit Consent
Where explicit consent is legally required for the processing of personal data, your explicit consent will be obtained separately.
In particular, for commercial electronic communications and other activities requiring separate approval under applicable legislation, the necessary permissions and consents will be obtained separately.
The absence or withdrawal of explicit consent will not affect processing that is legally required or necessary for the establishment and performance of a contract.
12. Cookies
Tepenet may use cookies and similar technologies on its website and digital platforms for purposes such as improving user experience, ensuring secure and proper operation of the website, measuring performance and remembering user preferences where necessary.
Where required, user preferences will be obtained for non-essential cookies.
Further information regarding cookies may be provided separately in Tepenet's Cookie Policy.
13. Data Security
Tepenet takes the necessary technical and administrative measures to prevent unlawful processing and access to personal data, ensure the secure storage of personal data, and prevent loss or unauthorized acquisition of personal data.
Such measures may include:
Access authorization,
User account security,
System and network security,
Logging and monitoring,
Backup procedures,
Prevention of unauthorized access,
Employee awareness and confidentiality obligations.
14. Updates to This Notice
Tepenet may update this Personal Data Protection and Privacy Notice in accordance with changes in legislation, changes in the Company's activities or updates to personal data processing processes.
The current version of this Notice will be published on Tepenet's website.
Last Updated: 14/08/2026
Tepenet İnternet Telekomünikasyon İletişim Limited Şirketi
