Personal Data Protection Notice (KVKK)

Last Updated: March 11, 2026

1. Identity of the Data Controller

Pursuant to the Turkish Personal Data Protection Law No. 6698 ("KVKK"), your personal data is processed by Datascope Bilişim ve Yazılım Tic. A.Ş. ("Fronta" or the "Company") in its capacity as the data controller, whose details are set forth below.

Trade Name: Datascope Bilişim ve Yazılım Tic. A.Ş.

MERSIS No: 271201436100001

Address: Sales & PMO Office : Akdeniz, Cumhuriyet Blv No:120, 35210 Konak, Izmir / Turkiye

R&D Center: Gülbahçe Mah. Icmeler Cad. 14/1 No: B05 Urla, Izmir / Turkiye

Registered Email (KEP): -

Phone: +90 532 686 5136

Email: kvkk@fronta.com.tr

Website: https://fronta.com.tr

2. Purposes and Legal Bases for Processing Personal Data

Your personal data is processed based on the legal grounds set forth in Articles 5 and 6 of the KVKK, for the purposes outlined below:

2.1. Performance of a Contract (Article 5/2-c)

• Providing access to and managing accounts on Fronta RevOps, FieldMate, Oneview, and Middleware platforms
• Delivering distribution channel management, field operations, and revenue assurance services
• Providing AI-powered analytics services (Fronta Insight, Promo, Order, Stock)
• Conducting customer support and technical assistance operations
• Performing API integrations and data synchronization processes
• Monitoring SLA obligations and performance reporting

2.2. Compliance with Legal Obligations (Article 5/2-ç)

• Issuing invoices and maintaining accounting and tax records
• Fulfilling legal reporting and audit requirements
• Complying with legal notification obligations to authorized public institutions and organizations
• Fulfilling obligations under electronic commerce legislation

2.3. Legitimate Interest (Article 5/2-f)

• Ensuring platform security, detecting and preventing unauthorized access
• Measuring and improving service quality and conducting platform performance analyses
• Creating statistical analyses and business intelligence reports using anonymized and aggregated data
• Planning and executing information security processes

2.4. Explicit Consent (Article 5/1)

• Sending commercial electronic communications (newsletters, campaigns, promotions)
• Profiling activities for marketing and advertising purposes
• Collecting data through non-essential cookies

3. Categories of Personal Data Processed

Identity Data — Name, surname, title, company name. Purpose: Account creation, contract management.

Contact Data — Email, phone, business address. Purpose: Communication, support, notifications.

Financial Data — Billing information, payment records. Purpose: Invoicing, accounting.

Transaction Security Data — IP address, session logs, device information. Purpose: Security, access control.

Customer Transaction Data — Platform usage records, transaction history. Purpose: Service delivery, performance.

Marketing Data — Cookie data, preferences, behavioral analytics. Purpose: Marketing (with explicit consent).

4. Methods of Collecting Personal Data

Your personal data is collected through the fronta.com.tr website and its subdomains via electronic means, platform registration and login forms, contact and demo request forms, email, phone and other communication channels, cookies and similar tracking technologies, API integrations from business partners, and through contractual processes in physical or electronic form.

5. Transfer of Personal Data

5.1. Domestic Transfers

Your personal data may be transferred to the following recipient groups within the scope of Article 8 of the KVKK and limited to the purposes stated above:

• Business partners and suppliers: Platform infrastructure services, payment services, communication services
• Legal, accounting, and audit service providers
• Authorized public institutions and organizations: Courts, tax offices, regulatory authorities

5.2. International Transfers

Fronta may transfer your personal data internationally in connection with cloud infrastructure services (AWS, Microsoft Azure, Google Cloud). International transfers are carried out pursuant to Article 9 of the KVKK and the amendments introduced by Law No. 7499, in accordance with the Standard Contractual Clauses (SCCs) published by the Turkish Personal Data Protection Board.

Where adequate protection is not available in the receiving country, the safeguards determined by the Board (SCCs, undertakings, or binding corporate rules) are implemented.

6. Personal Data Retention Periods

Your personal data is retained for the duration required by the processing purpose and in compliance with the statute of limitations periods prescribed by applicable legislation. When the processing purpose ceases and the legal retention periods expire, your personal data is deleted, destroyed, or anonymized in accordance with our Personal Data Retention and Disposal Policy.

Contractual data (Turkish Code of Obligations): 10 years after contract termination

Accounting and invoice records (Tax Procedure Law): 10 years from the end of the relevant calendar year

E-commerce transaction records (Law No. 6563): 3 years

Log records (Law No. 5651): 2 years

Marketing data (explicit consent): Until consent is withdrawn

7. Automated Decision-Making and Profiling

The Fronta platform performs automated data analysis through its AI-powered analytics modules (Fronta Insight, Promo, Order, Stock). These analyses support business decisions including demand forecasting, promotion optimization, order recommendations, and inventory management.

The results generated through these processes are informational in nature and should not be used as the sole basis for final business decisions. Pursuant to Article 11/1(g) of the KVKK, you have the right to object to any adverse outcome arising from the analysis of your data exclusively through automated systems.

8. Data Subject Rights (KVKK Article 11)

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

1. To learn whether your personal data is being processed
2. To request information about the processing if your personal data has been processed
3. To learn the purpose of processing and whether your data is used in accordance with that purpose
4. To know the third parties to whom your personal data has been transferred, domestically or internationally
5. To request the rectification of your personal data if it has been processed inaccurately or incompletely
6. To request the deletion or destruction of your personal data under Article 7 of the KVKK
7. To request that rectification, deletion, and destruction operations be notified to third parties to whom your personal data has been transferred
8. To object to any adverse outcome arising from the analysis of your processed data exclusively through automated systems
9. To claim compensation for damages incurred due to the unlawful processing of your personal data

9. How to Submit a Request

To exercise the rights listed above, you may submit a request by sending an email to kvkk@fronta.com.tr, through registered electronic mail (KEP), or by written application via notary public.

Your request will be concluded within 30 (thirty) days at the latest. If the process entails an additional cost, a fee may be charged in accordance with the tariff determined by the Turkish Personal Data Protection Board.

If your request is denied, the response is deemed insufficient, or no response is provided within the specified period, you may file a complaint with the Turkish Personal Data Protection Board within 30 (thirty) days of learning of the response and in any case within 60 (sixty) days of the application date.

This Notice has been prepared for informational purposes pursuant to Article 10 of the Personal Data Protection Law No. 6698 and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform.

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Terms of Use

Last Updated: March 11, 2026

1. Parties and Scope

These Terms of Use ("Terms") govern the use of the website, platform, and services ("Services") provided by Datascope Bilişim ve Yazılım Tic. A.Ş. ("Fronta") through the fronta.com.tr domain and its subdomains.

Any individual or legal entity ("User") who accesses the website, creates an account, or uses the Services is deemed to have read, understood, and accepted these Terms. If you do not accept these Terms, please refrain from using the Services.

2. Company Information

Trade Name: Fronta Bilgi Teknolojileri A.Ş.

MERSIS No: [To be inserted]

Address: Sales & PMO Office, İzq / 404, İzmir / Türkiye

R&D Center: Urla, İzmir / Türkiye

Email: info@fronta.com.tr

Website: https://fronta.com.tr

3. Service Description

Fronta is a B2B SaaS (Software as a Service) platform operating in the fields of distribution channel management, field operations, revenue assurance (RevOps), and AI-powered business intelligence. The primary services offered include:

• Fronta Middleware: A business intelligence layer that unifies disparate data sources
• Fronta RevOps: A strategic profitability and sales network management platform
• Fronta FieldMate: A low-code and AI-powered field operations platform
• Fronta Oneview: An integrated distributor management and cross-channel data integration platform
• Fronta Insight, Promo, Order, Stock: AI-powered decision optimization modules
• Consulting Services: Digital transformation consulting, project management, and data analytics

The Services are provided under a "service agreement" within the framework of the Turkish Code of Obligations, not as a product sale.

4. Account Creation and User Obligations

4.1. Account Security

The User is responsible for the accuracy, currency, and confidentiality of their account information. You are responsible for all activities carried out through your account credentials, and you must immediately notify Fronta of any unauthorized access.

4.2. Usage Rules

The User agrees to comply with the following rules when using the Services:

• Acting in compliance with the laws of the Republic of Türkiye and international law
• Not infringing upon the personal data, intellectual property rights, or other rights of third parties
• Not engaging in activities that jeopardize platform security (reverse engineering, malware, unauthorized access attempts, etc.)
• Not using the Services for the purpose of developing competing products or services
• Not sharing unlawful, misleading, or harmful content through the platform
• Complying with API usage limits and the conditions specified in the technical documentation

5. Intellectual Property Rights

All intellectual property rights in the Fronta platform, software, algorithms, AI models, designs, logos, content, databases, and all other materials belong exclusively to Fronta Bilgi Teknolojileri A.Ş. and are protected under the Turkish Law on Intellectual and Artistic Works No. 5846 and other applicable legislation.

The User is granted a non-exclusive, non-transferable, non-sublicensable, limited license to use the Services for the duration of the agreement. This license automatically terminates upon expiration of the agreement.

Ownership of User data remains with the User. Fronta processes User data solely for the purpose of service delivery. Fronta may use anonymized and aggregated data for service improvement and statistical analysis purposes.

6. Fees and Payment

Service fees are determined in the subscription agreement executed between the parties. Invoices are issued in accordance with Turkish legislation. Fronta reserves the right to suspend or terminate the service in the event of late payment. Fee changes will be communicated at least 30 (thirty) days before the start of the new period.

7. Service Level and Availability

Fronta targets a monthly uptime of 99.5% for the platform. Scheduled maintenance is excluded from this calculation and will be communicated at least 48 hours in advance. Fronta shall not be held liable for interruptions caused by force majeure events (natural disasters, cyberattacks, infrastructure provider outages, regulatory changes, etc.).

8. AI and Automated Analysis Disclaimer

The analyses, predictions, recommendations, and optimization results generated by Fronta's AI-powered modules (Insight, Promo, Order, Stock) are provided solely for informational and decision-support purposes. These results:

• Do not constitute any guarantee, commitment, or promise of definitive outcomes
• Should not be used as the sole basis for business decisions
• Do not substitute for professional advisory services

The User utilizes AI outputs at their own assessment and responsibility. Fronta shall not be held liable for any direct or indirect damages arising from business decisions based on AI analyses.

9. Limitation of Liability

Pursuant to Article 115 of the Turkish Code of Obligations, limitation of liability in cases of gross negligence or willful misconduct is void. Subject to this mandatory provision:

• Fronta's total liability under these Terms is limited to the total service fees paid by the User during the 12 (twelve) month period preceding the event giving rise to the damage.
• Fronta shall not be held liable for indirect damages, loss of profit, data loss, business interruption, reputational harm, or consequential damages.
• This limitation does not apply to intellectual property infringements, breaches of confidentiality obligations, personal data protection violations, and payment obligations.

10. Confidentiality

The parties agree to keep confidential all proprietary information acquired within the scope of the business relationship, for the duration of the agreement and for 3 (three) years following its termination, and not to disclose it to third parties or use it for purposes other than those of the agreement. This obligation is subject to legal requirements and court orders.

11. Amendments to the Terms

Fronta reserves the right to update these Terms. Material changes adverse to the User will be communicated to the User via email and/or in-platform notification at least 30 (thirty) days before taking effect. A User who does not accept the changes has the right to terminate the agreement within 30 days of the notification date. Continued use of the Services without objection within the notified period constitutes acceptance of the changes.

12. Termination

Either party may terminate the agreement by providing 30 (thirty) days' written notice. Fronta has the right to terminate immediately in the following cases:

• The User materially breaches these Terms and fails to remedy the breach within 15 days despite written warning
• The User declares bankruptcy, files for concordat, or becomes insolvent
• The User is found to be using the Services for unlawful purposes

In the event of termination, User data will be returned to the User within 30 days of the termination date, or deleted/destroyed upon the User's request.

13. Force Majeure

Natural disasters, war, terrorism, pandemics, government decisions, cyberattacks, infrastructure provider outages, and similar events beyond the parties' control constitute force majeure. The parties' obligations are suspended during the force majeure period. If the force majeure event exceeds 90 (ninety) days, the parties have the right to terminate the agreement.

14. Governing Law and Dispute Resolution

These Terms are governed by the laws of the Republic of Türkiye. Disputes arising from the application or interpretation of these Terms shall be subject to mandatory mediation under the Turkish Mediation in Civil Disputes Law No. 6325. If mediation is unsuccessful, the Izmir Courts and Enforcement Offices shall have jurisdiction.

15. Severability

If any provision of these Terms is found to be invalid, void, or unenforceable, the remaining provisions shall continue to be valid and binding. The invalid provision shall be deemed replaced by the valid provision that most closely reflects the parties' intent.

16. Contact

For any questions, requests, or communications regarding these Terms of Use, please send an email to info@fronta.com.tr.

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Privacy Policy

Last Updated: March 11, 2026

1. Introduction

This Privacy Policy describes the practices of Datascope Bilişim ve Yazılım Tic. A.Ş. ("Fronta") regarding the collection, processing, and storage of personal data through the fronta.com.tr website and its platforms. This policy has been prepared in accordance with the Turkish Personal Data Protection Law No. 6698 (KVKK), the European Union General Data Protection Regulation (GDPR), and other applicable legislation.

This Privacy Policy serves as a general data governance document; activity-specific disclosures are provided through separate Privacy Notices (Aydınlatma Metinleri).

2. Data Controller

Trade Name: Fronta Bilgi Teknolojileri A.Ş.

Address: Sales & PMO Office, İzq / 404, İzmir / Türkiye

KVKK Contact: kvkk@fronta.com.tr

General Contact: info@fronta.com.tr

Website: https://fronta.com.tr

3. Data Controller and Data Processor Roles

Fronta may act in two different capacities in its data processing activities:

3.1. Fronta as Data Controller

Fronta is the data controller for the processing of personal data belonging to its own website visitors, direct platform users, job applicants, and business partners.

3.2. Fronta as Data Processor

When processing distribution channel data, field operations data, and business intelligence data on behalf of its B2B clients, Fronta acts as data processor. In this context, each B2B client is the data controller and Fronta is the data processor. The relationship between the parties is governed by a separate Data Processing Agreement.

4. Types of Personal Data Processed

4.1. Directly Collected Data

• Identity and Contact Information: Name, surname, email address, phone number, company name, title
• Account Information: Username, password (encrypted), account preferences
• Financial Information: Billing address, tax identification number, payment details
• Communication Content: Demo request form submissions, support requests, email correspondence

4.2. Automatically Collected Data

• Technical Data: IP address, browser type and version, operating system, device information
• Usage Data: Page views, click behavior, session durations, platform usage statistics
• Cookie Data: Session cookies, preference cookies, analytics cookies (please refer to our Cookie Policy for details)

4.3. Data Obtained from Third Parties

• Data transferred via API from business partners and integration providers
• Commercial information obtained from publicly available sources

5. Distinction Between Personal Data and Commercial Data

A significant portion of the data processed on the Fronta platform consists of commercial data belonging to legal entities (company revenues, market analytics, distribution metrics, inventory levels, etc.). Such data does not qualify as personal data and falls outside the scope of the KVKK, provided it is not capable of identifying a natural person.

However, sales representative data, manager contact information, and individual performance analytics within the platform constitute personal data and are protected under the KVKK.

6. Legal Bases for Data Processing

Your personal data is processed based on the following legal grounds:

• KVKK Article 5/2-c: Directly related to the establishment or performance of a contract
• KVKK Article 5/2-ç: Necessary for the data controller to fulfill its legal obligations
• KVKK Article 5/2-e: Necessary for the establishment, exercise, or protection of a right
• KVKK Article 5/2-f: Necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject
• KVKK Article 5/1: Explicit consent (solely for marketing communications and non-essential cookies)

7. Data Security Measures

Fronta implements the necessary technical and administrative measures to ensure the security of personal data in accordance with Article 12 of the KVKK:

7.1. Technical Measures

• Data transmission security through SSL/TLS encryption
• Database-level encryption (AES-256)
• Multi-factor authentication (MFA)
• Firewalls, intrusion detection and prevention systems (IDS/IPS)
• Regular vulnerability scans and penetration testing
• Backup and disaster recovery procedures

7.2. Administrative Measures

• Data access authorization policies and the principle of least privilege
• Regular KVKK and data security training for employees
• Data processing inventory and record-keeping system
• Data breach response plan and procedures
• Subcontractor and business partner audit processes

8. International Data Transfers

Fronta may transfer personal data internationally through cloud infrastructure providers (AWS, Microsoft Azure, Google Cloud) and certain third-party service providers in connection with service delivery.

International transfers are carried out within the framework of Article 9 of the KVKK and the updated regulations introduced by Law No. 7499. The primary transfer mechanism is the Standard Contractual Clauses (SCCs) published by the Turkish Personal Data Protection Board, which are applied in Turkish and without modification.

Users may request information about the countries to which data is transferred and the safeguards applied by contacting kvkk@fronta.com.tr.

9. Additional Rights Under the GDPR

For users accessing the Services from within the European Economic Area (EEA), the following GDPR rights apply in addition to the rights provided under the KVKK:

• Right to data portability (GDPR Article 20)
• Right to request restriction of processing (GDPR Article 18)
• Right to detailed information regarding automated decision-making processes (GDPR Article 22)
• Right to lodge a complaint directly with the relevant EU supervisory authority

GDPR-related requests from EEA users may be directed to gdpr@fronta.com.tr.

10. Children's Privacy

The Fronta platform is designed for B2B purposes and is not intended for individuals under the age of 18. Fronta does not knowingly collect personal data from individuals under 18. If such a situation is identified, the relevant data will be promptly deleted.

11. Third-Party Links

The fronta.com.tr website may contain links to third-party websites. Fronta is not responsible for the privacy practices of these websites. Users are advised to separately review the privacy policies of third-party sites accessed through such links.

12. Policy Updates

Fronta reserves the right to update this Privacy Policy in response to legal requirements, technological developments, or changes in business processes. Material changes will be communicated to Users by publication on the website and/or via email. The current version is always available at fronta.com.tr.

13. Contact

For questions, requests, and communications regarding this Privacy Policy:

• KVKK requests: kvkk@fronta.com.tr
• GDPR requests: gdpr@fronta.com.tr
• General inquiries: info@fronta.com.tr

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