PERSONAL DATA PROTECTION, COOKIE, AND COMMERCIAL COMMUNICATION CONSENT TEXT

1. Information on the Protection and Processing of Personal Data

1.1. In order to protect fundamental rights and freedoms, primarily the privacy of private life, and to determine the obligations of real and legal persons who process personal data, we, as POSHET – BENER HAMAMCI, acting as the Data Controller, provide this information in accordance with Article 10 of the Law on the Protection of Personal Data No. 6698 (KVKK), which was published in the Official Gazette dated April 7, 2016, and numbered 29677.

1.2. As POSHET – BENER HAMAMCI, we aim to ensure that personal data are processed in compliance with the Constitution of the Republic of Turkey, international agreements on human rights to which Turkey is a party, and the Law on the Protection of Personal Data No. 6698 (KVKK). All personal data shared with our company will be processed lawfully, in connection with and to the extent necessary for our activities and services.

2. Definitions

2.1. The terms personal data, special categories of personal data, and data processing used in this disclosure text are based on the definitions in the KVKK.

• 2.1.1. Law on the Protection of Personal Data (KVKK): Refers to the Law No. 6698 on the Protection of Personal Data, which came into force on April 7, 2016.
• 2.1.2. Personal Data: Any information relating to an identified or identifiable natural person.
• 2.1.3. Data Processor: A real or legal person who processes personal data on behalf of the data controller.
• 2.1.4. Data Controller: A real or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.
• 2.1.5. Processing of Personal Data: Any operation performed on personal data, whether through automated means or not, such as collection, recording, storage, preservation, alteration, reorganization, disclosure, transfer, acquisition, making available, classification, or prevention of use.

3. Principles for Processing Personal Data

3.1. Personal data belonging to the data subject will be processed by the Company as the data controller in compliance with the principles specified in Article 4 of the KVKK:

• In accordance with the law and good faith principles.
• Accurately and up-to-date when necessary.
• For specific, explicit, and legitimate purposes.
• In connection with, limited to, and proportionate to the purposes of processing.
• Stored for the period required by relevant legislation or for the purposes of processing.

4. Purpose of Processing Your Personal Data

4.1. Personal data will be processed within the framework of the purposes and conditions specified in Articles 4, 5, and 6 of the KVKK, as follows:

• In accordance with the law and rules of honesty.
• In connection with, limited to, and proportionate to the purposes of processing.
• Accurate and up-to-date.
• For specific, clear, and legitimate purposes.
• Processed for the period stipulated in the relevant legislation or as necessary for the purposes of processing.

4.2. Your personal data may be processed for the following purposes:

• To carry out necessary work by our business units to benefit you from the products and services offered by our company.
• To recommend products and services offered by our company according to your preferences.
• To plan and execute after-sales support services.
• To ensure legal, technical, and commercial-business security for the persons involved in the business relationship.
• To manage human resources policies, evaluate job applications, and fulfill legal obligations as an employer.
• To ensure data security, monitor information security processes, plan and conduct IT infrastructure management, follow financial and accounting transactions, and track legal processes.
• To plan and carry out corporate communication activities and determine and implement business strategies.

5. Transfer of Personal Data

5.1. Your personal data may be transferred to:

• Our business partners, suppliers, shareholders, affiliates, authorized public institutions, and private persons, within the framework of Articles 8 and 9 of the KVKK.
• To fulfill our legal obligations, provide information, and exercise our legal rights, including the right to defense, to authorized public institutions and judicial authorities.
• To our service providers and business partners located abroad when necessary for IT, marketing, or analytical activities.

6. Data Collection Method and Legal Basis

6.1. Your personal data may be collected through verbal, written, and/or electronic means by obtaining your explicit consent when necessary, in compliance with the law and rules of honesty, and within the scope of legitimate purposes. The data may be collected through various channels, including the company’s website, mobile applications, social media accounts, and other communication methods.

7. Data Retention and Deletion

7.1. Personal data will be retained for the duration required by relevant legislation. If a retention period is not stipulated, data will be retained for the period necessary for the purpose of processing and for any legal claims that may arise afterward. After the expiration of these periods, data will be deleted, destroyed, or anonymized.

8. Rights of the Data Subject

8.1. You have the right to:

• Learn whether your personal data is being processed.
• Request information if your data has been processed.
• Learn the purpose of processing and whether it is used in line with that purpose.
• Know the third parties to whom data has been transferred domestically or abroad.
• Request correction if your data is incomplete or incorrectly processed.
• Request deletion or destruction of your data.
• Object to any adverse outcome resulting from automated processing.
• Demand compensation if you suffer damages due to unlawful processing.

8.2. You can submit your requests regarding your personal data to POSHET – BENER HAMAMCI through the contact information provided on the website.

CONSENT FOR COMMERCIAL COMMUNICATION

By accepting this agreement, I consent to the processing and use of my personal data for commercial communication activities (SMS, email, phone calls) conducted by POSHET – BENER HAMAMCI, including personalized campaigns, promotions, and surveys.

This consent is digitally accepted and approved by {ALICI_TAM_AD_UNVANI} on {GUNCEL_TARIH}.

SELLER: POSHET BENER HAMAMCI

BUYER: {ALICI_TAM_AD_UNVANI}