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PERSONAL DATA PROTECTION AND PRIVACY AND COOKIE POLICY

Dear User,

As DP TEKSTİL MAĞAZACILIK DAĞ VE PAZ. TUR. TİC. A.Ş. and in our capacity as the data controller, we hereby provide you some information under this Privacy Statement with a view to collect and process your personal data that you provided to us while using our website, including your special personal data under the scope of the law on the Protection of Personal Data (“KVKK”) and the relevant legislation.  You are kindly recommended to carefully read this privacy statement where you may find information on the identity of the data controller and its representative, the purpose of processing your personal data, to whom and with which purpose your personal data shall be disclosed, the legal reasons of collecting your personal data, your rights in your capacity as the data subject as may be disclosed to you during the phase of the collection and processing these data including your special personal data.  Definitions of some of the terms used in the KVKK are given below, so that you can understand better: 

Explicit Consent:  refers to the informed consent concerning a certain issue given at one’s free will.  

Anonymization: Refers to the process of making the personal data in question unidentifiable with a real person whose identification is identified or may be identified, even by matching with other data. 

Data Subject: means the natural person whose personal data are processed, 

Personal Data: Any information that relates to an identified or identifiable individual, natural person. 

Processing of Personal Data: refers to all kinds of transactions made on the data including obtaining, recording, storage, retention, changing, rearrangement, explanation, transfer, take-over and classification thereof or prevent the use thereof, fully or partially, by automatic means or, by non-automatic means, provided that they are part of any data recoding system. 

Board:  Board of Protection of Personal Data, 

Institution: Institution of the Protection of Personal Data  

Data Processor: refers to a natural or legal person or entity which processes the personal data on behalf of the Data Controller based on the authority given by the Data Controller, 

Data Recording System:  refers to the recording system by which the personal data are processed based on a configuration according to specific criteria. 

Data Controller : refers to a natural or legal person or entity which determines the purposes and means of processing of the personal data and is in charge of establishment and management of data recording system, 

1. Method and Legal Reason of the Collection and Processing of Personal Data

The personal data of our esteemed customers are collected and processed through all kinds of verbal, written or electronic environment in line with the above-mentioned purposes for the purpose of offering our goods and services in compliance with the relevant legislation and enabling our company to fulfill its obligations under the law fully and properly.  Your personal data shall be collected, processed and shared under the scope of the conditions and purposes of processing personal data specified in the articles 5 and 6 of KVKK and in line with the legal reasons and purposes set forth under the scope of this privacy statement. 

2. Data Controller, Privacy Statement and Explicit Consent of the Data Subject under the Scope of KVKK.

Pursuant to the relevant law, the personal data belonging to you, including the special personal data, shall be collected and processed by our company, in our capacity as the data controller under the scope of the guidelines set forth below.  KVKK requires the data controllers to enlighten the data subjects pursuant to the article 10 of the law.  The purpose of this obligation to enlighten which is entrusted to the data controllers is to concretely put forward the purposes for which the personal data of the data subjects may be processed, the persons to whom and for which purposes the processed personal data may be forwarded and the method of collection of special personal data applied by the data controller and its legal reasons, the rights of the data subject and the identity of the data controller and representative.   In line with this privacy statement, we aim at keeping you fully informed about how your personal data shall be collected and processed and reminding you your rights.  Explicit consent refers to an informed consent concerning a specific issue given at one’s free will.  In other words, explicit consent is the declaration of approval made by you as explicitly as leaving no room for doubt in favor of processing of your personal data, including your special personal data, at your free will based on sufficient information, after reading this privacy statement. 

3. Your Personal Data to be Processed by Our Company and the Purpose of Processing Them.

The collection and processing of the personal data belonging to natural persons, including their special personal data, requires the explanation of the purpose of collecting and processing them explicitly in accordance with the provisions of the relevant legislation.  If you give explicit consent the personal data belonging to you shall be processed by our company under the scope and for the purposes of: 

 -          Providing better service and various advantages to its customers, sales and marketing, providing information, development of special promotion activities directed at the customer portfolio, providing information about promotion activities, campaigns and their conditions, conducting questionnaires and customer satisfaction surveys, ensuring the performance and acceleration of your purchasing operations, planning and implementation of the commercial and/or business strategies and ensuring the legal, technical and commercial, business security of the data subjects which are involved in a business relation with our shopping site and planning and performance of the activities needed for the customization of the goods and services offered by our company paying regard to the likes, habits of use and needs of the data subjects and offering and introducing them accordingly. 

 -          Development of campaigns directed at the customers, making cross sales, determining the target group, tracking the customer movements and carrying out activities directed at increasing the experience of the user and development of the operation of the Internet site belonging to our shopping site and its mobile application and its customization depending on the needs of the customers.

 -          Carrying out customized, direct and indirect marketing and remarketing activities and carrying out segmentation, target setting, analysis and in-house reporting activities. 

 -          Offering our valuable customers a more special and effective shopping experience and creating and tracking visitor records based on the analysis of visitor movements and preferences monitored during the use of the website apart from the personal data left at www.brandwho.com, email addresses and membership forms.  

 -          Planning and performance of sales and marketing processes for the goods and/or services offered by our website, including conducting market researches, planning and performance of customer satisfaction activities and planning and performance of the management processes of customer relations, planning and performance of the processes to create and/or increase loyalty and engagement to the goods and/or services offered by our shopping site; in line with the approval given by our customers and may be shared with the persons indicated in this privacy statement. 

In addition to the above-mentioned purposes, your personal data shall by no means be used for commercial purposes except as may be required by the above-mentioned activities and the cases required by the relevant legislation.  In line with the exceptions provided for by the articles 5(2) and 6(3) of Law on the Protection of Personal Data, DP TEKSTİL MAĞAZACILIK DAĞ VE PAZ. TUR. TİC. A.Ş. is entitled to collect and process your personal data including your special personal data without the explicit consent of the data subject, for purposes as exemplified below, provided that: (i) it is clearly required by the relevant laws, (ii) it is necessary for the protection of the life or bodily integrity of a person who is not capable of expressing his consent due to an actual impossibility or of a person whose statement of consent is not granted legal validity, (iii) processing the personal data belonging to the parties of a contract is required, provided that it is directly related to the execution and enforcement of a contract, (iv) it is required for the data controller to fulfill its legal obligation, (v) if the personal data were made public by the data subject himself, (vi) processing personal data is required for the establishment , exercise or protection of a right, (vii) processing personal data is required for the protection of the legitimate interests of the data controller, provided that the basic rights and liberties of the data subject are not thereby harmed.    

 -          Carry out the necessary activities by the relevant business units to carry out the commercial activities on our shopping web-site and further carry out the related business processes; 

 -          Establishment of the potential rights and claims of the relevant parties, 

 -          Providing information to the competent authorities under the relevant legislation,

 -          Ensure the performance of the obligations under the scope of the Law on the Protection of Consumers, Law on the Regulation of Retail Trade, Law on the Regulation of Electronic Trade, Regulation on Distance Contracts and other relevant legislation through all kinds of channels, including but not limited to our company, subsidiaries of our company or our website and social media pages. 

 - Receipt and delivery of your orders and enabling you to carry out e-commerce shopping activities at our website properly and carrying out the related processes. 

 4. Our Cookie Policy

Our shopping website is entitled to correlate the behavior of a user visiting the website, regardless of being a member, with a cookie available on the browser and define remarketing lists based on the metrics such as the number of pages visualized, length of the visit, and the targeted completion number.  Later, the targeted advertisement content may be displayed to that user on the website or other websites within the Advertisement Network, depending on the user’s area of interest.  During forwarding Google AFS advertisements to our shopping website, Google may place cookies on the browser of users or use web signs to collect information. 

5. Transfer of Your Personal Data Inside the Country or to Abroad  

The articles 8 and 9 of KVKK addresses the transfer of personal data.  This information provided by us is necessary to transfer your data lawfully in the light of the regulations provided for in the law.  The personal data belonging to our customers may be shared with our company's officers, our affiliates, business partners, suppliers, shareholders, legally authorized institutions and organizations and private entities under the scope of the purposes of the transfer of personal data as specified in the articles 8 and 9 of the law, including performance of the activities by our business units  to let the data subjects benefit from the goods and services offered by our shopping website and carrying out the related business processes, letting the related work units carry out the activities needed for the realization of the commercial activities of our company and carrying out the related business processes, planning and execution of commercial and/or business strategies of our company, ensuring the legal, technical and commercial security of our company and the persons who are in business relationship with our company and planning and performance of the activities needed for the customization of the goods and services offered by our shopping website depending on the likes, habits of use and needs of the data subjects and their presentation and introduction to the data subjects accordingly.  Pursuant to the framework contract for the payment organizations to be approved at the phase of payment and the Regulation on the Measures for Prevention of Laundering Crime Revenues and Financing of Terrorism, the name and surname and contact details of the website user may be shared with the payment institutions for the purpose of the verification of identity.  Our company is entitled to transfer the personal data to third persons within the country and also to abroad under the scope of the above-mentioned purposes, provided that the conditions set forth in the Law numbered 6698 are fulfilled. 

6. Retention of Your Personal Data 

As a requirement of the principle of being limited with the purpose, your personal data are processed within the limit of the fulfillment of the purposes explained in this privacy statement and, at any rate, of the period of time required for the processing thereof pursuant to the practices of our company and customary practices of the commercial life; and they are deleted, removed or anonymized after the expiry of that period of time. Your personal data entered into the system may only be changed by you; and our company takes all kinds of technical and administrative measures required to prevent access to and changing thereof by others.  However, DP TEKSTİL MAĞAZACILIK DAĞ VE PAZ. TUR. TİC. A.Ş. and its patented brands disclaims any liability due to the fact that your membership address and password is known or your membership is used by the third persons.  Your credit card details requested from you on the payment page are by no means retained in the servers of DP TEKSTİL MAĞAZACILIK DAĞ VE PAZ. TUR. TİC. A.Ş. or the companies serving to it in order to ensure our valuable customers' security at highest degree. We ensure that all transactions directed at payment are made between the bank and your computer over the www.brandwho.com interface belonging to DP TEKSTİL MAĞAZACILIK DAĞ VE PAZ. TUR. TİC. A.Ş.  In addition to this, in cases where explicitly required by the law, where the processing of your personal data is required in order for us to fulfill our legal obligations, where personal data are made public by the data subject himself and where the processing of your personal data is necessary for the protection of the legitimate interests of our company in its capacity as the data controller, provided that the basic rights and liberties of the data subject are not harmed, your data may be used even if the periods of time stated under this heading have expired, within the limits of the purposes set forth in this sentence.  For that reason, access to your personal data for any other purpose shall not be allowed and they shall be used only to the extent necessary.  When that necessity ends, your personal data shall be duly deleted, removed or anonymized.  

7. Rights of the Owner of Personal data in His Capacity as the Data Subject. If you, our esteemed customers, want to exercise your rights under this heading and/or under the scope of KVKK in your capacity as the owner of the personal data processed and forwarded by our company under the scope of the procedures and principles set forth in this privacy statement and the relevant legislation, our company shall finalize the requests stated in your application submitted for that purpose within thirty (30) days at the latest.  However, if the execution of this transaction imposes an additional cost for the company, the payment of the fee stated in the tariff determined by the Personal Data Protection Board may be requested.  Pursuant to the article 11 of the Law on the Protection of Personal Data our esteemed customers or visitors (data owner) are entitled to:

i)          Learn whether your personal data were processed or not,

 ii)        if processed, request information about it,  iii) Learn the purpose of processing your personal data and whether they were used in line with their purpose of use, iv) Know the third persons at home or abroad to whom personal data were transferred, v)  Request the correction of your personal data if they were processed incompletely or wrongly and further request that the third parties to whom your personal data were transferred be informed about those changes.  vi) request deletion or removal of your personal data which were collected, processed and transferred in accordance with the relevant law and legislation if the reasons requiring their processing disappeared and further request that the third persons to whom your personal data were transferred be informed about the transactions made under this scope, (vii) raise an objection against any result against you that may come out based on the analysis of your processed personal data exclusively through automatic systems, and  (viii) request compensation of the losses that you may incur due to the unlawful processing of your personal data.

You may exercise the above-mentioned rights by applying to our company through the email address info@brandwho.com or other channels stated in the Law on the Protection of Personal Data No. 6698. Changes may be made on the issues addressed in this form in line with the legal and technological developments.

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