As OZAN DEMİRBAŞ, we attach utmost importance to the privacy and security of the information and data of our customers, employees, employee candidates, and all our business partners. For this reason, in accordance with the Law No. 6698 on the Protection of Personal Data, we would like to inform you about the reasons for processing your personal data by OZAN DEMİRBAŞ ("OZAN DEMİRBAŞ") in the capacity of Data Controller, the legal basis for this, the method of collection, your rights arising from the relevant Law, and to fulfill our obligation to inform under this Law.

1. As OZAN DEMİRBAŞ, to whom are we addressing this information?
First of all, we would like to state that your personal data may be processed by OZAN DEMİRBAŞ in accordance with the provisions of the Law No. 6698 on the Protection of Personal Data, based on your explicit consent. Additionally, we would like to remind you that in cases falling within the scope of Article 5/2 of the Law on the Protection of Personal Data, obtaining consent from individuals is not required.

In accordance with Article 10 of Law No. 6698, we are addressing this information to all users who connect to/use the e-commerce channels of ozandemirbas.com; those who connect to the guest network (Wi-Fi) in OZAN DEMİRBAŞ offices, warehouses, and stores; all users of OZAN DEMİRBAŞ mobile applications; all customers listed in the OZAN DEMİRBAŞ database (CRM system); customers who shop from OZAN DEMİRBAŞ stores or ozandemirbas.com e-commerce channels; all users who connect to/use these channels; those who use any of the communication options on ozandemirbas.com; individuals who visit OZAN DEMİRBAŞ stores for any purpose; customers who shop from OZAN DEMİRBAŞ stores or the OZAN DEMİRBAŞ.com website; all customers who contact OZAN DEMİRBAŞ via OZAN DEMİRBAŞ social media accounts (including but not limited to sharing comments and making requests); participants in competitions organized by OZAN DEMİRBAŞ; all customers who fill out surveys or forms to benefit from the opportunities provided by OZAN DEMİRBAŞ to its customers; all other cardholders issued or to be issued by OZAN DEMİRBAŞ to offer advantages to customers, especially OZAN DEMİRBAŞ customer loyalty cardholders, and those who fill out surveys or forms for the use of these cards; as well as job applicants who submit their resumes to OZAN DEMİRBAŞ via career portals, İŞKUR, email, Facebook, Instagram, and/or other social media platforms, through a reference, or by physically filling out an application form; employees currently working at OZAN DEMİRBAŞ; former employees whose employment contract has ended for any reason; all business partners within the scope of our commercial activities and their employees; and, without being limited to these, all natural persons who have shared/will share their personal data with OZAN DEMİRBAŞ in person, remotely, verbally, in writing, or electronically; who have provided/will provide it directly; or who have enabled/will enable OZAN DEMİRBAŞ to obtain it.

The information of our customers who register and/or update their records through all OZAN DEMİRBAŞ invoicing systems and other platforms (OZAN DEMİRBAŞ e-commerce channels, OZAN DEMİRBAŞ.com customer information update screen) is stored in our accounting infrastructure, ERP enterprise resource planning application, and reporting systems in a manner that can only be accessed by authorized personnel.

These data can be accessed when necessary through various corporate applications and queried based on different criteria. The points and discounts offered to our customers as advantages during payment are also provided by accessing these data.

No customer data and/or data related to the legal entities we work with are shared with any third-party company. For all third-party companies that will have any form of access to these data, security and confidentiality agreements are made, ensuring the protection of the data in accordance with the relevant legal regulations.

2. What does the processing of your personal data mean?
The processing of personal data refers to any operation performed on the data, whether by automated means or non-automated means as part of any data recording system, including obtaining, collecting, recording, storing, preserving, altering, rearranging, disclosing, transferring, acquiring, making available, classifying, or preventing its use.

3. For what purposes and legal grounds are we processing your personal data?
Any personal data collected directly or indirectly within OZAN DEMİRBAŞ and depending on the services provided by OZAN DEMİRBAŞ, its commercial activities, and even legal requirements, will be processed based on the purpose of collection. All personal data obtained directly or indirectly from the individuals mentioned above will be processed accordingly.

a) To verify the identity of individuals making purchases from OZAN DEMİRBAŞ.com and/or OZAN DEMİRBAŞ e-commerce channels; to make the necessary notifications to fulfill all contractual obligations, primarily the distance sales contract and contracts made in accordance with the Consumer Protection Law; to perform the required actions;
b) To provide information to all public officials upon request, primarily in response to requests from Civil and Criminal Courts, in matters related to public security and as required by legislation;
c) Primarily, to inform about the special and general campaigns organized by OZAN DEMİRBAŞ (such as promotions, advertisements, discounts, etc.); to use it in all marketing activities of OZAN DEMİRBAŞ;
d) To identify our customers who make purchases from the store, website, and/or mobile applications, and to carry out marketing activities based on this information;
e) To use in various marketing and advertising activities, and to conduct marketing activities, surveys, and market analysis through electronic means and/or physical means via affiliated organizations within this scope;
f) To evaluate and report customer complaints and suggestions regarding our services, and to share data with our business partners within this scope and for marketing activities;
g) To fulfill our legal obligations and exercise our rights arising from the applicable legislation;
h) To transfer to third parties and third-party companies (our affiliated business partners) from whom we receive services, for the fulfillment of legal obligations;
i) To store data in databases for the purpose of fulfilling contractual obligations (such as product delivery, etc.);
j) To store your contact information in databases for the purpose of reminding you of your rights against OZAN DEMİRBAŞ;
k) To recruit employees within the framework of OZAN DEMİRBAŞ's human resources policies and needs, and to manage and improve the recruitment processes;
l) To evaluate job applications, finalize the process, and contact candidates who have applied for the job;
m) It may be processed by OZAN DEMİRBAŞ to evaluate the performance of our employees for the execution of our human resources policies, and for the purpose of evaluating, developing, and improving this policy and our services.

Our OZAN DEMİRBAŞ stores, central offices, and warehouses are monitored by security cameras to ensure the safety of our customers, job candidates, and employees. Therefore, we would like to inform you that images of individuals visiting our stores, central offices, and warehouses may occasionally be recorded by security cameras. Additionally, in accordance with legal requirements for public safety, information may be shared with public officials upon requests from administrative and judicial authorities, and these images may be shared with them.

We would like to inform our job candidates who submit their resumes to OZAN DEMİRBAŞ for the purpose of applying through the methods mentioned above that their resumes, along with the information collected at the time of application, may be used for evaluation in the position applied for or for potential future positions, and may be stored in OZAN DEMİRBAŞ's HR data. The personnel files of employees currently working at OZAN DEMİRBAŞ and those of former employees who have previously worked at OZAN DEMİRBAŞ are stored within the company in accordance with our legal obligations and continue to be retained for this purpose.

We would also like to indicate that personal data of all our business partners and their employees, who benefit from the protection of the Law on the Protection of Personal Data within the scope of our commercial activities, may be processed by OZAN DEMİRBAŞ as part of its customer portfolio for the fulfillment of contractual obligations during and after the continuation of the business relationship. All of your personal data, as detailed above, is processed in accordance with the fundamental principles set forth by the KVKK, and within the conditions and purposes of personal data processing specified in Articles 4, 5, and 6 of the KVKK, including but not limited to the Turkish Code of Obligations No. 6098, the Law No. 6502 on Consumer Protection, the Labor Law No. 4857, the Law No. 29166 on the Regulation of Electronic Commerce, and regulations established pursuant to these laws, in compliance with all legal regulations and in line with the above-mentioned purposes.

4. To which individuals and organizations can we transfer your personal data for the mentioned purposes?
First of all, we would like to emphasize that your personal data is not shared with third parties without obtaining your explicit consent.
However, we would also like to inform you that we are required to share your personal data due to our legal obligations. For example, we may share your personal data upon request from judicial authorities and public institutions as required by law. Additionally, to fulfill our obligations arising from the law, your personal data may be transferred to our affiliated business partners from whom we receive services, solely for this purpose. Furthermore, your personal data may be shared with third parties under contract in order to fulfill our contractual obligations with you. Before making such transfers, we take technical and legal measures to prevent any violation of rights for both parties. However, we would like to clarify that we are not responsible for any violations occurring under the responsibility of the third party with whom we share the data.

Additionally, your personal data may be transferred to our business partners, suppliers, service providers, Group Companies, company officials, shareholders, legally authorized public institutions, and private individuals, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law (KVK Law), for purposes such as ensuring the legal and commercial security, oversight, administrative operations, and evaluation processes of those involved with OZAN DEMİRBAŞ, as well as for the implementation of OZAN DEMİRBAŞ's human resources policies.

In order to provide you with better services and for various marketing activities related to product groups that fall within your area of interest, your personal data may be shared with various agencies, advertising companies, survey companies, other third parties, and relevant business partners.

We would also like to mention that, upon request from third-party company officials, your information may be shared for reference purposes regarding former employees who have previously worked at OZAN DEMİRBAŞ.

In accordance with the KVKK and the 1st and 3rd Articles mentioned above, your personal data collected may be transferred in compliance with the fundamental principles set forth by the KVKK and within the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK, as well as for the purposes outlined above.

Additionally, personal data may be transferred abroad by OZAN DEMİRBAŞ for the purposes mentioned above;

• If the data subject's explicit consent is obtained, or
• In cases where the data subject's explicit consent is not available, but one or more of the other conditions mentioned above are met;
• If there is adequate protection in the country to which the data is transferred, and
• In cases where there is insufficient protection in the country to which the data is transferred, the relevant OZAN DEMİRBAŞ, together with the data controller in the foreign country, must provide written assurance of adequate protection, and the transfer can only take place with the approval of the Personal Data Protection Authority.

5. How do we collect your personal data?
Personal data may be collected for the purposes mentioned above, not limited to the following methods; through fully or partially automated means or non-automated methods, as part of any data recording system, via OZAN DEMİRBAŞ's offices, stores, workplaces, website, mobile applications, social media platforms, cameras, and other similar tools, in oral, written, or electronic form. Below are some illustrative examples of how this data may be collected:
 

• Call center: The information of all individuals who contact us by calling our customer service line at OZAN DEMİRBAŞ (+90 212 282 92 09) may be processed, limited to the purposes mentioned above.
• OZAN DEMİRBAŞ E-Commerce Channels: Through our website, all customers may contact OZAN DEMİRBAŞ or apply for membership if they wish. In addition, ozandemirbas.com is a site that uses cookies. Cookies are small text files saved to your hard drive when you download a file or visit a website. In other words, they are files created by previously visited websites that store browsing information such as your website preferences or profile details. Therefore, cookies are used to provide you with better service by delivering campaign information related to the product groups you are interested in and making product promotions.
• By applying directly to proje@ozandemirbas.com or the OZAN DEMİRBAŞ Headquarters: proje@ozandemirbas.com is our written communication channel that allows our customers to contact OZAN DEMİRBAŞ via email. The information of all individuals who contact us through this channel will be stored for communication purposes. The information of all individuals who contact OZAN DEMİRBAŞ physically (Headquarters) or remotely (phone: +90 212 282 92 09) will also be stored for communication purposes.
• All OZAN DEMİRBAŞ stores, headquarters, and warehouses: The footage of all visitors and employees recorded by security cameras will be stored. Additionally, the personal information of individuals visiting our stores, headquarters, and warehouses may be processed, limited to the purposes mentioned above.
• Job Applications: Personal data related to job applications is collected through career portals, email, İŞKUR, referrals, and by filling out a physical application form.

6. What Are Your Rights Under Article 11 of the Personal Data Protection Law?
You can apply to OZAN DEMİRBAŞ by using the communication channels listed below and provided on the ozandemirbas.com website:

You have the right to learn whether your personal data is processed, the purpose of its processing, and whether it is being used in accordance with that purpose. You can also find out which third parties, either in Turkey or abroad, your data has been transferred to, and you can request information regarding the processed data. If any incorrect or incomplete processing is identified, you may request corrections, and the relevant processing operation can also be communicated to the third parties to whom your personal data has been transferred. Furthermore, without the need to provide any justification, upon your request, your personal data may be deleted, destroyed, or anonymized. However, we would like to remind you that personal data that we are required to retain by legal obligations cannot be deleted, destroyed, or anonymized. Additionally, even if your data has been processed in accordance with KVKK and other relevant legal provisions, you have the right to request the deletion or destruction of your personal data if the reasons for processing have ceased, and this request can be communicated to third parties to whom the data has been transferred. You also have the right to object to any decision that is made solely by automated systems, which leads to a result detrimental to you. If you believe that your personal data has been processed unlawfully and this has caused damage, you also have the right to take legal action against OZAN DEMİRBAŞ.

In accordance with Article 13, Paragraph 1 of the Personal Data Protection Law (KVK Law), you may submit your request to exercise the above-mentioned rights to our company in writing or through other methods specified by the Personal Data Protection Authority. In this regard, the channels and procedures through which you can submit your written request under Article 11 of the KVK Law are explained below. Your requests will be processed by OZAN DEMİRBAŞ within the legal time frame specified by the KVKK, and you will be informed about the outcome.

Article 28, Paragraph 2 of the Law lists the cases in which data subjects do not have the right to request. In this context:

• The processing of personal data is necessary for the prevention of a crime or for a criminal investigation.
• The processing of personal data that has been made public by the individual themselves.
• The processing of personal data based on the authority granted by law for the execution of supervisory or regulatory duties by authorized public institutions, or by professional organizations with the status of public institutions, for the purpose of disciplinary investigations or prosecutions.
• The rights specified above regarding personal data cannot be exercised in cases where the processing of personal data is necessary to protect the economic and financial interests of the State in relation to budget, taxation, and financial matters.

According to Article 28, Paragraph 1 of the Law, in the following cases, the data will be outside the scope of the Law, and the requests of data subjects will not be processed with regard to these data:

• The processing of personal data by natural persons, provided that the data is not shared with third parties and the obligations regarding data security are complied with, within the scope of activities related to themselves or family members living in the same household.
• The processing of personal data for purposes such as research, planning, and statistics by anonymizing the data for official statistics.
• The processing of personal data for artistic, historical, literary, or scientific purposes, or within the scope of freedom of expression, provided that it does not violate national defense, national security, public safety, public order, economic security, privacy, or personality rights, or constitute a crime.
• The processing of personal data within the scope of preventive, protective, and intelligence activities conducted by public institutions and organizations authorized by law to ensure national defense, national security, public safety, public order, or economic security.
• The processing of personal data by judicial authorities or enforcement authorities in relation to investigations, prosecutions, trials, or enforcement proceedings.

7. How long will your personal data be processed?
OZAN DEMİRBAŞ determines the retention periods for personal data by considering the applicable regulations and the purposes for which the data is processed. In accordance with the KVKK, personal data processed for the purposes stated in this Privacy Notice will be deleted, destroyed, or anonymized and continued to be used once the purpose for processing the data is no longer valid, and/or the statutory retention periods for processing the data have expired, in accordance with Article 7, paragraph 1 of KVKK.

8. How Can You Exercise Your Rights as a Data Subject?
In accordance with Article 11 of the KVKK, in order to exercise the above-mentioned rights, you can contact OZAN DEMİRBAŞ by completing the Application Form provided via the link and submitting it with the necessary identity verification information to the following address: Esentepe Mah. Büyükdere Cad. Levent Loft No: 201/1 - Floor: 7 Apartment: 113 Levent / İstanbul. Alternatively, you may submit the signed hard copy in person at this address, through a notary, by registered mail, or by sending the form with a secure electronic signature via registered email to proje@ozandemirbas.com. For third parties to apply on behalf of personal data owners, a notarized power of attorney must be provided by the data owner authorizing the representative to act.

OZAN DEMİRBAŞ will resolve the request as quickly as possible and no later than thirty (30) days, free of charge, depending on the nature of the request. However, if the process requires an additional cost, the fee specified in the tariff determined by the Personal Data Protection Authority will be charged.