In accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), your personal data will be processed by our Company as a Data Controller for purposes related to business activities, as described below, including recording, storing, updating, transferring, and/or classifying your personal data.

In this context, our Company commits to taking all necessary technical and administrative measures to prevent the unlawful processing of your personal data, to prevent unlawful access to your data, and to ensure its protection, as per the Law and Regulations aimed at protecting personal data and safeguarding individuals’ fundamental rights and freedoms, especially the right to privacy.

This document is intended for all individuals whose personal data is processed by our Company, excluding our employees or those who have applied for a job with our Company.

The personal data processed as a Data Controller includes, but is not limited to:

• Name, surname, Turkish ID number, address, phone number, email address, signature, physical space/security camera footage, call center/service quality voice recordings, bank account number, and cookie records.

Purposes and Legal Grounds for Processing Personal Data

Your personal data will be processed by the COMPANY within the framework of the following purposes and legal grounds:

• To provide COMPANY products and services to you, fulfill our obligations to you, organize records and documents, and comply with information storage, reporting, notification, tax, and other obligations stipulated by local and international legal regulations,
• To present you with personalized advertisements, campaigns, advantages, and other benefits for sales and marketing activities aimed at improving the quality of services and products,
• To communicate with you for IT requirements, system structures, the necessity of the IT support services received, and to transfer the necessary information regarding these services and products,
• To conduct traffic measurement, statistical analyses, segmentation/profiling, and CRM studies for sales and marketing activities,
• To measure and improve customer satisfaction, manage complaints, receive your feedback and suggestions regarding new services and products, receive your issue/error notifications, provide information about products and services, and your complaints and requests,
• To manage your online sales membership, process your orders, execute payment transactions, collaborate with third parties for logistics partnerships to ensure product delivery, recommend products and services that may interest you, engage in online behavioral advertising and marketing, manage customer portfolios, measure and improve service quality, communication, optimization, auditing, risk management, and control, promotions, analysis, interest determination, scoring, profiling, marketing, sales, and advertising communication,
• To use your personal data in any products and services provided to you within the scope of the COMPANY’s main business activities as defined in the COMPANY’s articles of association, including comparative product and/or service offerings, modeling, development, and/or enhancement of existing or new products,
• To comply with information storage, reporting, and notification obligations stipulated by official institutions, fulfill contractual requirements, and fulfill the legal obligations to which the COMPANY is subject regarding the use of these services,
• To determine and implement the COMPANY’s commercial and business strategies, including managing financial operations, communication, market research, and social responsibility activities, procurement operations (request, offer, evaluation, order, budgeting, contract), internal system and application management operations, and legal operations,
• To review, evaluate, and respond to requests from official authorities or from you.

Your personal data collected within the scope of the purposes mentioned above may be transferred to:

• The COMPANY’s business partners, shareholders, subsidiaries,
• Persons or organizations authorized by the provisions of the Turkish Commercial Code, Turkish Code of Obligations, and other legislation,
• Legally authorized public institutions and organizations, administrative bodies, and legal authorities,
• Natural or legal persons from whom we receive services, cooperate with, or partner with in providing comparative product/service offers, analysis, evaluation, advertising, and for other purposes mentioned above, institutions with whom we have agreements to send communications to our customers, courier companies that deliver orders placed through our online store, under the conditions specified in Articles 8 and 9 of the Law No. 6698.

Method and Legal Grounds for Collecting Personal Data

Your personal data is collected by our COMPANY through various channels such as our stores, website, mobile applications, call centers, and social media accounts, either verbally, in writing, or electronically, and through other channels that may be established/formed in the future, primarily within the framework of legal regulations and for the purposes mentioned above.

The legal grounds for collecting personal data include fulfilling the contract, compliance with the law, making personal data public by the data subject, necessity for establishing, exercising, or protecting a right granted to you, necessity for the legitimate interests of the COMPANY without harming your fundamental rights and freedoms, and the necessity for the COMPANY to fulfill its legal obligations.

Rights of the Personal Data Owner Under Article 11 of Law No. 6698

As personal data owners, you can submit your requests related to your rights to our COMPANY using the methods outlined below. Our COMPANY will resolve the request within the shortest time possible, but no later than thirty days, depending on the nature of the request. No fee will be charged for responses up to ten pages. For every page exceeding ten pages, a processing fee of 1 Turkish Lira will be charged per page. If the response to the application is provided on a recording medium such as a CD or flash drive, the fee charged by our COMPANY will not exceed the cost of the recording medium.

In this context, personal data owners have the following rights:

• To learn whether their personal data is processed or not,
• To request information if their personal data has been processed,
• To learn the purpose of processing their personal data and whether they are used in accordance with their purpose,
• To know the third parties to whom personal data is transferred domestically or abroad,
• To request the deletion or destruction of personal data in accordance with the conditions stipulated in the Law No. 6698 and other relevant laws, despite being processed in accordance with the provisions of the Law No. 6698, if the reasons for processing are no longer valid, and to request notification of the transaction to third parties to whom personal data has been transferred,
• To object to the occurrence of any result that is to their detriment through the analysis of processed data exclusively by automated systems,
• To request compensation for the damage in case of loss due to the unlawful processing of personal data.

To exercise your rights mentioned above, you can submit your request in Turkish and in writing or through registered electronic mail (KEP), secure electronic signature, mobile signature, or by using the email address previously notified to our COMPANY and registered in our system, in accordance with Article 13 of Law No. 6698 and the Communiqué on the Procedures and Principles of Application to the Data Controller dated 10.03.2018 and numbered 30356. Our COMPANY reserves the right to verify your identity before responding.

This disclosure text has been prepared in accordance with the Law No. 6698 and the Regulations and Communiqués published under this Law and within the scope of Unique Sales’ personal data processing purposes and policies. Necessary changes may be made to the disclosure text in line with the changes in the relevant legal regulations and/or Unique Sales’ personal data processing purposes and policies.