KVKK

Our valued customers;

Ceylans Tekstil Photography and Video Services San. As İç ve Dış Tic LTD ŞTİ, as a data controller within the scope of the Personal Data Protection Law No. 6698, we will be able to record, classify, process, store, update and transfer the personal data of our customers and employees to third parties where permitted by the legislation. With this clarification text, we inform you about our mutual rights and obligations in accordance with the provisions of the Law.

1- YOUR PERSONAL DATA AND THE PURPOSE OF PROCESSING

Personal information belonging to you; Your visit to our website, your shares in telephone or e-mail correspondence are collected from sources such as your visit to our workplace. Ceylans Tekstil Photography and Video Services San. If you purchase goods or services from İç ve Dış Tic LTD ŞTİ or otherwise enter into a commercial or legal relationship, from this data; especially identification information (name, surname, TR identity number, gender, date of birth,); your contact data (e-mail address, address and telephone information, IP address), Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. Data related to the product you purchased within the scope of its field of activity, your visual and audio data, Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. will be processed within the scope of compulsory legitimate interests, for the purpose of performance of the contract and fulfillment of legal obligations, within the framework of the reasons for compliance with the law specified in the 2nd paragraph of Article 5 of the Law.

Again, apart from the ones mentioned above, Ceylans Tekstil Photography and Video Services San. Ceylans Tekstil Foto ve Video Hizmetleri San. You have the fundamental right and privileges to prepare and present various reports, analyzes and studies so that you can benefit from customer services, consumer rights and other opportunities within this scope by analyzing your personal product habits through automatic systems regarding the products you purchase from İç ve Dış Tic LTD ŞTİ. provided that you do not harm your freedoms, location data, education data, occupation data, clothing data, vehicle license plate and image features, family members data, Ceylans Tekstil Photography and Video Services San. İç ve Dış Tic LTD ŞTİ . Your personal data and financial data expressing your usage habits, preferences, tastes and likes regarding all kinds of products and services offered by our Company can be processed with your consent.

2-LEGAL REASONS FOR PROCESSING PERSONAL DATA

Our company Ceylans Tekstil Photography and Video Services San. To be able to benefit from our products and services offered by İç ve Dış Tic LTD ŞTİ., to develop our product range with the information received, to provide a product variety according to your liking, to provide a personal marketing service about you by taking your information described above, to provide service with the "best product" principle , to analyze your personal shopping habits through automated systems and to benefit from the products you buy/interest and related customer services, consumer rights and other opportunities to be used by group companies, business partners, suppliers, service providers, and/or commercial activities related to them. It can be processed in cases where it is necessary or compulsory for legally legitimate interests, provided that the financial/legal responsibilities can be fulfilled and/or your fundamental rights and freedoms are not harmed.

If you do not have your previous consent and permission; We will request your consent for your personal data, which is not included in one of the reasons for compliance with the law stated above and in article 5/2 of the law, as required by law. In this case, you will be able to give permission in the digital environment with the same legal quality and value as the written signed permission.

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3-SHARING AND TRANSFER OF DATA

Your personal data, obtained directly from you through our websites, mobile applications and provided by our company through various channels, provided that adequate and effective measures are taken in accordance with the security and privacy principles determined in the legislation; Public institutions or organizations that are authorized to request this data due to legal obligations may share it with domestic and foreign institutions and business partners that we have contracted with due to our activities.

4- YOUR RIGHTS UNDER THE LAW

As personal data owners, you can submit your requests regarding your rights to Ceylans Tekstil Photography and Video Services San. It includes your mandatory information written in the application form or filling out the personal data application form published on the same web address, with the methods regulated in the Internal and Foreign Tic LTD ŞTİ Personal Data Protection and Processing Policy and the data owner application procedure (based on the notification of application procedures to the data owner) and another document or e-mail address. Ceylans Tekstil Foto ve Video Hizmetleri San. İç ve Dış Tic LTD ŞTİ. and Ceylans Tekstil Photography and Video Services San. Ceylans Tekstil Foto ve Video Hizmetleri San. If you forward it to İç ve Dış Tic LTD ŞTİ, Ceylans Tekstil Photography and Video Services San. İç ve Dış Tic LTD ŞTİ will conclude the request free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the process requires an additional cost, Ceylans Tekstil Photography and Video Services San. The fee in the tariff determined by the Personal Data Protection Board will be collected by İç ve Dış Tic LTD ŞTİ. In this context, personal data owners;

⦁ • Learning whether personal data is processed or not,

⦁ • If personal data has been processed, requesting information about it,

⦁ • Learning the purpose of processing personal data and whether they are used in accordance with its purpose,

⦁ • Knowing the third parties to whom personal data is transferred at home or abroad,

⦁ • Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,

⦁ • Requesting the deletion or destruction of personal data in the event that the reasons requiring its processing have disappeared, although it has been processed in accordance with the provisions of the Law No. 6698 and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,

⦁ • Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

⦁ • It has the right to demand the compensation of the damage in case of loss due to unlawful processing of personal data.

regards

For comprehensive information about your personal data, Ceylans Tekstil Foto ve Video Hizmetleri San. You can review the İç ve Dış Tic LTD ŞTİ PERSONAL DATA PROTECTION AND PROCESSING POLICY.

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade LTD STI

PERSONAL DATA PROCESSING POLICY

LOGIN

Ceylans Tekstil Photography and Video Services San. For İç ve Dış Tic LTD ŞTİ ("Company"), the protection of personal data belonging to its customers, employees and other real persons with whom it has relations is of great importance.For the processing and protection of personal data, this Policy and Ceylans Tekstil Foto ve Video Hizmetleri San. The process and the targeted purpose managed by other written Policies within the body of İç ve Dış Tic. Ltd. ŞTİ.'s employees and third parties' personal data is processed and protected in accordance with the law.

In this context, Ceylans Tekstil Photography and Video Services San. Necessary administrative and technical measures are taken by İç ve Dış Tic LTD ŞTİ.

For the processing of personal data in this Policy, Ceylans Tekstil Foto ve Video Hizmetleri San. The following basic principles adopted by İç ve Dış Tic LTD ŞTİ will be explained:

⦁ • Processing of personal data within the scope of consent,

⦁ • Processing personal data in accordance with the law and honesty rules,

⦁ • Keeping personal data accurate and up-to-date when necessary,

⦁ • Processing personal data for specific, explicit and legitimate purposes,

⦁ • Related, limited and measured processing of personal data for the purpose for which they are processed,

⦁ • Keeping personal data for as long as required by the relevant legislation or for the purpose for which they are processed,

⦁ • Clarifying and informing personal data owners,

⦁ • Creating the necessary infrastructure for personal data owners to exercise their rights, Taking the necessary measures for the protection of personal data,

⦁ • To act in accordance with the relevant legislation and KVK Board regulations in the determination and implementation of the processing purposes of personal data, transferring them to third parties,

⦁ • Special regulation of the processing and protection of sensitive personal data

EPISODE 1

1.1 ABOUT THE POLICY

1.2 Purpose

The purpose of the Personal Data Processing Policy (“Policy”) is Ceylans Tekstil Photography and Video Services San. Determination of the principles regarding the processing of personal data of third parties regarding the current and potential customers, employees, business partners, visitors, shareholders, company managers, employee candidates, employees and officials of the institution that cooperates, of İç ve Dış Tic LTD ŞTİ. Protection of rights and freedoms, determination of necessary rights and obligations within the scope of legal and legal processing of personal data, Ceylans Tekstil Photography and Video Services San. Creating awareness on the protection of personal data and data privacy in the eyes of the employees of İç ve Dış Tic LTD ŞTİ, especially the provision of Article 20 of the Constitution, the Law on the Protection of Personal Data No. 6698 ("Law") and the secondary regulations of this Law. It consists of complying with the relevant legislation and taking the necessary measures in this direction.

1.3 Scope

The policy created covers all kinds of information and documents that can be associated with an identified or identifiable natural person, included in the definition of "Personal Data" of the Law, and the measures taken and arrangements made regarding them.

1.4 Responsibles

Ceylans Tekstil Photography and Video Services San. Ceylans Tekstil Photography and Video Services San. İç ve Dış Tic LTD ŞTİ Personal Data Protection Committee is responsible. Ceylans Tekstil Photography and Video Services San. İç ve Dış Tic LTD ŞTİ . Ceylans Tekstil Foto ve Video Hizmetleri San. Units and related employees who use/manage the systems in which personal data are kept, processed or transferred within the body of İç ve Dış Tic LTD ŞTİ are responsible.

1.5 DEFINITIONS

The terms in this Policy have the meanings set forth below.

Description Description

Personal Data Any information relating to a real person with an identified or identifiable identity. Accordingly, data belonging to legal entities are not protected under the Law. Sensitive Personal Data Data about the race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data

Explicit Consent Consent on a specific subject, based on information and freely expressed.

Law No. 6698 on the Protection of Personal Data Processing of Personal Data Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over personal data completely or partially automatically or by non-automatic means provided that it is a part of any data recording system All kinds of operations carried out on data such as making it available, classifying or preventing its use.

Committee Ceylans Tekstil Photography and Video Services San. İç ve Dış Tic LTD ŞTİ Personal Data Protection Committee is the committee that prepares this policy and its members are the heads of the CRM, E-COMMERCE, INFORMATION TECHNOLOGIES and LAW department units.

Institution Personal Data Protection Authority

The company Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade LTD STI

Data Processor The natural or legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller.

Data Controller The natural 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.

Deletion of data means that all relevant users within the company are encrypted to prevent access to personal data and only the data protection officer has this password.

Destruction of Data It refers to the complete elimination of personal data, physically or technologically, in a way that cannot be recovered.

CHAPTER 2

2.1 PRINCIPLES OF PROCESSING PERSONAL DATA

Ceylans Tekstil Photography and Video Services San. İç ve Dış Tic LTD ŞTİ obtains, processes and transfers personal data to third parties within the framework of the following principles and principles. Ceylans Tekstil Photography and Video Services San. İç ve Dış Tic LTD ŞTİ is directly responsible.

2.2 Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. 's Personal Data Processing Principles

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. Personal data is obtained, processed and securely stored for a lawful and legitimate purpose with due care. When the purpose of processing personal data ceases or ends, personal data is anonymized or deleted/destroyed with an appropriate method in line with this Policy. For this process, Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. A Data Retention and Disposal Policy has been established within the body. Data Retention and Destruction Policy Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. It is a sub-member of the Personal Data Protection and Processing Policy.

2.2.1 Privacy

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. The processes of processing personal data are carried out in accordance with the principles of confidentiality. In this context, Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. , prevents any unauthorized access to personal data to the extent that all technical and physical possibilities allow, and implements all possible technical and administrative measures. It carries out periodic audits regarding this.

2.2.2 Legality

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. , while providing you with product sales, after-sales services, product promotion and other services within the limits stipulated by the laws, obtains and processes personal data in accordance with the rules of honesty and law. Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. , informs the persons concerned of the purposes of using personal data and obtains the consent of the persons concerned within the scope of the law when necessary.

2.2.3 Timeliness and Accuracy

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. Personal data is kept complete and accurate and updated when necessary. Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. , makes the necessary arrangements to determine whether the personal data is correct or to correct, change, update or delete insufficient data.

2.2.4 Certainty and Transparency

The principle of processing data for a specific, explicit and legitimate purpose; Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. It ensures that the data processing purpose is clearly and precisely determined and that this purpose is legitimate. Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. , does not process data for other purposes, except for data collection and processing purposes that it makes transparent to the data subject. The legitimate aim is Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. the data processed by; means that it is related and necessary to the work it has done or the service it has provided.

2.2.5 Due Diligence, Moderation and Consistency

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. Personal data processed by us are only processed in a way that is consistent with the purpose specified when the data was collected, and in this context, by making a limitation as required by the business. Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. Personal data will not be collected for uncertain data processing purposes that may arise in the future, and this data will not be used, processed or transferred in any way that is not suitable for the purpose of obtaining personal data. In accordance with the minimum data principle, personal data is kept limited and measured for the purpose of obtaining, and data that is not necessary for this purpose is not stored.

2.2.6 Limited Time

This data, Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. by; The periods for the processed data are determined and kept. In the event that the main purpose requiring the processing of personal data disappears and this data is no longer needed, the personal data in question are deleted. If the laws stipulate the periods for keeping the data, these data are kept in accordance with the periods stipulated in the relevant legislation; After the expiry of the period stipulated in the legislation, these data are transferred to Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. It is deleted/destroyed or anonymized from the systems/devices where the data is stored or from the environments where it is physically located.

2.2.7 Selection and Consent

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. , informs the data owner fully and duly about the processing of personal data. When necessary, it obtains the consent of the data owner regarding the said processing, and offers the data owner the option to withdraw the consent given to them or to request their data. Regarding this, Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. Personal Data Application Procedure has been established within the framework of the framework, and transactions are carried out in accordance with the principles in this framework.

2.3 Legal Processing of Personal Data

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. 5.2 of the law in order to process personal data and sensitive personal data in accordance with the law. If one of the other reasons for compliance with the law listed in the article does not exist; seeks the existence of the explicit consent of the person concerned,

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. 3.1. above, the processing activities in question. It executes in full compliance with the principles specified in the section.

2.4. Purposes of Processing Personal Data

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. Personal data collected by us and special quality personal data are processed within the framework of the two main purposes stated below, in accordance with the principle of transparency and openness;

a) Reasons for legal action for the purpose of fulfilling administrative/legal/financial obligations

⦁ • Invoicing due to product or service sale

⦁ • Membership agreements concluded within the framework of the loyalty program

⦁ • Retention of records in accordance with tax laws

⦁ • Creation of personal file in accordance with the labor law,

⦁ • Providing health services within the scope of occupational medicine

⦁ • Recording of cameras and visitors for security reasons

⦁ • Keeping digital traces and records of the consent and permissions obtained from the customer in the digital environment as proof

⦁ • Other legitimate interests to be considered legally necessary

⦁ • Responsibility for legal processing

b) Fulfillment of our business activities

⦁ • Product Sales

⦁ • After-Sales Services and Marketing Activities

c) Improving our service standards and providing customized services for each user

⦁ • Improvement of services: Ensuring customer satisfaction by evaluating requests and complaints by relevant units, conducting/evaluating customer surveys when necessary, and taking customer feedback into account

⦁ • Carrying out marketing activities with the “Best Product” Principle by making Customer and Service Segmentation: Reporting, inspecting and improving the services received by customers through call centers, website or authorized dealers and sales/service points within the framework of quality standards and making necessary analyzes, To be able to promote and inform about products and services via e-mail, SMS and other communication means, to increase the recognition of the company through messages to be sent with announcements / celebrations and other content, and to provide general or personalized advertisements, announcements and campaign information for the promotion and marketing of our services.

For more detailed information on the purposes of processing personal data, Ceylans Tekstil Foto ve Video Hizmetleri San. Domestic and Foreign Trade. LTD. STI. You can refer to the Illumination Text.

2.5. Transfer of Personal Data

The principles for the processing of personal data also apply to the transfer of personal data. Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. , to third parties if necessary and compulsory for the realization of the purposes stated below; Personal data can be transferred to foreign countries that are declared to have sufficient protection by the KVK Board or, in the absence of sufficient protection, to foreign countries where data controllers in Turkey and the relevant foreign country undertake an adequate protection in writing and where the permission of the KVK Board is available.

⦁ • Fulfilling the obligations stipulated in accordance with the law or regulations,

⦁ • Fulfilling the court decision or the decision/instruction of the regulatory and supervisory public institution,

⦁ • Ensuring administrative and technical measures as well as infrastructure security and

⦁ • In case of legal dispute, Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. protection of rights.

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. , transfers personal data limited to the purpose of transfer to third parties and takes the necessary measures in this regard. In this regard, Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. In the capacity of Data Controller, it is in a supervisory position before the 3rd Persons, who are the Transferred Recipient Group.

Personal data Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. In case of express consent of the relevant person or one or more of the reasons for compliance with the law, in parallel with the purposes of processing; Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. 's subsidiaries, business partners, authorized representatives, official institutions and organizations, service providers, third parties whose services we benefit from or cooperate with, such as companies providing call center services.

Third parties to whom personal data are transferred cannot use and process the transferred personal data for their own personal or commercial purposes other than the purpose of transfer. Third parties to whom personal data are transferred, Ceylans Tekstil Foto ve Video Hizmetleri San. Domestic and Foreign Trade. LTD. STI. It is obliged to comply with the instructions given by the Company and to take all necessary technical and administrative measures to ensure data security.

In case the transfer is made abroad, it is possible to transfer to countries with sufficient protection to be determined by the Board with the existence of the conditions required for the processing of personal data, and if there is no such protection, the data controllers in Turkey and the relevant foreign country must provide sufficient protection in writing. Personal data can be transferred to Ceylans Tekstil Foto ve Video Hizmetleri San. Domestic and Foreign Trade. LTD. STI. can be transferred abroad.

In accordance with Articles 8 and 9 of the KVK Law, the personal data of data subjects managed by this Policy can be transferred to the following categories of persons:

⦁ • Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. to business partners,

⦁ • Bank and insurance companies and Law Firms,

⦁ • Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. to its suppliers,

⦁ • Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. company officials,

⦁ • Legally Authorized public institutions and organizations,

2.6. Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. PERSONAL DATA INVENTORY AND CLASSIFICATION OF PERSONAL DATA

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. before; Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. In line with the legitimate and lawful personal data processing purposes of KVK Law, based on and limited to one or more of the personal data processing conditions specified in Article 5 of the KVK Law, in particular the principles specified in Article 4 regarding the processing of personal data, in accordance with the KVK Law. In compliance with the general principles set forth in the KVK Law and all obligations set forth in the KVK Law, the personal data owners within the scope of this Policy (Customers, Employees, Visitors, Third Parties, Employee Candidates, Employees of the Institutions We Collaborate) limited to the personal data owners in the following categories. data is processed by informing the relevant persons.

Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. A personal data inventory has been created in accordance with the Data Controllers Registry Regulation issued by the Personal Data Protection Authority. This data inventory includes data categories, data source, data processing purposes, data processing process, Recipient groups to which data is transferred, and retention periods. In this context, Ceylans Tekstil Photography and Video Services San. Domestic and Foreign Trade. LTD. STI. The following types of data categories include, but are not limited to, these types.

PERSONAL DATA CATEGORY PERSONAL DATA CATEGORY DISCLOSURE

Communication Data It is the data group that can be used to reach the person (Phone, address, e-mail, Fax number, IP address, ).

Identity Data Data group that contains information about the identity of the person (Name, surname, TCKN, mother's name, father's name, place of birth, date of birth, gender, wallet serial number, copy of identity card, tax no, SSI no, nationality data, copy/scan of marriage certificate. , employee card

Health Data It is the data group that contains the health information of the person (Blood group, medical history, check-up result, consultation report, diet form).

Vehicle Data It is the data group containing the vehicle information of the person (Plate number, license information).

Location Data It is the data group containing the location data of the person (GPS location).

Audio/Visual Data It is the data group that contains the visual and audio data of the person (Photo, sound recording, camera recording, driver's license photocopy/scan, ID photocopy/scan, passport photocopy/scan).

Digital Trace Data It is a data group (Log ) that contains digital traces formed as a result of processing personal information.

Financial Data It is the data group that contains the financial information of the person (Bank account number, IBAN number, card information, bank name, financial profile, mail order form, credit rating).

Biometric/Genetic Data It is the data group that contains the biometric/genetic data of the person (Fingerprint, genetic information, vein print).