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Personal Data Clarification Text for Members and Visitors

KVKK INFORMATION TEXT

POLAR STAR JR. Textile Import and Export Co.Ltd. As a company, we attach great importance to the processing and preservation of all personal data belonging to all persons affiliated with the Company, including those who benefit from our products and services, in accordance with the Law on the Protection of Personal Data No. 6698 ("LPPD Law"). In this context, as defined in the LPPD Law, in accordance with the title of "Data Controller" and again in accordance with Article 10 of the LPPD Law and the Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Obligation to Disclose ("Communiqué") published in the Official Gazette No. 30356 dated 10 MARCH 2018 by the Personal Data Protection Board, in order to fulfill the duty of informing personal data owners during the collection of personal data; During the collection of personal data by our Company, the identity of our Company, the purpose for which personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method and legal reason for collecting personal data, and the rights of the personal data owner within the scope of Article 11 of the LPPD Law. we present this information.

Definition of Personal Data

Within the framework of Article 3/I(d) of the PDP Law, "personal data" refers to any information relating to identified or identifiable real persons. In this context, personal data refers to any information relating to an identified or identifiable real person. For example; your name, surname, Turkish identity number, address, telephone number, e-mail address, date of birth, the IP number you access, information regarding the transactions you have made, etc. information relating to you are your personal data. In addition, according to the PDP Law; data relating to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and attire, memberships in associations, foundations, unions, etc., health, sexual life, criminal conviction and security measures, as well as biometric and genetic data, etc. are special personal data. In this context, anonymous information, information made anonymous and other data that cannot be associated with a specific person are not considered personal data in accordance with our Company's Policy on this matter.

Who is responsible for your personal information?

As POLAR STAR JR. (referring to its current and/or future affiliates, subsidiaries, joint ventures and all branches and offices of these companies at home/abroad and/or organizations with which it cooperates), we process your personal data as the "Data Controller" as defined in the Personal Data Protection Law No. 6698 ("LPPD"), as explained below and within the limits prescribed by the legislation. In order to obtain more detailed information about our purposes of processing your personal data and our transfers, and to read our detailed information regarding the Personal Data Protection Law, you can review the "Privacy Rules, Personal Data Protection Policy and Communication Information" text on our corporate web page, which you can access from the link www.polarstarjr.com/gizlilik-ve-guvenlik-politikasi.

Collection, Processing and Purposes of Processing of Personal Data

Your Personal Data may vary depending on the service, product or commercial activity provided by our Company; and is/may be collected verbally, in writing or electronically through automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar means.

Within the scope of Article 5.2 and Article 6.3 of the PDP Law, in order to fulfill our legal obligations, to establish or perform a contract, to fulfill our legal obligations, to establish, exercise or protect a right and to protect our legitimate interests without harming your fundamental rights and freedoms, and in terms of personal data you have made public, it may be processed without your explicit consent. Again, your personal data may be processed within the scope of the purposes specified in this Disclosure Text, provided that your explicit consent is obtained within the scope of Article 5.1 and Article 6.2 of the PDP Law. You may obtain all our products without being included in our other membership programs and memberships, especially the Polar Star Jr. membership. On the other hand, since Polar Star Jr. offers special advantages to its members, you give your explicit consent to the processing of your Personal Data, except for exceptional cases, by being included in the programs/being a member in order to benefit from membership advantages.

Your collected personal data is/will be processed in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law and other applicable legal regulations for the purposes of ensuring that our business units carry out the necessary work to enable you to benefit from the products and services offered by our Company, that the products and services offered by our Company are customized and recommended to you according to your tastes, usage habits and needs, that the legal and commercial security of our Company and the persons who have a business relationship with our Company (administrative operations for communication carried out by our Company, ensuring the physical security and control of the Company's locations, business partner/customer/supplier (authorized persons or employees) evaluation processes, legal compliance process, financial affairs, etc.), that the commercial and business strategies of our Company are determined and implemented, and that the human resources policies of our Company are carried out.

For What Purposes Will Personal Data Be Processed, To Whom and For What Purposes Can It Be Transferred?

Your collected personal data will be used for the following purposes: correctly planning, executing and managing our Company's commercial collaborations, management and communication activities and strategies in accordance with the law and the purpose of the Personal Data Protection Law; carrying out the necessary work by our business units to ensure that personal data owners benefit from our products and services in the best way possible and recommending them by customizing them according to their demands, needs and requests; ensuring data security at the highest level; developing the services offered on our website and eliminating errors on the website; communicating with personal data owners who submit their demands and complaints; ensuring demand and complaint management; event management; providing information to authorized institutions based on legislation; creating and monitoring visitor records; ensuring the legal and commercial security of our Company, our group companies and persons who have a business relationship with our Company (administrative operations for communication carried out by our Company, ensuring the physical security and control of the Company's locations, business partner/customer/supplier/authorized/employee evaluation processes, reputation research processes, legal compliance process, auditing, financial affairs, etc.); determining and implementing our Company's commercial and business strategies. Limited to the purposes of ensuring the implementation of our Company's human resources policies, it may be processed within the framework of the personal data processing conditions and purposes specified in Articles 5 and 6 of the PDP Law and may be transferred to our business partners, suppliers, group companies, Company officials, shareholders, legally authorized public institutions and private persons within the scope of the personal data transfer conditions specified in Articles 8 and 9 of the PDP Law. If the processing activity carried out for the aforementioned purposes does not meet any of the conditions stipulated under the Law, your explicit consent is obtained by the Company regarding the relevant processing activity.

Method and Legal Reason for Collecting Personal Data

Your personal data is obtained through our audit and consultancy services, written/digital applications made to our Company employees, our website, calls to our phone numbers, social media, SMS channels, and other verbal, written or electronic media, automatic or non-automatic methods and other channels through which our Company communicates with you or may communicate with you in the future, in order to carry out our activities and to fulfill our contractual and legal obligations with you, and the personal data obtained is stored for legal periods in accordance with the relevant Legislation.

Rights of the Personal Data Owner

Pursuant to Article 11 of the KVKK;

(i) To learn whether personal data is processed, (ii) To request information if personal data is processed, (iii) To learn the purpose of processing personal data and whether they are used in accordance with their purpose, (iv) To know the third parties to whom personal data is transferred in the country or abroad, (v) To request correction of personal data if they are processed incompletely or incorrectly, (vi) To request deletion or destruction of personal data within the framework of the conditions stipulated in Article 7, (vii) To request notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data is transferred, (viii) To object to the emergence of a result against the person by means of analysis of processed data exclusively through automated systems, (ix) To request compensation for the damages incurred due to unlawful processing of personal data.

As personal data owners, if you submit your requests regarding your rights to our Company using the methods set out below in this Personal Data Processing Information Text, our Company will finalize the request free of charge within thirty days at the latest, depending on the nature of the request. However, if a fee is foreseen by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged.

In accordance with Article 13, paragraph 1 of the KVKK, you may submit your request to our Company regarding the exercise of your rights specified above in writing or through other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application to our Company in writing in accordance with the KVKK. In this context, in order to exercise your rights specified above, you may submit your request including the necessary information identifying your identity and explanations regarding the right you request to exercise among the rights specified in Article 11 of the KVKK to our Company via the e-mail address info@polarstarjr.com.

In accordance with Article 4 of the KVKK, POLAR STAR JR. is obliged to keep your personal data accurate and, if necessary, up-to-date. In this context, in order for POLAR STAR JR. to fulfill its obligations arising from the current legislation, our customers must share accurate and, if necessary, up-to-date data with POLAR STAR JR. If your data changes in any way, we kindly request that you update your data by contacting us through the communication channels specified below.

Email: info@polarstarjr.com

Contact Address: Fenerbahce Neighborhood Operator Doctor Cemil Topuzlu Street No:30

Kadikoy / ISTANBUL

Phone Number: 0 (216) 519 66 77

- Method and Legal Reason for Collecting Personal Data

Your personal data is collected by our Company through technical and process methods implemented on different channels such as the website, mobile applications and physical channels, in order to provide you with our commercial services using these channels and to carry out our commercial activities within this framework, within the framework of legal reasons that arise and are implemented based on the relevant legislation, contracts, demands, commercial practices and rules of honesty, in order for our Company to fulfill its legal responsibilities, to fulfill the requirements of the business relationship we have established with you and in this direction, to establish, use and protect the rights we mutually have and to protect the legitimate interests of our Company by observing the fundamental rights and freedoms of the personal data owners with whom we are in a relationship.

How to Evaluate the Data Owner's Consent Regarding the Processing of Personal Data

Regarding the permissions you have given for the processing of your personal data, you can request changes to your personal data processing permissions to our e-mail address info@polarstarjr.com.


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