Privacy and Personal Data Protection Policy

1.Introduction

Modaselvim Tekstil San. ve Tic. A.Ş. (“Company”) attaches utmost importance to protect the fundamental rights and freedoms of individuals, especially the privacy of private life regulated in Article 20 of the Constitution, in the protection and processing of personal data. In this context, it pays attention to the protection and processing of personal data in accordance with the law in accordance with the Law on Protection of Personal Data No. 6698 ("Law" or "KVK Law") and acts with this understanding in all its planning and activities.

Our company does not only evaluate the protection and processing of personal data, which is the basis of the privacy of private life, within the scope of compliance with the legislation, but puts the value it places on the basis of its approach. Acting with this awareness, our Company takes all necessary administrative and technical measures to protect and process personal data in accordance with the law.

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2.Aim of Policy

The purpose of the Protection and Processing of Personal Data Policy ("Policy") is primarily in the 20 th article of the Constitution in the protection and processing of personal data, which is fully or partially automated in accordance with the purpose of the Law, or processed non-automatically, provided that it is part of any data recording system. To protect the fundamental rights and freedoms of individuals, including the confidentiality of private life, regulated in the article. In line with the purpose of the policy, it is aimed to ensure full compliance with the legislation in the protection and processing of personal data carried out by our Company and to protect the privacy and data security right of personal data owners.

3.Scope of Policy

This policy was created due to the use of services accessed through Modaselvim. It has been prepared for our services, which are reached via our website www.modaselvim.com, via social media, by calling our order and support line, by e-mail, by filling in return forms or by any means. The policy has been prepared for our customers and potential customers and their employees / officials, our website visitors and will be applied within the scope of the specified persons. The Company informs these personal data owners about the Law by publishing this Policy on its website. This Policy will not be applied to legal entities, in whatever capacity.

This Policy will be applied to the above mentioned persons if our personal data is processed by our Company, which is fully or partially automated or non-automated provided that it is part of any data recording system. In case the data is not included in the scope of "Personal Data" within the scope specified below or if the personal data processing activity carried out by our Company is not in the above mentioned ways, this Policy will not be applied.

4.Collection of Personal Data

When you create your personal data on our site, create a membership account, subscribe via social media, contact our social media accounts, fill out a form on www.modaselvim.com, update your account information or add information, purchase products and / or services, order and we collect, process and store when you make a call / create an order, fill out the return form, contact via e-mail and visit our website.

Your personal data collected when you create a membership account through our site, make membership transactions and contact with social media, fill out a form on www.modaselvim.com, update your account information or add information, purchase products and / or services are listed below:

•Name Surname, e-mail and mobile phone information,

•The products that you added to the cart, you placed your order, the old order information, product size information,

•TR identity number, if not Turkish citizenship information, or tax identification number,

•Date of birth and gender information,

•Address information,

•Member shopping list, price alarm list and stock alarm list,

•Gift Voucher and Point information,

•Financial information such as IBAN, account number received according to your purchase option,

•Member order tracking code, required tracking code and tracking information for cargo operations,

•Information such as profile information, profile photo that you allow in membership transactions made on social media,

•Profile information, shared photos, reviews and requests when communicating via social media,

•Information on the forms on the website, updated user information,

•The addresses given when you buy the product (delivery address, invoice shipping address)

•Information required for identification within the scope of applicable legislation

Your personal data collected in the transactions you make through the order and support line are as follows:

•Telephone call voice recordings,

•Name Surname, e-mail, telephone information for the purpose of creating an order form,

•Invoice and delivery address information

•Product information and size information

•The products that you added to the cart, you placed your order, the old order information, product size information,

•Financial information such as IBAN, account number received according to your purchase option,

•Member order tracking code, required tracking code and tracking information for cargo operations,

•Information such as profile information, profile photo that you allow in membership transactions made on social media,

•Information required for identification, within the scope of applicable legislation

Your personal data collected when you fill in the return form are as follows:

•Return and requested products and size information,

•Name Surname, IBAN of the account holder to be returned

•Returning Name Surname, telephone, address and signature information, reason for return,

Your personal data collected when you communicate via e-mail are as follows:

•E-mail address,

•Request and order information,

•Other information provided by the contact person

You can review the Cookie Policy and Clarification Text on www.modaselvim.com about the data collected when you visit our internet address and mobile application.

You undertake to have express consent to the transfer of such information to us by personal data (such as the delivery and billing address of another person, information about the owner of a card that does not belong to you, bank and account information of third parties).

5.Legal Cause of Collection of Personal Data

Our company does not process personal data without the explicit consent of the person concerned. Personal data can only be processed without the explicit consent of the person concerned, if one of the following conditions exists:

•Clearly prescribed by law;

•Personal data has been made public by the person concerned,

•Providing the processing of personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

•It is mandatory for our company to fulfill its legal obligation,

•Data processing is mandatory for the establishment, use or protection of a right,

•Data processing for the legitimate interests of our Company is mandatory, provided that it does not harm the fundamental rights and freedoms of those concerned.

6.Purpose of Processing Personal Data

Your personal data given above pays utmost attention to be in accordance with the relevant legislation and the requirements of the integrity rule, to be accurate and up to date. Our company clearly and precisely determines the purpose of data processing and ensures that this goal is legitimate. Our company does not process data for any other purpose than those stated. As such, it shows sensitivity in complying with the principle of certainty and clarity in legal transactions and texts, where personal data processing purposes are explained.

Our company pays attention that the processed personal data is suitable for the realization of the specified goals and avoids processing the data that is not related to the realization of the purpose or not needed. Our company does not collect or process personal data for purposes that do not exist and are intended to be realized later. It fulfills the processing conditions set out in the Law as if it is the first time that it begins to process data to meet the needs that may arise later. It also limits the processed data to only what is required to achieve the purpose. Within the scope of proportionality principle, it establishes a reasonable balance between data processing and the desired purpose.

Our company complies with these periods if there is a period foreseen in the relevant legislation for data retention; otherwise, it retains personal data only for the time required for the purpose for which it was processed. If there is no valid reason for further storage of personal data by our company, the data in question is deleted, destroyed or anonymized. Procedures regarding the storage and destruction of personal data are regulated in detail in our Company's Personal Data Retention and Disposal Policy.

In this context, your personal data described above;

•Execution of goods / services sales processes,

•Carry out after-sales support services,

•Carrying out customer relationship management processes,

•Carrying out activities related to customer satisfaction,

•Execution of goods / services / production and operation processes,

•Execution of contract processes

•Execution / audit of business activities,

•Conducting communication activities

•Carrying out logistics activities,

•Carrying out financial and accounting affairs,

•Activities to be carried out in accordance with the legislation

•Carrying out marketing analysis studies,

•Execution of advertising / campaign / promotion processes,

•Conducting supply chain management processes,

•Execution of product / service marketing processes

•Follow-up of requests / complaints,

•Conducting audit / ethical activities,

•Giving information to authorized people / institutions and organizations,

•Creating and following up visitor records,

it is processed and stored for its purposes.

7. 7.Purpose of Transfer The Personal Data And to Whom It is Transfered / to Which Institution

Our company transfers personal data limited to the following purposes within the framework of the conditions specified in Articles 8 and 9 of the Law:

•Execution of Activities in Compliance with Legislation

•Execution of Financial and Accounting Affairs

•Conducting communication activities

•Execution of goods / service sales processes,

•Carrying out customer relationship management processes,

•Carrying out activities related to customer satisfaction,

•Execution of goods / services / production and operation processes,

•Legal Affairs Tracking and Execution

•Execution of Goods / Services Production and Operation Processes

•Conducting marketing analysis studies,

•Execution of advertising / campaign / promotion processes,

•Execution of product / service marketing processes

•Execution of Contract Processes

•Tracking of Claims and Complaints

•Giving Information to Authorized Persons / Institutions and Organizations

•Execution of Management Activities

•Carrying out logistics activities,

•Conducting audit / ethical activities,

Our company can transfer the personal data to the following individuals and organizations limited to the subject groups and data subject to the purpose of the data transfer:

•Business Partners,

•Suppliers,

•Authorized public institutions and organizations (including authorities abroad if necessary)

•Real persons or private legal entities (Cooperated institutions: Cargo companies, Independent audit firms, insurance companies, law firm and banks etc.)

8.Disposal of Personal Data And Storage Time

8.1. Destruction of Personal Data

Without prejudice to the provisions regarding the destruction of personal data in other laws, our Company deletes the personal data it has processed in accordance with this Law and other laws, ex officio or upon the request of the person concerned, in accordance with the Personal Data Retention and Destruction Policy in case the reasons requiring its processing disappear. Destroys or anonymizes.

Deletion of personal data refers to the process of making personal data inaccessible and unusable for the users concerned.

Data destruction; It refers to the process of making the personal data in no way accessible, retrieved and reusable by anyone.

Anonymizing data, masking personal data, variable extraction, generalization etc. refers to the process of making it unrelated to an identifiable or identifiable natural person under any circumstances, even if it is matched by other techniques.

8.2. Storage Time of Personal Data

Our company stores personal data in accordance with the periods stipulated in laws and other legislation. If there is no retention period stipulated in laws and other legislation, personal data is stored for the time required for the purpose of processing that personal data in accordance with our Company's Personal Data Retention and Destruction Policy, and then deleted, destroyed or anonymized within the framework of periodic destruction periods.

9.Lighting And Rights of The Contact Person

In accordance with Article 10 of the KVK Law, our company enlightens the relevant persons during the acquisition of personal data. In this context, the identity of the Company representative, if any, will be clarified for what purpose the 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 that the personal contact holds.

9.1. Conditions For Which Policy And Law Will Not Be Fully or Participated

The provisions of this Policy and Law will not be applied in the following cases:

•Processing of personal data by real persons within the scope of activities related to him or his family members living in the same residence, provided that they are not given to third parties and obligations regarding data security are complied with,

•Processing personal data for purposes such as research, planning and statistics by making it anonymous with official statistics,

•Processing personal data for art, history, literature or scientific purposes or within the scope of freedom of expression provided that they do not violate national defense, national security, public security, public order, economic security, privacy or personal rights, or constitute a crime,

•Processing personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to provide national defense, national security, public security, public order or economic security,

•Processing of personal data by judicial authorities or enforcement authorities regarding investigations, prosecutions, trials or enforcement proceedings.

Subject to the purpose and basic principles of this Policy and Law and proportionally, the 10th regulator of the data controller's lighting obligation, the 11th regulator of the data subject and the 16th regulator of the obligation to register in the Data Controllers, with the exception of the right to claim the loss, will not be applied if:

•Personal data processing is necessary for the prevention of crime or for criminal investigation,

•Processing of personal data publicized by the person concerned,

•The fact that personal data processing is necessary for the disciplinary investigation or prosecution by executing auditing or regulatory duties and by disciplinary investigation or prosecution by authorized and authorized public institutions and organizations and public institutions on the basis of the authority given by law,

•Personal data processing is necessary for the protection of the State's economic and financial interests in relation to budget, tax and financial matters.

9.2. Rights of The Related Person in Accordance to The KVK Law

Our company notifies its rights to the relevant people in accordance with Article 10 of the Law, provides guidance on how to use these rights and carries out the necessary internal functioning, administrative and technical arrangements for all these. The rights of persons whose personal data are processed pursuant to Article 11 of the Law are listed below:

•Learning whether personal data is processed,

•If personal data is processed, requesting information about it,

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

•To know the third parties to whom personal data are transferred domestically or abroad,

•Requesting correction of personal data if it is incomplete or incorrectly processed,

•Request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the Law,

•Requesting the notification (correction and destruction) of the transactions made in accordance with the clauses (d) and (e) of Article 11 of the Law to third parties to whom personal data are transferred,

•To object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems,

•Requesting the elimination of the damage in case the personal data is damaged due to the illegal processing of personal data.

Requests and applications regarding the implementation of the Law “Yenibosna Merkez, Oruç Reis Sokağı No:5, 34197 Bahçelievler/İstanbul”can be delivered in writing or sent via Notary or in electronic form by using a registered electronic mail (KEP) address (modaselvim@hs01.kep.tr), using a secure electronic signature or mobile signature.

In requests and applications,

•Name, surname and signature if the application is in writing,

•For citizens of the Republic of Turkey T. C. identification number, nationality for foreigners, passport number or identity number, if any,

•The place of residence or business address that is the basis of the notification,

•Electronic mail address, telephone and fax number, if any,
Demand

must be present.

Information and documents related to the subject should be attached to the application.

Our company finalizes the requests in the application free of charge as soon as possible and within thirty days at the latest depending on the nature of the request. However, in case the transaction in question requires a cost, the fee in the tariff determined by the Board may be charged.

Our company can accept the request sent to it, as well as refuse it by explaining its justification and informs the relevant person in writing or electronically. In case the request in the application is accepted, our Company fulfills its requirement as soon as possible and informs the concerned person. In case the application is caused by the fault of our Company, the fee collected is returned to the relevant person.

In case the application is rejected, the answer given is insufficient or the application is not answered in due time; the person concerned has the right to complain to the Board within thirty and possibly sixty days from the date of application.