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    BESTEL TECHNOLOGICAL PRODUCTS IND. TRD. INC. CLARIFICATION TEXT ABOUT GATHERING, PROCESSING AND PROTECTING THE PERSONAL DATA

    GENERAL INFORMATION AND DEFINITIONS

    This text has been prepared within the scope of Article 10 of the Personal Data Protection Law No: 6698 to fulfill the disclosure obligation. The definitions of the following terms in the information text refer to the definitions specified in the Regulations and Communiques issued regarding Law No. 6698 and are as follows:

    • Personal data: Any information relating to an identified or identifiable natural person,
    • Processing of Personal Data: Any operation which is performed upon personal data such as collection, recording, storage, preservation, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization or blocking its use by wholly or partly automatic means or otherwise than by automatic means which form part of a filing system,
    • Data Subject: Natural person whose personal data is processed,
    • Explicit Consent: Freely given specific and informed consent,
    • Anonymization: Rendering personal data by no means identified or identifiable with a natural person even by linking with other data,
    • Data Controller: Natural or legal person who determines the purposes and means of the processing of personal data, and who is responsible for the establishment and management of the filing system.
    • Filing System: Any recording system through which personal data are processed by structuring according to specific criteria,
    • Contact Person: Natural person notified by the data controller which is a natural and legal person established in Turkey and by the representative who represents the data controller which is a natural and legal person not established in Turkey during the registration with the Registry for communicating with the Authority relating to obligations within the scope of the Law and secondary legislation to be prepared under the Personal Data Protection Law
    • Personal Data Storage and Disposal Policy: Policy which data controllers issues as a basis for erasure, destruction, and anonymization of personal data and determination of maximum storage period for the purpose for which personal data are processed.

    INFORMATION ABOUT THE DATA CONTROLLER

    In legal entities, the data controller is the legal entity. The data controller is responsible for its obligations under the Law of legal persons resident in Turkey, representing the entity empowered body/person or persons are fulfilled with ingenuity. The body authorized to represent the legal entity, in terms of the implementation of the Law, may assign one or more persons to the obligations to be imposed. This assignment does not remove the liability of the legal entity under the provisions of the Law.

    CLARIFICATION OBLIGATIONS

    Bestel Inc. is obligated to inform the data subjects while collecting the personal data regarding

    • The identity of the data controller and if any, its representative,
    • The purposes for which personal data will be processed,
    • The persons to whom processed personal data might be transferred and the purposes for the same,
    • The method and legal cause of collection of personal data,
    • The rights of the natural person whose data is processed.

    Also, regarding the security of data, the data controller shall take all necessary technical and organizational measures for providing an appropriate level of security to

    • Prevent unlawful processing of personal data,
    • Prevent unlawful access to personal data,
    • Safeguard personal data.

    In defiance of the provisions of Law No. 6698 Bestel Inc. does not disclose the personal data, obtained by conducting to ensure the enforcement of the provisions of Law No. 6698 in its institution or organization, to anyone else or does not use it for purposes other than processing.

    PERSONAL DATA TO BE PROCESSED

    The personal data to be processed by Bestel Inc. is as follows and new information may be added and/or modified if required and/or required by law.

    Personal data subjected to data processing is as follows:

    • Personal information such as name, surname, identity number, date of birth, etc.
    • The contact information such as an address, phone, fax, email, etc.
    • Information about tax office and tax number
    • Information about the job and educational status

    METHODS TO GATHER PERSONAL DATA

    In addition to the related person directly, personal data can be gathered indirectly depends on the purpose, besides online marketplaces, online forms, branches, and business partners. The data provided by our customers who take any action in websites or mobile applications of Bestel Inc. are processed by Bestel Inc. under the consent of our customers and the provisions of the legislation.

    The websites registered as www.kilicoglu.com.tr, www.megaroncati.com.tr, and www.catiustasi.com.tr owned by Bestel Inc., are using cookies.

    Cookie; is a small file or part of a file stored on a World Wide Web user's computer, created, and subsequently read by a website server, and containing personal information (such as a user identification code, customized preferences, or a record of pages visited).

    To better serve its visitors and within the scope of its legal obligation, online platforms owned by Bestel Inc. will collect, process, share your browsing information with third parties, and store it securely, without being used outside the purposes and scope specified in the Description text about the Protection of Personal Data.

    To create a summary about your preferences; www.megaroncati.com.tr, www.kilicoglu.com.tr, and www.catiustasi.com.tr are storing the cookies, log files, empty gif files, and/or information gathered by third-party sources. Also, can track your browsing history and usage history to provide personalized promotions, advertisements, marketing offers, and improving the content and experience of website/mobile application.

    www.kilicoglu.com.tr, www.megaroncati.com.tr, www.catiustasi.com.tr can match the different information about you by using online and offline information gathers and uses alongside the information gathered from the third party resources.

    Bestel Inc. is using session cookies and persistent cookies on its platforms (www.kilicoglu.com.tr, www.megaroncati.com.tr, and www.catiustasi.com.tr). A session cookie will be expired when you close the browser. A persistent cookie can be stored on your device for a long time. By following the steps in the “help” section of your browser or visiting “www.allaboutcookies.org” or www.youronlinechoices.eu, you can remove persistent cookies and block either persistent cookies or session cookies. If you block persistent cookies or session cookies, you can keep using the mobile application or the website, but you may not be able to access all functions of the website or your access may be limited.

    HOW BROWSER COOKIES ARE USED

    Cookies of www.kilicoglu.com.tr, www.megaroncati.com.tr and www.catiustasi.com.tr are used to remember your preferences and personalize your experience on the usage of website/mobile application. This usage contains the cookies that save your password and keep your session open to help you to prevent the loss of time because of writing the password multiple times each time you visit the website and the cookies that help us to remember you in further visits to our websites or mobile applications. To analyze the users browsing www.kilicoglu.com.tr, www.megaroncati.com.tr, and www.catiustasi.com.tr, Google Analytics cookies are used.

    To identify how you use the website/mobile app, including monitoring the location from where you are connected to www.kilicoglu.com.tr, www.megaroncati.com.tr, and www.catiustasi.com.tr, which content you view on the website/mobile app, and how you use the website/mobile app such as the duration of your visit.

    To offer you content and advertising that is more matching to you and your areas of interests, in other words, for targeted advertising/promotion. In this way, when you use www.kilicoglu.com.tr, www.megaroncati.com.tr, and www.catiustasi.com.tr, it provides you content and advertising that are more matching for you, and does not provide you content or offers that you previously specified that you are not interested in.

    HOW DOES THE WEBSITE USE THIRD-PARTY COOKIES FOR ADVERTISING AND RE-TARGETING?

    www.kilicoglu.com.tr, www.megaroncati.com.tr, and www.catiustasi.com.tr websites may also use cookies to activate “advertising technology” through search engines to provide you with advertising it believes will interest you when you visit the website and/or the other websites which places an ad related to our websites. Advertising technology uses information about your previous visits to the website/mobile app, and the other website/mobile apps in which our websites place an ad, to provide you member-specific advertising. When offering these ads, a unique third-party cookie can be installed on your browser to be able to recognize you. By following the steps in the “help” section of your browser or visiting “www.allaboutcookies.org” or www.youronlinechoices.eu, you can remove persistent cookies and block either persistent cookies or session cookies.

    THE PURPOSE OF PROCESSING THE PERSONAL DATA

    Bestel Inc. is processing the personal data in the scope of purposes listed below. These purposes are:

    • Fulfillment of the obligations about public claims, tax, etc. in the scope of Tax laws, Turkish Commercial Code Act No. 6102, and the other legislative regulations
    • Taking measures to protect the consumer rights within the scope of No: 6502 Law on Consumer Protection,
    • Receiving orders about the products of related persons on Bestel Inc., sales and deliveries of the products to related persons, collection of the price, providing after-sale service related to the product sold, measuring the customer satisfaction, and if any, gathering and considering the suggestions and complaints about the related product,
    • Drawing up the distance sales agreement about the shopping on online marketplaces, verifying the identity of the related person,
    • Improving the quality of service
    • Engaging in a campaign, advertisement, promotion, and introduction besides providing information, about the product or services

    TRANSFER OF PERSONAL DATA

    Bestel Inc. does not transfer the personal data gathered under data processing purposes without the explicit consent of the related person. Bestel Inc. can transfer the personal data to not only allowed/legally compelled persons, institutions, and/or organizations, but also to the public entities, which has the rights to obtain the personal data, like the Turkish Revenue Administration, Turkish Employment Agency, Social Security Institution, Financial Crimes Investigation Board, Interbank Card Center, Credit Bureau, domestic/foreign subsidiaries of Bestel Inc., companies act as a branch, institutions, and organizations under the cooperation about program/business partnership, PTT branches, consultancy or independent auditing providers, under the condition of the rights of the related person according to Law No: 6698.

    GETTING THE EXPLICIT CONSENT OF RELATED PERSON ABOUT THE PROCESSING OF PERSONAL DATA

    Personal data gathered to process by Bestel Inc., can be processed by getting the explicit consent of the related person in accordance with Law No. 6698. Explicit consent means freely given specific or informed consent of the related person.

    In accordance with Article 5/2 of Law No. 6698, personal data may be processed without obtaining the explicit consent of the data subject if one of the below conditions exist:

    • It is expressly permitted by any law.
    • It is necessary to protect the life or physical integrity of the data subject or another person where the data subject is physically or legally incapable of giving consent.
    • It is necessary to process the personal data of parties of a contract, provided that the processing is related to the execution or performance of the contract.
    • It is necessary for compliance with a legal obligation to which the controller is subject to.
    • The relevant information is revealed to the public by the data subject herself/himself.
    • It is necessary for the institution, usage, or protection of a right.
    • It is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed.

    DATA RETENTION PERIOD

    Bestel Inc. destructs the personal data (deleting, destroying, or anonymizing), after the expiration of the maximum regulatory detention duration, within the scope of related Laws or the other regulations, or the expiration of the purpose of processing the personal data.

    RIGHTS OF DATA SUBJECT

    Everyone, in connection with herself/himself, has the right to;

    • Learn whether her/his personal data has been processed.
    • Request information as to processing if her/his data have been processed.
    • Learn the purpose of the processing of personal data and whether data are used under their purpose.
    • Know the third parties in the country or abroad to whom personal data have been transferred.
    • Request rectification in case personal data is processed incompletely or inaccurately.
    • Request deletion or destruction of personal data within the framework of the conditions set forth under article 7.
    • Request notification of the operations made as per indents (d) and (e) to third parties to whom personal data has been transferred.
    • Object to occurrence of any result that is to her/his detriment through the analysis of personal data exclusively through automated systems.
    • Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data.

    by applying to the data controller.

    APPLICATION TO DATA CONTROLLER

    Every data subject can apply to the data controller about their right within the scope of Law No. 6698 Article 11. Data subjects can take advantage of this right by only applying in Turkish. Data subjects can request their applications from Bestel Inc. through one of the listed channels below. Accordingly, data subjects can apply:

    • In written form
    • Through Registered Electronic Post (REM),
    • Through secure e-signature or mobile signature
    • Through email address registered in the system of Bestel Inc. or the notified by the related person.

    On applications, the information listed below is required;

    • Name, surname and, if in written form, signature
    • Personal identity number for the citizen of Turkish Republic; passport number, nationality or, if available, identity number for non-citizens,
    • Residential or business address for notices,
    • If available; electronic mail address, phone, or fax number for notices,
    • The subject of the request.

    Information and the documents related to the subject shall be attached to the application. Application requests can be made by using the “Application Form”. Related persons can make an application through contact channels described in the “2-INFORMATION ABOUT THE DATA CONTROLLER” section in this document.

    Bestel Inc. can conclude the applications without any charges as soon as possible or within 30 business days, depends on the qualifications of the application. Nevertheless, the application can be tollable within the scope of “The Communiqué on Procedures and Principles for Compliance with the Obligation to Inform” Article 7. If the application is down to the data subject, the cost for the application will be refunded to the related person.

    CHANGES AND UPDATES

    This acknowledgment text is prepared within the scope of data processing purposes and policies of Bestel Inc., and Law No 6698 besides Regulation and Communiqués published in the scope of the same Law. This acknowledgment text is amendable by the future changes on the data processing purpose or the policy of Bestel Inc. and/or the related legal legislation. The latest acknowledgment text can be accessed from www.kilicoglu.com.tr.

    Bestel Technological Products Industry and Trade Inc.

    Number of the Central Registry Number System (CRNS – MERSIS): 0166002970000012

    Address: Industrial Zone, 11th Street, Eskisehir

    Phone: +90 444 26 11 - +90 222 236 11 41

    Fax: +90 222 236 11 45

    Email: kilicoglu@kilicoglu.com.tr

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