Information Notice on Processing of Personal Data

INFORMATION NOTICE FOR THE LAW ON PROTECTION OF PERSONAL INFORMATION AVAILABLE ON ELLEAIR.COM.TR

ELLEAIR INTERNATIONAL TURKEY takes the possible highest level of security measures in order to ensure that your personal data is collected, stored and disclosed as required by the laws, and also to protect your privacy.

We intend to inform you about the methods for collection of your personal data and the purposes of processing thereof as well as the recipients and legal reasons thereof, and your rights with respect thereto in the most transparent manner in accordance with Section 10 of the "Law Nr. 6698 on Protection of Personal Data" and based on your satisfaction.

a) Data Controller

Your personal data may be collected and processed by ELLEAIR INTERNATIONAL TURKEY KISISEL BAKIM URUNLERI URETIM ANONIM SIRKETI ("the COMPANY"), acting in the capacity of data controller, as per the Law Nr. 6698 on Protection of Personal Data ("the Law Nr. 6698"), as described below.

b) Purpose of Processing of Personal Data

The COMPANY may collect the personal data of its employees and customers, and the visitors of its website or workplace, or the potential customers, including the identity, contact details, customer transaction, process security, legal transactions and compliance, marketing and sales information and consumption and behavioral habits.

Your personal data collected shall be processed as per the purposes and terms of processing of the personal data as prescribed under Sections 5 and 6 of the Law Nr. 6698 for the purpose of:

- Providing the COMPANY products and services to you, and fulfilling our obligations to you, and issuing the records and documents, and complying with the information storage, reporting, information, tax and other obligations as prescribed under the local and international legal regulations;

- Providing you with the special advertisements, campaigns, advantages and other benefits with respect to the sales and marketing activities that will be carried out in order to improve the quality of the services and products;

- Establishing communication in order to transmit the necessary information to you with respect to the information processing requirements, system structure, the requirement for information processing support services received;

- Carrying out the activities for traffic measurement, statistical analysis, segmentation/profiling and CRM that will be performed with respect to the sales and marketing activities;

- Measuring and improving the customer satisfaction, and managing the complaints, and receiving your opinions and suggestions with respect to the new services and products, and receiving your notifications with respect to any problem/error, and informing you about the products and services as well as about your complaints and requests;

- Managing your website membership with respect to useful advices and surprise gifts, and ensuring that the gifts are sent to you by providing the logistics cooperation with the third parties, and recommending the products and services that may be of interest to you, and the online behavioral advertising and marketing, and the customer portfolio management, and measuring and improving the service quality, and the communication, optimization, inspection, and the risk management and control, and the promotion, analysis, and determination of the interests, and scoring, profiling, marketing, sales, advertising, communication;

- Carrying out the competition processes through the social media accounts of the COMPANY;

- The comparative product and/or service offer, modeling, current or new product activities and/or developments, and being used with respect to any and all kinds of products and services that will be offered to you under the law and relevant regulations, which regulate the works/activities as specified under the articles of association of the COMPANY that is the subject of your disclosure of your personal data to the COMPANY;

- Complying with the information storage, reporting, informing obligations as prescribed by the official institutions, and fulfilling the requirements as specified under the agreements, and fulfilling the legal obligations of the COMPANY with respect to use of such services;

- Reviewing, assessing and responding the requests received from the official authorities or you.

c) Recipients of Personal Data Processed and Purposes of Transmission

Provided that it is limited to achievement of the purposes as specified above, your personal data collected may be transmitted to:

- The holding, by which the COMPANY is bound, and the subsidiaries, business partners and shareholders thereof;

- The persons or organizations permitted by provisions prescribed under the Turkish Commercial Code, Turkish Code of Obligations and other regulations;

- The public institutions and organizations, administrative authorities and legal authorities;

- The real or legal persons, from whom we procure service in order to perform the product/service comparison, analysis, assessment, advertising and to achieve the purposes as specified above, and with whom we cooperate for such purposes, and to the institutions and organizations, which are the program partner, and to the institutions that we have contracted in order to send the messages we send to our customers, and to the courier companies that deliver the orders placed from our online store to you; in accordance with the personal data processing terms and requirements and purposes as prescribed under the Sections 8 and 9 of the Law Nr. 6698.

d) Method and Legal Reason(s) for Collection of Personal Data

Your personal data shall be collected by the COMPANY through the channels such as our stores , website and mobile application, contact form, field of your story, call centers, social media accounts verbally, in writing or electronically, or mainly through the other channel that will be established/may be created in the future;

in a manner to be limited to existence of the legal reasons with respect to the fact that the agreement is performed for the purposes, as specified above, in accordance with the statutory regulations, and that it has explicitly been prescribed under the law, and that your personal data has been made public by you, and that it is mandatory to establish, exercise and protect the right, which will be granted to you, and that it is mandatory for the COMPANY to fulfil its legitimate interests and legal obligations in a manner not to cause any damage to your fundamental rights and freedoms.

e) Rights of the Personal Data Owner under the Section 11 of the Law Nr. 6698

In the event that you, as the personal data owners, submit your requests for your rights to the COMPANY by means of the methods as specified below, then the COMPANY shall conclude the request as soon as possible and within a period of thirty days, at the latest, based on the nature of the request. It shall not be charged for the reply up to ten pages. A transaction fee of 1 Turkish Lira shall be charged for each page more than ten pages. In the event that the requests are responded through any recording medium such as CD, flash drive, etc., then the fee, which may be claimed by our COMPANY, shall not exceed the cost of the recording medium. Accordingly; the personal data owners shall be entitled;

To inquire whether their personal data has been processed, or not; and
To ask for information about their personal data, if it has been processed; and
To find out the purpose of processing of your personal data and whether they have been used for the purposes intended, or not;
To know about the national and international third parties, to whom your personal data is disclosed;
To ask for correction of any imperfect or inaccurate data, in case of any imperfect or inaccurate processing thereof, and to ask for providing information about the processes, performed for such purpose, to the 3rd parties, to which such personal data has been transmitted; and
To ask for deletion or disposal of such personal data if the reasons requiring processing of such data have disappeared although such personal data has been processed in accordance with the provisions prescribed under the Law Nr. 6698 and the other applicable laws, and to ask for providing information about the processes, performed for such purpose, to the 3rd parties, to which such personal data has been transmitted; and
To raise any objection against occurrence of any consequence against you by analyzing your data processed by means of the exclusively automatic systems;
To claim for compensation of any and all damages and/or losses that they might have incurred in the event that such personal data has been processed in breach of the law.

You may submit your request for exercise of your rights, as specified above, in Turkish and in writing, or by using the registered electronic mail (REM) address, secure electronic signature, mobile signature or the electronic mail address, which has previously been provided to the COMPANY, and which is registered in our system, in accordance with the 1st paragraph of the Section 13 of the Law Nr. 6698 and the Communiqué Nr. 30356 on Procedures and Principles of Filing an Application with the Data Controller, dated 10.03.2018. The COMPANY shall be entitled to identify you before replying.

Your application is required to include:

Your full name, and your signature, in case of written applications;
Your Republic of Turkey ID number for the nationals of the Republic of Turkey; and your passport number, if you are a foreign national; or your personal ID number, if available;
Your residential or workplace address for notification purposes;
Your e-mail address, telephone and fax number for notification purposes, if available;
The subject matter of your request, and any information and documentation in relation to the subject, if available, are required to be attached to the application.

You may submit your applications, in writing, to ELLEAIR INTERNATIONAL TURKEY KISISEL BAKIM URUNLERI URETIM ANONIM SIRKETI situated at Balcik Koyu Pelitliyolu Cd.No 138 Gebze/Kocaeli, acting in the capacity of the data controller, by attaching the necessary documents thereto. You can find the application form here.

You may also submit your applications, by e-mail, through eitr@daiogroup.com.

Any and all information and documentation, depending on the nature of your request, are required to be submitted to us perfectly and accurately. In the event that such information and documentation are not submitted properly, then some problems might arise during performance of the researches, to be carried out upon your request, by the COMPANY perfectly and properly. In such case, the COMPANY declares that it reserves its legal rights. Therefore, your application is required to be sent perfectly in a manner to include any and all information and documentation to be sought depending on your request. It shall be entitled:

To inquire whether their personal data has been processed, or not; and
To ask for information about their personal data, if it has been processed; and
To find out the purpose of processing of your personal data and whether they have been used for the purposes intended, or not;
To know about the national and international third parties, to whom your personal data is disclosed;
To ask for correction of any imperfect or inaccurate data, in case of any imperfect or inaccurate processing thereof, and to ask for providing information about the processes, performed for such purpose, to the 3rd parties, to which such personal data has been transmitted; and
To ask for deletion or disposal of such personal data if the reasons requiring processing of such data have disappeared although such personal data has been processed in accordance with the provisions prescribed under the Law Nr. 6698 and the other applicable laws, and to ask for providing information about the processes, performed for such purpose, to the 3rd parties, to which such personal data has been transmitted; and
To raise any objection against occurrence of any consequence against you by analyzing your data processed by means of the exclusively automatic systems;
To claim for compensation of any and all damages and/or losses that they might have incurred in the event that such personal data has been processed in breach of the law.

Your application is required to include:

Your full name, and your signature, in case of written applications;
Your Republic of Turkey ID number for the nationals of the Republic of Turkey; and your passport number, if you are a foreign national; or your personal ID number, if available;
Your residential or workplace address for notification purposes;
Your e-mail address, telephone and fax number for notification purposes, if available;
The subject matter of your request, and any information and documentation in relation to the subject, if available, are required to be attached to the application.

You may submit your applications, in writing, to ELLEAIR INTERNATIONAL TURKEY KISISEL BAKIM URUNLERI URETIM ANONIM SIRKETI situated at Balcik Koyu Pelitliyolu Cd.No 138 Gebze/Kocaeli, acting in the capacity of data controller, by attaching the necessary documents thereto. You can find the application form here.

You may also submit your applications, by e-mail, through eitr@daiogroup.com.