1.INTRODUCTION

Security and/or protection of your personal data is among our priorities as LEVERS VIRTUAL MAGAZACILIK SANAYİ VE TİCARET LİMİTED ŞİRKETİ (Company/Our Company). With this awareness, as the Company, we attach great importance to the processing and preservation of all kinds of personal data belonging to all persons related to the Company, including those who benefit from our products and services, in accordance with the Law on the Protection of Personal Data No. 6698 (KVK Law). In this respect, the Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Clarification Obligation, published in the Official Gazette No. 30356 on 10 March 2018 by the Personal Data Protection Board as Data Controller as defined in the KVK Law and again with the 10th Article of the KVK Law. In accordance with the (Communiqué), to fulfill the duty of informing the personal data owners during the acquisition of personal data; During the acquisition of personal data by our company, the identity of our Company, the purpose for which the personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method of collecting personal data and the legal reason and the rights of the personal data owner under Article 11 of the KVK Law. We present this information.sunarız.

Expressions such as us and us in this Clarification Text are used to express LEVERS VIRTUAL MAGAZACILIK SANAYİ VE TİCARET LİMİTED ŞİRKETİ, unless otherwise expressly stated.dır.

2.PERSONAL DATA

Personal Data Definition

Within the framework of KVK Law m.3/I(d), personal data means all kinds of information related to identified or identifiable natural persons. In this context, personal data; means any information relating to a specific or identifiable natural person. For instance; your name, surname, TR identity number, address, telephone number, e-mail address, date of birth, IP number you have access to, information about the transactions you have made, etc. information about you is your personal data. In addition, according to the KVK Law; people's race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, clothing, association, foundation, union, etc. data on membership, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, etc. data are special categories of personal data. In this context, anonymous information, anonymized information 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.z.

The Concept of Processing Personal Data

Processing of personal data within the framework of Article 3/I(e) of the KVK Law, obtaining, recording, storing, preserving, changing, rearranging personal data fully or partially automatically or non-automatically provided that it is a part of any data recording system, It refers to all kinds of operations performed on data such as disclosure, transfer, takeover, making available, classifying or preventing its use.

3. SCOPE OF LIGHTING

Identity of Data Controller

In accordance with the KVK Law, the Corporate Identity of LEVERS SANAL MAĞAZACILIK SANAYİ VE TİCARET LİMİTED ŞİRKETİ, who is the Contact Data Supervisor, as the Data Controller refers to 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. The information is as follows:dir:

Collection, Processing and Processing Purposes of Personal Data

Your Personal Data may vary depending on the service, product or commercial activity provided by our Company; automatically or non-automatically, offices, branches, dealers, call center, website, social media channels, mobile applications and similar means orally, in writing or electronically.

K.V.K. Law Article 5.2 and Article 6.3, for the purposes of fulfilling our legal obligations, establishing or performing a contract, fulfilling our legal obligations, establishing, exercising or protecting a right and protecting our legitimate interests without harming your fundamental rights and freedoms, and without your express consent in terms of personal data you have made public. can be processed. Again, your personal data can also be processed within the scope of the purposes specified in this Clarification Text, provided that your express consent is obtained within the scope of Article 5.1 and Article 6.2 of the Law on GDPR. You can procure all of our products without being included in our other membership/loyalty program/programs and memberships, especially the Paul Kenzie membership/loyalty program. On the other hand, since our Paul Kenzie membership/Loyalty program and other loyalty programs and our memberships offer special advantages to their members, you expressly consent to the processing of your Personal Data, except for exceptional circumstances, together with your participation in the programs/membership in order to benefit from the program/membership advantages.

Your collected personal data, the work required by our business units to take advantage of the products and services offered by our Company, the products and services offered by our Company are customized according to your tastes, usage habits and needs, and recommended to you, (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 or employees) evaluation processes, legal compliance process, financial affairs, etc.), Determination and implementation of our company's commercial and business strategies and for the purpose of ensuring the execution of our company's human resources policies, within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law and in accordance with other applicable legal legislation. Truck.

To Whom and For What Purpose the Personal Data Processed Can Be Transferred to Domestic and/or Abroad

Your collected personal data; Our business units carry out the necessary work to benefit you from the products and services offered by our company, customize the products and services offered by our company according to your tastes, usage habits and needs, and offer you the legal and commercial security of our company and those who have a business relationship with our company (by our company Administrative operations for the communication carried out, ensuring the physical security and control of the company's locations, business partner/customer/supplier (authorized or employees) evaluation processes, legal compliance process, financial affairs, etc.), determination and implementation of our company's commercial and business strategies, and our company's human resources for the purposes of ensuring the implementation of its policies,

To the administrative and official authorities that are legally required to be transferred, to the relevant persons and institutions in order to fulfill the legal obligations and as required by the legislation, to independent audit companies, tax consultants and other external professional consultants, lawyers, insurance companies, partners, services received due to legal obligations and within the framework of legal limitations. or to domestic and foreign third parties, our shareholders, business partners, suppliers, legally authorized public institutions and private persons, both within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law, as well as other legal regulations. transferred/can be transferred..

Your collected personal data; To foreign countries declared to have sufficient protection by the KVK Board (Foreign Country with Sufficient Protection) or to foreign countries where the data controllers in Turkey and the relevant foreign country undertake an adequate protection in writing and where the permission of the KVK Board (Sufficient Protection) is available. Foreign Country of the Data Controller Undertaking the Protection) is transferred/can be transferred. Accordingly, our company is/will act in accordance with the regulations stipulated in Article 9 of the KVK Law and other legal regulations.tir.

Method and Legal Reason for Personal Data Collection

Your personal data, our auditing and consultancy services, written/digital applications to our Company's employees, our website, calling our phone numbers, social media, SMS channels, and other verbal, written or electronic media, automatic or non-automatic methods, and our Company's communication with you. It is obtained for the purpose of carrying out our activities, fulfilling our contractual and legal obligations between you and us by providing it through other channels that it communicates with or may contact in the future, and the personal data obtained are stored within legal periods in accordance with the relevant Legislations.

Rights of Personal Data Owners Enumerated in Article 11 of the KVK Law

As personal data owners, if you submit your requests regarding your rights to our Company through the methods set out below in this Clarification Text, our Company will conclude the request free of charge within thirty days at the latest, depending on the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged. In this context, personal data owners, K.V.K. Pursuant to Article 11 of the Law;

To learn whether your Personal Data is processed, to request information about it if it has been processed, to learn the purpose of processing your Personal Data and whether it is used in accordance with its purpose, to know the third parties in the country or abroad to whom your personal data is transferred, to request correction of personal data if it is incomplete or incorrectly processed, Requesting the deletion or destruction of personal data in case of disappearance of the reasons requiring the processing of personal data to be evaluated within the scope of the principles of time and legitimacy, requesting that the personal data be corrected, deleted or destroyed, notifying the third parties to whom the personal data is transferred, analyzing the processed personal data exclusively through automated systems Objection to this result if a result occurs against them, request the compensation of the damage in case their Personal Data is processed unlawfully and they suffer damage due to this reason. they have the rights.

Pursuant to paragraph 1 of Article 13 of the KVK Law, you may submit your request to our Company to exercise your above-mentioned rights in writing or by 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 KVK Law. In this context, the channels and procedures through which you will submit your application in writing to our Company within the scope of Article 11 of the KVK Law are explained below:

Your request, including the necessary information to identify you in order to exercise your above-mentioned rights, and your explanations regarding your right that you request to exercise from the rights specified in Article 11 of the KVK Law; By filling out the form at www.paulkenzie.com, you can send a signed copy of the form to KARADENİZ MAH. OLD EDİRNE ASPHALTI CAD. VENEZIA EVLERI J BLOK NO: 408 J INTERIOR DOOR NO: 3 GAZİOSMANPAŞA/ İSTANBUL personally with the documents identifying your identity, send it through a notary public or other methods specified in the KVK Law, or send the relevant form securely to the address levers@hs01.kep.tr. electronically signed.

In cases where your personal data is processed with explicit consent, we would like to emphasize that if you withdraw your explicit consent, you will be removed from the membership/loyalty program where such explicit consent-based processing is required, and you will not be able to benefit from the advantages you have benefited from thanks to such processing as of the relevant date.