PERSONAL DATA PROCESSING AND PROTECTION POLICY

Sinba Textile Imp. expulsion Industry and Trade. Ltd. Şti (hereinafter referred to as the " Company ") attaches great importance to the confidentiality and protection of personal data. The Company makes the necessary efforts to protect the personal data processed by the Company in the best possible way within technical and administrative possibilities.

This Personal Data Protection Policy (hereinafter referred to as " KVK Policy ") covers data that is processed or can be associated with natural persons only and directly by and under the control of the Company. Processing of Personal Data; It refers to all kinds of operations performed on the data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, making available, classifying or preventing the use of the said data, in whole or in part, by automatic or non-automatic means.

This KVK Policy has been prepared to determine the Company's practice regarding which personal data of natural persons are processed in what way, for what purpose and for how long within the scope of the activities carried out within the Company, and to enable individuals to access this KVK Policy and obtain information about the Company's practice and the rights they have. .

HOW IS PERSONAL DATA OBTAINED?

Personal data; Sales, marketing, advertising, etc. between you and the company. as a result of the activities and "In what circumstances and for what purposes does the Company process your personal data?" It is obtained by the following methods for the purposes stated under the heading and the implementation of existing Company policies and procedures:

1. It is shared directly by you ; All kinds of information, documents, etc. can be obtained by contacting the company. Data can be obtained by sharing the information with the person upon request.
2. It can be provided due to contractual relationship ; Sales, distance sales, etc. concluded between you and the company. It includes the information provided in mandatory situations related to the establishment, implementation and termination of contracts and the sales process, as well as all the data you provide during the continuation of the contractual relationship. You are deemed to have accepted the accuracy and up-to-dateness of the personal data in question.
3. Registration and account information: If you open an account to use the service offered by the Company, to create this account; You may be required to provide "Personal Data" such as name-surname, date of birth, TR ID number, e-mail address and password.
4. Don't pay; Due to the service it offers, the Company may provide financial account information such as credit card information when making payments by real persons. Such information is not processed or stored by the Company. However, the current summary transaction information may be processed by the Company without including credit card and/or bank account information regarding the transaction in question.
5. Customer service; We may process your Personal Data necessary for all your communications with our customer support team.
6. Location information from mobile device; We may process your precise location information if your device settings are enabled and you allow it to be shared with us.
7. Advertising, promotion, publicity etc. available for activities; Personal data is processed for advertising or market and public opinion research only if the purpose of collecting this information is compatible with these purposes and if the individuals have their express written consent. If information is collected only for advertising purposes, data owners may not provide this information. The data subject is informed of his freedom to provide his information for this purpose. Within the scope of giving this consent, the data owner can choose between appropriate communication channels such as postal mail, e-mail or telephone.

FOR WHAT PURPOSES ARE PERSONAL DATA PROCESSED ?

The company processes personal data primarily within the scope of the explicit consent received from data owners. In addition, in cases clearly stipulated in the legislation; In case it is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract; In cases where processing is necessary for the Company to fulfill its legal obligations; In cases where personal data is made public by the relevant person himself; In cases where data processing is necessary for the establishment, exercise or protection of a right and if data processing is mandatory or necessary for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the employee, employee data is processed limited to the legitimate purposes in question.

In addition, personal data; It is processed in line with the purposes stated in this KVK Policy and the employment contract and for the purpose of implementing the Company's policies and procedures, in accordance with the Personal Data Protection Law No. 6698 and for the purposes detailed below.

The Company's main purposes/reasons for processing employee data are as follows:

Your personal data; Fulfilling, sustaining, executing and developing our activities, advertising, promotion, campaigns and similar activities for services and products in accordance with all relevant laws and regulations such as the Turkish Commercial Code, the Law on Consumer Protection, the Turkish Code of Obligations, etc. regarding all kinds of products we provide services or sell. making, fulfilling the requirements of the contracts that have been or will be issued, planning, statistics, customer satisfaction studies, ensuring security, maintaining the legal and commercial security of people who have business relations with our company, business partnership, customer evaluation processes, legal and financial affairs and similar commercial activities. and determination and implementation of business strategies, human resources, execution of accounting policies, ensuring physical security and auditing, compliance with domestic and international legislation, compliance with information transfer, storage and reporting obligations required by public institutions or other authorities, providing you with better and more reliable service. In order to be given and maintained uninterruptedly, it is processed within the conditions and purposes specified in Articles 5 and 6 of the KVK Law.

Your Personal Data may be collected verbally, through automatic or non-automatic methods, through our company headquarters, our website, social media channels, parties with whom we have a business relationship and/or from which our company receives services as a complement to its activities, service and intermediary service providers, contracted organizations and other similar channels. can be collected in writing or electronically.

WITH WHOM IS PERSONAL DATA SHARED?

Your Personal Data will not be shared with third parties without your explicit consent, except for the scope specified in this Privacy Policy, except for the exceptional cases stipulated in the legislation.

The company may transfer personal data to the following persons and institutions for certain purposes;

a) To our company's business partners, on a limited basis, in order to ensure that the purposes of establishing the business partnership are fulfilled,

b) To the company's suppliers and service providers, on a limited basis, in order to ensure that the services that the Company outsources from the supplier and necessary to carry out the Company's commercial activities are provided to the Company,

c) To the Company Shareholders, limited to the design of strategies regarding the commercial activities of the Company and audit purposes in accordance with the relevant legislation,

d) To legally authorized public institutions and organizations, limited to the purpose requested by the relevant public institutions and organizations within their legal authority,

e) To legally authorized private legal persons, limited to the purpose requested by the relevant private law persons within their legal authority.

f) Upon the request of judicial authorities or in cases where it is required by applicable laws, regulations, other legal regulations, court decisions and prosecutorial requests, or in case of restructuring, sale, redistribution of assets, merger, disposal or other changes of control of the Company or It is possible to disclose or transfer if the financial situation of the Company changes. These recipients may be located in the Americas (including the United States), Europe, Asia and other regions where data protection legislation differs from our country. Your data held electronically can only be kept under the control and supervision of the Company within another legal entity from which the Company receives services. In this regard, it may be possible to keep personal data on computers located outside the Company and access records from these computers.

Personal data by the company; Once the foreign countries with adequate protection are declared by the Board, it will only be transferred to these countries. For countries declared to lack adequate protection; Personal data will be transferred in cases where the data controllers in Turkey and the relevant foreign country undertake to provide adequate protection in writing and the Board has permission or the data owner gives approval.

WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

Personal Data owners may apply to the Company to:

• Learning whether personal data is processed or not,
• Requesting information if personal data has been processed,
• Learning the purpose of processing personal data and whether they are used for their intended purpose,
• Knowing the third parties to whom personal data is transferred at home or abroad,
• Requesting correction of personal data if they are incomplete or incorrectly processed,
• Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in the relevant legislation,
• To request that correction, deletion and destruction operations carried out in accordance with the relevant legislation be notified to third parties to whom personal data has been transferred,
• Objecting to the emergence of a result that is unfavorable to the individual by analyzing the processed data exclusively through automatic systems,
• Requesting compensation for the damage in case of damage due to illegal processing of personal data,

has the rights.

Data owners can submit their above-mentioned requests on the company website. Application form may be forwarded to the Company in writing. In accordance with the above-mentioned requests, the Company may provide a reasoned positive/negative response in writing or digitally.

It is essential that no fee is charged for the necessary procedures regarding the requests. However, if the transactions require a cost, it is possible to request a fee based on the tariff determined by the Personal Data Protection Board (“Board”) in accordance with Article 13 of the Personal Data Protection Law No. 6698.

PERSONAL DATA STORAGE PERIOD

Unless a longer storage period is required or permitted by the relevant legislation, the Company will store your Personal Data for the period necessary to fulfill the purposes outlined in this Personal Data Processing and Protection Policy and until the data owner requests the deletion of their data. .

ENSURING PERSONAL DATA SECURITY

The company is committed to protecting personal data in a safe and reasonable manner. It carries out technical and administrative measures using various methods and security technologies to ensure the appropriate level of security in order to prevent unlawful processing and access of personal data and to ensure the preservation of personal data. In addition, special personal data are processed by taking adequate measures determined by the Board.

The Company will not disclose the personal data it has obtained to anyone else, contrary to the provisions of this KVK Policy and the Personal Data Protection Law No. 6698, and will not use it for purposes other than processing. The Company declares that if personal data is shared in accordance with the provisions of this KVK Policy, it will request that the sharing channels in question comply with the commitments set out under this article.

KVK POLICY CHANGES

The Company may update and change the provisions of this KVK Policy at any time. The updates and changes made by the Company with this KVK Policy will be valid from the date of publication on the Portal.

Contact information

Merkez Mahallesi Çifte Cevizler Cad.

No:23 Saruhan Plaza K:2, D:42

TR 34381 Şişli / ISTANBUL - Türkiye

Tel: +90 212 231 31 27

Tel: +90 212 231 31 24

Fax: +90 212 231 31 27

info@kameya.com

Validity Date: 31.12.2021

Last Update Date: 01.01.2021

PERSONAL DATA PROCESSING AND PROTECTION POLICY

Sinba Textile Imp. expulsion Industry and Trade. Ltd. Şti (hereinafter referred to as the " Company ") attaches great importance to the confidentiality and protection of personal data. The Company makes the necessary efforts to protect the personal data processed by the Company in the best possible way within technical and administrative possibilities.

This Personal Data Protection Policy (hereinafter referred to as " KVK Policy ") covers data that is processed or can be associated with natural persons only and directly by and under the control of the Company. Processing of Personal Data; It refers to all kinds of operations performed on the data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, making available, classifying or preventing the use of the said data, in whole or in part, by automatic or non-automatic means.

This KVK Policy has been prepared to determine the Company's practice regarding which personal data of natural persons are processed in what way, for what purpose and for how long within the scope of the activities carried out within the Company, and to enable individuals to access this KVK Policy and obtain information about the Company's practice and the rights they have. .

HOW IS PERSONAL DATA OBTAINED?

Personal data; Sales, marketing, advertising, etc. between you and the company. as a result of the activities and "In what circumstances and for what purposes does the Company process your personal data?" It is obtained by the following methods for the purposes stated under the heading and the implementation of existing Company policies and procedures:

1. It is shared directly by you ; All kinds of information, documents, etc. can be obtained by contacting the company. Data can be obtained by sharing the information with the person upon request.
2. It can be provided due to contractual relationship ; Sales, distance sales, etc. concluded between you and the company. It includes the information provided in mandatory situations related to the establishment, implementation and termination of contracts and the sales process, as well as all the data you provide during the continuation of the contractual relationship. You are deemed to have accepted the accuracy and up-to-dateness of the personal data in question.
3. Registration and account information: If you open an account to use the service offered by the Company, to create this account; You may be required to provide "Personal Data" such as name-surname, date of birth, TR ID number, e-mail address and password.
4. Don't pay; Due to the service it offers, the Company may provide financial account information such as credit card information when making payments by real persons. Such information is not processed or stored by the Company. However, the current summary transaction information may be processed by the Company without including credit card and/or bank account information regarding the transaction in question.
5. Customer service; We may process your Personal Data necessary for all your communications with our customer support team.
6. Location information from mobile device; We may process your precise location information if your device settings are enabled and you allow it to be shared with us.
7. Advertising, promotion, publicity etc. available for activities; Personal data is processed for advertising or market and public opinion research only if the purpose of collecting this information is compatible with these purposes and if the individuals have their express written consent. If information is collected only for advertising purposes, data owners may not provide this information. The data subject is informed of his freedom to provide his information for this purpose. Within the scope of giving this consent, the data owner can choose between appropriate communication channels such as postal mail, e-mail or telephone.

FOR WHAT PURPOSES ARE PERSONAL DATA PROCESSED ?

The company processes personal data primarily within the scope of the explicit consent received from data owners. In addition, in cases clearly stipulated in the legislation; In case it is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract; In cases where processing is necessary for the Company to fulfill its legal obligations; In cases where personal data is made public by the relevant person himself; In cases where data processing is necessary for the establishment, exercise or protection of a right and if data processing is mandatory or necessary for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the employee, employee data is processed limited to the legitimate purposes in question.

In addition, personal data; It is processed in line with the purposes stated in this KVK Policy and the employment contract and in accordance with the Personal Data Protection Law No. 6698 for the purpose of implementing the Company's policies and procedures and within the scope of the purposes detailed below.

The Company's main purposes/reasons for processing employee data are as follows:

Your personal data; Fulfilling, sustaining, executing and developing our activities, advertising, promotion, campaigns and similar activities for services and products in accordance with all relevant laws and regulations such as the Turkish Commercial Code, the Law on Consumer Protection, the Turkish Code of Obligations, etc. regarding all kinds of products we provide services or sell. making, fulfilling the requirements of the contracts that have been or will be issued, planning, statistics, customer satisfaction studies, ensuring security, maintaining the legal and commercial security of people who have business relations with our company, business partnership, customer evaluation processes, legal and financial affairs and similar commercial activities. and determination and implementation of business strategies, human resources, execution of accounting policies, ensuring physical security and auditing, compliance with domestic and international legislation, compliance with information transfer, storage and reporting obligations required by public institutions or other authorities, providing you with better and more reliable service. In order to be given and maintained uninterruptedly, it is processed within the conditions and purposes specified in Articles 5 and 6 of the KVK Law.

Your Personal Data may be collected verbally, through automatic or non-automatic methods, through our company headquarters, our website, social media channels, parties with whom we have a business relationship and/or from which our company receives services as a complement to its activities, service and intermediary service providers, contracted organizations and other similar channels. can be collected in writing or electronically.

WITH WHOM IS PERSONAL DATA SHARED?

Your Personal Data will not be shared with third parties without your explicit consent, except for the scope specified in this Privacy Policy, except for the exceptional cases stipulated in the legislation.

The company may transfer personal data to the following persons and institutions for certain purposes;

a) To our company's business partners, on a limited basis, in order to ensure that the purposes of establishing the business partnership are fulfilled,

b) To the company's suppliers and service providers, on a limited basis, in order to ensure that the services that the Company outsources from the supplier and necessary to carry out the Company's commercial activities are provided to the Company,

c) To the Company Shareholders, limited to the design of strategies regarding the commercial activities of the Company and audit purposes in accordance with the relevant legislation,

d) To legally authorized public institutions and organizations, limited to the purpose requested by the relevant public institutions and organizations within their legal authority,

e) To legally authorized private legal persons, limited to the purpose requested by the relevant private law persons within their legal authority.

f) Upon the request of judicial authorities or in cases where it is required by applicable laws, regulations, other legal regulations, court decisions and prosecutorial requests, or in case of restructuring, sale, redistribution of assets, merger, disposal or other changes of control of the Company or It is possible to disclose or transfer if the financial situation of the Company changes. These recipients may be located in the Americas (including the United States), Europe, Asia and other regions where data protection legislation differs from our country. Your data held electronically can only be kept under the control and supervision of the Company within another legal entity from which the Company receives services. In this regard, it may be possible to keep personal data on computers located outside the Company and access records from these computers.

Personal data by the company; Once the foreign countries with adequate protection are declared by the Board, it will only be transferred to these countries. For countries declared to lack adequate protection; Personal data will be transferred in cases where the data controllers in Turkey and the relevant foreign country undertake to provide adequate protection in writing and the Board has permission or the data owner gives approval.

WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

Personal Data owners may apply to the Company to:

• Learning whether personal data is processed or not,
• Requesting information if personal data has been processed,
• Learning the purpose of processing personal data and whether they are used for their intended purpose,
• Knowing the third parties to whom personal data is transferred at home or abroad,
• Requesting correction of personal data if they are incomplete or incorrectly processed,
• Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in the relevant legislation,
• To request that correction, deletion and destruction operations carried out in accordance with the relevant legislation be notified to third parties to whom personal data has been transferred,
• Objecting to the emergence of a result that is unfavorable to the individual by analyzing the processed data exclusively through automatic systems,
• Requesting compensation for the damage in case of damage due to illegal processing of personal data,

has the rights.

Data owners can submit their above-mentioned requests on the company website. Application form may be forwarded to the Company in writing. In accordance with the above-mentioned requests, the Company may provide a reasoned positive/negative response in writing or digitally.

It is essential that no fee is charged for the necessary procedures regarding the requests. However, if the transactions require a cost, it is possible to request a fee based on the tariff determined by the Personal Data Protection Board (“Board”) in accordance with Article 13 of the Personal Data Protection Law No. 6698.

PERSONAL DATA STORAGE PERIOD

Unless a longer storage period is required or permitted by the relevant legislation, the Company will store your Personal Data for the period necessary to fulfill the purposes outlined in this Personal Data Processing and Protection Policy and until the data owner requests the deletion of their data. .

ENSURING PERSONAL DATA SECURITY

The company is committed to protecting personal data in a safe and reasonable manner. It carries out technical and administrative measures using various methods and security technologies to ensure the appropriate level of security in order to prevent unlawful processing and access of personal data and to ensure the preservation of personal data. In addition, special personal data are processed by taking adequate measures determined by the Board.

The Company will not disclose the personal data it has obtained to anyone else, contrary to the provisions of this KVK Policy and the Personal Data Protection Law No. 6698, and will not use it for purposes other than processing. The Company declares that if personal data is shared in accordance with the provisions of this KVK Policy, it will request that the sharing channels in question comply with the commitments set out under this article.

KVK POLICY CHANGES

The Company may update and change the provisions of this KVK Policy at any time. The updates and changes made by the Company with this KVK Policy will be valid from the date of publication on the Portal.

Contact information

Merkez Mahallesi Çifte Cevizler Cad.

No:23 Saruhan Plaza K:2, D:42

TR 34381 Şişli / ISTANBUL - Türkiye

Tel: +90 212 231 31 27

Tel: +90 212 231 31 24

Fax: +90 212 231 31 27

info@kameya.com

Validity Date: 31.12.2021

Last Update Date: 01.01.2021