A. PURPOSE OF PERSONAL DATA PROTECTION AND PROCESSING POLICY:

serrtourLtd. Ltd. Şti (“Company”), in accordance with the Law on Protection of Personal Data No. 6698 (“KVKK”), with this “Information” letter we have prepared as Data Controller, we provide you with the 10th and “Relevant Information Obligation of the Data Controller” in the KVKK. Within the framework of article 11 titled “Rights of the Person”; We would like to inform you about the purpose for which your personal data will be processed, to whom and for what purpose your processed personal data can be transferred, the method and legal reason for the collection of your personal data, and your other rights listed in Article 11 of the KVKK: We process, record, transfer, share and store within the limits prescribed by official legislation. Our company,

B. COLLECTION, PROCESSING AND PROCESSING PURPOSE OF PERSONAL DATA:

By our company, which operates in the fields specified in detail in the Company's Articles of Association, due to the said activities; your verbal, written or electronic personal data is collected and processed.

Your personal data will be used to provide services related to the activities of our company and to increase the quality of these services, to carry out sales, marketing and other activities of our company, to comply with information storage, reporting and informing obligations.

In addition, your personal data may also be used within the scope of studies such as CRM (Customer Relationship Management) applications to be made for sales and marketing activities, as well as increasing the quality of service we offer you.

Your personal data will not be used for purposes other than the above-mentioned purposes without your explicit consent, and will not be shared or transferred to third parties, except for legal obligations and official institutions/organizations. Our company, your personal data in question only; KVKK art. In other cases stipulated in 5/f.2, we can use this data with our domestic or foreign affiliates, direct or indirect affiliates and joint ventures, or as required by a legal obligation, in order to provide value-added services, opportunities and opportunities to our customers and to increase the service quality. with the public institutions or organizations authorized to request, and provided that adequate measures are taken, may share it with domestic or foreign institutions, suppliers, authorized dealers/dealers/business partners with whom we have contracted due to our activities. Although your personal data may vary depending on the services, products or commercial activities provided by our Company; It can be collected verbally, in writing or electronically through automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar tools. As long as you benefit from our company's products and services, your personal data can be processed by creating and updating. In addition, with the intention of using the services of our Company; Although the services provided by our company may vary depending on the products or commercial activities; It can be collected verbally, in writing or electronically through automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar tools. As long as you benefit from our company's products and services, your personal data can be processed by creating and updating. In addition, with the intention of using the services of our Company; Although the services provided by our company may vary depending on the products or commercial activities; It can be collected verbally, in writing or electronically through automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar tools. As long as you benefit from our company's products and services, your personal data can be processed by creating and updating. In addition, with the intention of using the services of our Company; may be collected in writing or electronically. As long as you benefit from our company's products and services, your personal data can be processed by creating and updating. In addition, with the intention of using the services of our Company; may be collected in writing or electronically. As long as you benefit from our company's products and services, your personal data can be processed by creating and updating. In addition, with the intention of using the services of our Company;

a. When you use our call center or website,

b. When you visit our company, our website or our social media channels/media,

c. Your personal data may be processed when you attend trainings, seminars or organizations organized by our company.

Your personal data obtained from you with your consent or due to other legal compliance reasons stated in the laws of the Republic of Turkey;

(i) Our business units can carry out the necessary work to benefit you from the products and services offered by our company;

(ii) Suggesting the products and services offered by our company to you by customizing them according to your tastes, usage habits and needs;

(iii) Ensuring the legal and commercial security of our Company and the people who have a business relationship with our Company (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.);

(iv) Improving the services provided by our company and improving our quality policy,

(v) You are informed about and benefited from the general and special campaigns, promotions, promotions, discounts and similar advantages offered by our company;

(vi) To be able to process the data obtained together with your personal data, preferences, transactions and browsing time in the relevant channels when you log in with your user name and password in order to receive services from the channels offered by our company, in order to provide you with the information and services you have requested;

(vii) To make notifications (renewal, expiration, etc.) regarding all kinds of loyalty cards issued and/or to be issued by our Company and its related companies/organizations and website memberships of our Company and its related companies/organizations, and any communication that may be established with you, to inform about new services and products to be offered, changes, innovations and similar issues in personal data policies and membership conditions; (viii) To inform you about the information, events and services you will request from our company;

(ix) Determination and implementation of our company's commercial and business strategies;

(x) Ensuring the execution of our company's human resources policies and;

(xi) In the event that it is clearly stated in the legislation or if necessary, for the purposes of fulfilling a legal obligation determined by the legislation, within the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law, our Company and its related companies/organizations,

It can be processed by other real and/or legal persons specified in Article (C).

C. METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA:

Your personal data is obtained in all kinds of verbal, written or electronic media, in line with the purposes specified in the above articles, in order to present our products and services as a Company within the determined legal framework, and in this context, for our Company to fulfill its contractual and legal responsibilities completely and accurately. Your personal data collected for this legal reason is processed, recorded, transferred, shared and stored for the purposes specified in article (B) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law.

D. PROCESSING OF PRIVATE DATA:

According to the KVK Law, data related to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric data. and genetic data are special categories of personal data. Our company also takes adequate precautions in the processing of personal data of special nature, determined by the Personal Data Protection Board. In order to provide better service, our company will process the private data of individuals only with the consent of the relevant person and only to serve the purpose of collection.

E. TO WHOM AND FOR WHAT PURPOSES THE PROCESSED PERSONAL DATA MAY BE TRANSFERRED:

Your collected personal data may be transferred to DIGITALCAKE, legally authorized public institutions and private individuals in order to serve the purposes specified in Article (B), within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law.

F. TRANSFERRING PERSONAL DATA ABROAD:

Our company has the authority to transfer personal data abroad in accordance with the conditions determined by the Personal Data Protection Board in the KVK Law, in accordance with the other conditions in the law and after obtaining the explicit consent of the person for this purpose.

G. RIGHTS OF THE PERSONAL DATA OWNER STATED IN ARTICLE 11 OF THE KVK LAW:

Within the scope of the KVK Law, we accept that the data subject has the right to be informed and approved before the processing, recording, transfer, sharing and storage of his personal data, and that he has the right to determine the fate of the data after the data is processed, recorded, transferred, shared and stored.

In this context, if you submit your requests regarding your rights as personal data owners to our Company through the methods set out below in this "Information Text on the Processing of Personal Data", our Company will conclude the request free of charge within thirty days at the latest, depending on the nature of the request.

Pursuant to the Communiqué on Application Procedures and Principles to the Data Controller published by the Personal Data Protection Board, regarding your requests regarding your rights as personal data owners.

I. If your application will be answered in writing, up to ten pages will not be charged. A transaction fee of 1 Turkish Lira may be charged for each page over ten pages. ii. If the response to the application is given in a recording medium such as a CD or flash memory, the fee that may be requested by our Company as the data controller cannot exceed the cost of the recording medium. In this context, personal data owners;

a. Learning whether personal data is processed or not,

b. If personal data has been processed, requesting information about it,

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

D. Knowing the third parties to whom personal data is transferred at home or abroad,

e. Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,

f. To request the deletion, destruction or anonymization of personal data within the framework of the conditions stipulated in Article 7 of the KVK Law and to notify the third parties to whom the personal data has been transferred,

g. Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

h. In the event that personal data is damaged due to unlawful processing, it has the right to demand the compensation of the damage. However, individuals do not have a right to anonymized data within the Company.

Our company may share personal data with relevant institutions and organizations in order to exercise the legal powers of a judicial duty or state authority in accordance with the business and contractual relationship.

H. TIMES THAT YOUR PERSONAL DATA WILL BE PROCESSED:

In accordance with the KVK Law, your personal data processed for the purposes specified in this “Informative Text on the Processing of Personal Data” disappears when the purpose that requires processing according to article 7/f.1. When the expiration period expires, your personal data will be deleted, destroyed or anonymized by us.

I. SITUATIONS WHERE OUR COMPANY CAN PROCESS YOUR PERSONAL DATA WITHOUT YOUR EXPRESS CONSENT, ACCORDING TO THE LAW:

Pursuant to Article 5 of the KVKK, our Company may process your personal data, which it has received in accordance with the law, without your explicit consent, in the following cases:

I. If you, as the data owner, are unable to express your consent due to actual impossibility, or in cases where your consent is not legally valid, it is necessary to process your personal data in order to protect your own or someone else's life or physical integrity,

ii. It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract you have concluded with our company and its related companies/organizations, other real and/or legal persons specified in Article (C),

iii. It is mandatory for our company to fulfill a legal obligation, iv. Your personal data has been made public by you,

v. Data processing is mandatory for the establishment, exercise or protection of a right, vi. Data processing is mandatory for the legitimate interests of our Company, provided that it does not harm your fundamental rights and freedoms.

J. TO MAKE A REQUEST UNDER THE PERSONAL DATA PROTECTION LAW:

Pursuant to paragraph 1 of Article 13 of the KVK Law, you may submit your request regarding the exercise of your above-mentioned rights to our Company through the method(s) determined/to be determined by the Personal Data Protection Board.

Alternatively, if you wish, you can submit your application in writing to our Company in accordance with the KVK Law. Law No. 6698 art. You can always   contact us by sending an e-mail to [email protected] in order to exercise these rights set forth in Article 11.

Only  the [email protected]  e-mail address should be used for matters related to your personal data, and requests and notifications from channels other than this address will not be evaluated.

Rights regarding personal data can only be exercised about personal data. Requests for the data of people other than the person who filled out the form and whose official documents are attached to it will not be considered.

Forms without official documents identifying your identity will not be considered. Even when data deletion requests are fulfilled, we inform you that we are obliged to share the data with the official authorities if requested by the official authorities.

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