Cookie Policy

It is among our top principles to protect the privacy of the data subjects who visit the web site run by ÖZDİSAN ELEKTRONİK PAZARLAMA SAN. TİC. ANONİM ŞİRKETİ (the “Company”) at the address of www.ozdisan.com (“Data Subject”). The Web Site Privacy and Cookies Policy (the “Policy”) describes (1) the processing of the personal data of data subjects and how this Policy shall be applied and used.

This Privacy Notice is intended to determine such conditions and terms applicable to the use of the personal data that is shared by the Web Site users/ members/ visitors (the “Data Subject”) with the Company or that the Company generates during the use by the Data Subject of the Web Site in the course of the services provided over the web site (“Site”) run by the Company and/ or service providers.

The Data Subject represents that they have been informed about the processing of their personal data with this Privacy Policy and that they consent to the use of their personal data as specified herein.

1. Which Data is Processed?

Under this section, the data processed by the Company and considered as personal data in accordance with the Personal Data Protection Law are, without limitation, listed as follows: Unless otherwise expressly stated, the term "personal data" shall include the following information within the scope of the terms and conditions provided under this Privacy Notice.

• ID details (Name and Surname)- if contact forms or registration forms are completed,
• Contact details (Address, E-mail address)- if contract forms or registration forms are completed,
• Customer Transaction Data and Marketing Info (Order details and History, Campaigns, Surveys, Likes)
• Transaction Info (Behavior and Digital Trace, IP)
• Technical specifications of the device in use (Computer, Phone) (Type of the device) and software data (Operating System)
• Location (from where you have access to the web site)

The Company collects the data about the use by the Data Subject of the Web Site by means of cookies, which are technical communication files and IP data are collected by means of cookies in order to map out the habits for having access to the services offered over the Web Site and its use. Depending on their types, cookies collect data in general based on your browsing and usage preferences in the device which you use to have access to the Web Site. These data include the pages you have access to, our services and products that you review and your navigation in the Web Site.

Pursuant to Articles 3 and 7 of the Personal Data Protection Law, data that is irreversibly anonymized will not be considered as personal data in accordance with the provisions of the aforementioned law and the processing activities related to this data will be carried out without being bound by the provisions of this Privacy Notice.

2. For what purposes is the data used?

The Company processes the personal data provided by the Data Subject in order to make use of the products and services available at its web site, to send notices and updates about the products and services to the data subjects, to assess the messages received over the web site, to respond to information inquiries, to draft, process and conclude complaints, to provide after-market services,

to respond to inquiries about the Company products and services, to provide data subjects with notices and updates about the products and services that the data subject is interested in, to send information about the Company products and services to such contact addresses provided by the data subjects upon request, to carry out business operations, including the provision of after-market services, to design and apply commercial and business strategies, to ensure the legal, technical and commercial security of our Company and those who have business deals with them, and accordingly, to provide the Data Subject with necessary information in this respect and to fulfill the obligations inherent in this kind of operations.

The Company also processes the personal data in question to improve and develop the services provide by it, and accordingly, to give necessary information to the Data Subject and to fulfill its obligations inherent in the services provided by it.

The said personal data shall also be used to contact the Data Subject, to improve his Web Site experience (including the improvement of existing services, creating new services and services customized for the person),

and it may also be used for the Company's reporting and business development operations, and to proceed with various statistical evaluations, to create a database and to carry out market researches without keeping the Data Subject anonymous.

3. Parties to whom your personal data are transferred and the purpose of transfer

Your personal data may be transferred to our suppliers that are our group companies, the statutorily authorized public agencies and private persons in line with the purposes of processing your personal data and subject to the purposes and terms and conditions applicable for personal data processing as set out in Articles 8 and 9 of the PDP Law.

The Company may transfer the personal data of the Data Subject and the new data obtained by using this personal data to third parties, who make use of the Company’s services to such extent limited to the purpose of providing such services to the Data Owner in order to realize the purposes specified under this Privacy Notice.

The Company discloses such Personal Data to its subsidiaries and affiliates and group companies and outsourcers, hosting service providers, law firms, research companies, business partners, suppliers, company shareholders or call centers and similar third parties, including those who send SMS (subject to the compliance with the provisions in other applicable legislation for authorities) in order to develop the experiences enjoyed by the Data Subject (including improvement and personalization), to ensure the security of the Data Subject, to detect fraudulent or unauthorized uses, to investigate into operational evaluations, to cure those faults in the Web Site or the Company services, and to fulfill any of the objectives set out in this Privacy Notice.

The Company may process and transfer personal data to third parties without the further consent of the Data Subject pursuant to Articles 5 and 8 of the Personal Data Protection Law and/ or subject to the exceptions set out in the applicable legislation. The major examples of such transfer are given below:

• Provided not to cause any harm to the fundamental rights and freedoms of the Data Subject, where it is mandatory to process data for the legitimate interests of the Company,
• Where it is mandatory to process data in order to establish, use or protect a right,
• Where the information is made public by the Data Subject himself,
• Where it is mandatory to fulfill legal requirements,
• Where it is necessary to process personal data in order to establish or perform any contract between the Data Subject and the Company, provided that it is directly related thereto,cc
• Where it is mandatory to protect the vital interests or physical integrity of the data subject or another person where the data subject who is unable to explain his/her consent due to the physical disability or whose consent is not deemed legally valid,
• Where it is explicitly required under the applicable laws

4. Methods and Legal Grounds to collect your personal data

During your visit to our Web Site, your personal data are collected by means of cookies, which are technical communication files in line with the data procession terms and requirements dictated by the Law.

As it was mentioned above, the Company uses cookies and may transfer your personal data to third parties offering analysis services only for the use of such services to the extent required by them accordingly.

The said technical communication files are tiny text files that are sent by the Web Site to the Data Subject browser in order to be stored in the main memory. A technical communication file makes it more convenient to use Internet in that sense as it remembers the status and preference settings about a web site. A technical communication file is designed, and used for the purposes, to collect statistical data about the number of users of a web site in proportion to time, the purposes of their visits, how many times they visit the site and for how long they spend time there and to help the generation of ads and contents dynamically from the user pages customarily designed for users. A technical communication file has not been designed to collect any other personal data from the main memory. The majority of browsers are designed to accept technical communication files initially; however, a user may change browser settings at all times at his sole discretion in order to ensure that no technical communication file shall be received or a warning shall be emitted if this kind of file is sent. The Company also has the right to associate the behaviours of the Data Subject at the web site in a cookie embedded in the browser and to define re-marketing lists based on certain metrics such as the number of viewed pages, the duration of the visit and the target completion number in order to carry out online behavioural advertisement and marketing operations. Later targeted advertisement contents may be displayed to the Data Subject based on the areas of his interest at the Web Site or at other web sites covered by the video advertising network.

5. Rights of the Data Subject under Article 11 of the Personal Data Protection Law

A data subject shall have the following rights that can be exercised upon an application to the Company:

• To find out whether personal data concerning them are being processed,
• To request information regarding that if their personal data is processed,
• To learn the purpose of personal data processing and whether they are used in accordance with its purpose,
• To know the third persons to whom the personal data is transferred in the country and abroad,
• To request correction of any personal data that has been processed incompletely or inaccurately,
• To request the deletion or destruction of personal data subject to terms and conditions set out in the applicable law,
• To request that any correction, erasure or destruction carried out pursuant to the applicable legislation is to be notified to third parties to whom such data is transferred,
• To object to any adverse outcome resulting from the processing of personal data exclusively through automated systems,
• To request compensation for damages in the event of suffering damages as a result of the unlawful processing of personal data.

As personal data owners, in case you send your requests regarding your rights to our Company with the methods regulated below, our Company will finalize the request as soon as possible and at the latest within a maximum of thirty days depending on the nature of the request. No fee shall be charged for up to ten-page reply. 1 (one) Turkish lira transaction fee shall be charged per page above ten pages. Where the reply to the application is given in a recorded media such as CD, flash memory, etc., the fee that the Company may change may not exceed the cost of the recorded media.

You can send your request to exercise your rights listed above in Turkish and in writing or by using the registered Electronic Mail (REM) address, a secure electronic signature, a mobile signature or the electronic mail address that has been already notified to the Company and is now saved in our system pursuant to Article 13/1 of the Law no. 6698 and the Communique no. 30356 on the Terms and Procedures to Apply to the Data Controller (published on 10.03.2018). The Company reserves its right to verify your identity before giving a reply.

Your application should include the following details:

• Your name, surname, and if the application is in writing, your signature;
• For Turkish Republic citizens, your Turkish Republic ID no, and if you are a foreign citizen, then your nationality, passport number, or if any, your ID number;
• Your place of residence or office address required for service of process, or
• Your electronic mail address, phone or facsimile number for notices, if any,
• The subject matter of your request, and any other document and information about that subject matter, which should be all attached to the application form.

You can send your applications by means of the PDPL Application Form available at our web site.

If you wish to make your application in writing, you can deliver it to our Company’s address below by attaching required documents as our Company acts as the data controller: Dudullu OSB, DES Sanayi Sitesi 104 Sok.A7 Blok No:54-56 Ümraniye / Istanbul

If you wish to e-mail your application, please send it to the following e-mail address: [email protected]

You can send your applications that you wish to be send via the REM address to our following address: [email protected]

Any information and documents depending on the nature of your request need to be provided to us in complete and correct form. Unless the required documents and information are properly provided, there may be problems in the full and quality conduct of the investigations that are to be carried out by the Company pursuant to your request. The Company declares that it shall reserve its statutory rights in such a case. Therefore, your application must be sent in complete form with all required documents and information, depending on the nature of your request.

6.Retention Period of the Personal Data

The Company will retain the personal data provided by the Data Subject for the period required by the aforementioned processing purposes. Furthermore, in the event of any dispute that may arise between the Company and the Data Subject, the Company may retain personal data limited to the purpose of realizing the necessary defenses within the scope of the dispute and for the statute of limitations determined in accordance with the relevant legislation.

7. Data Security Measures and Commitments

The Company undertakes to take all required technical and administrative measures and to carry out necessary audits and inspections:

• To ensure that the personal data shall not be processed unlawfully,
• To ensure that there shall be no unlawful access to personal data, and
• To safeguard personal data,

subject to such terms and conditions defined herein or as set out in the applicable legislation.

The Company cannot disclose the personal data obtained regarding the Data Subject to anyone else in violation of the provisions of this Privacy Notice and the Personal Data Protection Law and cannot use the same for the purposes other than processing. In the event that links are directed to other applications through the Site, the Company shall not bear any responsibility for the privacy policies and contents of the applications.

8. About Cookie Policy

This Cookie Policy describes what cookies are and in what way we use them. You have to read this policy to understand what cookies are, in what way we use them, the types of cookies that we use, meaning, the data that we collect by using the cookies, how we use such data and how to control cookie preferences. Please read our Privacy Policy in order to find out more information about the way we use, store and retain your personal data. You can change or withdraw your consent in the Cookie Notice posted at our web site at any time you wish to.

Your consent shall be applicable to the following fields:

• ozdisan.com
• google.com
• yandex.com

What is a cookie?

Cookies are tiny text files that are used to store small data. When the web site is downloaded to your browser, cookies are stored in your device. These cookies allows us to ensure the smooth operation of the web site, to make the web site more secure, to offer a better user experience and to analyze what kind of performance the web site shows, and what is used for what and the areas that need to be improved. We use cookies in order to make use of our Web Site in the most efficient manner and to improve our user experience. If you do not wish to use cookies, you can delete or block cookies from the settings of your browser. However, we would like to remind you that the use by you of our web site may be affected from it.

In what way do we use cookies?

Third party cookies used in our web sites are basically used to understand what kind of performance the web site displays, to see your interactions with our web site, to ensure the security of our services, to display such advertisements related to you, and to offer a better service to you all around.They help a better user experience and speed up your future interaction with our web site.

Cookie are tiny text files stored by the web sites that you visit in your device or network server by means of browsers.

The primary purposes of using cookies in our Web Site are listed below:

• To improve the services provided to you by enhancing the functionality and performance of the web site,
• To improve, and provide new features over, the Web Site, and to personalize offered features based on your preferences,
• To ensure the legal and commercial security of you, the Web Site and our Company

What kind of cookies do we use?

Like the majority of online services, our Web Site also uses first and third party cookies for a series of purposes. First party cookies are mostly required to ensure the correct functioning of the web site and they do not collect any identifiable personal data.

Basic: Certain cookies are mandatory to allow you to experience all functions of our web site. They allow us to maintain user sessions and prevent security threats. They do not collect or store personal data. For instance, these cookies allow you to log in your account, to add products to your basket and to make payment securely.

Statistical figures: These cookies store certain data such as the number of visitors to the web site, the number of unique visitors, which pages of the web site are visited and the source of the visit etc. These data help us to analyze how good the web site’s performance is and to find out the spots that we need to improve.

Marketing: Our web site places ads. These cookies are used to personalize the ads that we display to you in a meaningful and significant way for you. These cookies also help us track the efficiency of these advertisement campaigns.

The data that is stored in these cookies may also be used to allow third party advertisement service providers to display ads to you at other web sites in the browser.

Functional: These are the cookies that help us perform some insignificant functions in our web site. Among these functions are the placement of contents like videos or sharing the contents from the web site in the social media platforms.

Preferences: These cookies help us save your settings and define browsing preferences such as preferred language. This way, you enjoy a better and more efficient experience during your future visits to our web site.

How can I control cookie preferences?

In addition, each browser offers different methods to block and delete cookies used by web sites. You can change the settings of your browser to block/ delete cookies.

To learn more about how to administer and delete identification details, please visit wikipedia.org, www.allaboutcookies.org

Types of cookies used in our Web Site

Is it possible for data subjects to block the use of cookies?

You have the means to customize your preferences about cookies by changing the settings of your browser.

Effectiveness of the Web Site Privacy Policy

The Web Site Privacy Policy is dated 15.04.2019. The Company amended the provisions of this Privacy Notice on 01.02.2023. In the event that the entire Policy or its specific provisions are renewed, the effectiveness date of the Policy shall be renewed.

The Policy shall be published at www.ozdisan.com and shall be offered for the access of the data subjects upon their demand.

You can have access to detailed information for processing your personal data by reading the Company Privacy Notice for the Protection of Personal Data, which is shared with the public over www.ozdisan.com.

DATA CONTROLLER’S ID