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Personal Data Protection and Processing Policy

1. PURPOSE AND SCOPE

Business: KARMI BİLGİ TENKNOLOJİLERİ A.Ş. ("Hereinafter referred to as KARMİ"), our customers, employees, employee candidates, company shareholders, company officials, visitors and business partners, including, but not limited to, all natural persons we come into contact with during our activities, which is a constitutional right We attach utmost importance to the protection of personal data and compliance with the regulations in the Personal Data Protection Law No.6698.

In this direction, we take all necessary technical and administrative measures in order to prevent the unlawful processing of personal data, unlawful access to these data and to ensure the preservation of personal data, as Data Supervisor.

As KARMİ, with this Personal Data Protection and Processing Procedure, we aim to inform you about the collection, use, processing, transfer, storage of personal data, our processes and systems and our basic principles.

2. PROCEDURES AND PRINCIPLES FOR THE PROTECTION OF PERSONAL DATA

3.1. GENERAL PRINCIPLES

M of the Constitution. 20 / III personal data can only be processed in cases stipulated by law or with the express consent of the person, and the protection of personal data is guaranteed. In line with this right granted to personal data owners, KARMI BİLGİ TEKNOLOJİLERİ A.Ş. processes personal data in accordance with the principles specified in the relevant legislation or in cases where the person has express consent, in accordance with the following principles:

3.1.1. Processing in Compliance with the Law and the Rules of Good Faith:

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. Acts in accordance with all legal regulations and the rule of honesty in the processing of Personal Data.

3.1.2. Ensuring that Personal Data is Accurate and Updated when Required

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. Necessary measures are taken to ensure that the Personal Data processed by the Company are accurate and up-to-date, and necessary opportunities are provided to the Data Owners by informing them in order to ensure that the processed data reflect the real situation.

3.1.3. Processing for Specific, Clear and Legitimate Purposes

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. clearly and precisely determines the legitimate and legal purpose of processing personal data. KARMI BİLGİ TEKNOLOJİLERİ A.Ş. is linked to the business activity it carries out and operates as much as necessary for them.

3.1.4. Being Related, Limited and Measured for the Purpose of Processing

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. , Processes Personal Data in a way that is convenient for the realization of the determined purposes and avoids the processing of Personal Data that are not related to or needed for the realization of the purpose.

3.1.5. Retaining for the Period Stipulated in the Relevant Legislation or Required for the Purpose for which they are processed

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. The personal data processed by us are kept only for the period stipulated in the relevant legislation or required for the purpose for which they are processed. In this context, KARMI BİLGİ TEKNOLOJİLERİ A.Ş. If there is a period stipulated in the relevant legislation for data storage, If there is no such period, it retains the data only for the period required for the purpose for which it was processed.

3.2. PURPOSE OF PROCESSING PERSONAL DATA

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. Your Personal Data obtained by you may be processed within the scopes described below:

To ensure that our legal obligations are fulfilled as required or required by legal regulations,

Providing software services and other outsourcing services to fulfill operational activities,

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. The commercial activities specified in the articles of association are subject to the legislation and KARMI BİLGİ TEKNOLOJİLERİ A.Ş. Carrying out the necessary studies by the relevant units in order to be carried out in accordance with the policies and carrying out activities in this direction,

Determination, planning and implementation of KARMİ short, medium and long term commercial policies,

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. The service products and projects offered by the company are customized according to the tastes, usage habits and needs of the relevant people, and information about the products, services and projects,

To be able to provide an effective customer service,

Submission of services and offers,

Providing information about all kinds of promotions, campaigns, sweepstakes,

To be able to carry out all kinds of marketing and advertising activities,

Determining visitor profiles,

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. ensuring commercial reliability,

Ensuring that requests, demands and complaints are answered and resolved,

Providing support services to Customers and Visitors within the scope of the contract and within the framework of service standards,

Conducting market research and statistical studies,

KARMI BİLGİ TEKNOLOJİLERİ A.Ş. Establishing contact with people who have a business relationship with,

Marketing, sleepm management, vendor / supplier management,

Planning, control and execution of information security processes,

Establishing and managing information technology infrastructure,

Planning and execution of employees' access authorizations to Data Owner information,

Follow-up of financial and / or accounting transactions, including invoicing,

Follow-up of legal affairs,

Planning and execution of corporate communication activities,

· Ensuring that the data are accurate and up-to-date.

3. Persons to whom Your Personal Data is Transferred and Transfer Purposes


Your personal data are transferred in accordance with the following table within the scope of the realization of the above-mentioned purposes:


Transferred Person


Domestic and Foreign Suppliers


Transfer Purpose


realization of storage, storage, processing and archive activities, execution of information security processes, online membership, execution of sales processes, execution of communication activities, management of customer relations, execution of requests / complaints / application processes, realization of payment transactions, returning of incorrect collections, advertising / campaign / promotion processes, product / service marketing processes, company / product / service commitment processes, user experience studies, cookie processing activities, display of the closest store when the location is shared


Transferred Person


Domestic and Foreign Suppliers / Retail Group Companies


Transfer Purpose


Conducting commercial communication activities for advertising / promotional / marketing activities (in case of express consent)


Transferred Person


Retail Group Companies / Business Partners


Transfer Purpose


Sharing orders with the relevant retail group companies and providing product and service supply, conducting joint projects


Transferred Person


Authorized Public Institutions and Organizations


Transfer Purpose


Fulfilling the demands in accordance with the law within the scope of legislation, regulatory and supervisory activities, carrying out and finalizing alternative dispute resolution methods and litigation processes, requesting from courts

Contracted Law Firm Preparing for alternative dispute resolution methods and lawsuits, completing the processes in question


4. Collection Method of Your Personal Data


Your Personal Data; It is collected electronically through our website / mobile application.

5. Legal Reasons for Processing Your Personal Data


Your personal data are processed based on the following legal reasons:


• We process if explicitly stipulated in the laws: Your data can be processed if the relevant legislation requires data processing, especially the Law No. 5651 on the Regulation of Broadcasts on the Internet and the Fight Against Crimes Committed Through These Publications, and the Regulation of Electronic Commerce No. 6563.

• Provided that it does not harm the fundamental rights and freedoms of your party, we process it because it is necessary for the legitimate interests of our company: it constitutes a legal reason for the fulfillment of some of the above-mentioned personal data processing purposes.

• We process because it is mandatory for the establishment, use or protection of a right: it creates a legal reason for data processing activities that require data processing to establish, exercise or protect a right, such as alternative dispute resolution for personal data processing purposes, or the use of personal data for proof in court proceedings.

• We are operating because it is mandatory for the fulfillment of a legal obligation: it creates legal grounds for data processing purposes such as fulfillment of legal requests within the scope of secondary legislation, regulatory and supervisory activities, alternative dispute resolution methods and execution and conclusion of litigation processes, request from courts.

• Provided that it is directly related to the establishment or execution of a contract, we are processing it because it is necessary to process personal data belonging to the parties of the contract: it constitutes a legal reason for the personal data processing activities required for the establishment or performance of the contract, such as the establishment of the membership agreement, the completion of online sales transactions with your membership information.

• We process if you have explicit consent: Identity (Name-surname, gender) Contact (Mobile phone, e-mail address) Customer Transaction (order, basket information) Marketing (shopping history information, survey, cookie records, information obtained through campaign work) Conducting the marketing processes of the products / services, creating general or personalized campaigns, discounts, promotions and advertisements within the scope of the company activities, targeting, segmentation, reporting, profiling, marketing and analysis applications, making your personal data as specified in the KVK explicit consent text, Submit -up impressions, personalized impressions and offersFor the purpose of delivering notifications within the scope of advertising and marketing / communication activities; Identity (Name-surname) Communication (Mobile phone, e-mail address), conducting surveys on customer satisfaction and loyalty processes regarding products and services, informing about promotions, campaigns, advantages, discounts, competitions, invitations, sweepstakes, activities and events can be processed for the purposes of commercial communication activities, including sending commercial messages through contact information for advertising and marketing.


6.Measures Taken for Your Data Security and Principles Adopted


6.1. Security measures


KARMI BİLGİ TEKNOLOJİLERİ A.Ş. Ş., we support all kinds of privacy and security solutions to prevent unlawful processing of your personal data obtained through our website / mobile application, to prevent unlawful access to your personal data and to ensure the protection of personal data. All kinds of administrative and technical measures required for the realization of these solutions for the protection of your data are meticulously carried out by our Company.


6.1.a. Administrative Measures


KARMI BİLGİ TEKNOLOJİLERİ A.Ş. Ş., we provide our personnel with the necessary trainings in order to process and protect your personal data in accordance with the law, and regularly audit their employees to measure their level of compliance with the Law. We adopt the compliance and diligence shown by our personnel to the Law as a criterion in the performance evaluation of our personnel.

Although these measures are taken within the company, we ensure your data security by signing confidentiality agreements and commitments with our suppliers and business partners with whom we share your personal data in accordance with the law, and ensure that our stakeholders show sufficient sensitivity for your personal data.


In addition to these training, audits and precautions, in case a violation occurs about your personal data, intervention plans have been prepared to remedy this violation and the necessary preparations have been made to remedy the violation by working with the Board as the Company.


6.1.b. Technical Measures


As one of the leading companies in Turkey, we pay special attention to information technologies and data security in order to protect the personal data of a wide range of customers we deal with. Therefore, KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. We give priority to the employment of experienced and certified personnel in this field.

In addition, an IT infrastructure equipped with security measures in accordance with international standards has been established in order to ensure data security and to prevent unlawful access to your data. For the smooth functioning of the system built on this infrastructure, it is constantly inspected from within.


We comply with the technical precautions given by the Personal Data Protection Authority such as encryption, authorization matrix, application and network security, data masking, firewalls, backup, key management and up-to-date anti-virus systems in our IT infrastructure, where the data we collect with our website / mobile application are processed and stored. .

In addition, intrusion detection and prevention systems have been established to prevent attacks on our IT infrastructure, and the security of the system is regularly checked by performing risk analysis, data classification, vulnerability scans and penetration tests. In order to carry out all these procedures, software programs and support in accordance with international standards are also taken as a requirement of the importance we attach to your personal data.


Finally, we do not store card information for purchases made on our website / mobile application, we comply with the conditions required by PCI DSS (Payment Card Industry Data Security Standard) in payments, and all the information determined by the Personal Data Protection Authority in the management of our information system. We are delighted to report that technical precautions and ISO 27001 standards have been followed.


6.2 Principles Adopted


KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. as;


• to take security measures with the sensitivity required by the nature of your personal data in the processing of your personal data, to show the care that the Company has shown at least to protect its own information in order to protect your data,

• not to process or share your personal data without your consent when your consent is required,

• to collect limited and only necessary data on our website / mobile application, to act in accordance with the principle of data minimization decided by the Personal Data Protection Authority,

• paying attention to your personal data being accurate and up-to-date,

• Based on your transparent informing about the processing and transfer of all your personal data,

• to inform you in accordance with this transparency principle upon your request

• We would like to state that we take it as a principle to show sensitivity in complying with all legal regulations on the protection of personal data.


KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. Ş., we would like to state that the security measures specified in this Privacy Policy and the principles adopted are valid on our website / mobile application. In case of redirection to other sites or applications through our website, KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. For this reason, we ask you to be careful about such redirects from our site / mobile application.


7. Your Right to Apply to the Data Controller


We would like to state that you have the following rights regarding your personal data in accordance with the provisions of Article 11 of the Law:


• Learning whether personal data is processed,

• Requesting information if personal data has been processed,

• Learning the purpose of processing personal data and whether they are used appropriately for their purpose,

• To know the third parties in the country or abroad to whom personal data have been transferred,

• To request correction of personal data if it is incomplete or incorrectly processed,

• Requesting the deletion or destruction of personal data,

• In case personal data is corrected, deleted or destroyed, requesting that these transactions be notified to third parties to whom personal data have been transferred,

• Object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,

• To demand the compensation of the damage in case of damage due to the unlawful processing of personal data.


You can submit your requests regarding your above-mentioned rights by reading the "Information Regarding Application Form Under the Scope of KVKK" text on our website, through one of the ways specified in the text.


Your application is KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. Within the scope of the provisions of the KVK Law and Communiqué, your application will be answered within thirty days from the date we receive it, and the response will be sent to you in writing or electronically. Within the scope of the applications made, the COMPANY NAME does not charge any fee as a rule, but if the transaction requires additional costs, the fees determined by the Board may be charged.


COOKIE DISCLOSURE TEXT


DATA CONTROLLER


KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. ("Hereafter referred to as KARMI.") As ("Data Supervisor"), we value the sensitivity of your visitors to our website ("www.karmigame.com") on privacy while collecting information that will help us improve your online experience. we provide.


With the Cookie Clarification Text, we aim to inform you about cookies. This Cookie Clarification Text contains explanations on the different types of cookies used on our website and how you can control them.


The cookie is a small text file and it holds a certain amount of data that our website can send to your browser. It can then be stored on your computer's hard drive and accessed by our web server. These cookies can then be received by us and our web pages and services can be arranged through cookies. In the Cookie Clarification Text; We refer to all technologies including cookies, pixels, web beacons and gifs as cookies.


By using our website, you accept the use of cookies and other technologies specified in this Cookie Clarification Text. You can make changes to cookie settings from your browser settings. If you do not want cookies to be used, you will not have access to many features that make your visiting experience more efficient, and some of our services will not work properly. You can find detailed information about not wanting to use cookies in the last part.


KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. Ş., we can add new cookies to the cookies used on our website, opt out of using or change them. We would like to state that we have the right to unilaterally change the Cookie Clarification Text at any time.


METHOD AND LEGAL REASON OF COLLECTING PERSONAL DATA


Your personal data are collected electronically through cookies and the said personal data are processed for the legitimate interests of our Company in accordance with Article 5 of the Personal Data Protection Law, provided that the fundamental rights and freedoms of the relevant person are not harmed. In addition, your identity (name-surname, gender), contact (mobile phone, e-mail address), marketing (shopping history information, survey, cookie records, information obtained through campaign work), your personal data, general and personalized campaigns, advantages and promotions and advertisements. creating, carrying out marketing processes of products / services, targeting, segmentation, reporting, profiling, marketing and anal It is processed on the basis of your explicit consent if you give it for the purpose of carrying out trace studies, notifications, pop-up displays, personal offers, customization of user screens, updating and enriching the data shared with group companies by the COMPANY NAME within the scope of the advertising and marketing / communication activities of the COMPANY NAME.


WHAT PURPOSE OF PERSONAL DATA WILL BE PROCESSED


Cookies enable you to navigate our website and use certain features, improve our website experience or collect other statistical data, remember choices you make (such as language preference, country location or other online settings) and provide personalized or enhanced features you choose, making our site easier to use. to better tailor our products, services and our website to your needs and interests, to provide advertisements more relevant to you and your interests, to limit the number of times you see an ad, to measure the effectiveness of an ad campaign, and to provide you with our website and online services and third-party websites and online It is processed for the purposes of presenting advertisements for the relevant target in its services and making profiling studies.


Necessary cookies


Necessary cookies help make a website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies. These are usually placed in response to actions by you that represent a service request. These cookies do not store any information that can personally identify you.


Cookie Name


Google Analytics


Purpose of usage


Google Analytics is Google's free analytics tool that helps website and app owners understand what visitors are doing on their websites and apps. This tool can use a set of cookies to collect information and report site usage statistics to Google without identifying visitors. As a user navigates between web pages, Google Analytics provides website owners with JavaScript tags to record information such as the page a user sees, such as the URL of the page. Google Analytics JavaScript libraries use HTTP Cookies to "remember" what interactions a user has done with the website on previous pages. The main cookie used by Google Analytics is the "_ga" cookie.


In addition to reporting site usage statistics, the data collected by Google Analytics at Google properties can also be used, along with some of the advertising cookies described above, to help show you more relevant ads on Google properties (such as Google Search) and across the web, and to measure interactions with the ads we show.


For more information about Analytics cookies and privacy information, you can visit this site.

https://policies.google.com/technologies/types?hl=tr


Duration of Use


Persistent cookies, Session cookies


Cookie Name


Google Ads


Purpose of usage


Google Ads cookies are a small piece of text sent to your browser by the website you are visiting. This helps the website remember information about your visit (for example, your preferred language and other settings). In other words, it can provide convenience and make the site more useful on your next visit. Cookies are used for many purposes. For example, we use them to remember your safe search preferences, to show you more relevant ads, to determine how many visitors to a page, to help you sign up for our services, to protect your data, or to remember your ad settings. You can visit the link to see a list of the types of cookies used by Google.


https://policies.google.com/technologies/cookies?hl=tr


Duration of Use


Persistent cookies, Session cookies


Functional Cookies


These cookies enable our website to offer richer functionality and personalization based on your previous visits and choices on our site. Functional cookies allow the choices you make on our website (such as your username, language, or the region you are in) to be remembered and provide enhanced, more personalized uses. For example, these cookies can be used to remember changes you have made to text size, fonts and other parts of our web pages that you can customize.


Targeting and Promotional Cookies


We use these cookies to deliver ads that are more relevant to you and your interests. It is also used to limit the number of times you see an ad and measure the effectiveness of an ad campaign. These cookies remember that you visit our website and use this information to tailor ads for our products and services when you visit third-party websites.


These cookies can be placed on our website by our business partners. These may be used and shared by these companies to create a profile of your interests and to provide you with relevant advertisements on other sites.


Third-Party Cookies


KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. We work with a number of business partners who can also place cookies on your device on our behalf when you visit our website so that our business partners can offer their advertisements to you in their respective areas. We strive to identify and promote these cookies before they are used so that you can decide whether you want to accept these cookies.


Cookie Name


Facebook


Purpose of usage


Cookies; It helps us deliver, protect and improve Facebook Products by personalizing content, customizing ads, measuring ad results, providing a safer experience. In parallel with the developments and updates we make to Facebook Products, we may change the cookies we use from time to time, but we always use it for the following purposes:


• We use cookies to verify your account and to determine that you are logged into your account. In this way, we can make it easier for you to access Facebook Products and provide you with appropriate experience and features.

• We use cookies to keep your account, data and Facebook products safe and secure.

• We use cookies to show advertisements and make recommendations of businesses and other organizations to people who may be interested in the products, services, or the purposes they are associated with.

• We use cookies to be able to run functions that help us provide Facebook products.

• We use cookies to give you the best possible experience.

• We use cookies to better understand how people use Facebook products and to improve these services.


For more information on using Facebook Pixel, you can visit:


https://www.facebook.com/about/privacy


Duration of Use


Persistent cookies, Session cookies


Cookie Name


Gemius Prism


Purpose of usage


Gemius stores cookies information about visitors' activity on websites and their interaction with the advertisements displayed (e.g. number of views (hits), time spent on the website watched, technical data of the device used (screen resolution, operating system) or an IP number). This information about activities on the Internet is organized for statistical purposes and to provide other services. While these statistics are provided, personal data are not shared. Relevant cookie data are not used for any retatgeting or media purchases without the consent of the company. The relevant analytics data belongs to the company. Information about clicks or ad emissions, the content viewed by users can be used for optimization as needed. GemiusPrism codes are asynchronous codes, there will be no basket to slow down on your site.


For more information about Gemius cookie usage, you can visit:


https://www.gemius.com/cookie-policy.html


Duration of Use


Persistent cookies, Session cookies


Preventing the use of cookies


Below is information on what steps should be followed to prevent the use of cookies on different internet browsers.


Internet Explorer


1. Open the desktop and tap or click the Internet Explorer icon on the taskbar.

2. Tap or click the Tools button and Internet options.

3. Tap or click the Privacy tab, then move the slider under Settings up and tap or click the OK button to block all cookies.


Microsoft Edge


1. Click the three-dot section in the upper right corner of your Microsoft Edge browser and navigate to the Settings section.

2. In the new window that comes up, after you say Select Items to Clean, select the sections you want to clean from the window that appears.

3. There are many sections here. You can start the cleaning process by choosing the one you want.


Google Chrome


1. Open Chrome on your computer.

2. Click More Settings at the top right.

3. Click Advanced at the bottom.

4. Click Content settings under Privacy and security.

5. Click on Cookies.

6. Look for the name of the Website under All cookies and site data.

7. Click the Uninstall icon to the right of the site.


Mozilla Firefox


1. Click the Firefox Menu button and select Options.

2. Select the Privacy and Security panel and go to the History section.

3. Change the Firefox setting to Let use custom settings for history.

4. Click the Show cookies button. Cookies window will appear.

5. In the search field, type the name of the site whose cookies you want to delete. Cookies matching your search will be displayed.

6. Select the cookie (s) you want to delete and click the Delete selected button.

7.Cookies window by clicking the Close button.

Close it. Then close the about preferences page.


• Safari


1. Choose Safari> Preferences.

2. Click Privacy.

3. Click Website Data.

4. Select one or more websites, and then click Delete or Delete All.


You can find more information about how to do this in other main web browsers at https://www.esb.org.tr/cerez-bellek or https://www.aboutcookies.org.


You can also delete it through any cookie third party software left behind by the websites you visit. The following links contain detailed information on how to manage (and disable) cookies in some commonly used browsers:


Chrome Browser: https://support.google.com/accounts/answer/61416?hl=en

Internet Explorer: https://support.microsoft.com/tr-tr/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox: https://support.mozilla.org/tr/products/firefox/protect-your-privacy/cookies

Safari: https://support.apple.com/tr-tr/guide/safari/manage-cookies-and-website-data-sfri11471/mac


YOUR RIGHTS IN ACCORDANCE WITH THE PROTECTION OF PERSONAL DATA


We would like to state that you have the following rights in relation to your personal data in accordance with the provisions of Article 11 of the Law


• Learning whether personal data is processed,

• Requesting information if personal data has been processed,

• Learning the purpose of processing personal data and whether they are used appropriately for their purpose,

• To know the third parties in the country or abroad to whom personal data have been transferred,

• To request correction of personal data if it is incomplete or incorrectly processed,

• Requesting the deletion or destruction of personal data,

• In case personal data is corrected, deleted or destroyed, requesting that these transactions be notified to third parties to whom personal data have been transferred,

• Object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,

• To demand the compensation of the damage in case of damage due to the unlawful processing of personal data.


In accordance with the text "Information Regarding Application Form" within the scope of KVKK, you can send your requests regarding your rights stated above; COMPANY FULL TITLE (Mersis No: 0524131944000001) ADALET MAH. MANAS BLV. FOLKART TOWERS NO: 47 B İÇ KAPI NO: 2601 BAYRAKLI / İZMİR via your e-mail address registered in our system to the e-mail address [email protected], regardless of being registered in our system, by using mobile signature / e-signature kvkk @karmigame.com You can send it to karmigame.com e-mail address or via KEP to [email protected]


Your application is KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. Within the scope of the provisions of the KVK Law and Communiqué, your application will be answered within thirty days from the date we receive it, and the response will be sent to you in writing or electronically. Within the scope of the applications made, KARMİ BİLGİ TEKNOLOJİLERİ A.Ş. As a rule, it does not charge any fees, but if the transaction requires additional costs, the fees determined by the Board may be charged.