As GFC Retail Consulting, we attach great importance to the privacy and security of your personal data.

In this context, all kinds of personal data belonging to all persons related to GFC Retail Consulting, including our customers who benefit from our products and services and our business contacts, are processed in accordance with the Law on Protection of Personal Data No. 6698 (“KVKK”), and Storage is one of our priorities. We would like to inform you as follows about the purposes of processing your personal data, the methods and reasons for the collection of your data, your rights regarding the processing of your personal data, and the application procedures and principles, which are the method of exercising these rights, with the title of "Data Controller" we carry pursuant to KVKK and with the awareness of this responsibility.

a. What is Personal Data? What Personal Data do we collect?

Personal data, personal information about your identity (name, surname, TR identity number, etc.), address and phone information, vehicle and plate information, family status information, IP address, bank account information, such as all kinds of can be associated with you. Information (“Personal Data”) and Special Quality Personal Data, which is a special type of it, is based on race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, dress, association, foundation or union membership, health, means sensitive personal data such as your data on sexual life, criminal convictions and security measures, and your biometric and genetic data (“Special Quality Personal Data”). The explanations we make for your Personal Data on this page also include your Special Personal Data.

In this context, as GFC Retail Consulting, when necessary, in accordance with the KVKK, our customers, business contacts, employees, employee candidates, platform (internet / mobile sites and applications) users, visitors, subcontractors and similar business relationships We collect Personal Data of the authorities and employees of the institution we are in. We may detail the Personal Data we collect as follows:

• Identity Data: Name, surname, T.R. It is data about the identity of the person, such as identity number, identity photocopy.
• Contact Data: Telephone numbers, addresses, e-mail addresses that we collect from our customers, business contacts, employees, employee candidates, platform (internet / mobile sites and applications) users, visitors, and subcontractors and similar corporate officials and employees Data that enables communication with the person, such as IP address.
• Data of Family Members: Data about the family members and relatives of the person concerned, which we collect from our employees, employee candidates, subcontractors and similar institutions with whom we have a business relationship, in accordance with the relevant legislation and/or in order to protect the legal and other interests of our Company or the person concerned.
• Financial Data: Data such as wages, salary information, bank account information that we collect from our employees, employee candidates, customers, business contacts, subcontractors and similar institutions and employees, according to the legal relationship our company has established with the data subject.
• Physical Space Security Data: These are personal data such as security and camera recordings taken from our customers, business contacts, employees, employee candidates, visitors and officials and employees of the institutions with which we have subcontractors and similar business relations, at the entrance to the physical space and during their stay.< /li>
• Communication and Complaint Management Data: Obtained from our customers, business contacts, platform (internet / mobile sites and applications) users, visitors, subcontractors and officials and employees of institutions with which we have a similar business relationship, in the process of receiving and evaluating all kinds of requests or complaints against our company. are personal data.
• Special Quality Personal Data: Health data, biometric data (audio and video recordings) specified in Article 6 of the KVKK that we collect from our customers, business contacts, employees, employee candidates, visitors, subcontractors and similar institutions officials and employees. data such as religion, association and union information.
• Other Data: Data processed for technical transaction security, purchasing information, which we collect from our customers, business contacts, employees, employee candidates, platform (internet / mobile sites and applications) users, and subcontractors and similar corporate officials and employees, It is the data collected by automatic means with cookies and other means.

b. What Methods and Legal Reasons Do We Collect / Process Your Personal Data?

We collect your Personal Data automatically or non-automatically, verbally, verbally, in writing or electronically, through the following main purposes and methods and other channels that may be added to them in the future.

Your Personal Data can be shared on our internet and mobile platforms (internet / mobile sites and applications), various social media channels, GFC Retail Consulting . Through our social media accounts operated on behalf of Kit Group Promotion, through our call center managed by Kit Group Promotion Marketing and other communication methods including e-mail, short messages (“SMS”) or multimedia messages (“MMS”) Within the scope of the sales and marketing activities of Pazarlama Ticaret A.Ş, through the Contracts we signed with you or your company, of which you are authorized, commercial offers, printed and electronic forms, business cards and other documents given by you within the scope of our customer visits, Kit Group Promotion Pazarlama Ticaret A.Ş group companies, through third parties such as business contacts, dealers and sales channels, manufacturers or companies that supply services/products, and through various channels, including sources such as the Trade Registry, verbally, in writing or in electronic form, fully or partially, automatically or in any form. We collect it by various non-automatic methods as part of the data recording system.

We process your Personal Data, which we collect in accordance with the above methods, based on one or more of the following legal reasons:

• Your explicit consent,
• Provisions of laws and regulations in force in the Republic of Turkey allow processing,
• When you are unable to express your consent due to actual impossibility, it is compulsory for the protection of your person's or someone else's life or bodily integrity,
• It is necessary for the performance of the contract we have concluded with you or your company,
• It is necessary to process your Personal Data in order to fulfill our legal obligations,
• Your Personal Data has been made public by you,
• GFC Retail Consulting is necessary for the exercise or protection of our legal or contractual rights,
• The processing of your Personal Data is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms.

As Kit Group Reklam Pazarlama Ticaret A.Ş, we keep all Personal Data we process in accordance with the periods required by the KVKK and other legislation, and in any case, by taking all necessary administrative and technical measures, as long as the above legitimate purposes are not eliminated.

c. For What Purpose We Process Your Personal Data?

We process your Personal Data we collect for the following general purposes, depending on its nature:

1. Fulfilling the requirements of the contracts concluded by Kit Group Promotion Marketing and Trading Inc., supplying the products and services offered, performing the production, sales, delivery and installation processes, developing products and services and making the necessary studies and evaluations to benefit you, sales Performing post-maintenance and repair operations
2. Following and realizing the obligations arising from consumer legislation and responding to consumer applications
3. Following up and evaluating the demands and complaints of relevant persons such as customers and consumers, providing support services, consumer satisfaction management and implementation of planning, statistics and satisfaction surveys in this context
4. Performing quality assessment and improvement studies in order to provide better and reliable products and services and to ensure sustainability, auditing of suppliers, subcontractors and similar business relations
5. Carrying out advertisement and marketing activities for the products and services offered by GFC Retail Consulting, informing about promotion, promotion, campaign, offer, event and similar issues and new products and services, carrying out corporate communication activities
6. Executing Marketing and CRM (Customer Relationship Management) studies
7. Organization of corporate communication and other events and invitations within this scope and providing information about them, conducting market research studies
8. In order to improve the digital platforms we offer to our customers, consumers and business contacts and to provide an efficient and personalized experience to the platform users, the number, type, frequency of visits, behaviors, geographical locations and similar statistics of the users of the platform (internet and mobile sites and applications) Providing personalized content, campaigns and advertisements according to their interests and needs, using cookies for this purpose
9. GFC Retail Consulting Ensuring the legal and commercial security of the people who have a business relationship with our company (planning the administrative operations for communication carried out by our company, ensuring the physical security and supervision of the locations of the Company, evaluation and audit processes of the business partner / customer / supplier (authorized or employees), legal compliance process, etc. .)
10. Exercise of legal rights, use of information regarding the transaction history as evidence in case of dispute after the termination of the legal relationship
11. Determination and implementation of commercial, legal and business strategies of Kit Group Promotion Pazarlama Ticaret A.Ş.
12. Execution of human resources, accounting/financial policies of Kit Group Promotion Pazarlama Ticaret A.Ş.
13. Planning, auditing and executing information security processes
14. Compliance with domestic and international legislation, provision of information requested by public institutions and organizations, fulfillment of reporting obligations.

d. Transfer of Personal Data and Processing of Personal Data by Third Parties

The Company may transfer personal data to a third natural or legal person in accordance with KVKK regulations. In this case, the Company ensures that the third parties it transfers also comply with this Policy. In this context, necessary protective regulations are added to the contracts concluded with third parties.

• Transfer of personal data to third parties in Turkey; Personal Data may be transferred by the Company to third parties in Turkey without seeking explicit consent in exceptional cases specified in Article 5.2 and Article 6.3 of the KVKK, or by obtaining the explicit consent of the Relevant Person in other cases (Article 5.1 and Article 6.2 of the KVKK). >
• Transfer of personal data to third parties abroad; Personal Data may be transferred by the Company to third parties abroad, without seeking explicit consent in exceptional cases specified in Article 5.2 and Article 6.3 of the KVKK, or by obtaining the explicit consent of the Relevant Person in other cases (Article 5.1 and Article 6.2 of the KVKK). However, one of the following conditions is required for the foreign country to be transferred.
• The foreign country to which personal data is transferred has the status of countries with adequate protection by the Board
• In the event that the foreign country where the transfer will take place is not included in the safe countries list of the Board, provided that the Company and the Data Controllers in the relevant country make a written commitment to ensure adequate protection and obtain permission from the Board

e. Your Rights and Application Procedure

e.1. Your Rights Regarding Your Personal Data

GFC Retail Consulting We would like to point out that you have the following rights regarding your data being processed within the scope of our company and its subsidiaries:

1. Learning whether your Personal Data is processed,
2. Getting information about your Personal Data if it is being processed
3. Learning what is the purpose of processing your Personal Data and whether your personal data is used in accordance with its purpose,
4. Learning who the third parties are, if any, to whom the data is transferred at home or abroad, and which data is transferred,
5. Requesting correction of the processed Personal Data if it is incomplete or incorrect,
6. In case of correction, deletion or destruction of your personal data, requesting the notification of these processes to the third parties to whom your Personal Data has been transferred,
7. To request the deletion or destruction of your processed Personal Data, in case the reasons requiring the processing of your Personal Data disappear or your Personal Data loses its up-to-dateness,
8. Objecting to the emergence of a result against you by analyzing your processed Personal Data exclusively through automated systems,
9. You have the right to demand the compensation of the damage if you suffer damage due to the unlawful processing of your Personal Data.

e.2. Application

Your requests regarding your Personal Data, by filling out the application form linked below:

1. Delivery to the information office at our company address in the Data Controller Identity information field or by sending a notification to the same address via a Notary,
2. Can be done via registered e-mail.

Kit Group Promotion Pazarlama Ticaret A.Ş will conclude the requests made to it free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. If a cost arises due to the fulfillment of your requests, we can only charge you the fees in the tariff determined by the Personal Data Protection Board.

As a result of the requests made, we can accept the requests or reject them by explaining the reason, and we can forward this response to the requester in writing or electronically. If the request is accepted, we, as GFC Retail Consulting, are obliged to fulfill the request immediately.

e.3. Complaint

If the requests you have made to GFC Retail Consulting are rejected by GFC Retail Consulting, if you are not satisfied with the response given by GFC Retail Consulting or if the response is not given, then 30 (30) days from the date of notification of the response to you. thirty) days and in case of no response, you can file a complaint to the Personal Data Protection Board within 30 days from the end of the 30 (thirty) day period.

f. Data Controller Credentials

The term GFC Retail Consulting used in this text has been prepared for the subsidiary of GFC Retail Consulting, which is established in Turkey and whose information is given below, and is addressed to the data subjects for whom the following company is the data controller:

GFC Retail Consulting

Address: Küçükbakkalköy Mahallesi Çınar Sokak No:21 Ataşehir/Istanbul/Türkiye

Phone: +90 216 572 0 572

E-Mail: info@gfcretail.com

Application Form within the Scope of KVKK

To the personal data owners defined as the data subject in the Law on the Protection of Personal Data No. 6698 (hereinafter referred to as the "Applicant"), certain requests regarding the processing of their personal data in Article 11 of the KVK Law right to exist. In accordance with the first paragraph of Article 13 of the KVK Law; Applications regarding these rights to our Company, which is the data controller, must be submitted to us in person, in writing in Turkish, and by the following methods determined by the Personal Data Protection Board (“Board”).

The following is information on how to send written applications to us.

According to the Communiqué on the Procedures and Principles of Application to the Data Controller (OG dated 10/03/2018 and numbered 30356), the following information must be present in the applications.

Information to be filled during the application:

• Name, surname and signature if the application is written,
• For citizens of the Republic of Türkiye, T.R. identification number, nationality for foreigners, passport number or identification number, if any,
• Domain or workplace address for notification,
• E-mail address, telephone and fax number for notification, if any,
• Subject of the request

In addition, information and documents related to the subject are attached to the application.

In case you want to make an application regarding your personal data, the following application form must be filled in completely. This application form is prepared to determine your relationship with our Company, to fully identify your personal data processed by our Company, if any, and to respond to your application in a correct and legal time. has been done. In order to eliminate the legal risks that may arise from illegal and unfair data sharing and to ensure the security of your personal data, our Company reserves the right to request additional documents and information (copy of identity card or driver's license, etc.) for identification and authorization. In the event that the information regarding your requests you submit within the scope of the form is not correct and up-to-date or an unauthorized application is made, our Company does not accept any liability for such wrong information or requests arising from unauthorized applications.

Your applications submitted to us will be answered free of charge within thirty days at the latest from the date of receipt of your request, in accordance with the second paragraph of Article 13 of the KVK Law, depending on the nature of the request.