DOĞANLAR MOBİLYA GRUBU İMALAT SAN. VE TİC. A.Ş. WEBSITE CLARIFICATION TEXT WITHIN THE SCOPE OF THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

Website: https://www.doganlarmobilyagrubu.com

Phone Number: +90 216 425 00 02

E-Mail Address: [email protected]

Address: Kosifler Plaza, İçerenköy Mah. Sibel Sok. No:19, Ataşehir / Istanbul

This Clarification Text has been prepared by Doğanlar Mobilya Grubu İmalat San. ve Tic. A.Ş. (“Doğanlar Mobilya”), acting as the data controller, in order to inform you within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data (“Law”) and the Communiqué on the Procedures and Principles to be Followed in Fulfillment of the Obligation to Inform.

Pursuant to the provisions of the Law, any information that identifies or makes you identifiable is considered “Personal Data” and shall be processed by Doğanlar Mobilya, acting as the Data Controller, within the scope described below.

“Processing of Personal Data” refers to any operation performed on personal data, including obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying, or preventing the use of such data.

With full awareness of this responsibility and as the Data Controller, we process your personal data in the manner explained below and within the limits prescribed by applicable legislation.

This Clarification Text becomes effective as of the date it is published by our Company. Doğanlar Mobilya reserves the right to amend this Clarification Text whenever necessary. Any amendments shall become effective immediately upon publication at https://www.doganlarmobilyagrubu.com/.

Purposes of Obtaining, Processing and Using Your Personal Data by Our Company

Your personal data may be collected through our stores and face-to-face channels by non-automatic methods if you sign contracts, undertakings and other forms, or through digital sales contracts by fully or partially automated methods.

Your personal data may also be collected through call centers, websites, mobile applications, online applications, cookies, social media channels, text messages, e-mails and voice response systems by fully or partially automated methods, and processed in accordance with the legislation on the protection of personal data for the purposes and legal grounds stated below.

Our Company processes personal data within the scope of its activities in accordance with the relevant legislation and for the purposes listed below.

1. Identity Information

Processed Personal Data: Name and surname, gender, date/place of birth, signature, identity document copy, marital status, passport information, passport copy, Turkish Republic identity number, nationality information.

Purposes of Processing Personal Data:

• Execution of information security processes
• Creation of current account records
• Conducting activities in compliance with legislation
• Execution of finance and accounting affairs
• Execution of loyalty processes for company/products/services
• Follow-up and execution of legal affairs
• Execution of communication activities
• Execution of business continuity activities
• Execution of logistics activities
• Execution of after-sales support services for goods/services
• Execution of sales processes for goods/services
• Execution of production and operation processes for goods/services
• Execution of customer relationship management processes
• Execution of activities aimed at customer satisfaction
• Hotel reservation
• Execution of marketing analysis activities
• Execution of advertising/campaign/promotion processes
• Execution of social responsibility and civil society activities
• Execution of contract processes
• Execution of strategic planning activities
• Execution of marketing processes for products/services
• Ensuring the security of data controller operations
• Providing information to authorized persons, institutions and organizations
• Reporting to management
• Execution of management activities

Legal Grounds for Processing Personal Data:

The personal data specified in this Clarification Text are processed by Doğanlar Mobilya for the purposes listed above based on the following legal grounds set forth under Article 5 of the Law and the relevant legislation:

• It is explicitly provided for by laws,
• Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract,
• Processing is necessary for the data controller to fulfill its legal obligation,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

2. Contact Information

Processed Personal Data: Address, phone number, e-mail address.

Purposes of Processing Personal Data:

• Creation of current account records
• Execution of access authorization processes
• Execution of finance and accounting affairs
• Execution of loyalty processes for company/products/services
• Follow-up and execution of legal affairs
• Execution of communication activities
• Execution of business continuity activities
• Execution of logistics activities
• Execution of after-sales support services for goods/services
• Execution of sales processes for goods/services
• Execution of production and operation processes for goods/services
• Execution of customer relationship management processes
• Execution of activities aimed at customer satisfaction
• Execution of marketing analysis activities
• Execution of advertising/campaign/promotion processes
• Execution of contract processes
• Execution of strategic planning activities
• Meeting organization
• Execution of marketing processes for products/services
• Ensuring the security of data controller operations
• Providing information to authorized persons, institutions and organizations

Legal Grounds for Processing Personal Data:

Your personal data within this scope are processed by Doğanlar Mobilya for the purposes listed above based on the following legal grounds set forth under Article 5 of the Law and the relevant legislation:

• It is explicitly provided for by laws,
• Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract,
• Processing is necessary for the data controller to fulfill its legal obligation,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

3. Transaction Security Information

Processed Personal Data: Credit card information, payment amount, expenditure amount, password.

Purposes of Processing Personal Data:

• Execution of finance and accounting affairs
• Execution of access authorization processes

Legal Grounds for Processing Personal Data:

• It is explicitly provided for by laws,
• Processing is necessary for the data controller to fulfill its legal obligation,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

4. Personnel Information

Processed Personal Data: Bank account information, number/ages/education details of children, activity certificate, job/occupation, IBAN information, signature circular, lease agreements, graduation information, tax certificate, tax number.

Purposes of Processing Personal Data:

• Execution of finance and accounting affairs
• Execution of loyalty processes for company/products/services
• Follow-up and execution of legal affairs
• Execution of communication activities
• Execution of business continuity activities
• Execution of after-sales support services for goods/services
• Execution of sales processes for goods/services
• Execution of production and operation processes for goods/services
• Execution of customer relationship management processes
• Execution of activities aimed at customer satisfaction
• Execution of marketing analysis activities
• Execution of advertising/campaign/promotion processes
• Execution of contract processes
• Execution of strategic planning activities
• Execution of marketing processes for products/services
• Providing information to authorized persons, institutions and organizations

Legal Grounds for Processing Personal Data:

• It is explicitly provided for by laws,
• Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract,
• Processing is necessary for the data controller to fulfill its legal obligation,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

5. Risk Management Information

Processed Personal Data: Findeks report.

Purposes of Processing Personal Data:

• Follow-up and execution of legal affairs
• Execution of communication activities
• Execution of business continuity activities
• Execution of after-sales support services for goods/services
• Execution of sales processes for goods/services
• Execution of production and operation processes for goods/services
• Execution of customer relationship management processes
• Execution of contract processes
• Providing information to authorized persons, institutions and organizations

Legal Grounds for Processing Personal Data:

• Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract,
• Processing is necessary for the data controller to fulfill its legal obligation,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

6. Visual and Audio Records

Processed Personal Data: Photograph, voice recording, meeting records including video/audio, video, video recording.

Purposes of Processing Personal Data:

• Use in R&D activities
• Improving product recommendations and recommending products according to customer needs
• Follow-up and execution of legal affairs
• Execution of communication activities
• Execution of sales processes for goods/services
• Execution of customer relationship management processes
• Execution of activities aimed at customer satisfaction
• Execution of advertising/campaign/promotion processes
• Execution of social responsibility and civil society activities
• Execution of marketing processes for products/services
• Ensuring the security of data controller operations

Legal Grounds for Processing Personal Data:

• It is explicitly provided for by laws,
• Processing is necessary for the data controller to fulfill its legal obligation,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

7. Legal Transaction Information

Processed Personal Data: Data contained in case files.

Legal Grounds for Processing Personal Data:

Your personal data within this scope are processed by Doğanlar Mobilya for the purposes listed above based on the following legal grounds set forth under Article 5 of the Law and the relevant legislation:

• Processing is necessary for the establishment, exercise or protection of a right,
• Processing is necessary for the data controller to fulfill its legal obligation,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

8. Financial Information

Processed Personal Data: Check, mortgage document, letter of guarantee.

Purposes of Processing Personal Data:

• Conducting activities in compliance with legislation
• Execution of finance and accounting affairs
• Execution of sales processes for goods/services

Legal Grounds for Processing Personal Data:

• Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract,
• Processing is necessary for the data controller to fulfill its legal obligation.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

9. Professional Experience Information

Processed Personal Data: Company information, job/occupation, title.

Purposes of Processing Personal Data:

• Execution of finance and accounting affairs
• Execution of after-sales support services for goods/services
• Execution of sales processes for goods/services
• Execution of production and operation processes for goods/services
• Execution of customer relationship management processes
• Execution of activities aimed at customer satisfaction
• Execution of advertising/campaign/promotion processes
• Ensuring the security of data controller operations

Legal Grounds for Processing Personal Data:

• Your personal data within this scope are processed by Doğanlar Mobilya for the purposes listed above based on Article 5 of the Law and the relevant legislation,
• Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract,
• Processing is necessary for the data controller to fulfill its legal obligation,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

10. Customer Transaction Information

Processed Personal Data: Invoice, warranty certificate, customer number, order information, complaint information, request/complaint/suggestion information, sleeping position.

Purposes of Processing Personal Data:

• Use in R&D activities
• Execution of finance and accounting affairs
• Execution of loyalty processes for company/products/services
• Execution of communication activities
• Execution of business continuity activities
• Execution of after-sales support services for goods/services
• Execution of sales processes for goods/services
• Execution of production and operation processes for goods/services
• Execution of customer relationship management processes
• Execution of activities aimed at customer satisfaction
• Execution of marketing analysis activities
• Execution of advertising/campaign/promotion processes
• Execution of strategic planning activities
• Execution of marketing processes for products/services
• Improving product recommendations and recommending products according to customer needs
• Execution of management activities
• Reporting to management

Legal Grounds for Processing Personal Data:

• It is explicitly provided for by laws,
• Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract,
• Processing is necessary for the data controller to fulfill its legal obligation,
• Processing is necessary for the establishment, exercise or protection of a right,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

11. Marketing

Processed Personal Data: Survey data.

Purposes of Processing Personal Data:

• Execution of communication activities
• Execution of activities aimed at customer satisfaction
• Execution of advertising/campaign/promotion processes

Legal Grounds for Processing Personal Data:

Your personal data within this scope are processed by Doğanlar Mobilya for the purposes listed above based on the legal ground that processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject, as set forth under Article 5 of the Law and the relevant legislation.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

12. Body Measurements

Processed Personal Data: Height, weight.

Purposes of Processing Personal Data:

• Use in R&D activities
• Improving product recommendations and recommending products according to customer needs
• Execution of sales processes for goods/services
• Execution of advertising/campaign/promotion processes

Legal Grounds for Processing Personal Data:

• Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract,
• Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases outside the scope of the purposes listed above, your personal data are processed based on your explicit consent, the details of which are specified in the Explicit Consent Text.

Sharing of Your Personal Data

• Doğanlar Mobilya transfers your personal data to the recipient groups listed below in accordance with the purposes set forth in this Clarification Text and the applicable legal grounds, within the scope of the Law and other relevant legislation, by taking the necessary technical and administrative measures and only to the extent required for the relevant purpose.
• Your personal data may be transferred to domestic and foreign group companies listed at https://www.doganlarmobilyagrubu.com/hakkimizda, authorized persons acting on behalf of Doğanlar Mobilya, or to our affiliates and subsidiaries listed at the same address, limited to the purposes listed above.
• Your personal data may be transferred to suppliers and business partners we work with for the provision or delivery of the products and services you wish to purchase or use.
• Your personal data may be transferred to business partners, supplier companies, banks and financial institutions with whom cooperation is established and/or from whom services are received for the purposes of providing and promoting products and services.
• Your personal data may be transferred to lawyers, auditors, consultants and service providers.
• Your personal data may be transferred to your attorneys, guardians and representatives authorized by you.
• Your personal data may be transferred to authorized institutions, organizations and persons who are entitled to request personal data under the relevant legislation and legal obligations.
• Your personal data may be shared with hospitals and healthcare institutions for emergency medical interventions and for fulfilling occupational health and safety obligations.
• Necessary technical and legal measures are taken to prevent violations of rights during the sharing of data with third parties.

Retention Periods of Your Personal Data

In accordance with the Law and relevant legislation, your personal data will be retained throughout the period during which the services are provided, for the purpose of fulfilling obligations arising from the nature of the services we provide, and thereafter for reasonable periods in accordance with the relevant legislation in order to fulfill legal obligations.

In addition, in the event of a potential dispute, your personal data may be retained for the limitation periods prescribed under the relevant legislation, limited to the purpose of carrying out necessary defenses within the scope of such dispute.

Cases Where Explicit Consent Is Not Required for the Processing of Personal Data Under the KVKK

Personal data may be processed without explicit consent if at least one of the following conditions exists:

• It is explicitly provided for by laws,
• Processing is necessary for the protection of the life or physical integrity of the person who is unable to express consent due to actual impossibility or whose consent is not legally valid,
• Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract,
• Processing is necessary for Doğanlar Mobilya to fulfill its legal obligation,
• The personal data have been made public by the data subject,
• Processing is necessary for the establishment, exercise or protection of a right,
• Processing is necessary for the legitimate interests of Doğanlar Mobilya, provided that it does not harm the fundamental rights and freedoms of the data subject.
• In addition, your personal data relating to health and sexual life may be processed without explicit consent by Doğanlar Mobilya only for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, and planning and managing healthcare services and their financing.

Your Rights Arising from the Law on the Protection of Personal Data

Pursuant to Article 11 of the Law, you may apply to Doğanlar Mobilya through the methods specified in the “Contact” section of this Clarification Text and exercise the following rights:

• To learn whether your personal data are being processed,
• To request information if your personal data have been processed,
• To learn the purpose of processing your personal data and whether they are used in accordance with such purpose,
• To know the third parties to whom your personal data have been transferred domestically or abroad,
• To request correction if your personal data have been processed incompletely or inaccurately,
• To request deletion or destruction of your personal data within the framework of the conditions set forth under Article 7 of the Law,
• To request notification of the correction, deletion or destruction transactions to third parties to whom your personal data have been transferred,
• To object to the occurrence of a result against you through the analysis of your processed personal data exclusively by automated systems,
• To claim compensation if you suffer damage due to unlawful processing of your personal data.

If the processing of your request requires an additional cost, you may be required to pay the fee determined by the Personal Data Protection Board.

Your requests included in your application will be concluded as soon as possible and no later than 30 (thirty) days, depending on the nature of the request.

Rights relating to personal data may only be exercised by individuals with respect to their own personal data.

Contact

You may submit your requests regarding the implementation of the Law and your questions regarding your personal data through one of the following methods:

• By using the e-mail address previously notified to Doğanlar Mobilya and registered in the Company’s system, you may submit your request prepared in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller to [email protected].
• After downloading the “Application Form Regarding Personal Data” to your device and filling it out digitally, you may submit it via your registered electronic mail address (KEP) to [email protected].
• After printing the form, you may fill it out in writing and send it together with documents verifying your identity to the following address by post or through a notary:
  DOĞANLAR MOBİLYA GRUBU İMALAT SAN. TİCARET A.Ş. Kosifler Plaza, İçerenköy Mah. Sibel Sok. No:19, Ataşehir / Istanbul

For applications submitted in writing, Doğanlar Mobilya reserves the right to request additional information and/or documents in order to verify your identity and ensure data security.