Personal Data Protection Law (KVKK)

ECN Cosmetics Inc. (“ECN”), as the Data Controller under the Law No. 6698 on the Protection of Personal Data (“KVKK”/“Law”), presents the following explanations to the attention of its members, customers, and third parties using our website in order to fulfill its obligation to inform. ECN reserves the right to make changes to this Information Text as necessary, and such changes will become effective upon publication.

Personal data shared with ECN is under ECN's supervision and control. In accordance with the relevant provisions of applicable legislation, ECN, as the Data Controller, assumes responsibility for establishing the necessary organizational structure, taking and adapting technical measures to protect the confidentiality and integrity of your personal data.

This Privacy Notice informs you about the procedures and your rights regarding the processing, transfer, storage, and destruction of your personal data shared with ECN, as well as the use and protection of your personal data under the Law.

1. Legal Basis for the Collection of Personal Data and Personal Data Collected

The processing, transfer, storage, and destruction of your personal data are carried out within the framework of the law.

Depending on the nature of the products and services you will receive from ECN, and within the scope of the relationship we will establish; the type, nature, history of the relationship between ECN and the data subject, the method of obtaining the data, and the personal data processed in accordance with the principles in the Law and the ECN Personal Data Processing and Protection Policy are as follows:

• Identity Information: First name, last name
• Contact Information: Address, email, mobile phone.
• Shopping Information: Information about your purchase such as date, time, quantity, contents, payment method, and billing details.
• Financial Data: Credit card, debit card, or account information relating to payment transactions,
• Marketing Data: Purchase history information, surveys, behavioral and digital footprint information obtained through cookies when you use our websites, data obtained through campaign activities, and other personal data you personally provide in the context of your requests, suggestions and complaints, all collected with the permission of our customers, prospective customers and other relevant individuals.

2. Methods of Collecting Personal Data

Your personal data is collected by ECN during the online shopping services provided, and the collection of personal data, ____ This information can be obtained during a visit to our website (through membership, newsletter subscription), as well as via email and social media channels.

3. Reason for Processing Personal Data

Your personal data is used for the following purposes:

• In order to verify and confirm customer identity, and to identify customer information during transactions,
• Managing relationships with customers, support service providers, business partners or suppliers, recording addresses and other necessary information for conducting after-sales support services, sending orders to the reported addresses, and carrying out the procurement, sales processes and after-sales support services in relation to fulfilling the obligation arising under the contract.
• In order for payments to be processed for products purchased by customers,
• In accordance with the relevant articles of the Distance Selling Contract and the Law on Consumer Protection, we communicate with our customers regarding the terms, current status, and updates of the contracts we have concluded, provide necessary information, and fulfill the obligations undertaken pursuant to the contracts we have concluded.
• Planning, monitoring, and execution of information security processes.
  Establishing and managing information technology infrastructure, ensuring that data is up-to-date and accurate, maintaining accounting records,
• To organize all records and documents that will serve as the basis for processing, whether in electronic (internet/mobile, etc.) or physical form.
• To store, report, and inform judicial and administrative institutions that we have an obligation to provide information to, upon request or as required by law, regarding matters relating to public safety.
• To provide users with a better shopping experience, to inform our customers about our products that they may be interested in "by taking into account their interests", to communicate campaigns, to plan and carry out personalized sales and marketing activities with your permission, to conduct promotions and campaigns, and to inform you about campaigns conducted by our company,
• To increase user satisfaction, to get to know our customers who shop through the website and/or mobile applications and to use this information in customer base analysis, to use it in various marketing and advertising activities and to organize electronic and/or physical activities through contracted organizations within this scope, to carry out planning and statistical activities required by our Company and to determine the related commercial and business strategies,
• Through our partner institutions and solution providers, we can offer suggestions to our customers and inform them about our services.
• To evaluate customer complaints and suggestions regarding our services,
• In order to provide you with better and more reliable service, your personal data will be processed within the scope of the conditions and purposes for processing personal data specified in Articles 5 and 6 of the Law.

4. Third Parties to Whom Your Personal Data Is Transferred

The sharing of our customers' personal data with third parties takes place within the scope of the customers' consent, and as a rule, personal data is not transferred to third parties without the customer's approval. However, due to our legal obligations and limited to these, personal data is shared with public institutions and organizations and judicial authorities authorized to receive information under the law.

• The information of the Member Customer/Guest Customer and the person to whom the purchased product will be delivered, as well as the information of the person to whom the invoice will be issued, is shared with the shipping company for the purpose of sending the invoice and the relevant product to the relevant person.
• The phone numbers and/or email addresses of Member Customers/Guest Customers may be shared with the commercial electronic communication service provider for the purpose of conducting promotional and advertising campaigns, and offering benefits and opportunities in line with their shopping preferences, likes, and habits, based on their consent for commercial electronic communication.
• Website and application usage preferences and browsing history may be shared with our domestic and international business partners from whom we receive cookie services or newsletter subscription services, for the purpose of segmentation and communicating with Member Customers/Guest Customers according to their likes and preferences.
• Customer data may be shared with electronic money and/or payment service providers to enable payment processing for purchased products.
• Personal data may be shared with domestic/foreign, public/private institutions and organizations, suppliers, and other third parties or organizations from whom our company receives services, support, or consultancy, or with whom we collaborate, as well as with our consultants, shareholders, or solution partners and other group companies. It may also be shared with our domestic and/or foreign service providers who process personal data on behalf of our company in the areas of storage, archiving, and information technology support (servers, hosting, software, cloud computing, etc.).

In addition, personal data is transferred to contracted third parties in order to provide the services we have committed to and to perform quality control of the services provided. Your Personal Data may be shared with ECN's shareholders, program partner institutions and organizations with whom we cooperate to carry out our activities, domestic/foreign individuals and institutions from whom we receive cloud storage services, domestic/foreign organizations with whom we have agreements regarding sending commercial electronic messages to our customers, and various agencies, advertising companies and survey companies in Turkey and abroad, and other third parties and relevant business partners in Turkey and abroad within the scope of various marketing activities to provide you with better service and ensure customer satisfaction, including the planning and execution of necessary activities by the relevant business units to carry out the necessary work and related business processes within the limits committed to the performance of the commercial activities carried out by ECN, and the planning and execution of necessary activities to customize and recommend ECN's products and services to relevant individuals according to their preferences, usage habits and needs.

5. Rights of the Data Subject Whose Personal Data is Processed

In accordance with Article 11 of the Law, you have the following rights regarding your personal data.

• To find out whether your personal data is being processed,
• The right to request information regarding the processing of personal data.
• To learn the purpose of processing personal data and whether it is being used appropriately for that purpose.
• Knowing the third parties to whom personal data is transferred, whether domestically or internationally.
• Requesting the correction of personal data if it has been processed incompletely or inaccurately.
• Requesting the deletion or destruction of personal data,
• The right to request notification of corrections, deletions, or destructions of personal data to third parties to whom the personal data has been transferred.
• The right to object to an outcome that is detrimental to oneself, resulting from the analysis of processed data exclusively through automated systems.
• The right to claim compensation for damages incurred as a result of the unlawful processing of personal data.

6. If you wish to contact us regarding your rights and claims

In accordance with your legal rights stipulated in the relevant laws and other regulations, you can submit your requests using the attached “KVKK Application Form” to our address: Esentepe Mah. Büyükdere Caddesi Ferko Signature No:175/6 Şişli / İstanbul, either in person or via notary public. Alternatively, in accordance with Article 5 of the “Notification on the Procedures and Principles for Applications to the Data Controller,” you can send your request to __@__ using a registered electronic mail (“KEP”) address, secure electronic signature, mobile signature, or the email address you previously provided to the Company and which is registered in our systems.

Your requests submitted to our company will be answered in writing or electronically as soon as possible, and no later than 30 (thirty) days, depending on the nature of your request.

This Privacy Notice has been prepared to fulfill the obligation to inform pursuant to Article 10 of the Personal Data Protection Law (KVKK).