PERSONAL DATA PROTECTION AND PRIVACY POLICY

As the “Company”, we would like to inform you that we attach great importance to the protection of your personal data and that we take all necessary measures in compliance with the applicable legal regulations.

Our Company takes the necessary precautions to protect the personal data of our valued members and customers, franchisees, dealers, business partners, shareholders, employees, job applicants, visitors to our website, and all other natural persons who establish any form of relationship with us. In this context, we have prepared this Personal Data Protection and Privacy Policy (“Privacy Policy”) in order to inform you about our Company’s rules and policies regarding the processing of personal data and the use of cookies and similar technologies in accordance with the Law No. 6698 on the Protection of Personal Data (“KVK Law”).

We would like to remind you that, in all matters regarding the confidentiality, protection, processing, use, modification, and communication of member and customer information within our Company, website, and mobile applications, you will be subject to this Privacy Policy, and that you should review this text each time you use our website to ensure that you accept its terms.

As the data controller, depending on the type and nature of the relationship between our Company and the data subject, our Company may provide different personal data policies and/or notices other than this text. In such cases, the specific policies and notices provided to the data subject may include provisions that differ from or supplement those set forth in this Privacy Policy, and such specific policies and notices shall prevail.

1. LEGAL BASIS AND GENERAL PRINCIPLES

1.1. Legal Basis

The protection of personal data is regulated primarily by the Law No. 6698, as well as:

Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed through Such Publications,

Law No. 6563 on the Regulation of Electronic Commerce,

Turkish Penal Code No. 5237,

and the relevant secondary legislation.

1.2. Definition of Personal Data

Under the KVK Law, “personal data” refers to any information relating to an identified or identifiable natural person. Anonymous data, anonymized data, and data that cannot be associated with a specific person are not considered personal data within the scope of this Privacy Policy.

1.3. Definition of Data Processing

Processing of personal data refers to any operation performed on personal data, whether fully or partially automated or non-automated as part of a data recording system, such as collection, recording, storage, retention, alteration, reorganization, disclosure, transfer, acquisition, making available, classification, or prevention of use.