A PLACE

CLARIFICATION ON THE PROTECTION OF PERSONAL DATA AS PER LAW NO.6698
ON THE PROTECTION OF PERSONAL DATA (“LAW NO.6698”)

CLARIFICATION TEXT

A company duly incorporated under the laws of the Republic of Turkey; We, ECE Türkiye Proje Yönetimi A.Ş
Tax Registration Office: Bogazici Corporate Tax Office;
Tax ID: 570 011 0803 Trade Registry No: Istanbul Trade Registry Office no.446939;
MERSIS No: 0570011080300016;

“As the Company ”; Vacting in the capacity of the data controller within the scope of our business relations, hereby inform that:

Your personal data requested by us and/or that you shared with us, as applicable, shall be recorded, stored, maintained, reorganized, shared with institutions authorized to request such personal data as per applicable law in connection with, limited to, and to the extent necessary for the purpose of processing such personal data as well as they may be disclosed, transferred to, or categorized by third parties in Turkey subject to conditions set forth in the Law No.6698, and they may be processed in any other manner as defined in the Law No.6698 within the scope of the purpose necessary for processing such personal data thereof.

Your personal data that may be subject to processing are as follows:

PURPOSES FOR PROCESSING NATURAL PERSON CUSTOMER DATA

The Company may process your personal data for such purposes and reasons including but not limited to the following purposes and legal reasons thereof:

Your personal data shall be maintained for a period stipulated in the applicable regulations or as required for the purposes of processing such personal data.

Your aforementioned personal data are processed for the following purposes:

• Archiving your details on participating in and becoming eligible for shopping mall campaigns;
• Providing customer support and contacting the Customer as per Service Agreement;
• Contacting the Customer via telephone, e-mail, and SMS text message in order to inform the Customer about shopping mall campaigns and activities;
• Sending Customer customer-specific campaign offers based on the shopping activities of the Customer, and reporting;
• Control of Customer data and rights and informing the Customer upon Customer’s request;
• Ensuring that the rewards or gifts are sent to the Customer based on the customer-specific reward system;
• Ensuring the definition of Customer records as well as Customer inquiries;
• Creating the Customer record as well as creating Username, updating, and disabling the Customer record; and
• Reporting

We strive for continuous development and improvement so as to render services provided to our customers in the best way possible. In this regard, we may process your personal data for the following purposes:

• Performing quality control and improving the quality of services provided;
• Distinguishing between rightful and wrongful customers in case of customer complaints; improving customer satisfaction; understanding customer needs and ensuring the improvement of processes related to customers;
• Sending gifts to customers and their families;
• Conducting customer satisfaction analyses and questionnaires;
• Responding to incoming calls and ensuring support processes;
• Conducting customer satisfaction analyses regarding the services provided to customers;
• Contacting the customers regarding the services provided;
• Ensuring mass e-mail management;
• Conducting market research, sales and marketing analyses, administrative analyses, and financial planning;
• Interpretation of CRM (Customer Relationship Management) use;
• Ensuring efficient operation of customer database; and
• Ensuring continuous progression of research and development activities.

SHARING CUSTOMER/POTENTIAL CUSTOMER NATURAL PERSON REPRESENTATIVE DATA WITH THIRD PARTIES

In the following cases, we may share your personal data with third parties in Turkey and abroad:

We strive for continuous development and improvement so as to render services provided to our customers in the best way possible. In this regard, we may share your personal data with third parties in Turkey and abroad for the following purposes:

We may send you gifts in order to thank you for working with us, to celebrate and congratulate you on your special occasions. In order for us to send these gifts to you, we may share your personal data such as your name and last name, address, and telephone number as may be required for the delivery of such gifts with third parties (e.g. the company/platform sending such gifts, courier company, etc.).

We may share your personal data with call center(s) (third-party suppliers providing services as making calls and accepting incoming calls) that we collaborate outside our business hours in order to provide support and contact to our customers whenever required.

We collaborate with third-party companies in Turkey and abroad to send mass e-mails and SMS text messages with an aim to notify our customers about recent developments, advertisements, promotions, and news. We share your personal data with these companies only to the extent required for this purpose.

We may share your required personal data with companies, based in Turkey and abroad, for conducting customer satisfaction analyses in order to understand whether our customers are satisfied with our services or not and to discover more opportunities about how we can make you and our other customers more satisfied.

We may share your personal data with our affiliated companies and audit firms as required for auditing and reporting of the processes regarding our CRM records and for achieving this purpose. We may process your personal data suitable for the purpose of processing, whenever required, in the relevant software for the management of accounting and financial processes. Such personal data may be recorded in the dedicated data recording medium of the relevant software.

In order to ensure that the records including your personal data are maintained for a period of storage, we may send the relevant records to third-party archiving, Internet Server, and CRM Software companies providing such services.

In addition, we may share such personal data with our attorneys in order to use our right of defense, and with relevant institutions within the scope of our obligations to fulfill legal requests such as court orders or request for evidence provided that it is in compliance with applicable laws and legal procedures thereof.

YOUR RIGHTS

Pursuant to article 11 of the Law no.6698, you have the following rights regarding your personal data provided that you prove your identity to us in person:

Learning about whether the Company has processed your personal data, and requesting for further information if your personal data have been processed;

Learning about the purpose of processing your personal data and about whether your personal data are used in compliance with the intended purpose;

Learning about whether your personal data are shared in Turkey or abroad, and with whom such personal data are shared.

In addition, you may request from the Company to correct any inaccurate and/or incomplete personal data, and request for notifying the recipients with whom such personal data are or may be shared in this regard.

You may request for disposal (deletion, destruction, or making anonymous) of your personal data pursuant to the conditions set forth in article 7 of the Law no.6698.

You may request for third parties with whom your personal data are or may be shared to be notified about your request for the disposal of such personal data.

However, we shall determine which disposal method is suitable based on the conditions of the concrete case upon evaluation of your request for disposal of such personal data. Within this scope, you may always request information about why we selected such disposal method.

You may raise an objection to the results of your personal data analysis created by exclusively using an automated system provided that such results are against your interests.

You may claim for damages in case you suffer from damages arising out of processing your personal data against the applicable law.

Your requests contained in your application shall be concluded free of charge within thirty (30) days at the latest based on the nature of your requests. However, you may be required to pay a fee determined by the Board of Protection of Personal Data in case such request requires any additional cost to the Company.

Contact Details
In order to exercise your rights defined in the above paragraph titled YOUR RIGHTS, please complete the Application Form available on our Web site, including your identification details, the right(s) that you wish to exercise, and a detailed account of your request, and send this Application Form to the address specified therein (Defterdar Yokuşu, No: 3 Tophane, 34425 Karaköy Beyoğlu - Istanbul) by registered mail with return receipt via PTT (Post Office Department of Turkey).

APPLICATION FORM FOR DATA OWNERS TO EXERCISE THEIR RIGHTS

As the Web site www.axisistanbulavm.com, we respect your privacy rights and strive for ensuring your privacy during your visit on our Web site. Further details on the security of your personal data are provided below for your information.
Log Files
As in many standard Web servers, log files are also recorded on www.axisistanbulavm.com for statistical purposes. Such log files contain standard information such as your IP address, Internet service provider, the features of your Web browser, your operating system, and the pages you visit on our Web site. Such log files are strictly used for statistical purposes only and do not violate your privacy. Your IP address and other details are not associated with your personal details.
Cookies
The term cookie defines a small text file placed on your computer’s hard disk by the Web page server. Such cookies may be used in certain parts of our Web site for the convenience of our users. This is completely subject to your authorization and it is possible for you to prevent the use of cookies by changing the settings of your Web browser at your own discretion.
External Links
The Web site www.axisistanbulavm.com provides external links to various Web sites different from our own Web site. www.axisistanbulavm.com shall not be responsible for the contents or privacy policies of the Web sites for which our Web site provides external links or advertisements in the form of Web banners. Providing such external links, in this case, is legally considered as making a reference.
Contact
You may contact us from our contact page about your questions, comments, and views regarding the privacy policy applicable to www.axisistanbulavm.com.