CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA

As Dinossi Teknoloji Limited Company ("Dinossi" or "Company"); the confidentiality and security of your personal data is among our top priorities. In this context, we would like to inform you about your personal data in order to fulfill our disclosure obligation arising from Article 10 of the Personal Data Protection Law No. 6698 ("KVKK"). Personal data means any information that makes your identity specific or identifiable. Your personal data processed by Dinossi, the purposes of their processing, the recipient groups to which they can be transferred, the method of collection, the legal reason and your rights regarding such personal data are provided below.

A- OUR MEMBERS

1- Which personal data are processed by Dinossi?

Persons who log in from the website or the application installed on mobile devices by accepting the membership conditions on the Dinossi platform and follow and/or purchase the products on the platform are defined as "Member". If you become a member of the Dinossi platform, the following personal data may be processed.

- Your Identity Information: your name, surname, gender and age, Turkish ID Number (processed only if you purchase certain product groups in accordance with the legislation)
- Your Contact Information: cell phone number, delivery address, e-mail address,
- Your Customer Transaction Information: your order and billing information, delivery transaction information, transaction history information about your purchases, request and complaint information, information that you personally share in your comments and questions in case you make comments and / or ask questions about the products on the platform, information about the content of conversations with Dinossi assistant via chat channel,
- Your Transaction Security Information: IP address information, password and password information, cookie information,
- Your Legal Action Information: information in correspondence with authorized persons, institutions and organizations, information in lawsuits and enforcement files, your legal information request information,
- Your Auditory Recording Information: Your voice recording in case you contact the call center.

2- What are the purposes and collection methods of processing your personal data?

Your identity, contact and customer transaction information; Within the scope of our contractual relationship, it is collected and processed automatically from you personally, electronically from the mobile application or website for the following purposes.

- Execution of processes for the establishment and performance of the contract,
- Execution and supervision of finance and accounting processes,
- Conduct and supervision of the company's business activities,
- Execution of invoicing processes,
- Execution of logistics, cargo activities and follow-up of delivery processes,
- Realization of purchase transactions through the website/mobile applications and confirmation of the identity information of the transactor,
- In case of your explicit consent, to be able to use it in various marketing and advertising activities, to provide you with a better shopping experience and to carry out activities to increase your satisfaction, especially to offer you products in accordance with your preferences,
- To increase customer satisfaction, to be able to recognize our customers who shop on the platform and use them in customer environment analysis, and to carry out activities to develop and improve the products and services offered by our Company,
- Conducting strategic analysis studies,
- Conducting communication activities,
- Offering products that you may be interested in, taking into account your interests,
- Contacting and informing about the conditions, current status and updates of the contracts concluded through our platform under the relevant articles of the Distance Sales Contract and the Law on Consumer Protection,
- In case of your explicit consent, informing you about developments, opportunities and innovations at Dinossi,
- Recognizing our customers who shop on the website and/or mobile applications, conducting activities to be used in customer environment analysis and conducting surveys electronically and/or physically through contracted organizations in this context,
- Evaluation of your requests, complaints and suggestions regarding our products and services,
- Providing you with information about products,
- Providing after-sales support services for goods and services,
- Execution of information security processes,
- Ensuring the security of operations in relation to the Dinossi platform,
- Ensuring that activities are carried out in accordance with the legislation,
- Follow-up and execution of legal affairs,
- Providing information to authorized persons, public institutions and organizations.

Your transaction security information; Within the scope of our contractual relationship, it is collected and processed automatically from you personally, electronically from the mobile application or website for the following purposes.

- Execution of processes for the establishment and performance of the contract,
- Conduct and supervision of the company's business activities,
- Realization of purchase transactions through the website/mobile applications and confirmation of the identity information of the transactor,
- In case of your explicit consent, to be able to use it in various marketing and advertising activities, to provide you with a better shopping experience and to carry out activities to increase your satisfaction, especially to offer you products in accordance with your preferences,
- To increase customer satisfaction, to be able to recognize our customers who shop on the platform and use them in customer environment analysis, and to carry out activities to develop and improve the products and services offered by our Company,
- Execution of information security processes,
- Ensuring the security of operations in relation to the Dinossi platform,
- Ensuring that activities are carried out in accordance with the legislation,
- Providing information to authorized persons, institutions and organizations.

Your legal transaction information; Within the scope of our contractual relationship, it is collected and processed automatically from you personally, mobile application, website in electronic environment for the following purposes.

- Execution of processes for the establishment and performance of the contract,
- Conduct and supervision of the company's business activities,
- Evaluation of your requests, complaints and suggestions regarding our products and services,
- Execution of information security processes,
- Ensuring the security of operations in relation to the Dinossi platform,
- Ensuring that activities are carried out in accordance with the legislation,
- Follow-up and execution of legal affairs,
- Providing information to authorized persons, institutions and organizations.

Your auditory recording information is collected and processed for the following purposes when you contact the call center.

- Execution of processes for the establishment and performance of the contract,
- Conducting communication activities,
- Carrying out activities aimed at providing you with a better shopping experience and increasing your satisfaction, especially the execution of campaigns, offering you products in accordance with your preferences,
- Carrying out activities to develop and improve the products and services offered by our Company,
- Offering products that you may be interested in, taking into account your interests,
- Contacting and informing about the conditions, current status and updates of the contracts concluded through our platform under the relevant articles of the Distance Sales Contract and the Law on Consumer Protection,
- In case of your explicit consent, informing you about developments, opportunities and innovations at Dinossi,
- Recognizing our customers who shop on the website and/or mobile applications, conducting activities to be used in customer environment analysis and conducting surveys electronically and/or physically through contracted organizations in this context,
- Evaluation of your requests, complaints and suggestions regarding our products and services,
- Ensuring the security of operations in relation to the Dinossi platform,
- Ensuring that activities are carried out in accordance with the legislation,
- Follow-up and execution of legal affairs,
- Providing information to authorized persons, institutions and organizations.

3- What is the legal reason for processing your personal data?

Dinossi processes your personal data under the heading "Which of your personal data is processed by Dinossi?" for the purposes set out above, based on the reasons for compliance with the law set out in Articles 5, 8 and 9 of the KVKK and set out below.

- 6563 Law on the Regulation of Electronic Commerce, Turkish Commercial Code No. 6102, Turkish Criminal Code No. 5237 and Law No. 6502 on the Protection of Consumers based on the legal reason that it is clearly stipulated in the legislation to which our Company is subject, especially the Law on the Regulation of Electronic Commerce, Turkish Commercial Code No. 6102, Turkish Criminal Code No. 5237 and Law No. 6502 on Consumer Protection; fulfillment of our obligations arising from the legislation, especially the activities to ensure the security of the operations on the company platform, to carry out information security processes, to ensure that the activities are carried out in accordance with the legislation,
- Based on the legal reason that it is necessary to process your personal data, provided that it is directly related to the establishment or performance of the contract; execution of the activities for the establishment of contracts concluded on our platform under the relevant articles of the Law on Consumer Protection such as distance sales contract, execution of activities for the realization of your purchase transactions, execution and supervision of the company's business activities, follow-up of delivery processes, evaluation of your requests, complaints and suggestions regarding our products and services, execution and supervision of finance and accounting processes, execution of communication activities,
- Based on the legal reason that it is mandatory for our Company to fulfill its legal obligations; fulfilling the legal obligations specified in the secondary legislation to which our Company is subject and/or in the decisions, guidelines and guides published by the competent authorities, especially the Regulation on Distance Contracts and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce, providing information to authorized persons, institutions and organizations, ensuring that the activities are carried out in accordance with the legislation, following and conducting legal affairs, conducting financial and accounting affairs,
- Based on the legal reason that data processing is mandatory for the establishment, exercise or protection of a right; execution of legal and litigation affairs,
- Carrying out activities for the development and improvement of the products and services offered by our company, based on the legal reason that data processing is mandatory for the legitimate interests of our company, provided that it does not harm fundamental rights and freedoms,
- Based on the legal reason of your explicit consent; transferring personal data abroad.

4- To whom and for what reasons does Dinossi transfer your personal data?

Our Company takes care to process your personal data in accordance with the principles of "need to know" and "need to use", by ensuring the necessary data minimization and taking the necessary technical and administrative security measures. Since the execution or supervision of business activities, ensuring business continuity, and the operation of digital infrastructures require continuous data flow with different stakeholders, we are obliged to transfer the personal data we process to third parties for certain purposes. In addition, it is very important that your personal data is accurate and up-to-date so that we can fully and properly fulfill our contractual and legal obligations. For this purpose, we have to work with various business partners and service providers.

Your personal data, execution of the marketplace operation, execution of the delivery processes of the products you order, managing your requests for assistance and support for your processes, carrying out activities to increase your experience and satisfaction, carrying out activities to develop and improve the products and services offered by our company, providing you with a better shopping experience and carrying out activities to increase your satisfaction, ensuring business continuity, ensuring information security, fulfilling legal obligations, and to the extent necessary limited to the purposes specified in the second article of this clarification text:

Based on the legal reasons that it is clearly stipulated in the legislation to which our Company is subject and that it is mandatory for the fulfillment of its legal obligation, and that it is necessary for the establishment or performance of the contract;

- With the seller of the product and the service provider for the purpose of conducting procurement processes,
- With the seller of the purchased product, cargo companies and private couriers in order to carry out logistics activities and to follow up the delivery processes, you and/or the person on whose behalf the product will be delivered,
- With our business partners, the seller of the purchased product, our consultants and service providers, banks, financial advisors in order to carry out invoicing processes,
- With business partners and other service providers that offer call center services for the provision of goods and services sales and after-sales support services,
- With business partners and service providers offering services in the field of quality control, complaint management and risk analysis of services,
- With our relevant business partners, consultants and service providers, banks, financial advisors for the management of financial and accounting processes, identification and assessment of risks and prevention of fraud,
- With the e-invoice business partner to send the e-invoice to the customer electronically; with cargo and courier companies, private integrator, independent audit, customs, financial advisor / accounting service providers for physical contract or invoice delivery,
- With tax offices for the fulfillment of tax obligations, with the authorities of the Republic of Turkey Ministry of Treasury and Finance for invoices and collection receipts during tax audits,
- Our business partners and service providers who provide, operate or service our IT infrastructure,
- With our business partners providing services in the field of risk management and financial reporting processes,

Based on the legal reasons that data processing is mandatory for the establishment, exercise or protection of a right, that it is clearly stipulated in the legislation to which our company is subject and that it is mandatory for the fulfillment of its legal obligation;

- Lawyers, auditors, forensic IT experts, cyber security consultants, tax consultants and other third parties and business partners from whom we receive consultancy and services within the scope of fulfillment of legal obligations,
- Regulatory and supervisory bodies and authorized public institutions and organizations such as courts and enforcement offices,
- Your personal data may be shared with other public institutions or organizations authorized to request your personal data, our affiliates in Turkey and/or abroad, our suppliers, our business partners, banks we have contracted with and third parties from whom we receive products or services.

B- GUEST MEMBERS

1- Which personal data are processed by Dinossi?

People who follow and/or purchase products on the Dinossi platform without being a member of the Dinossi platform are defined as "Guest Member". During your use of the Dinossi platform as a guest member and shopping, your personal data below are processed.

- Your Identity Information: first name, last name,
- Your Contact Information: cell phone number, delivery address, e-mail address,
- Your Customer Transaction Information: order and information, billing information, delivery transaction information, transaction history information about your purchases, request and complaint information,
- Your Transaction Security Information: IP address information, cookie information,
- Your Legal Action Information: information in correspondence with authorized persons, institutions and organizations, information in lawsuits and enforcement files, your legal information request information,
- Auditory Recording Information: If you contact the call center, please provide an audio recording.

2- What are the purposes and collection methods of processing your personal data?

Your identity, contact and customer transaction information is collected and processed automatically from you personally, electronically from the mobile application or website for the following purposes.

- Execution of processes for the establishment and performance of the contract,
- Execution and supervision of finance and accounting processes,
- Conduct and supervision of the company's business activities,
- Execution of logistics activities and follow-up of delivery processes,
- Realization of purchase transactions through the website / mobile applications and confirmation of the identity information of the transactor,
- Carrying out activities to develop and improve the products and services offered by our Company,
- Conducting strategic analysis studies,
- Conducting communication activities,
- Contacting and informing about the conditions, current status and updates of the contracts concluded on our platform under the terms of the distance sales contract and the relevant articles of the Law on Consumer Protection and establishing the membership agreement,
- Evaluation of requests, complaints and suggestions regarding our products and services,
- Providing after-sales support services for goods and services,
- Execution of information security processes,
- Ensuring the security of operations in relation to the Dinossi platform,
- Ensuring that activities are carried out in accordance with the legislation,
- Follow-up and execution of legal affairs,
- Providing information to authorized persons, institutions and organizations.

Your transaction security information; It is collected and processed automatically from you personally, electronically from the mobile application or website for the following purposes.

- Execution of processes for the establishment and performance of the contract,
- Conduct and supervision of the company's business activities,
- Realization of purchase transactions through the website / mobile applications and confirmation of the identity information of the transactor,
- Carrying out activities to develop and improve the products and services offered by our Company,
- Execution of information security processes,
- Ensuring the security of operations in relation to the Dinossi platform,
- Ensuring that activities are carried out in accordance with the legislation,
- Providing information to authorized persons, institutions and organizations.

Your legal transaction information; It is collected and processed automatically from you personally, mobile application, website in electronic environment for the following purposes.

- Execution of processes for the establishment and performance of the contract,
- Conduct and supervision of the company's business activities,
- Carrying out activities to develop and improve the products and services offered by our Company,
- Evaluation of your requests, complaints and suggestions regarding our products and services,
- Execution of information security processes,
- Ensuring the security of operations in relation to the Dinossi platform,
- Ensuring that activities are carried out in accordance with the legislation,
- Follow-up and execution of legal affairs,
- Providing information to authorized persons, institutions and organizations.

Your auditory recording information is collected and processed for the following purposes when you contact the call center.

- Execution of processes for the establishment and performance of the contract,
- Conducting communication activities,
- Carrying out activities to develop and improve the products and services offered by our Company,
- Contacting and informing about the conditions, current status and updates of the contracts concluded through our platform under the relevant articles of the Distance Sales Contract and the Law on Consumer Protection,
- Evaluation of your requests, complaints and suggestions regarding our products and services,
- Ensuring the security of operations in relation to the Dinossi platform,
- Ensuring that activities are carried out in accordance with the legislation,
- Follow-up and execution of legal affairs,
- Providing information to authorized persons, institutions and organizations.

3- What is the legal reason for processing your personal data?

Dinossi processes your personal data under the heading "Which of your personal data are processed by Dinossi?" for the purposes set out above, based on the reasons for compliance with the law set out in Articles 5, 8 and 9 of the KVKK and set out below.

- 6563 Law on the Regulation of Electronic Commerce, Turkish Commercial Code No. 6102, Turkish Criminal Code No. 5237 and Law No. 6502 on the Protection of Consumers based on the legal reason that it is clearly stipulated in the legislation to which our Company is subject, especially the Law on the Regulation of Electronic Commerce, Turkish Commercial Code No. 6102, Turkish Criminal Code No. 5237 and Law No. 6502 on the Protection of Consumers; fulfillment of our obligations arising from the legislation, especially the activities to ensure the security of the operations on the company platform, to carry out information security processes, to ensure that the activities are carried out in accordance with the legislation,
- Based on the legal reason that it is necessary to process your personal data, provided that it is directly related to the establishment or performance of the contract; execution of the activities for the establishment of contracts concluded on our platform under the relevant articles of the Law on Consumer Protection such as distance sales contract, execution of activities for the realization of your purchase transactions, execution and supervision of the company's business activities, follow-up of delivery processes, evaluation of your requests, complaints and suggestions regarding our products and services, execution and supervision of finance and accounting processes, execution of communication activities,
- Based on the legal reason that it is mandatory for our Company to fulfill its legal obligations; fulfilling the legal obligations specified in the secondary legislation to which our Company is subject and/or in the decisions, guidelines and guides published by the competent authorities, especially the Regulation on Distance Contracts and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce, providing information to authorized persons, institutions and organizations, ensuring that the activities are carried out in accordance with the legislation, following and conducting legal affairs, conducting financial and accounting affairs,
- Based on the legal reason that data processing is mandatory for the establishment, exercise or protection of a right; execution of legal and litigation affairs,
- Carrying out activities for the development and improvement of the products and services offered by our company, based on the legal reason that data processing is mandatory for the legitimate interests of our company, provided that it does not harm fundamental rights and freedoms,
- Based on the legal reason of your explicit consent; transferring personal data abroad.

4- To whom and for what reasons does Dinossi transfer your personal data?

Our Company takes care to process your personal data in accordance with the principles of "need to know" and "need to use", by ensuring the necessary data minimization and taking the necessary technical and administrative security measures. Since the execution or supervision of business activities, ensuring business continuity, and the operation of digital infrastructures require continuous data flow with different stakeholders, we are obliged to transfer the personal data we process to third parties for certain purposes. In addition, it is very important that your personal data is accurate and up-to-date so that we can fully and properly fulfill our contractual and legal obligations. For this purpose, we have to work with various business partners and service providers.

Your personal data, execution of the marketplace operation, execution of the delivery processes of the products you order, managing your requests for assistance and support for your processes, carrying out activities to increase your experience and satisfaction, carrying out activities to develop and improve the products and services offered by our company, providing you with a better shopping experience and carrying out activities to increase your satisfaction, ensuring business continuity, ensuring information security, fulfilling legal obligations, and to the extent necessary limited to the purposes specified in the second article of this clarification text:

Based on the legal reasons that it is clearly stipulated in the legislation to which our Company is subject and that it is mandatory for the fulfillment of its legal obligation, and that it is necessary for the establishment or performance of the contract;

- With the seller of the product and the service provider for the purpose of conducting procurement processes,
- With the seller of the purchased product, cargo companies and private couriers in order to carry out logistics activities and to follow up the delivery processes, you and/or the person on whose behalf the product will be delivered,
- With our business partners, the seller of the purchased product, our consultants and service providers, banks, financial advisors in order to carry out invoicing processes,
- With business partners and other service providers that offer call center services for the provision of goods and services sales and after-sales support services,
- With business partners and service providers offering services in the field of quality control, complaint management and risk analysis of services,
- With our relevant business partners, consultants and service providers, banks, financial advisors for the management of financial and accounting processes, identification and assessment of risks and prevention of fraud,
- With the e-invoice business partner to send the e-invoice to the customer electronically; with cargo and courier companies, private integrator, independent audit, customs, financial advisor / accounting service providers for physical contract or invoice delivery,
- With tax offices for the fulfillment of tax obligations, with the authorities of the Republic of Turkey Ministry of Treasury and Finance for invoices and collection receipts during tax audits,
- Our business partners and service providers who provide, operate or service our IT infrastructure,
- With our business partners providing services in the field of risk management and financial reporting processes,

Based on the legal reasons that data processing is mandatory for the establishment, exercise or protection of a right, that it is clearly stipulated in the legislation to which our company is subject and that it is mandatory for the fulfillment of its legal obligation;

- Lawyers, auditors, forensic IT experts, cyber security consultants, tax consultants and other third parties and business partners from whom we receive consultancy and services within the scope of fulfillment of legal obligations,
- Regulatory and supervisory bodies and authorized public institutions and organizations such as courts and enforcement offices,
- Your personal data may be shared with other public institutions or organizations authorized to request your personal data, our affiliates in Turkey and/or abroad, our suppliers, our business partners, banks we have contracted with and third parties from whom we receive products or services.

HOW DOES Dinossi PROTECT YOUR PERSONAL DATA?

Personal data shared with Dinossi is under the supervision and control of Dinossi. Dinossi has assumed the responsibility as the data controller to establish the necessary organization and take and adapt technical measures in order to protect the confidentiality and integrity of the information in accordance with the provisions of the relevant legislation in force. Being aware of our obligation in this regard;

- Penetration tests are conducted periodically in accordance with international and national technical standards on data privacy.
- Your personal data that you transmit to Dinossi through the website, mobile site and mobile application are protected using SSL (Secure Sockets Layer) technology.
- Risk analyses are regularly conducted regarding personal data processing activities and actions are taken to mitigate risks.
- Access and authorization controls are implemented to prevent unauthorized access to personal data.
- In this context, we would like to inform you that we always update our data processing policies.

YOUR RIGHTS REGARDING THE PROTECTION OF YOUR PERSONAL DATA

By applying to our Company through the methods specified in the "Contact for Your Rights and Requests" section of this Clarification Text,

- Learn whether your personal data is being processed,
- Request information if processed,
- To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
- Knowing the third parties to whom it is transferred domestically or abroad,
- To request correction of personal data in case of incomplete or incorrect processing,
- To request the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK,
- To request notification of the actions taken pursuant to your rights to rectification, deletion and destruction mentioned above to third parties to whom personal data have been transferred,
- To object to the occurrence of a result against you by analyzing your processed personal data exclusively with automated systems,
- You have the right to demand the compensation of your damages in case you suffer damage due to the processing of your personal data in violation of the relevant legislation.

CONTACT FOR YOUR RIGHTS AND DEMANDS

You can submit your questions and requests regarding your personal data with a petition organized in accordance with the conditions specified in the Communiqué on the Procedures and Principles of Application to the Data Controller or with the "Dinossi Teknoloji Limited Company Application Form" by the following methods. You can access the application form here.

Application Method Application Address
Written Application in Person Çamlık Mahallesi Dinç Sokak No:2 Kat:1 Dinossi Plaza, Ümraniye, Istanbul
Registered Electronic Mail (KEP) Signed with Secure Electronic Signature or Mobile Signature dino@dinossi.com
dino@dinossi.com from your e-mail address previously notified to our Company and registered in the system

*It is obligatory for the Relevant Persons who will apply for "In Person Written Application" to submit documents certifying their identity. In this context, we kindly request that only the front side of the identity card photocopy (so that the blood group and religion section is not visible) be submitted together with the application form for the written applications to be made in person to Çamlık Mahallesi Dinç Sokak No:2 Kat:1 Dinossi Plaza, Ümraniye, Istanbul.

**We kindly request that "Personal Data Protection Law Relevant Person Request" be written in the notification envelope of the application form or in the subject line of the e-mail.

As personal data owners, if you submit your requests regarding your rights to Dinossi, Dinossi will finalize your request free of charge within 30 (thirty) days at the latest. However, if the response to your application requires a cost in accordance with the legislation, Dinossi may charge a fee in the tariff determined by the Personal Data Protection Board.

ABOUT THE CLARIFICATION TEXT

Dinossi reserves the right to update this Statement on the Protection of Personal Data at any time within the framework of changes that may be made in the applicable legislation.

Updated Date : 21/12/2021