KVKK Information Text

1. INTRODUCTION

The security and/or protection of your personal data is among our priorities as Dagi Giyim Sanayi ve Ticaret Anonim Şirketi (“Company/Our Company”). With this awareness, as the Company, we place great importance on the processing and preservation of all kinds of personal data belonging to all persons related to the Company, including individuals benefiting from our products and services, in accordance with the Law on the Protection of Personal Data No. 6698 (“KVK Law”). Accordingly, as the “Data Controller” defined in the KVK Law and pursuant to Article 10 of the KVK Law and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Clarification Obligation (“Communiqué”) published in the Official Gazette No. 30356 dated 10 MARCH 2018 by the Personal Data Protection Board, to fulfill the obligation to inform personal data owners at the time of collecting personal data; our Company provides the data owners with this information including our Company’s identity, the purpose of processing the personal data, to whom and for what purpose the processed personal data may be transferred, the method and legal reason of personal data collection, and the rights of the data owner within the scope of Article 11 of the KVK Law.

The expressions such as “we” and “our” used in this Clarification Text refer to Dagi Giyim A.Ş., unless explicitly stated otherwise.

2. PERSONAL DATA

Definition of Personal Data

Within the scope of Article 3/I(d) of the KVK Law, “personal data” refers to any information relating to identified or identifiable natural persons. Accordingly, personal data means any information relating to a specific or identifiable real person. Examples include; your name, surname, Turkish ID number, address, phone number, email address, date of birth, IP address accessed, information related to transactions you have performed, etc. These are your personal data. Moreover, according to the KVK Law; sensitive personal data include data concerning race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing and appearance, association, foundation, union memberships, health, sexual life, criminal convictions and security measures, biometric and genetic data, etc. In this context, anonymous information, anonymized information, and other data that cannot be associated with a specific person are not considered personal data according to our Company’s Policy on this matter.

Concept of Processing Personal Data

Within the scope of Article 3/I(e) of the KVK Law, the processing of personal data refers to any operation performed on data such as obtaining, recording, storing, preserving, altering, reorganizing, disclosing, transferring, acquiring, making accessible, classification, or preventing use, whether fully or partially automated or non-automated as part of any data recording system.

3. SCOPE OF CLARIFICATION

Identity of the Data Controller

According to the KVK Law, “Data Controller” means the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. Therefore, the Corporate Identity Information of Dagi Giyim Sanayi ve Ticaret Anonim Şirketi, which is the “Data Controller” within the scope of the KVK Law, is as follows:

Collection, Processing and Purpose of Personal Data

Your personal data may vary depending on the service, product, or commercial activity provided by our Company; and can be collected verbally, in writing or electronically through automatic or non-automatic means via offices, branches, dealers, call centers, websites, social media platforms, mobile applications, and similar channels.

In accordance with Articles 5.2 and 6.3 of the KVK Law, personal data may be processed without explicit consent to fulfill our legal obligations, establish or perform a contract, fulfill legal responsibilities, establish, use or protect a right, and to protect our legitimate interests without harming your fundamental rights and freedoms and for personal data made public by you. Furthermore, personal data may also be processed within the scope of Articles 5.1 and 6.2 of the KVK Law with your explicit consent as stated in this Clarification Text. You may obtain all our products without being a member of the Dagi membership/loyalty program or other membership/loyalty programs. However, since Dagi membership/loyalty program and other loyalty programs provide special advantages to their members, by joining these programs/membership, you grant your explicit consent to the processing of your personal data, except in exceptional cases.

The personal data collected are processed or will be processed in accordance with the conditions and purposes of personal data processing stated in Articles 5 and 6 of the KVK Law and other applicable legislation in force, for purposes such as performing necessary activities by our business units to benefit you from the products and services provided by our Company, customizing the products and services offered according to your preferences, usage habits, and needs, ensuring the legal and commercial security of our Company and individuals who have business relations with us (administrative operations related to communication managed by our Company, ensuring physical security and supervision of Company locations, partner/customer/supplier (authorized or employees) evaluation processes, legal compliance processes, financial affairs etc.), determining and implementing our Company’s commercial and business strategies and executing our human resources policies.

To Whom and For What Purpose the Processed Personal Data May Be Transferred Domestically and/or Abroad

The collected personal data may be transferred domestically or abroad to carry out necessary work by our business units to benefit you from the products and services offered by our Company, to customize these products and services according to your preferences, usage habits and needs, to ensure the legal and commercial security of our Company and individuals in business relations with us (administrative operations for communication, ensuring physical security and supervision of locations, evaluation of partners/customers/suppliers (authorized or employees), legal compliance, financial affairs etc.), determining and implementing our commercial and business strategies and executing our human resources policies,

to administrative and official authorities legally required to receive the data, relevant persons and institutions for the fulfillment of legal obligations and requirements, independent audit firms within the scope of legal obligations and limitations, tax consultants and other external professional consultants, lawyers, insurance companies, partners, domestic and international third parties from whom services are or will be received, shareholders, business partners, suppliers, legally authorized public institutions and private persons; in accordance with the data processing conditions and purposes stated in Articles 8 and 9 of the KVK Law and other applicable legislation.

Your collected personal data may be transferred to foreign countries declared by the KVK Board to have adequate protection (“Foreign Country with Adequate Protection”) or, if adequate protection is not available, to foreign countries where data controllers in Turkey and the related foreign countries provide a written commitment to ensure adequate protection and have the permission of the KVK Board (“Foreign Country with Data Controller Committed to Adequate Protection”). Our Company acts and will act in accordance with the regulations envisaged in Article 9 of the KVK Law and other applicable legislation in this regard.

Method and Legal Reason for Collecting Personal Data

Your personal data are obtained by our audit and consultancy services, written/digital applications made to our Company employees, our website, phone calls to our numbers, social media, SMS channels, and other verbal, written or electronic means, either automatically or non-automatically, and through other channels by which our Company contacts or may contact you in the future, for the purpose of conducting our activities and fulfilling contractual and legal obligations between us. The obtained personal data are stored within legal retention periods pursuant to relevant legislation.

Rights of Personal Data Owners under Article 11 of the KVK Law

As personal data owners, if you submit your requests regarding your rights to our Company by the methods arranged below in this Clarification Text, our Company will conclude the request free of charge within thirty days at the latest, depending on the nature of the request. However, if a fee is imposed by the Personal Data Protection Board, a fee determined by our Company’s tariff will be charged. Within this scope, personal data owners have the following rights according to Article 11 of the KVK Law;

To learn whether their personal data is processed, to request information if processed, to learn the purpose of processing and whether it is used in accordance with that purpose, to know the third parties to whom their personal data is transferred domestically or abroad, to request correction if personal data is incomplete or incorrect, to request deletion or destruction of personal data when the reasons requiring processing are removed according to purpose, duration, and legitimacy principles, to request notification of the actions taken regarding correction, deletion or destruction to third parties to whom the data was transferred, to object to the emergence of a result against themselves if personal data is analyzed exclusively by automated systems, and to claim compensation for damages in case of unlawful processing of personal data.

According to the first paragraph of Article 13 of the KVK Law, you may submit your requests regarding the exercise of the rights mentioned above to our Company in writing or by other methods determined by the Personal Data Protection Board. Since the Board has not yet determined any method, you must submit your request in writing according to the KVK Law. Within this framework, the channels and procedures for submitting written requests to our Company within the scope of Article 11 of the KVK Law are explained below:

To exercise your rights mentioned above, you may submit your request, which includes necessary information to identify your identity and explanations about the rights you want to use under Article 11 of the KVK Law, by filling out the form at www.dagi.com.tr, and deliver a signed copy of the form along with identity documents in person to Merkez Mh. Birahane Sk. Koç Plaza No.3/1 34381 Bomonti-Şişli/Istanbul, or send it via notary or other methods specified in the KVK Law, or send the relevant form with a secure electronic signature to dagi@hs02.kep.tr.

In cases where your personal data is processed based on explicit consent, we would like to emphasize that if you withdraw your explicit consent, you will be removed from the membership/loyalty program where the processing is necessary, and you will no longer benefit from the advantages provided by such processing as of the relevant date.