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1.INTRODUCTION

The security and/or protection of your personal data is among our priorities as ÇAMLICA DENETİM LİMİTED ŞİRKETİ (“Company/Our Company”). With this awareness, as a Company, we attach great importance to the processing and storage of all personal data of all persons associated with the Company, including those who benefit from our products and services, in accordance with the Personal Data Protection Law No. 6698 (“PDP Law”). In this regard, as defined in the PDP Law, the “Data Controller” in his capacity as a data subject and in accordance with the Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Obligation to Inform ("Communiqué") published in the Official Gazette dated 10 MARCH 2018 and numbered 30356 by the Personal Data Protection Board, in order to fulfil the duty of informing personal data owners during the collection of personal data; We present this information regarding the identity of our Company, the purpose for which personal data will be processed, to whom and for what purpose the processed personal data may be transferred, the method and legal reason for collecting personal data, and the rights of the personal data owner within the scope of Article 11 of the Personal Data Protection Law during the collection of personal data by our Company to personal data owners.

The terms “we” and “our” Expressions such as, unless otherwise explicitly stated, are used to refer to ÇAMLICA DENETİM LİMİTED ŞİRKETİ .

2. PERSONAL DATA

Definition of Personal Data

Within the framework of Article 3/I(d) of the Personal Data Protection Law, "personal data" refers to any information relating to an identified or identifiable natural person. In this context, personal data refers to any information relating to an identified or identifiable natural person. For example; Your name, surname, Turkish identity number, address, telephone number, e-mail address, date of birth, the IP number you access, information about the transactions you have made, etc. are information about you. In addition, according to the Personal Data Protection Law; data about a person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, appearance and dress, membership in associations, foundations, unions, etc., health, sexual life, criminal conviction and security measures, biometric and genetic data, etc. are special personal data. In this context, anonymous information, anonymized information and other data that cannot be associated with a specific person are not considered personal data in accordance with our Company’s Policy on this matter.

Concept of Processing of Personal Data

Processing of personal data within the framework of Article 3/I(e) of the Personal Data Protection Law refers to any operation performed on data, such as obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, either fully or partially by automatic means or, provided that it is part of any data recording system, by non-automatic means.

3. SCOPE OF INFORMATION

Identity of the Data Controller

According to the PDP Law, the term "Data Controller" refers to 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. According to the PDP Law, the Addressee is the "Data Controller". The Corporate Identity Information of ÇAMLICA DENETİM LİMİTED ŞİRKETİ ’is as follows:

Trade Registry Number:
Central Registry Number:
Tax Office:
Central Address:	Alparslan Business Center Tozkoparan District, Haldun Taner Sk., 34173 Güngören/İstanbul
Phone:	+90 850 450 01 52
Fax:
Internet Site:	www.camlicadenetim.com
Email Address:	[email protected]

Collection, Processing and Purposes of Processing of Personal Data

Your Personal Data is used in the services, products and services provided by our Company.It may vary depending on the purpose or commercial activity; it is/may be collected verbally, in writing or electronically through automatic or non-automatic methods, offices, branches, dealers, call centers, websites, social media channels, mobile applications and similar means.

K.V.K. Within the scope of Article 5.2 and Article 6.3 of the Law, in order to fulfill our legal obligations, to establish or perform a contract, to fulfill our legal obligations, to establish, exercise or protect a right and to protect our legitimate interests without harming your fundamental rights and freedoms and in terms of personal data you have made public, it may be processed without your explicit consent. Again, your personal data may be processed within the scope of the purposes specified in this Disclosure Text, provided that your explicit consent is obtained within the scope of Article 5.1 and Article 6.2 of the Personal Data Protection Law. You can obtain all of our products without being a member of our other membership/loyalty program(s), especially the Paul Kenzie membership/loyalty program. In return, since the Paul Kenzie membership/loyalty program and our other loyalty programs and memberships offer special advantages to their members, in order to benefit from the program/membership advantages, you expressly consent to the processing of your Personal Data, except for exceptional cases, by joining/being a member of the programs.

Your collected personal data will be processed by our business units to make you benefit from the products and services offered by our Company, to offer you the products and services offered by our Company by customizing them according to your tastes, usage habits and needs, and to ensure that our Company and the persons who have a business relationship with our Company have legal rights. and ensuring commercial security (administrative operations regarding communication carried out by our Company, ensuring physical security and control of Company locations, business partner/customer/supplier (authorized or employees) evaluation processes, legal compliance process, financial affairs etc.), determining and implementing our Company's commercial and business strategies and ensuring the implementation of our Company's human resources policies, within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law and in accordance with other applicable legislation. is/will be processed.

To Whom and for What Purpose Can Processed Personal Data Be Transferred Domestically and/or Abroad

Your Personal Data Collected; Our business units carry out the necessary work to enable you to benefit from the products and services offered by our Company, to offer you the products and services offered by our Company by customizing them according to your tastes, usage habits and needs, to ensure the legal and commercial security of our Company and the persons who have a business relationship with our Company (administrative operations directed at communication carried out by our Company, to ensure the physical security and control of the Company's locations, business partner/customer/supplier (authorized persons or employees) evaluation processes, legal compliance process, financial affairs etc.), for the purpose of determining and implementing our Company's commercial and business strategies and ensuring the execution of our Company's human resources policies,

To administrative and official authorities to which it is legally required, to relevant persons and institutions as required by legislation and to fulfill legal obligations, to independent auditing companies, tax consultants and other external professional consultants, lawyers, insurance companies, partners, domestic and foreign companies from which services are received or to be received, due to legal obligations and within the framework of legal limitations. parties, shareholders, business partners, suppliers, legally authorized public institutions and private persons, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the PDP Law and other legal legislation.

Your collected personal data; to foreign countries declared as having sufficient protection by the PDP Board ("Foreign Countries with Sufficient Protection") or in the absence of sufficient protection, to TurkeyIt is/may be transferred to foreign countries where the data controllers in Turkey and the relevant foreign country undertake in writing to provide adequate protection and where the permission of the Personal Data Protection Board is available (“Foreign Country Where the Data Controller Undertakes to Provide Adequate Protection” is located). In this regard, our Company acts/will act in accordance with the regulations stipulated in Article 9 of the Personal Data Protection Law and other legal regulations.

Method and Legal Reason for Collecting Personal Data

Your personal data are obtained through our audit and consultancy services, written/digital applications made to our Company employees, our website, calls to our phone numbers, social media, SMS channels, and other verbal, written or electronic media, automatic or non-automatic methods and other channels through which our Company communicates with you or may communicate with you in the future, in order to carry out our activities and to fulfill the contractual and legal obligations between you and us. are obtained for the purpose of fulfilling our obligations and the personal data obtained are stored within the legal periods in accordance with the relevant legislation.

Rights of the Personal Data Owner Listed in Article 11 of the Personal Data Protection Law

As personal data owners, if you forward your requests regarding your rights to our Company through the methods set out below in this Disclosure Text, our Company will finalize the request free of charge within thirty days at the latest, depending on the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by our Company will be collected. In this context, personal data owners, in accordance with Article 11 of the Personal Data Protection Law;

Learning whether their Personal Data has been processed, requesting information about it if it has been processed, learning the purpose of processing their Personal Data and whether it is used in accordance with its purpose, learning the third party to which their personal data is transferred domestically or abroad, to know the persons, to request correction of their personal data if they are processed incompletely or incorrectly, to request deletion or destruction of their personal data if the reasons requiring processing of their personal data are eliminated, within the scope of the principles of purpose, duration and legitimacy, and in case of correction, deletion or destruction of their personal data, to request that these operations be carried out by the third party to which the personal data is transferred. They have the right to request that the information be notified to the relevant persons, to object to the result if a result occurs against them in case their processed personal data is analyzed exclusively through automatic systems, and to request compensation for the damage if their Personal Data is processed against the law and they suffer damages for this reason.

In accordance with Article 13, paragraph 1 of the PDP Law, you can submit your request regarding the use of your rights specified above to our Company in writing or through other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application to our Company in writing in accordance with the PDP Law. In this context, the channels and procedures through which you will submit your written application to our Company within the scope of Article 11 of the Personal Data Protection Law are explained below:

In order to exercise your rights specified above, you must submit your request including the necessary information to identify you and the explanations regarding the right you request to exercise from among the rights specified in Article 11 of the Personal Data Protection Law; By filling out the form at www.paulkenzie.com, you can personally deliver a signed copy of the form to Alparslan İş Merkezi Tozkoparan Mahallesi, Haldun Taner Sk., 34173 Güngören/İstanbul with documents proving your identity, send it through a notary or other methods specified in the Personal Data Protection Law, or send the relevant form with a secure electronic signature to [email protected].

In cases where your personal data is processed with explicit consent, if you withdraw your explicit consent, you will be removed from the membership/loyalty program where processing based on explicit consent is required, and you agree that We would like to emphasize that you will not be able to benefit from the advantages you have benefited from through the transactions in question as of the relevant date.