KVKK DATA PROCESSING POLICY

KVKK Data Processing Policy

1. INTRODUCTION

EHM MAĞAZACILIK SANAYİ VE TİCARET A.Ş. The permissions granted to (“TÜRKLISH HOME”) regarding PRIVACY and PROTECTION of PERSONAL DATA, as well as the basic information on the protection of personal data, are listed below.

In the event that the department that refers to these RULES is approved, it will be deemed to be deemed to have been accepted that all of these rules have been learned, read and the Data owner has given authorization to TÜRKÇE HOME regarding this content .

TÜRKÇE HOME, Law No. 6698 on the Protection of Personal Data m. In order to fulfill the obligation of illumination arising from Article 10 , the following explanations are presented to the information and attention of customers, third parties who use our website and/or mobile applications.

TÜRKÇE HOME has the right to update the regulations on the Protection of Personal Data, partially or completely, at any time within the framework of the changes that can be made in the current legislation, and the changes in the legal regulations will be considered binding for both TÜRKÇE HOME and our Customer/followers.

2. PURPOSE AND SCOPE

The Law on Protection of Personal Data was published in the Official Gazette dated 7 April 2016 and numbered 29677. The KVK Law is regulated to protect the fundamental rights and freedoms of real persons, including the privacy of private life, which is also protected by the Constitution, and to determine the obligations of natural and legal persons who process personal data. In addition, the Law No. 6563 on the Regulation of Electronic Commerce includes a provision on the protection of personal data. Penal sanctions are envisaged in some cases for the protection of personal data through the provisions of the Turkish Penal Code No. 5237.

On the other hand, it is necessary to collect and use data in order to fulfill our obligations arising from the Law No. 6502 on the Protection of the Consumer and the Regulation on Distance Contracts

3. DEFINITION AND ABBREVIATIONS

In this section, special terms and phrases, concepts, abbreviations, etc. in the policy. briefly explained.

3.1. TÜRKÇE HOME : EHM MAĞAZACILIK SANAYİ VE TİCARET A.Ş.

3.2. Explicit Consent: Consent regarding a specific subject, which is given based on information and free will, and is limited for data processing purposes.

3.3. Anonymization: Making personal data incapable of being associated with an identified or identifiable natural person in any way, even by matching with other data.

3.4. Employee: ENGLISH HOME Staff.

3.5. Service Provider: Personnel of the company (supplier, subcontractor, customer, etc.) from which TÜRKÇE HOME receives and/or provides services.

3.6. Personal Data Owner (Relevant Person): The natural person whose personal data is processed.

3.7. Personal Data: Any information relating to an identified or identifiable natural person.

3.9. Special Quality Personal Data: Information that, if learned, may cause the person concerned to be victimized or exposed to discrimination.

3.10. Processing of Personal Data: Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available personal data by fully or partially automatic or non-automatic means provided that it is a part of any data recording system, All kinds of operations performed on data such as classification or prevention of use.

3.11. Data Processor: It is the natural or legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller.

3.12. Data Controller: It is the natural or legal person who determines the purposes and means of processing personal data, is responsible for establishing and managing the data recording system, and is obliged to register with the Data Controllers Registry.

3.13. KVK Board: Personal Data Protection Board

3.14. KVK Authority: Personal Data Protection Authority

3.15. KVK Law: Law on Protection of Personal Data published in the Official Gazette dated 7 April 2016 and numbered 29677

3.16. Policy: TÜRKÇE HOME , Personal Data Protection and Processing Policy.

4. WAYS OF COLLECTING PERSONAL DATA :

The data given by our customers who make transactions from the englishhome.ae website or mobile website or ENGLISH HOME mobile applications, request the sending of newsletters, campaigns and promotions and the like, carry out membership transactions, and shop are processed by TÜRKÇE HOME in accordance with the consent of our customers and the provisions of the legislation. .

In addition, the web and mobile site englishhome.ae, which belongs to TÜRKÇE HOME , is a site that uses cookies. cookie; It is a file consisting mostly of letters and numbers, which is stored in the internet browser or hard disk of the device being used, allowing to obtain information about the internet browsing of the device in question. In order to provide better service to its visitors and within the framework of its legal obligations, www.englishhome.com will collect, process, share with third parties and securely store your browsing information, provided that it is not used outside of the purposes and scope specified in this Statement on the Protection of Personal Data.

englishhome.aemay match information collected from you on the site at different times or in different ways, such as information collected online and offline, and use this information together with information from other sources, such as third parties.

5. RESPONSIBILITIES

5.1 Data Controller

Pursuant to the KVK Law, obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, of personal data in whole or in part, by automatic or non-automatic means provided that it is a part of any data recording system, Any operation performed on the data, such as classification or prevention of its use, means the processing of personal data.

TÜRKÇE HOME is responsible for the establishment and management of the data recording system by determining the processing purposes and means of the personal data registered in the database and has registered in the Data Controllers Registry.

5.2 Representative responsible for Data Protection

When the Data Controllers Registry is established , TÜRKÇE HOME will appoint a data controller representative required for registration in the Data Controllers Registry, and this person will be an expert Representative who will be responsible for the protection and processing of all personal data, taking security measures and conducting regular audits. will appoint.

5.3 Data Processor

Real or legal persons who process personal data on behalf of TÜRKÇE HOME pursuant to the authorization given by TÜRKÇE HOME of the data archived within the scope of the relevant legal legislation and the approval/permissions given by the Customer/data owners (For example; contractors, suppliers)

5.4 Liability

If personal data is processed by another real or legal person on behalf of TÜRKÇE HOME with the authorization given by TÜRKÇE HOME, the 3rd persons who process data with TÜRKÇE HOME as the data controller are jointly responsible for the necessary protection and taking the regulations/measures ordered by other legal regulations. ENGLISH HOME ; As the data controller within the scope of their responsibilities pursuant to the legal legislation, the trust they provide to the relevant persons who share their personal data with them; periodically audits the compliance of data processors with the privacy policy in order to ensure that it is maintained in the same way by its business partners, service providers, suppliers and contractors.

6. LEGAL OBLIGATIONS

In accordance with the KVK Law, TÜRKÇE HOME has legal obligations within the scope of protection and processing of personal data. These obligations are listed as follows:

6.1 Disclosure obligation

TÜRKÇE HOME is obliged to inform the person concerned during the collection of personal data and in this context, to inform the relevant person on the following issues within the scope of the relevant legislation:

• The identity of the data controller and its representative, if any,
• For what purpose the personal data will be processed,
• To whom and for what purpose the processed personal data can be transferred,
• The legal reason for collecting the personal data,
• The rights of the person concerned.

Within the scope of TÜRKÇE HOME's lighting obligation; will inform the related persons about the processing of their personal data by different means. In addition , TÜRKÇE HOME attaches importance to the fact that the policies open to the public are understandable by the personal data owners. The membership and confidentiality agreement on the websites of ENGLISH HOME companies contains information on the above-mentioned issues.

Which tools will be used to inform the Relevant Persons are determined by the internal policies.

6.2 Obligation to inform

The rights of the person from whom the personal data is provided, regarding the protection of personal data, regulated in Article 11 of the KVK Law (Section 12 of this document) are as stated. In accordance with the KVK Law, TÜRKÇE HOME evaluates the requests regarding the said rights; It is obliged to inform the Relevant Persons within the scope of the action to be taken in line with their requests, and this notification will be made within the period ordered by the legal legislation

Such requests must be submitted to ENGLISH HOME in writing by the Relevant Persons or by other methods to be determined by the KVK Board .TÜRKÇE HOME is working to provide the Related Person with more opportunities to apply and exercise their rights, so as not to contradict the Board's decision on this matter.

6.3 Obligation to ensure data security

As the data controller of TÜRKÇE HOME , the obligations regarding data security arising from Article 12 of the KVK Law are specified in the other regulations, particularly in Section 11 of this document, and the relevant legal legislation and mandatory matters brought by the Board will also be implemented by TÜRKÇE HOME.

6.4 Obligation to register with the Data Controllers Registry

TÜRKÇE HOME , pursuant to Article 16 of the KVK Law, is obliged to register with the Data Controllers Registry within the period determined and announced by the KVK Board in the Regulation and other legislation.

7. CLASSIFICATION OF PERSONAL DATA

7.1 Personal data:

The KVK Law defines personal data as any information relating to an identified or identifiable natural person. In this context, the person's data must be certain or identifiable (reaching the person when combined with other information). A person's name, surname, date and place of birth, identity, social security number, phone number, address, images, payment information, health information and similar information are included in the definition of personal data.

The subject of the Protection of Personal Data is natural persons whose data is processed, and legal persons are excluded from the scope. For this reason, information that does not contain information about a real person, such as a legal person's registration number, trade name and registration information, is not protected as personal data in accordance with the KVK Law.

7.2 Special categories of personal data:

Special categories of personal data; It is information that, if learned, may cause the person concerned to be victimized or exposed to discrimination; In KVK;

'' Data about race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, costume and clothing, membership to associations, foundations or unions, health, sexual life, criminal convictions, and security measures, as well as biometric and genetic data is Special Quality data.''

It is defined as It is forbidden to process sensitive personal data without the explicit consent of the person concerned, except for the cases expressly authorized by law.

In this context; This type of personal data is not processed by TÜRKÇE HOME , except for cases where it is required to be processed in accordance with the Law, or it is processed in accordance with the conditions specified in accordance with Article 6 of the KVK Law, provided that the explicit consent of the person concerned is obtained.

8. RULES OF PROCESSING PERSONAL DATA

8.1 Principles to be followed regarding the processing of personal data:

All collected personal data will be processed in accordance with the principles listed in Article 4 of the KVK Law and the conditions specified in Articles 5 and 6. TÜRKÇE HOME , in accordance with Article 4 of the KVK Law; is responsible for processing personal data in accordance with the law and honesty rules, accurate and when necessary, pursuant to up-to-date, specific, clear and legitimate purposes, in connection with the purpose, in a limited and measured manner.

In this Framework ;

• TÜRKÇE HOME is obliged to act in accordance with the rules, prohibitions, rights and principles stipulated by the laws and other legal regulations during the processing of personal data.

• TÜRKÇE HOME will be transparent during the processing of personal data, in accordance with the rules of honesty, and will comply with the obligation to inform and enlighten.

• TÜRKÇE HOME will be able to process personal data for legitimate and lawful reasons, that is, for limited purposes that are clearly defined and lawful, and within the scope of the permission given to it in cases where it needs permission.

• TÜRKÇE HOME will process personal data to the extent necessary. In this context, taking into account the principle of proportionality, personal data will not be used except for the activities carried out by TÜRKÇE HOME and the cases required by the purpose within the scope of these activities. In addition, the processing of personal data that is not needed or not needed will be avoided by exceeding the measure to achieve the purpose.

• TÜRKÇE HOME will keep personal data for the period stipulated in the relevant legislation or for the period required for the purpose for which they are processed, and after the expiration of this period, it will not keep this data without anonymization (if possible) for any reason.

8.2 TÜRKÇE HOME 's personal data processing purposes:

8.2.1. TÜRKÇE HOME processes personal data in accordance with Articles 5 and 6 of the KVK Law, for the purposes stated below and similar, in cases where approval is required, by obtaining the consent of the data subject person in accordance with the legal regulations:

• Personal and contact data: Name, surname, telephone, e-mail information are used for user registration and communication purposes.

• Demographic, Site and Application Navigation Data and Other data: The data collected by defining the interests of the users are used to provide better service by increasing the user experience along with the execution and development of operational activities such as business development, marketing and communication.

• Social Network Information: It is used to provide users with easier access to the site with their existing social network accounts and to provide better service by increasing the user experience with the execution and development of operational activities such as business development, marketing and communication.

• Location data: User's current location when using ENGLISH HOME< Website, Mobile site and applications; used if the user allows it. This data includes data about the precise or approximate location of Users. Location-based promotion and information can be made specific to the user.

8.2.2. Apart from the above-mentioned data-based purposes, data is generally collected for the following issues.

• Personal and contact data: Name, surname, telephone, e-mail information are used for user registration and communication purposes.

• Location data: User's current location when using ENGLISH HOME Website, Mobile site and applications; used if the user allows it. This data includes data about the precise or approximate location of Users. Location-based promotion and information can be made specific to the user.

8.2.2. Apart from the above-mentioned data-based purposes, data is generally collected for the following issues.

E-Mail, SMS, WhatsUp etc. Sending messages, bulletins and other publications via platform.

Answering questions and providing effective customer service,

To inform about new services,

Confirming the identity information of the shopper/dealer via the website/mobile applications,

To save the address and other necessary information for communication,

To communicate with our customers about the conditions, current status and updates of the contracts we have concluded under the relevant articles of the Law on Distance Sales Contract and Consumer Protection, and to provide the necessary information,

To arrange all records and documents that will be the basis of the transaction in electronic (internet / mobile etc.) or paper media,

To fulfill the obligations undertaken in accordance with the contracts we have concluded under the distance sales contract and the relevant articles of the Law on the Protection of the Consumer,

To be able to provide information to public officials, upon request and in accordance with the legislation, on matters related to public safety,

to provide our customers with a better shopping experience, to inform our customers about our products that may be of interest

to them, "taking into account the interests of our customers", to convey campaigns,

To increase customer satisfaction, to be able to recognize our customers who shop from websites and/or mobile applications and to use them in customer environment analysis, to use them in various marketing and advertising activities, and to organize surveys in electronic and/or physical environment through contracted institutions in this context,

To be able to offer suggestions to our customers by our contracted institutions and solution partners, to inform our customers about our services,

To be able to evaluate customer complaints and suggestions about our services,

To fulfill our legal obligations and to use the rights arising from the current legislation,

8.3 Ensuring that personal data is processed in accordance with the law:

TÜRKÇE HOME is obliged to take the following technical measures for the legal processing of personal data.

- Organizing the internal organization for the processing and storage of personal data in accordance with the Law,

- Establishing the technical infrastructure to ensure the security of databases where personal data will be stored,

- To determine the procedures for reporting the technical measures taken and audit processes,

• TÜRKÇE HOME takes the following administrative measures for the legal processing of personal data:

- To inform and train company employees on the legal protection and processing of personal data,

- to record the measures to be taken in case of unlawful processing of personal data by company employees in contracts, documents or policies made with company employees,

- to supervise the processing of personal data of data processors and partners with whom it works

responsible for.

9. PERSONAL DATA TRANSFER POLICY

The sharing of personal data of our customers with third parties takes place within the framework of the consent of the customers and as a rule, personal data is not transferred to third parties without the consent of the data subject/owner.

However, due to and limited to our legal obligations, personal data can be shared with courts and other public institutions, provided that it is not contrary to the legal regulations on KVK.

Personal data can be shared with ENGLISH HOME shareholders, our direct/indirect domestic/foreign affiliates, program partner institutions and organizations that we cooperate with to carry out our activities, domestic/foreign persons and institutions from which we get data storage services in the cloud, and domestic/foreign countries with which we have an agreement to send commercial electronic messages to our customers. institutions, the Interbank Card Center, the banks we have a contract with, and various domestic and foreign agencies, advertising companies and survey companies, and other domestic/foreign third parties and our relevant business partners, within the scope of various marketing activities in order to provide you with better service and ensure customer satisfaction.

9.1 Domestic transfer of personal data:

TÜRKÇE HOME is obliged to act in accordance with the decisions and regulations stipulated in the KVK Law and taken by the KVK Board regarding the transfer ENGLISH HOME personal data and sensitive data belonging to the relevant persons cannot be transferred to other real persons or legal entities without the express consent of the person concerned. In so far, in cases where the KVK Law and other laws make it mandatory, the data can be transferred to the authorized administrative or judicial institution or organization in the manner stipulated in the legislation and within the limits, without the explicit consent of the person concerned. In addition, as stipulated in Article 8 of the KVK Law, it is stipulated in paragraph 2 of Article 5 (for example, it is compulsory for the establishment or performance of a contract or fulfillment of a legal obligation) or as stipulated in paragraph 3 of Article 6 for special quality personal data. In some cases, it can be transferred without the consent of the person concerned. ENGLISH HOMEto third parties in Turkey with whom it has commercial cooperation/service, with personal data limited to the purpose of carrying out commercial purposes and activities, in accordance with the conditions stipulated in the Law and by taking all necessary security measures, after the termination of the business relationship with the third party. It can be transferred by the person to prevent their use.

9.2 Transfer of your personal data abroad:

TÜRKÇE HOME will not transfer confidential information abroad except in cases where it has received the consent of the person concerned . However, TÜRKÇE HOME may transfer personal data abroad to be processed in Turkey or to be processed and stored outside of Turkey. In exceptional cases where explicit consent is not sought for the transfer of personal data specified in the KVK Law, in addition to the conditions of processing and transfer without consent, adequate protection is sought in the country where the data will be transferred. The KVK board will determine whether adequate protection is provided or not; In the absence of adequate protection, data controllers in both Turkey and the relevant foreign country must undertake an adequate protection in writing and have the permission of the KVK Board.

9.3 Measures taken by ENGLISH HOME regarding the legal transfer of personal data:

• Measures taken from a technical point of view:

Unauthorized access and use of personal data processed, transferred or received as a result of transfer, by different affiliates within TÜRKÇE HOME , by different units within the said affiliates, and by natural or legal persons who process personal data on behalf of TÜRKÇE HOME based on the authorization given to it. takes measures to prevent it.

• Administrative measures taken:

ENGLISH HOME , by different affiliates within its body, by different units within the said affiliates, and by natural or legal persons who process personal data on its behalf based on the authority given by TÜRKÇE HOME , how and to whom access to personal data should be given in accordance with what processing purpose. its internal policies.

10. PERSONAL DATA STORAGE POLICY

10.1 Storage for the period stipulated in the relevant legislation or required for the purpose for which they are processed:

TÜRKÇE HOME retains the personal data it processes pursuant to Article 7 of the KVK Law and Article 138 of the Turkish Penal Code, only for the period required by the personal data processing purpose, if it is stipulated in the relevant legislation or if a period is not stipulated in the legislation. The retained data will be deleted after the purpose of keeping the data ends, and the maximum period for deletion is determined on average 2 years after the end of the purpose of keeping the data will.

For this reason, for each personal data, a different retention period may apply for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

For example, in accordance with Article 253 of the Tax Procedure Law, books and documents must be kept for 5 (five) years.

In another example, in accordance with the Regulation on Commercial Communications and Commercial Electronic Messages, in cases where the consent of the relevant person regarding the use of personal data for marketing or promotional purposes is withdrawn, the records of personal data should be kept for 1 (one) year from this date. The content of the commercial electronic message and any other record related to the post will be kept for 3 (three) years to be submitted to the relevant ministry when necessary.

On the other hand, a data may be processed for more than one purpose, and in such a case, unless there is a regulation in the legislation to the contrary, the relevant data is deleted, destroyed or anonymized and preserved when all the reasons causing the processing of the relevant data are eliminated.

10.2 Measures taken by TÜRKÇE HOME regarding the protection of personal data:

Personal data processed in accordance with the provisions of the KVK Law and other relevant laws will have to be deleted, destroyed or anonymized by TÜRKÇE HOME ex officio or upon the request of the person concerned, in such a way that these data will not be used or retrieved in any way. The procedures and principles regarding the destruction or anonymization of personal data in accordance with the law will be fulfilled in accordance with the principles and rules to be specified in the KVK Regulation.

• Measures taken from a technical point of view:

TÜRKÇE HOME establishes the necessary systems and control mechanisms for the deletion, destruction and anonymization of personal data.

• Administrative measures taken:

TÜRKÇE HOME , based on the authority given by TÜRKÇE HOME, to inform and raise awareness of real or legal persons who process personal data on its behalf, regarding the legal preservation of personal data; at the same time, it enables them to take measures regarding the legal preservation of their personal data and the deletion, destruction or anonymization of their personal data within the framework of the agreements concluded with these persons.

TÜRKÇE HOME is responsible for supervising the personal data protection activities carried out by natural or legal persons who process personal data on its behalf, based on the authorization it has given.

11. PERSONAL DATA SECURITY POLICY

11.1 TÜRKÇE HOME's Obligations Regarding Data Security Pursuant

to Article 12 of the KVK Law, TÜRKÇE HOME 's obligations regarding data security as data controller are as follows;

• TÜRKÇE HOME Personal data ; - to prevent unlawful processing , - to prevent unlawful access, - to ensure its protection,

- to prevent unlawful processing , - to

prevent unlawful access,

- to ensure its protection,

To take all kinds of technical and administrative measures for

• To carry out or have the necessary inspections made within the organization,

• To take the necessary measures so that the persons who process personal data on their behalf or the officials working in their bodies do not disclose the personal data they have learned during their duties to others in violation of the provisions of the law and do not use them for purposes other than processing, even if they leave their duties,

• Notifying the person concerned and the Board in case the processed personal data is unlawfully obtained by others

He will fulfill his obligations.

11.2 Measures taken by TÜRKÇE HOME regarding data security:

In order to fulfill its obligations regarding the security of personal data and to act quickly in cases where security poses a risk, TÜRKÇE HOME takes the measures listed below:

11.2.1. Technical and administrative measures taken to prevent unlawful access to personal data:

Technical and administrative measures to be taken are listed in the relevant sections regarding the processing, transfer and preservation of personal data. Although TÜRKÇE HOME is obliged to take these measures completely and to prevent unlawful access; if there is still unlawful access to personal data by third parties; takes all technical and administrative measures to prevent harm to the relevant persons in accordance with the relevant legislation on the protection of personal data and the Board decisions.

11.2.2. Measures taken for the protection of personal data and their control:

The data recording systems used within TÜRKÇE HOME are periodically monitored and audited whether they are created and used in accordance with the KVK Law and the relevant legislation, and reporting is made to the person or board authorized in this regard to the extent required by the legislation.

TÜRKÇE HOME, on the basis of its authorization, to inform real or legal persons who process personal data on its behalf, on the legal protection of personal data and to raise awareness; at the same time, it is obliged to determine provisions for the legal protection of personal data within the framework of contracts concluded with these persons.

11.2.3. Measures to be taken in case of unauthorized disclosure of personal data:

TÜRKÇE HOME is obliged to take measures to prevent unauthorized disclosure of personal data and to establish an internal policy regarding this. In addition, in such cases, TÜRKÇE HOME, as the data controller, is obliged to inform the persons whose personal data are disclosed in an unauthorized manner and the KVK Board.

12.RIGHTS OF THE RELATED PERSON

In accordance with the KVK, the Data Owner's data;

learning whether it is processed or not,

request information, if processed,

learning the purpose of processing and whether it is used in accordance with its purpose,

Knowing the third parties to whom it was transferred at home / abroad,

requesting correction if it is incomplete / incorrectly processed or changed,

To request deletion / destruction within the framework of the conditions stipulated in Article 7 of the KVK Law,

To request notification of the transactions made in accordance with subparagraphs (d) and (e) above, to the third parties to whom it has been transferred,

Objecting to the emergence of an unfavorable result because it is analyzed exclusively by automated systems,

To request the compensation of the damage in case you suffer damage due to the processing in violation of the KVK Law, has rights.

Right of access to personal data The persons concerned have the right to access their personal data without charge. For this reason, ENGLISH HOME to the relevant person within the scope of the relevant legal regulations;

• Learning whether their personal data is being processed;

• Requesting information on personal data if it has been processed;

• Learning the purpose of processing personal data and whether they are used in accordance with the purpose;

• The right to request to know the third parties whose personal data are transferred in the country or abroad.

It is committed to providing

Right of the Data Owner to change and/or delete their Personal data :

The persons concerned have the right to change or delete their personal data without being charged a fee. In this context;

• Requesting correction of personal data if it is incomplete or incorrectly processed;

• Requesting the deletion or destruction of personal data in case the reasons requiring the processing of personal data disappear;

• Requesting notification of the above-mentioned correction, deletion or destruction processes to third parties to whom personal data has been transferred;

• Objecting to the emergence of an unfavorable result by analyzing the processed data exclusively through automated systems.

Keeping Personal Data Up-to-Date :

In accordance with the KVK Law, we have an obligation to ensure that your personal data is accurate and up-to-date when necessary, therefore, in order to keep your personal data accurate and up-to-date, please notify us of any changes in your situation by calling 0850 7240 346 or by using the e-mail address [email protected] .

Application of the relevant person and evaluation of the application :

Subject to any limitation, within the scope of the rights provided by the relevant legal legislation, the persons concerned will be able to make a request to TÜRKÇE HOME in order to provide access to the personal data processed by TÜRKÇE HOME as soon as possible and to exercise the above-mentioned rights . TÜRKÇE HOME creates the necessary application channels to meet these access requests. Applications are answered as soon as possible and in any case within the time stipulated in the KVK Law.

Relevant persons will apply to the representative to be announced by TÜRKÇE HOME and to be announced in the Data Controllers Registry when the legal infrastructure is provided, through one of the relevant application methods. The representative of the data controller will conclude the requests regarding the processing and protection of personal data free of charge as soon as possible and in any case within 30 days at the latest. In any case, if the representative cannot be reached until this representative is appointed, the relevant person will be able to reach TÜRKÇE HOME via one of the communication channels under the previous paragraph and convey his request.

In order for this period to begin, the requests made by the relevant persons must be sent to the data representative in writing or by other methods determined by the KVK Board, and must also be submitted in full in documents identifying the data owner. Applications must be made in writing until a method is determined by the Board. During the application to be made by the person concerned, the person concerned should clearly state which right he/she has exercised and send the information and documents, if any, to the corporate address of Saray Mahallesi, Naya Sokak No: 3 Kat: 1 34768 Ümraniye, Istanbul, via registered mail with return receipt requested

he requests made by the data subject are accepted by the representative of the data controller or rejected by explaining the reason in the legislation office and a written or electronic response is reported. If the application is accepted, it is fulfilled by TÜRKÇE HOME In some cases, regarding the request for the processing/change/deletion of personal data, a positive response is not given to the request due to legal obligations or other reasons determined in accordance with Articles 5 and 6 of the KVK Law. In this case, the reasons for the refusal will be justified in detail and the legal basis will be reported.

In cases where the application is rejected by ENGLISH HOME within the scope of legal regulations, the answer given is insufficient or the answer is not given on time; The person concerned has the right to make a complaint to the KVK Board within 30 (thirty) days from the date of learning the answer and in any case within 60 (sixty) days from the date of application.

13. PURPOSE OF USE OF INTERNET COOKIES (COOKIES) and RIGHTS OF DATA RELATED :

This cookie practices policy; It applies to websites, mobile sites, Mobile Platforms, all kinds of applications, third party programs or platforms accessed and used by TÜRKÇE HOME or on behalf of them.

Element of purpose: Cookies are placed on devices (computer, app) to function properly, improve user experience, develop and optimize the site, serve more relevant, interest-based advertising, provide an interesting and personalized website/app and advertisement portfolio for visitors. phone, tablet) are small data snippets placed. Types of Cookies: Cookies may appear in different types according to different classification types. So-called session cookies are temporary cookies that are kept on your devices until you leave the website. Persistent cookies are cookies that remain on your device's hard drive for a long time.

Mandatory cookies enable the website to function properly and allow users to browse the site and benefit from its features. Mandatory cookies are anonymous.

Functional and Analytical cookies contain data about remembering your preferences, using the website effectively, optimizing the site to respond to user requests, and how visitors use the site. Due to their nature, these types of cookies do not contain usernames, etc. may contain your personal information.

Commercial cookies, on the other hand, serve to increase your usage experience by presenting similar products/content to the product/content you are targeting in line with your interests and choices, and by offering a more advanced, personalized advertising policy.

The above-mentioned session, permanent, functional and analytical and commercial cookies are kept in the background for about two months, and the necessary adjustments can be made in the user's internet browser settings. The removal process from these settings may vary based on the internet browser.

Third Party Cookies: TÜRKÇE HOME websites/mobile applications/mobile websites can work with third party (Google, Rtb House, Criteo, Related Digital) reliable and well-known advertising providers. In this case, third party providers place their own cookies in order to offer personalized advertisements by taking cookies into account. Cookies placed by third parties collect and process the browsing information of visitors on websites and analyze how they are used.

Cookie Permissions: By using ENGLISH HOME websites/mobile applications/mobile websites, you consent to the use of cookies in accordance with the scope of the "COOKIES POLICY".

Information about the use of cookies will be given with a pop-up window on the first visit to TÜRKÇE HOME websites/mobile applications/mobile websites. You will be deemed to have accepted when you close this window. It is possible to opt out of the use of cookies as stated in the last paragraph of the cookie types above.

You can remove persistent cookies and reject both session cookies and persistent cookies by following the instructions given in the "help" file of your internet browser.

Your information/data collected with cookies may be shared with 3rd party companies for targeted advertisement display.

Cookie Management: You can clear stored cookie data until you disable cookies. The location of these settings varies depending on the browser you are using. You can locate the relevant settings using the "Help" function in your browser.

It should be taken into account that if you do not accept certain cookies or if you cancel the authorization for the use of cookies, some functions of our internet/mobile site may be disabled, some services may not be used or the site may not display properly.

14. PUBLISHING THIS DATA POLICY

This data policy and rules will be notified to users with personal data, along with the obligation to inform within the scope of the legal legislation, and will also be published on the websites and mobile applications of ENGLISH HOME .

15. CHANGES AND UPDATES

The rights of the Data Owner in accordance with the KVK are the obligations of TÜRKÇE HOME . In this framework , in case of making or necessary changes in line with the economic and commercial decision of ENGLISH HOME or the decisions of the Legal legislation or the Personal Data Protection Board, relevant information, e-mail, sms, voice message and other available information to the Customer and related persons whose data is recorded. will be notified via at least one of the registered contact information.

16. RIGHT TO INFORMATION

You can reach us at any time at https://www.englishhome.com/bize-ulasin/ web address,[email protected] [email protected] e-mail address, 0850 7240 346 for any questions and comments regarding your personal data . Moreover; Saray Mahallesi, Naya Sokak No:3 K: 1, 34768 Ümraniye, Istanbul, by sending a registered letter with return receipt to the corporate mail address, you can get information via the preferred communication method and on the specified issues.

17. ENFORCEMENT

This data policy will be considered in force as long as it is published on the website, and TÜRKÇE HOME has the right to change it in accordance with the relevant legal legislation .

Saray Mahallesi, Naya Sokak No: 3 Floor: 1, 34768 Umraniye, Istanbul

Tel: 0850 7240 346

E-Mail: :[email protected]

EHM MAĞAZACILIK SANAYİ VE TİCARET A.Ş.

ENGLISH HOME