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CLARIFICATION TEXT ON THE LAW OF PROTECTION OF PERSONAL DATA
DISCLOSURE AND PRIVACY POLICY ON THE PROTECTION OF PERSONAL DATA

Safir Flexo provides the basic information on the protection of transferred personal data below. Alm Market presents the following clarifications to the attention of our customers and third parties using our website to fulfill the obligation of disclosure arising from Article 10 of the Personal Data Protection Law No. 6698 (“KVKK”). Safir Flexo reserves the right to update this disclosure text on the Protection of Personal Data at any time within the framework of changes that may be made in the applicable legislation.

1. What is the legal basis for Safir Flexo collecting personal data?
   There are various regulations regarding the use of personal data of our customers. Primarily, the principles of personal data protection are determined by the KVKK. In addition, the Law on the Regulation of Electronic Commerce No. 6563 contains provisions regarding the protection of personal data. Provisions of the Turkish Penal Code No. 5237 also foresee criminal sanctions for the protection of personal data in certain cases. Furthermore, data collection and use are necessary to fulfill our obligations arising from the Law on the Protection of the Consumer No. 6502 and the Distance Sales Contracts Regulation.

2. What methods does Safir Flexo use to collect personal data?
   The data provided by customers conducting transactions through the Projesoft website or mobile applications are processed by Safir Flexo with the consent of our customers and in accordance with legal regulations. The Projesoft website owned by Safir Flexo is a site that uses cookies. A cookie is a file, mostly consisting of letters and numbers, stored on the internet browser or hard disk of the device being used, enabling the identification of the device in question. To provide better service to visitors and within the scope of its legal obligation, Projesoft will collect, process, share with third parties, and securely store your browsing information, provided that it is not used for purposes other than those stated in this disclosure text. Projesoft cookies store information collected via log files, empty gif files, and/or third-party sources to create a summary of your preferences. Projesoft may track your browsing information and/or usage history on the site to offer special promotions, marketing offers, or to tailor the website or mobile app content to your preferences. Projesoft may match the information collected on the site from different methods or at different times, and may combine such information with data obtained from third-party sources. A session cookie expires when you close your browser, while a persistent cookie remains on your hard drive for a long time. You can remove persistent cookies and reject both session cookies and persistent cookies by following the instructions in your internet browser's "help" file or by visiting “www.allaboutcookies.org” or “www.youronlinechoices.eu.” If you reject persistent cookies or session cookies, you may continue to use the website but may not be able to access all its functions, or your access may be limited.

3. How are cookies used on the website?
   Projesoft uses cookies to remember your preferences and personalize your use of the website. This usage includes cookies that save your password and keep your website session open, thus saving you the trouble of entering your password multiple times during each visit. It also includes cookies that remember and recognize you on future visits to the site. Projesoft uses cookies to track how you use the website, such as from where you connect to the website, what content you view, and the duration of your visit. Projesoft uses cookies for advertising/promotion purposes to provide you with more relevant content and advertisements based on your interests and preferences. It ensures that you do not repeatedly see content or offers you have previously indicated you are not interested in.

4. How does the website use third-party cookies for advertising and retargeting?
   Projesoft may also use cookies to employ "advertising technology" to serve you advertisements it believes may interest you when you visit search engines, the website, mobile applications, or websites where the website advertises. Advertising technology uses information about your previous visits to the website, mobile applications, and the websites where the site advertises to provide personalized advertisements. When serving these ads, a unique third-party cookie may be placed on your browser to allow the website to recognize you. You can remove persistent cookies and reject both session cookies and persistent cookies by following the instructions in your internet browser's "help" file or by visiting “www.allaboutcookies.org” or “www.youronlinechoices.eu.”

5. For what purposes does Safir Flexo use personal data?
   Safir Flexo may record, store, update, disclose, transfer, classify, and process your personal information as permitted by law and to the extent necessary. Your personal data is used for the following purposes: confirming the identity of the customer making the transaction through the website, recording the address and other necessary information for communication, contacting customers about the terms, current status, and updates of the contracts we have signed under the relevant articles of the Distance Sales Contracts and Consumer Protection Law, making the necessary notifications, preparing all records and documents that will serve as the basis for transactions in electronic (internet/mobile, etc.) or paper form, fulfilling obligations undertaken in accordance with the contracts signed under the relevant articles of the Distance Sales Contracts and Consumer Protection Law, providing information to public officials on matters of public safety upon request and as required by law, improving the shopping experience of our customers, informing customers about products and services that may interest them, conveying campaigns, increasing customer satisfaction, recognizing customers who shop on the website, using customer analysis in various marketing and advertising activities, conducting surveys either electronically or physically through third parties within this scope, offering suggestions to our customers by our contracted institutions and solution partners, informing our customers about our services, evaluating customer complaints and suggestions regarding our services, fulfilling legal obligations, and exercising our rights arising from the current legislation.

6. How does Safir Flexo protect personal data?
   Personal data shared with Safir Flexo is under the supervision and control of Safir Flexo. Safir Flexo, as the data controller, is responsible for establishing the necessary organization and taking and adapting technical measures to protect the confidentiality and integrity of the data, as required by the applicable legal provisions. Aware of our responsibility in this regard, we would like to inform you that we have periodic penetration tests performed in compliance with international and national technical standards on data confidentiality and that we always keep our data processing policies updated.

7. Does Safir Flexo share personal data?
   The sharing of personal data belonging to our customers with third parties is carried out within the consent of our customers, and as a rule, personal data is not transferred to third parties without the consent of our customers. However, personal data may be shared with courts and other public institutions due to our legal obligations and limited to these. Moreover, to provide the services we have undertaken and to ensure quality control, personal data may be transferred to contracted third parties. During the transfer of data to third parties, necessary technical and legal measures are taken to prevent rights violations. However, Safir Flexo is not responsible for breaches that occur due to third-party data protection policies and the risk area under the responsibility of the third party.

8. What are your rights arising from the Personal Data Protection Law?
   According to KVKK, you have the following rights regarding your personal data:

a) To learn whether your personal data is processed,
b) To request information if your data has been processed,
c) To learn the purpose of the processing and whether it is used in accordance with its purpose,
d) To know the third parties to whom the data is transferred domestically or abroad,
e) To request the correction of your data if it is incomplete or inaccurate,
f) To request the deletion or destruction of your data under the conditions set forth in Article 7 of the KVKK,
g) To request notification of the actions taken pursuant to subparagraphs (d) and (e) to the third parties to whom your data has been transferred,
h) To object to any result arising against you as a result of the analysis of your data by exclusively automated systems,
i) To request compensation for any damages incurred due to the unlawful processing of your data.

9. How can I be informed about changes in personal data-related legislation?
   The rights you have under KVKK are Safir Flexo's obligations. We process your personal data with this awareness and in compliance with the legislation, and we will update this information on our page to comply with any legal changes. You can always easily follow the updates made through this page.

10. How can I ensure that my data is kept accurate and up-to-date?
    According to Article 4 of the KVKK, Safir Flexo has the obligation to keep your personal data accurate and up-to-date. In this regard, to fulfill our obligations arising from the applicable legislation, our customers must share their accurate and up-to-date data with Safir Flexo. If your data is subject to any changes, we kindly ask you to update your data by contacting us through the communication channels provided below.