VAY TRADE’S PERSONAL DATA PROTECTION POLICY, PERSONAL DATA CLARIFICATION AND CUSTOMERS’ CONSENT TEXT

As Vay Trade, we have prepared this Personal Data Protection Policy, Personal Data Clarification and Customers’ Consent Text (“PDPP”) in order to enlighten the data owners (Customers) regarding the processing, storage and transfer of their personal data within the framework of our activities arising from the Law on the Protection of Personal Data No. 6698 (“KVKK”). In addition to these, personal data of the Customers processed via cookies are also included herein. This PDPP shall be valid as of the date of its publication by Vay Trade. For the avoidance of doubt, Vay Trade can always make changes in the PDPP if necessary. Changes to be made become effective immediately upon the publication of the PDPP on the Digital Platform. Please be kindly informed that the phrases of “Customer” and “Digital Platform” used herein, shall have the same meanings described for them in the Membership and Online Commercial Sales Agreement. In order to become a Customer and shop from our Digital Platform, there is a membership requirement and in that regard, for benefiting from the personalized and privileged services on our Digital Platform, some of your personal data may need to be processed for the purposes specified below, shared with our contracted professional business partners and recorded in our programs and/or systems provided by our technology suppliers. Some of your personal data that needs to be processed in order to ensure the satisfaction of our customers are subject to the express consent of our Customers according to KVKK.

1. Categories of Processed Personal Data and Methods of Their Acquisition

The below-mentioned data of our Customers shall be processed by Vay Trade during providing our services through our Digital Platform:

* Your identity information (name, surname, date of birth, nationality, TR identity number, gender, passport validity date, passport number),

* Your contact information (e-mail address, billing and delivery addresses, phone number, mobile phone numbers shared by our Customers through online and/or printed forms);

* Your customer transaction information (request information, order information, billing information, customer comments etc.),

* Your financial information (credit card information),

* Your marketing information (cookie records, shopping history, explicit or implicit user ratings collected during your use of our Digital Platform),Your transaction security information (IP address information, website login and exit information, user name information, password information, traffic data such as connection time/duration) and

* Your location that can be collected according to your preferences in your internet browser and/or our company's mobile application or your internet browser while using our Digital Platform.

2. Processing Purposes and Legal Reasons of Processed Personal Data

* Once you become a Customer of our Digital Platform, your personal data will be (may be) processed by Vay Trade for the below mentioned purposes:

* Creating special advertisements, promotions, and campaigns customized for you,

* Cross-selling,

* Determination of the target audience,

* Carrying out activities to increase your user experience by following your customer movements,

* Improving the operation of the Digital Platform and personalizing it according to the Customers’ needs,

* Execution of direct and indirect marketing, personalized marketing and remarketing activities,

* Carrying out personalized segmentation, targeting, analysis, and internal reporting activities,

* Conducting market research,

* Planning and execution of sales and marketing processes of Vay Trade and its professional business partners, including for the purposes of planning and executing customer satisfaction activities and customer relationship management processes,

* Planning and execution of the processes of creating and/or increasing loyalty to the products and/or services offered by Vay Trade and

* Conducting communication activities for all these purposes described above.

Our Customers’ personal data will be processed by Vay Trade depending on the legal reason of “explicit consent” of our Customers as regulated under paragraph 1 of Article 5 of KVKK. Personal data of our Customers may be shared with third parties within the country including our business partners and suppliers. Moreover, based on the rules regulated under Article 9 of KVKK, the personal data of our Customers may be shared with other third parties, our business partners, and suppliers abroad.

3. Customers’ Rights Related To Processed Personal Data

We would like to kindly inform all of our Customers that, in accordance with Article 11 of KVKK, our Customers have the rights explained below in terms of their personal data processed by Vay Trade for maintaining the purposes as explained above:

* To learn whether your personal data is processed,

* To request information about your processed personal data, if your personal data has been processed,

* To learn the purpose of processing your personal data and whether they are used in accordance with the respective purpose,

* To learn about the third parties abroad or within the country to whom your personal data has been transferred,

* To request correction of your personal data if it is incomplete or incorrectly processed,

* To request deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK legislation,

* When you request deletion or destruction of your personal data with the correction of incomplete or incorrect data; to request this situation to be notified to the third parties to whom your personal data has been transferred,

* To object to the result in case of an adverse result by analyzing your processed data exclusively through automated systems, and

* To request indemnification of your damage, if you incur damages due to the illegal processing of your personal data.

By clicking the "Create my account" button on the sign-up page, you will be deemed to have consented to the processing of all your personal data listed above, limited to the processing purposes specified, without any pressure and expressly consenting. If you would like to make an application to Vay Trade in terms of your personal data, please do not hesitate to contact us via Email: support@vaytrade.com