Privacy Policy

Welcome to Vervati Atelier. We are extremely committed and sensitive to the protection and confidentiality of your Personal Data. This Privacy Policy and Clarification Text contain information about what Personal Data we collect, for what purpose we use them and how we process them. We declare that we will ensure the confidentiality of your Personal Data and that we will implement our policies and practices regarding the collection, use, storage, disclosure, transfer, security and access of your Personal Data within the limits drawn by the Law on Protection of Personal Data No. 6698 and relevant legislation. This Clarification Text has been prepared by İnnovanka Tekstil Gıda ve Dış Ticaret Limited Şirketi in order to carry out the retail service in line with the Law on Protection of Personal Data No. 6698.

Please review this Clarification Text and our Privacy Policy carefully. If you do not agree with the terms contained herein, please do not use our application.

Personal Data Processing Rules

Concepts

The definitions of the terms we use in this Policy are as follows:

Relevant Person: The natural person whose personal data are processed.

Law: Law on Protection of Personal Data dated March 24, 2016 and numbered 6698.

Registered Customer: Customers to whom we offer our services and who have a registered account on our website.

Personal Data Processing: 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, Any operation performed on the data, such as the classification or prevention of its use, is considered as the processing of personal data. All kinds of activities carried out in the process until the deletion, destruction or anonymization of personal data after the collection of personal data as specified.

Board: Personal Data Protection Board.

Institution: Personal Data Protection Authority.

Retail and Service: refers to the sale of goods or service (through physical or online channels) in relation to any of the following: HAUTE COUTURE KIDS & WOMEN CLOTHING AND ACCESSORIES

Deletion: Deletion, destruction or anonymization of personal data.

Data Controller: 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.

Principles governing the Processing of Personal Data

When processing your personal data, we act in accordance with the following principles:

We take the necessary care to ensure that your personal data is accurate and up-to-date.

We process your personal data for specific, clear and legitimate purposes and present these purposes to you in a transparent and understandable manner.

We only process your personal data when it is relevant, limited and proportionate to the processing purposes.

We retain your personal data only for as long as required by the legislation or for the purpose for which they are processed. If there is a period stipulated in the legislation for the storage of personal data, it complies with this period; If such a period is not foreseen, we only store your personal data for the period necessary for the processing purposes.

Legal Reasons for Personal Data Processing

We process your personal data based on the legal reasons set out in Articles 5 and 6 of the Law on the Protection of Personal Data No. 6698. According to this,

• We process your personal data if necessary for the conclusion or performance of a contract between you and us.

• We process your personal data for the establishment, exercise or protection of a right.

• We process your personal data in order to fulfill our legal obligations.

• We process your personal data when required by our legitimate interests.

In the absence of any of the above-mentioned personal data processing legal grounds, we only process your personal data based on your explicit consent. When we ask for your explicit consent to process personal data, we do so only on a specific subject, clearly and in a way that makes sure you understand the consequences of the data processing.

While processing your personal data based on one or more of these legal reasons, in the light of the Decision of the Personal Data Protection Board dated 25.03.2019 and numbered 2019/78 (https://www.kvkk.gov.tr/Icerik/5434/2019-78) We make a balanced assessment by comparing your fundamental rights and freedoms with the legitimate interests that will arise.

Which Personal Data Do We Process?

As a Registered Customer, we collect your personal data in various ways to create and manage your account and to provide you with our services. We may also need some other information in order for you to benefit from services and products that we think may be of interest to you and that are tailored to you. In general, we only use the personal data we receive from you for the purposes described in this Privacy Policy and to the extent permitted by the Personal Data Protection Law. The categories of personal data we collect from you are presented below:

Identity, Contact and Payment Information: Name-Surname, phone number, e-mail address, payment information, gender, age, preferences, likes, interests that you share when creating an account. We will also ask you to create a password for your account and we will keep this data encrypted.

User Actions: Information that our servers automatically collect through log records when you take actions on the Vervati Atelier website. This information includes information about your device such as IP address, device type, device identifier number, internet browser type, device location, and other technical information such as user transaction logs and application usage information.

Some of this information may be collected using cookies and similar technologies. For more explanation on this subject, read the "Cookies and Similar Technologies" section below.

Location Information: In order to provide you with services related to your location, we may request access and tracking permission from your mobile device to your location information continuously or only while you are using Vervati Atelier. In this context, if you want to make changes about the access permissions you will give us, you can do this in the settings of your device.

Cookies and Similar Technologies

At Vervati Atelier, we may use cookies and similar tracking technologies (for example, web beacons, tracking pixels and others) to personalize our services for you and to help improve your experience. When you log into our website, your personal information is not collected using tracking technology. Most browsers are set to accept cookies by default. You can remove or refuse cookies, but you should consider that this may affect the use and functionality of our website. You cannot reject web beacons. However, you can disable it by rejecting all cookies or by changing your web browser's settings to notify you when each cookie is installed, so you can accept or reject each cookie individually.

We also cooperate with certain third-party companies (for example, PLEASE SELECT APPROPRIATE: Adobe Analytics,] [Clicktale,] [Clicky,] [Cloudfare,] [Crazy Egg,] to analyze and monitor your use of our website, and to better understand online activities. [Flurry Analytics,] [Google Analytics,] [Heap Analytics,] [Inspectlet,] [Kissmetrics,] [Mixpanel,] [Piwik,] et al.) We may allow tracking technologies and remarketing services using first-party cookies and third-party cookies. By logging into our website, you consent to the collection and use of your information by these third-party vendors. That's why we recommend that you review these companies' privacy policies, opt-out features, and tools, and contact them directly to get answers to your questions.

Getting a new computer, installing a new browser, upgrading an existing browser, or deleting or otherwise modifying your browser's cookie files may also clear certain opt-out cookies, plug-ins or settings.

How Do We Process Your Personal Data?

We collect and process your personal data on our website by automatic and partially automated methods.

Why Do We Process Your Personal Data?

Generally, we process your personal data because having accurate information about you allows us to provide you with a more personalized experience. Specifically, we process your personal data for the following purposes:

• Making your Customer Registration application,

• Completion of your orders, payment status and verification of your details

• To be able to offer you the most suitable options and suggestions for your preferences, likes, interests, usage habits and location,

• To be able to offer you special advertisements and promotions, if you consent to receive advertising notifications,

• Administration, administration and maintenance of our website,

• Collecting anonymous statistical information in order to improve our services and increase the effectiveness of Vervati Atelier,

• To receive feedback from you and to follow up and finalize your requests or complaints,

• Fulfilling our activities and transactions in accordance with the applicable legislation,

• Performing user age verification checks,

• Detection and prevention of security risks, fraud and abuse,

• Examining and supervising the commercial activities of Vervati Atelier,

• Organizing and conducting user relationship management, user satisfaction surveys and developing communication strategies within this scope,

• Carrying out corporate communication activities,

• Establishing the necessary infrastructure, business plans and operations to ensure the legal, commercial and technical security of you and your personal data,

• Performance evaluation processes with business partners and suppliers and organization of these processes, legal compliance process,

• Elimination of possible conflicts and malfunctions,

Transfer of Your Personal Data

We share your personal data with certain groups of recipients in certain circumstances, as described below:

Authorized Persons, Official Institutions and Organizations

If we consider that disclosure of information about you is necessary to exercise, establish or defend our legal rights, to investigate or correct potential violations of our policies, or to protect the rights, property, and safety of you and others, we may not disclose your information to any authorized person or government agency or organization, any applicable law. We may share to the extent permitted or required by rule or regulation.

Affiliates

We may share your personal data with our affiliated companies. In this case, our affiliates will also be required to comply with this Privacy Policy. Affiliates refer to our parent company and any subsidiaries, joint venture partners or other companies that we control or are under joint control with us.

Third Party Service Providers

Providing data processing services to us or on our behalf, including data analysis services, e-mail services, hosting services, customer service, marketing support, financial, legal, accounting services, or that we disclose personal information in this Privacy Policy We may share it with third parties that process it for other purposes.

Our Business Partners

We may share your personal data with our business partners in order to offer you certain products, services and promotions.

Third Party Advertisers

We may use third party advertising companies to serve ads when you visit Vervati Atelier. These companies may use information about your visits to our website and other websites contained in web cookies to serve ads about goods and services that interest you.

Other Third Parties

We may share your information with advertisers and investors for general business analysis purposes. Based on your consent, we may also share your information with such third parties for marketing purposes as permitted by law. You can always withdraw your consent in this matter.

International Data Transfer

We may transfer your personal data to authorized institutions, affiliates, business partners and service providers located in countries outside of Turkey for the purpose of managing our activities and support services and fulfilling our legal obligations. Vervati Atelier servers are in [specify country]; however, our third party service providers and partners operate in many countries, including [specify COUNTRIES]. Therefore, it is possible for us to transfer your personal data to these countries.

Although the legal regulations regarding the protection of personal data in these countries may differ, Vervati Atelier takes appropriate measures to protect your personal data in these countries in accordance with this Policy. Among the measures we take to securely transfer your personal data abroad, to the extent appropriate and necessary, we also use standard contractual provisions for the legal processing of personal data with our affiliated companies, business partners and service providers.

Personal Data Security

We attach great importance to the secure storage of your personal information. For this purpose, we take appropriate technical and administrative measures, and industry, including anti-virus software, firewalls, access controls, encryption, detection and prevention software, to prevent unauthorized access, unlawful processing, loss, destruction and damage to your personal data. We use technology standards.

Secure payment infrastructure is provided by [……………………….].

When you choose a password to log into Vervati Atelier, it is your responsibility to keep this password confidential and we recommend that you use a separate password for Vervati Atelier and not share your password with anyone. As Vervati Atelier, we are not responsible for any unauthorized transactions made with your username and password.

Your Rights Under the Law on Protection of Personal Data

Article 11 of the Personal Data Protection Law regulates your rights as a relevant person. Accordingly, you have the following rights:

• Learning whether we process your personal data,

• Requesting information about this if we process your personal data,

• To learn the purposes of processing your personal data and whether they are processed in accordance with the purpose,

• Learning whether your personal data is transferred to third parties,

• If your personal data is transferred to third parties, whether in the country or abroad, learning the identities of these third parties,

• Requesting that your personal data be corrected if it is incomplete or incorrectly processed and that the action taken within this scope is notified to the third parties, if any, to which your personal data has been transferred,

• Requesting the deletion or destruction of your personal data in the event that the reasons for processing your personal data cease to exist, and the notification of the transaction, if any, to the third parties to whom your personal data has been transferred,

• Objecting to the consequences that may arise against you by analyzing your personal data exclusively through automated systems,

• Requesting compensation if you suffer a loss due to the unlawful processing of your personal data.

You can reach us by using the contact information provided in the "Contact Us" section below to exercise these rights and to send us your requests. In addition, in accordance with paragraph 1 of Article 13 of the Law on Protection of Personal Data No. 6698, titled "Application to Data Controller", you may submit your request in writing or by other methods determined by the Personal Data Protection Board.

We respond to all requests regarding the exercise of the rights related to the protection of personal data in accordance with the Law on the Protection of Personal Data. Depending on the nature of your request, your request will be concluded free of charge as soon as possible, but in any case not more than thirty days. However, if additional costs arise for us to fulfill your request, you may be charged at the rate determined by the Personal Data Protection Authority.

The Choices You Have Regarding Your Personal Data

Account info

Whenever you want,

● Update your account by logging into account settings

● To reach us using our contact information provided below

You can review your account, change your account information or close your account by any of the ways.

Upon your request to close your account, your account and personal data will be deactivated or deleted from our active databases. However, when we have a continuing legitimate requirement by law to retain your data for a certain period of time (for example, to provide you with a service you have requested, to fulfill our legal obligations, to prevent fraud, to troubleshoot malfunctions, to enforce our Terms of Use, our accounting requirements), certain information can be kept in our files. When the legitimate reasons for processing your personal data disappear, your personal data is deleted, destroyed or anonymized.

Emails and Messages

If you do not wish to receive correspondence, e-mail or other communications from us, you may opt-out of them by:

● Notifying your preference in this direction when registering on our website

● To update your preferences by entering your account settings

● Using the unsubscribe function in correspondence, e-mail or other communication sent to you

● To contact us using the contact information provided below

If you do not wish to receive correspondence, email or other communications from third parties, you should contact them directly.

Innovanka Tekstil Gıda ve Dış Ticaret Limited Şirketi is the data controller for the processing of your personal data. To send us any questions, comments and requests regarding this Personal Data Protection and Privacy Policy or the protection of your personal data, you can contact us via one of the following:

Address: Söğütözü Mahallesi 2177.Cadde No:10B/153 Çankaya/Ankara

[Phone Number] (0312) 267 20 00

[E-mail]

In addition, your request, which includes your explanations regarding the exercise of your rights listed in the Law No. 6698, must be submitted with the Personal Data Owner Request Form [REQUEST FORM LINK].

- to the [.................] e-mail address, or

- Söğütözü Mahallesi 2177.Cadde No:10B/153 Çankaya/Ankara address,

with documents identifying your identity,

- can personally transmit,

- send it through a notary public or other methods specified in the Law on the Protection of Personal Data No. 6698, or

- You can send your request to innovanka@hs01.kep.tr with a secure electronic signature.

Last updated: 02/03/2022