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POLICY REGARDING PERSONAL DATA

General information on the law of personal data;

Law No. 6698 on the Protection of Personal Data (hereinafter referred to as the KVKK) was adopted on March 24, 2016 and published in the Official Gazette No. 29677 of April 7, 2016. Some parts of the KVKK came into force on the date of publication, and some parts came into force on October 7, 2016.

Information on the capacity of data controller;

Pursuant to the KVKK No. 6698 and in the capacity of data controller, your personal data will be recorded, stored, updated, disclosed/transferred to third parties as permitted by law, classified and processed in the ways as indicated in the KVKK, within the framework described on this page.

How your personal data may be processed;

Pursuant to the KVKK No. 6698, your personal data that you provide to our company may be processed by us, in whole or in part, by being obtained, recorded, stored, amended, rearranged, in short, by being subjected to any transaction on data via automated means or, provided that they are part of a data recording system, via non-automated means. In the scope of the KVKK, all types of data processing are accepted as "processing of personal data.

Purposes and legal grounds for processing your personal data;

The personal data you provide will be processed for the following purposes;

• To meet the requirements of the services we provide to our customers, in accordance with contractual and technical requirements, and to improve the products and services we offer;
• To record identity, address and other necessary information to determine the data of the transaction owner as per Law No. 6563 on the Regulation of Electronic Commerce, Law No. 6502 on the Protection of Consumers, the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce published in the Official Gazette dated 26.08.2015 and numbered 29457 prepared based on the above regulations, and the Regulation on Distance Contracts published in the Official Gazette dated 27.11.2014 and numbered 29188 and other relevant legislation;
• To organize all records and documents that form the basis of payment systems, electronic contracts or relevant paper-based transactions prescribed in the field of banking and electronic payments; comply with the data retention, reporting and information requirements prescribed by law and other authorities;
• To be able to provide information to prosecutors, courts, and appropriate public officials in matters of public safety and litigation upon request and in accordance with law;

HOW WE COLLECT YOUR PERSONAL DATA

Your personal data may be processed and collected;

• Through forms on our company's website and mobile applications with information such as name, surname, Turkish ID number, address, telephone, business or private e-mail address and preferences on the pages logged in using the username and password, IP records of the transactions performed, cookie data collected by the browser, and data containing browsing time and details (location data);
• Verbally, in writing or electronically through our channels such as our sales and marketing department employees, branches, suppliers, other sales channels, paper forms, business cards, digital marketing and call center;
• In a physical or virtual environment, in a face-to-face or virtual setting, verbal or written or electronic media from people who share their personal data for purposes such as establishing a commercial relationship with our company, applying for a job, making an offer, giving a business card, resume (cv) and in other ways;
• Via data that is obtained indirectly through various channels, such as websites, blogs, competitions, surveys, games, campaigns and similar (micro) websites and social media, reading or clicking on e-bulletins, data provided by public databases, profiles and data shared by social media platforms.

Your Personal Data Obtained Before the KVKK Came Into Force;

Your personal data obtained, before April 7, 2016, the effective date of the KVKK, to collect membership details, receive electronic message consent, arrange product / service purchase and in other ways is also processed and stored in accordance with the terms and conditions set out in this document.

Transfer of your personal data abroad;

Your personal data collected by any of the above methods and to be processed in Türkiye or to be processed and stored outside of Türkiye may also be transferred to service intermediaries abroad (to countries accredited by the Personal Data Authority and where there is adequate protection for the protection of personal data), provided that it remains within the scope of the KVKK and contractual purposes.

Keeping Personal Data Current and Accurate;

Pursuant to Article 4 of the KVKK, our company is required to keep your personal data accurate and up to date. In this context, in order for our company to fulfill its obligations arising from the legislation in force, our customers are required to share accurate and up-to-date data or update them via the website / mobile application.

Rights of Personal Data Owner Pursuant to the KVKK No. 6698;

Article 11 of the KVKK No. 6698 came into force on October 07, 2016 and in accordance with the relevant article, the rights of the Personal Data Owner after this date are as follows: Owners of personal data have the right to exercise the following rights by contacting our company (data controller);

• To know if their personal data is processed or not,
• To request information if their personal data has been processed,
• To know the purposes for which personal data is processed and whether such data is used in accordance with their purpose,
• To know about the third parties to whom personal data is communicated, in the country or abroad,
• To request the rectification of personal data in the event of incomplete or inaccurate processing,
• To request the deletion or destruction of personal data under the conditions set forth in Article 7 of the KVKK,
• To request that these operations be communicated to third parties to whom personal data is communicated in the event of rectification, erasure or destruction of personal data,
• To raise an objection when the analysis of the processed data, carried out exclusively by automated systems, leads to a result that is detrimental to the data owner,
• To request compensation for the damage in the event of damage caused by the unlawful processing of personal data.

Firstep Intl. is the data controller under the KVKK. The data controller representative to be appointed by our company will be announced in the register of data controllers and on the website where this document is located, as soon as the legal infrastructure is available. Personal data holders may address their questions, opinions or requests to any of the following communication channels:

NAME/TITLE: Firstep Intl.
ADDRESS: Dubai
E-MAIL: info@firstepintl.com
PHONE: +971