BeforeSunset User Privacy Notice

A. Data Controller

In accordance with the Law on Protection of Personal Data numbered 6698 (“Law”), personal data relating to you shall be processed by BeforeSunset Inc. (“Company”) as the data controller, within the below-specified scope.
This User Privacy Notice explains in which scope your personal data collected within the framework of your relationship with our Company is processed. This User Privacy Notice also contains information regarding your rights in connection to your personal data.

B. Processed Personal Data Categories

Pursuant to the Article 3 and 7 of the Law, irrevocably anonymized personal data shall not be considered as personal data in accordance with the provisions of the Law. Your personal data categories that can be processed within the scope of BeforeSunset Platform (“Platform”) are as follows:
 - Identity Information (e.g. name, surname),
- Contact Information (e.g. address, email address, telephone number),
- Transaction Security (e.g. IP address information, network and device information, website login and exit information, code and password information),
- Marketing Information (such as survey responses based on voluntariness, cookies),
- Customer (i.e. Platform user (“User”)) Transaction Information: Purchase, purchase history information, invoice and payment type, return/withdrawal information, user and operation information, request/complaint provided by the User.
The Company does not record your credit/bank card information and solely transfer this information directly to the relevant payment institution.

C. Purpose of Processing of Personal Data

Your personal data that have been collected may be processed within the scope of the following purposes (“Purposes”); In order to conduct works which will enable our Company to offer you our products/services;
- Execution of procedures regarding the sale of products/services that you order, order delivery and agreement processes, issuance of invoices, management of online payment processes,
- Customer and User relations management,
- Improving and enhancing user experience regarding the Platform,
In order to customize products/services to your likings, habits of use and needs, provided that you give your explicit consent,
- Activating customizations presented on the Platform upon User requests and providing personalized products/services,
- Sending offers, advertisement and similar commercial electronic message to the User contact information,
- Carrying out Platform and User subscriptions,
In order to carry out Company’s commercial activities;
- Execution of accounting and finance processes,
- Execution of information security processes,
- Fulfillment of our obligations arising from the legislation,
- Provision of information and documents to authorized public institutions and organization and private persons and judicial and enforcement authorities and performance of our other legal obligations,
- Planning and implementing business and commercial strategies of the Company.

D. To Whom and For Which Purposes Processed Personal Data Shall be Transferred

Your personal data shall be transferred to our business partners, suppliers, payment service providers, banks, public institutions and organization and real persons authorized by law, judicial and enforcement authorities, public notaries, third parties rendering service to our Company in the fields of law and accounting in order to realize the above mentioned Purposes within the scope of the conditions of the processing personal data envisaged under Articles 8 the Law.
In addition, upon your “explicit consent” your personal data may be shared with companies residing abroad from which we receive services/products in areas such as storage, archiving, information technologies (server, hosting, program, cloud computing), security, server service, e-mail and online meeting on the purpose of execution of storage and archive activities, using e-mail, online meeting and similar online communication methods, planning information security processes and establishing and/or managing information technology infrastructure.

E. Method of Collecting Your Personal Data, and Legal Grounds

Your personal data will be collected by our Company by means of information/documents you submitted to our Company by hand, through the channels on the Platform, e-mail, shipment, telephone; application and registration forms published in written or electronic media and filled by you in order to register and use the Platform; by fully or partially automatic or non-automatic ways, for the purpose of making our Company’s products/services available to you. Your personal data are processed based on the below legal grounds: On the basis of the legal ground regarding the processing of personal data to be mandatory for the Company’s legitimate interests;
- Customer and User relations management,
- Execution of accounting and finance processes,
- Execution of information security processes,
On the basis of the legal ground regarding the processing of personal data belonging to contact parties to be required, provided that it is directly related to the execution or performance of a contact;
- Execution of procedures regarding the sale of products/services that you order, order delivery and agreement processes, issuance of invoices, management of online payment processes,
On the basis of the legal ground regarding the Company’s legal obligation;
- Fulfillment of our obligations arising under the legislation,
- Provision of information and documents to authorized public institutions and organization and private persons and judicial and enforcement authorities and performance of our other legal obligation,
Or on the basis of your explicit consent;
- Activating customizations presented on the Platform upon User requests and providing personalized products/services,
- Sending offers, advertisement and similar commercial electronic message to the User contact information,
- Carrying out Platform and User subscriptions.

F. Data Subject’s rights Under Article 11 of the Law

As a personal data owner, if you send us your request regarding your rights by the methods set out below, we will conclude your request free of charge as soon as possible depending on the nature of your request and within 30 (thirty) days at the latest. However, if the transaction requires a separate cost, the fee determined by the Personal Data Protection Board will be based on. Within this context, you have the following rights, as data owner;
- To learn whether your personal data were processed or not,
- If your personal data were processed, to request information on this subject,
- To learn the purpose of processing of your personal data, and whether or not they were used in compliance with the purpose,
- To learn the third persons to whom your personal data were transferred at home or abroad,
- If your personal data were processed inaccurately or incompletely, to request correction of the data, and to request that the procedure performed within this scope be notified to the third persons to whom your personal data were transferred,
- If, although the personal data were processed in compliance with the Law and any other related statutory provisions, the reasons that required processing of data are no longer applicable, to request that the personal data be deleted or destroyed, and within this scope, and if your personal data were inaccurately or incompletely processed, to request that the procedure performed be notified to the third persons to whom your personal data were transferred,
- To object to any results that are detrimental to you as a consequence of the analysis of your personal data exclusively through automated systems,
- To request reimbursement for any kind of loss incurred due to unlawful processing of your personal data.
You can forward your application/request related to the above-mentioned rights to us through methods below or other methods stipulated by Personal Data Protection Board.

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