1. INTRODUCTION

The security and/or protection of your personal data is among our priorities at Bakır Dünyası. With this awareness, we attach great importance to the processing and storage of all personal data belonging to all related individuals, including those who benefit from our products and services, in accordance with the Law No. 6698 on the Protection of Personal Data ("KVKK"). Accordingly, as the "Data Controller" as defined in the KVKK, and in accordance with Article 10 of the KVKK and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform published in the Official Gazette No. 30356 on March 10, 2018 by the Personal Data Protection Board, we fulfill our duty to inform personal data owners during the collection of personal data; We provide data subjects with this information regarding the identity of our company at the time of collection of their personal data, the purpose for which the personal data will be processed, to whom and for what purpose the processed personal data may be transferred, the method and legal basis for collecting personal data, and the rights of the data subject under Article 11 of the Personal Data Protection Law.

Unless explicitly stated otherwise, the terms “we” and “our” used in this Privacy Notice refer to Copper World.

2. PERSONAL DATA

Definition of Personal Data

Within the framework of Article 3/I(d) of the Personal Data Protection Law, "personal data" refers to any information relating to an identified or identifiable natural person. In this context, personal data refers to any information relating to an identified or identifiable natural person.

For example, your name, surname, Turkish Republic identity number, address, telephone number, email address, date of birth, IP address you accessed from, information about your transactions, etc., are your personal data. Furthermore, according to the Personal Data Protection Law (KVKK), data relating to a person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations, trade unions, etc., health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, etc., are considered special categories of personal data. In this context, anonymous information, information that has been anonymized, and other data that cannot be linked to a specific individual are not considered personal data according to our company's policy on this matter.

The Concept of Personal Data Processing

Within the framework of Article 3/I(e) of the Personal Data Protection Law, the processing of personal data refers to any operation performed on data, such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, acquiring, making available, classifying, or preventing the use of personal data, whether wholly or partly automated or non-automated, provided that it is part of any data recording system.

3. LIGHTING COVERAGE

Collection, Processing, and Purposes of Processing Personal Data

Your personal data may vary depending on the service, product, or commercial activity provided by our company; it is/may be collected verbally, in writing, or electronically through automated or non-automated methods, branches, websites, social media platforms, and similar means.

In accordance with Articles 5.2 and 6.3 of the Personal Data Protection Law (KVKK), your personal data may be processed without your explicit consent for the purposes of fulfilling our legal obligations, establishing or performing a contract, fulfilling our legal responsibilities, establishing, exercising or protecting a right, and protecting our legitimate interests without harming your fundamental rights and freedoms. Furthermore, your personal data may also be processed with your explicit consent, in accordance with Articles 5.1 and 6.2 of the KVKK, for the purposes stated in this Disclosure Statement. You can obtain all our products, including our Bakır Dünyası membership program, even without being a member of any of our programs or memberships. However, since the Bakır Dünyası membership program and our other loyalty programs and memberships offer special advantages to their members, by joining/becoming a member of these programs, you explicitly consent to the processing of your personal data, except in exceptional circumstances.

Your collected personal data is processed/will be processed in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law and other applicable legislation, for the purposes of enabling our business units to carry out the necessary work to allow you to benefit from our products and services, customizing and recommending products and services to you according to your preferences, usage habits and needs, ensuring the legal and commercial security of our company and those with whom our company has a business relationship, determining and implementing our company's commercial and business strategies, and ensuring the implementation of our company's human resources policies.

Please note that if you withdraw your explicit consent for the processing of your personal data, you will be removed from the membership/loyalty program for which such processing is necessary, and you will no longer be able to benefit from the advantages you enjoyed through such processing as of that date.

To Whom and for What Purpose the Processed Personal Data May Be Transferred Domestically and/or Internationally

Your collected personal data will be used for the following purposes: enabling our business units to carry out necessary work to allow you to benefit from our products and services; customizing and recommending products and services to you according to your preferences, usage habits, and needs; ensuring the legal and commercial security of our company and those with whom we have business relations; determining and implementing our company's commercial and business strategies; and ensuring the implementation of our company's human resources policies.,

Personal data is/may be transferred to administrative and official authorities as required by law, to relevant individuals and institutions to fulfill legal obligations, to independent auditing firms, tax consultants and other external professional consultants, lawyers, insurance companies, partners, domestic and foreign third parties from whom services are received or will be received, our suppliers, legally authorized public institutions and private individuals, both within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law and within the scope of other legal regulations.

Your collected personal data is/may be transferred to foreign countries declared by the Personal Data Protection Board to have adequate protection, or, in cases where adequate protection is not available, to foreign countries where data controllers in Türkiye and the relevant foreign country have provided a written guarantee of adequate protection and have the permission of the Personal Data Protection Board. Our company acts/will act in accordance with the regulations stipulated in Article 9 of the Personal Data Protection Law and other relevant legal legislation.

Method and Legal Basis for Personal Data Collection

Your personal data is obtained through various means, including audit and consulting services, written/digital applications to our employees, our website, phone calls, social media, SMS channels, and other verbal, written, or electronic means, through automated or non-automated methods, and through other channels through which our company communicates with you or may communicate with you in the future. This data is collected for the purposes of conducting our activities, fulfilling our contractual obligations, and legally complying with relevant legislation, and is stored for legal periods in accordance with applicable regulations.