1) Data Controller and Representative

Pursuant to the Personal Data Protection Law No. 6698 (“Law No. 6698”), your personal data may be processed by WEGROUP DIŞ TİCARET ANONİM ŞİRKETİ (hereinafter referred to as Michael Tommy), with its headquarters at DHALKALI MERKEZ MAH. ATLAS SK. NO: 6, Interior Door No: 2, KÜÇÜKÇEKMECE/ISTANBUL, within the scope described below as the data controller..

2) Definitions

a) Explicit consent: Consent on a specific subject, based on information and expressed with free will,

b) Anonymization: The process of making personal data incapable of being associated with an identified or identifiable real person, even when matched with other data.

c) President: The President of the Personal Data Protection Authority,

d) Relevant person: The real person whose personal data is processed,

e) Personal data: Any information relating to an identified or identifiable real person,

f) Processing of personal data: Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic or non-automatic means, provided that it is a part of any data recording system,

g) Board: Personal Data Protection Board,

h) Institution: Personal Data Protection Authority,

i) Data processor: The real or legal person who processes personal data on behalf of the data controller based on the authorization given on their behalf,

j) Data recording system: The recording system in which personal data is structured and processed according to certain criteria,

k) Data controller: Refers to the real 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.

3) Purposes of Processing Personal Data

Your collected personal data, carried out by micheal tommy, TO BENEFIT THE RELEVANT PERSONS FROM THE PRODUCTS AND SERVICES OFFERED, to carry out the necessary work by our relevant business units for the development of commercial activities and to carry out the related business processes, planning and execution of business activities, follow-up, planning and execution of micheal tommy's commercial and/or business strategies, management of relations with business partners and/or suppliers,   In marketing activities, including electronic commercial messages, for the purpose of carrying out the necessary work by our business units and solution partners in order to benefit the relevant real persons and legal entities from the products and/or services offered by Michael Tommy and carrying out the relevant business processes, planning and executing the sales processes of products and/or services, planning the marketing processes of products and/or services, creating and promoting special services for you use, sending commercial electronic messages such as advertisements, promotions, etc. by us, carrying out activities to determine the financial risks of customers, planning and executing customer relationship management processes, following up contract processes and/or legal requests, following up customer requests and/or complaints, customizing the products and services offered by the company according to the changing conditions, usage habits and needs of the business world and to the relevant persons and institutions. Planning and executing the activities necessary for recommendation and promotion, planning and/or executing the processes of creating and/or increasing loyalty to the products and/or services offered by Micheal Tommy, planning and/or executing customer satisfaction activities, ensuring the legal, technical and commercial occupational safety of Micheal Tommy and the relevant persons who have a business relationship with Micheal Tommy, following up legal affairs,  It will be processed within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law No. 6698 for the purposes of planning and executing the operational activities necessary to ensure that the Company's activities are carried out in accordance with the Company's procedures and/or relevant legislation, planning and executing the Company's audit activities, planning and/or executing the Company's financial risk processes.

4- Conditions of Processing Personal Data

a) Personal data cannot be processed without the explicit consent of the person concerned.

b) In the presence of one of the following conditions, it is possible to process personal data without seeking the explicit consent of the person concerned:

ba) If it is expressly stipulated by law.

bb) If it is necessary to protect the life or physical integrity of a person who is unable to express consent due to actual impossibility or whose consent is not legally valid.

bc) Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract.

bd) It is mandatory for the data controller to fulfill its legal obligation.

be) It has been made public by the person concerned.

bf) Data processing is mandatory for the establishment, exercise or protection of a right.

bg) Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller.

5-Conditions for processing sensitive personal data

a) Data related to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are sensitive personal data.

b) It is prohibited to process sensitive personal data without the explicit consent of the person concerned.

c) Personal data other than health and sexual life listed in the first paragraph may be processed without seeking the explicit consent of the person concerned, in cases stipulated by law. Personal data related to health and sexual life, on the other hand, can only be processed by persons or authorized institutions and organizations under the obligation of confidentiality for the purpose of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, without seeking the explicit consent of the person concerned.

d) In the processing of sensitive personal data, it is also necessary to take adequate measures determined by the Board.

6) To Whom and For What Purpose the Processed Personal Data Can Be Transferred

Your personal data collected;  Within the framework of Michael Tommy's business relations with you, it may be shared with our business partners, suppliers, shareholders, group companies, as well as legally authorized public institutions and/or private persons, limited to the above-mentioned purposes. Your personal data may be transferred and processed at home or abroad within the framework of the conditions and purposes of transferring personal data specified in Articles 8 and 9 of the Law No. 6698 and transferring it abroad, and provided that the limits drawn in the law are not exceeded.

7) Conditions for Transfer of Personal Data

a) Personal data cannot be transferred without the explicit consent of the person concerned.

b) Personal data;

ba) In the second paragraph of Article 5 of the Law No. 6698,

bb) Provided that adequate measures are taken, in the third paragraph of Article 6 of the Law No. 6698,

If one of the specified conditions is present, it can be transferred without seeking the explicit consent of the person concerned.

c) Other provisions in the laws regarding the transfer of personal data are reserved.

8-Transfer of personal data abroad

a) Personal data cannot be transferred abroad without the explicit consent of the person concerned.

b) Personal data, the existence of one of the conditions specified in the second paragraph of Article 5 and the third paragraph of Article 6 of the Law No. 6698 and in the foreign country where the personal data will be transferred;

(b) the availability of adequate protection;

bb) In the absence of adequate protection, data controllers in Turkey and in the relevant foreign country must undertake an adequate protection in writing and have the permission of the Board,

It can be transferred abroad without seeking the explicit consent of the person concerned.

c) Countries where there is adequate protection are determined and announced by the Board.

(d) Whether there is adequate protection in the foreign country and whether permission is to be granted under subsection (bb);

da) International conventions to which Turkey is a party,

db) Reciprocity regarding data transfer between the country requesting personal data and Turkey,

dc) Regarding each concrete personal data transfer, the nature of the personal data and the purpose and duration of processing,

dd) The relevant legislation and practice of the country to which the personal data will be transferred,

de) The measures undertaken by the data controller in the country where the personal data will be transferred,

evaluates and, if necessary, makes a decision by taking the opinion of the relevant institutions and organizations.

e) Without prejudice to the provisions of international conventions, personal data may be transferred abroad in cases where the interests of Turkey or the person concerned will be seriously harmed, but with the permission of the Board by taking the opinion of the relevant public institution or organization.

f) The provisions of Law No. 6698 and other laws regarding the transfer of personal data abroad are reserved.

9) Method and Legal Reason for Collecting Personal Data

Your personal data is processed for various legal reasons for the purposes of maintaining the business relationship and maintaining commercial activities, marketing its products and services more effectively, learning the needs and demands of the customer target audience and developing products and services for these needs and demands, promoting the developed products and services within the framework of Micheal Tommy's relations with you, and displaying it in the physical environment, It is collected verbally and/or in writing, electronically from sources such as e-mail. Your personal data collected for this legal reason is subject to the provisions of Article 3 of this Clarification Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law No. 6698. It can be processed and transferred for the purposes specified in the article.

10) Rights of the Personal Data Owner

Everyone, by applying to michael tommy as the data controller;

a) To learn whether personal data is processed or not,

b) If personal data has been processed, requesting information about it,

c) To learn the purpose of processing personal data and whether they are used in accordance with their purpose,

d) To know the third parties to whom personal data is transferred in the country or abroad,

e) Requesting correction of personal data in case of incomplete or incorrect processing,

f) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of Law No. 6698,

g) Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,

h) Objecting to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,

ı) In case of damage due to unlawful processing of personal data, it has the right to demand the compensation of the damage.

The Data Owner shall submit his/her requests regarding the processing and transfer of his/her personal data to Michael Tommy in writing or by E-Mail and other methods accepted by the Board.

Michael Tommy, as the Data Controller, concludes the requests in the application free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board may be charged.

Michael Tommy accepts or rejects the request by explaining the reason and notifies the person concerned in writing or electronically. If the request in the application is accepted, it is fulfilled by michael tommy. If the application is caused by the fault of A micheal tommy, the fee is refunded to the person concerned.

In cases where the application is rejected, the answer given is insufficient or the application is not answered in time; The person concerned may complain to the Board within thirty days from the date of learning of Michael Tommy's reply, and in any case within sixty days from the date of application.

This text is in accordance with Article 10 of the Law No. 6698 on the Protection of Personal Data. Within the framework of the Disclosure Obligation in the article, it was prepared by Michael Tommy in the capacity of Data Controller and presented to the information of the data owners.