Protection of Personal Data

Clarification Text on the Protection of Personal Data

As Levisell E-Commerce Limited (“Company”), the privacy and security of your personal data are among our top priorities. Our company processes your personal data in accordance with the regulations of the Personal Data Protection Law No. 6698 (“KVKK”). Your personal data refers to any information that makes your identity specific or identifiable.

If you become a “Platform Member” by accepting the Membership Agreement to benefit from the services offered in our company’s mobile applications and/or websites (collectively referred to as the “Platform”), we would like to inform you about the personal data we process.

1. Which personal data is processed by our company?
If you become a Platform Member, the following personal data will be processed:

Your User Account Information: Your first name, last name, customer number, membership email address, and, if you add it to your user information, your phone number, gender, date of birth, height, and weight. Your identity number (processed only in accordance with the relevant legislation if you purchase certain product groups).
Your Customer Transaction Information: Your order and invoice information, your transaction history regarding your purchases, your request and complaint information, your platform usage information, the information you personally share in your comments and questions if you comment and/or ask questions about the products on the platform, your points and evaluation information, and information about the content of conversations made via chat.
Your Delivery Information: Your phone number and delivery address provided for the delivery of the ordered product, along with your delivery transaction information.
Your Payment Information: Information regarding the payments and payment methods you have used, including your registered card information.
Your Transaction Security Information: Your device information, IP address, password and password hints, cookie information, platform access records, and your login method (via Google/Facebook).
Your Legal Transaction Information: Information in correspondence with authorized persons, institutions, and organizations, information in lawsuit and enforcement files, and your legal information request details.
Your Audio Recording Information: Your voice recording in case you call the call center.

2. What are the legal reasons, purposes, and collection methods for processing your personal data?
Your personal data may be collected electronically by our Company through fully or partially automated or non-automated means, provided that it is part of any data recording system. This collection occurs through mobile applications or websites that you utilize as part of our membership agreement for the Platform Service. When you contact us through live support, the call center, or email channels, the data is collected electronically through the channel you used to communicate, and physically if it is sent to our Company via printed forms, notifications, mail, or through legal authorities.

Our company processes your personal data for the purposes listed in the table below and based on the legal compliance reasons specified in Article 5 of the KVKK:

Processed Personal Data	Legal Reasons for Processing Your Personal Data	Purposes of Processing Your Personal Data
Your User Account Information, Customer Transaction Information, Delivery Information.	Presence of your explicit consent.	Conducting marketing, advertising, and promotional activities; offering special advantageous offers; and activities to enhance your satisfaction.

Legal Reasons, Purposes, and Processes for Processing Your Personal Data

Marketing and Communication Activities:
Carrying out marketing, advertising, and promotional activities; offering you special advantageous offers; conducting activities to increase your satisfaction by getting to know you better; and sending commercial electronic messages in this context.
Processed Personal Data:
Your User Account Information, Customer Transaction Information, Delivery Information, Payment Information, Transaction Security Information, Legal Transaction Information, Audio Recording Information.
Legal Reasons for Processing:
It is clearly prescribed by law.
Purpose:
Fulfilling the legal obligations of our company, including obligations arising from legislation to which our Company is subject, especially the Law on the Regulation of Electronic Commerce No. 6563, the Turkish Commercial Code No. 6102, the Turkish Penal Code No. 5237, and the Law on Consumer Protection No. 6502. This includes conducting platform activities in accordance with the legislation and fulfilling data sharing and preservation obligations.

Legal Obligations:
Fulfilling the legal obligations specified in the secondary legislation applicable to our Company, particularly the Regulation on Distance Contracts and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce, and/or the decisions, guidelines, and directives published by competent authorities. This includes carrying out purchasing processes for service groups, providing information to authorized persons, institutions, and organizations, ensuring that activities are carried out in accordance with the legislation, monitoring and conducting legal affairs, and handling finance and accounting matters.
Processed Personal Data:
Your User Account Information, Transaction Security Information.
Legal Reasons for Processing:
It is necessary for the establishment of our membership agreement with you.
Purpose:
Executing the processes for establishing the membership contract, managing the creation and closure of the Platform Member profile, and ensuring the security of operations regarding the Platform.

Membership Agreement Performance:
Processed Personal Data:
Your User Account Information, Customer Transaction Information, Delivery Information, Payment Information, Transaction Security Information, Legal Transaction Information, Audio Recording Information.
Legal Reasons for Processing:
It is necessary for the performance of our membership agreement with you.
Purpose:
Carrying out the processes for establishing and executing the membership contract, conducting activities for realizing your purchases through the Platform, auditing the Company’s business activities, performing information security processes, and investigating suspicious transactions to ensure the security of operations regarding the Platform.

Finance and Accounting Processes:
Processed Personal Data:
Your Payment Information, User Account Information, Customer Transaction Information, Delivery Information.
Legal Reasons for Processing:
It is necessary for the performance of our membership agreement with you.
Purpose:
Executing and auditing finance and accounting processes, and managing invoicing processes.

Delivery Processes:
Processed Personal Data:
Your Delivery Information, User Account Information, Customer Transaction Information.
Legal Reasons for Processing:
It is necessary for the performance of our membership agreement with you.
Purpose:
Tracking the delivery processes of the product you ordered and carrying out logistics activities.

Communication and Support Activities:
Processed Personal Data:
Your Audio Recording Information, User Account Information, Customer Transaction Information, Delivery Information.
Legal Reasons for Processing:
It is necessary for the performance of our membership agreement with you.
Purpose:
Conducting communication activities, evaluating requests, complaints, and suggestions regarding our products and services, providing support for your orders, and conducting after-sales support services for goods and services.

Transaction Security:
Processed Personal Data:
Your Transaction Security Information, User Account Information, Customer Transaction Information.
Legal Reasons for Processing:
It is necessary for the performance of our membership agreement with you.
Purpose:
Carrying out information security processes and investigating suspicious transactions to ensure the security of operations regarding the Platform.

Legal Matters:
Processed Personal Data:
Your User Account Information, Customer Transaction Information, Delivery Information, Payment Information, Transaction Security Information, Legal Transaction Information, Audio Recording Information.
Legal Reasons for Processing:
Processing for the establishment, exercise, or protection of a right.
Purpose:
Conducting legal and litigation matters, responding to your legal requests, examining and responding to your applications as a relevant person in accordance with the procedures, and resolving issues accordingly.

Legal Reasons and Purposes for Sharing Your Personal Data

Legal Disputes:
Sharing information with authorized persons, institutions, and organizations upon request.
Processed Personal Data:
Your User Account Information, Customer Transaction Information, Delivery Information, Transaction Security Information, Legal Transaction Information, Audio Recording Information.
Legal Reasons for Processing:
It is necessary for the legitimate interest of our company.
Purpose:
Ensuring that you have quick and easy access to products that suit your preferences and interests; providing a better user experience during service transitions between our Company’s Platform Services; developing and improving our user experience; enhancing our service quality; conducting analysis and reporting studies; and ensuring the security of Platform Service operations.

User Account Information:
Processed Personal Data:
Your User Account Information.
Legal Reasons for Processing:
It is necessary for the legitimate interest of our company.
Purpose:
Providing a better user experience in service transitions between our company’s Platform Services.

4. To whom and for what reasons does the company transfer your personal data?
Our company takes care to process your personal data in accordance with the principles of “need to know” and “need to use,” ensuring necessary data minimization and taking the necessary technical and administrative security measures. Since conducting or controlling business activities, ensuring business continuity, and operating digital infrastructures require continuous data flow with different stakeholders, we must transfer the personal data we process to third parties for certain purposes.

Furthermore, it is crucial that your personal data is accurate and up-to-date so that we can fully and properly fulfill our contractual and legal obligations. To achieve this, we collaborate with various business partners and service providers.

Our company shares your personal data with the relevant recipient groups to the extent necessary for the purposes listed in the table below and based on the legal compliance reasons specified:

Your Personal Data Shared by Our Company	Recipient Groups to Which Your Personal Data is Transferred	Legal Reasons for Sharing Your Personal Data	Purposes of Our Company for Sharing Your Personal Data
Your User Account Information, Customer Transaction Information, Delivery Information.	With affiliates, service providers, and business partners.	Having your explicit consent.	Carrying out marketing, advertising, and promotional activities; offering you special advantageous offers; and conducting activities to enhance your satisfaction by getting to know you better.
Your User Account Information, Customer Transaction Information, Delivery Information, Payment Information, Transaction Security Information, Legal Transaction Information, Audio Recording Information.	With authorized public institutions and organizations, such as regulatory and supervisory institutions, courts, and enforcement offices.	It is clearly prescribed by law.	Fulfilling the legal obligations of our company.
		Processing for the establishment, exercise, or protection of a right.	Conducting marketing, advertising, and promotional activities; offering you special advantageous offers; and enhancing your satisfaction by getting to know you better.
		The exercise and protection of a right in the event of a legal dispute.

To Whom and for What Reasons Does the Company Transfer Your Personal Data?

With Lawyers and Consultants:
Personal data may be shared with lawyers, auditors, tax consultants, digital forensic experts, cyber security consultants, our group companies, affiliates, and other third parties and business partners from whom we receive consultancy and services.
Processed Personal Data:
Your User Account Information, Customer Transaction Information, Delivery Information, Payment Information.
Legal Reasons for Processing:
Processing is necessary for the establishment, exercise, or protection of a right.
Purpose:
Conducting our company’s audit activities, carrying out legal consultancy processes, ensuring the security of company operations, and conducting investigations into suspicious transactions.

With Sellers or Service Providers:
Personal data may be shared with the seller or service provider of the product you wish to purchase.
Processed Personal Data:
Your User Account Information, Customer Transaction Information, Delivery Information, Payment Information.
Legal Reasons for Processing:
It is necessary for the establishment or performance of the contract.
Purpose:
Ensuring that you benefit from the Platform Services, establishing and executing the membership agreement, carrying out billing processes, and completing purchasing processes.

Fulfilling Legal Obligations:
Personal data may be shared to fulfill the obligations arising from the legislation to which our Company and the seller from whom you purchase products are subject, especially the Law No. 6563 on the Regulation of Electronic Commerce, the Turkish Commercial Code No. 6102, the Consumer Protection Law No. 6502, the Distance Contracts Regulation, and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce.
Processed Personal Data:
Your User Account Information, Delivery Information.
Recipient Groups:
With product sellers, cargo companies, private couriers.
Legal Reasons for Processing:
It is necessary for the establishment or performance of the contract.
Purpose:
Carrying out logistics activities and monitoring delivery processes.

With Customer Support Service Providers:
Personal data may be shared with our business partners providing call center services and other customer support services.
Processed Personal Data:
Your User Account Information, Customer Transaction Information, Delivery Information, Audio Recording Information.
Legal Reasons for Processing:
It is necessary for the establishment or performance of the contract.
Purpose:
Providing sales and after-sales support services for goods and services, ensuring customer satisfaction, and addressing customer demands and complaints.

With Audit and Financial Service Providers:
Personal data may be shared with our business partners who provide independent audit, customs, financial advisor/accounting services, our group companies, subsidiaries, private integrators, technology companies, and other service providers.
Processed Personal Data:
Your User Account Information, Customer Transaction Information, Delivery Information, Payment Information, Transaction Security Information, Legal Transaction Information.
Legal Reasons for Processing:
It is necessary for the establishment or performance of the contract.
It is necessary for the legitimate interest of our company.
Purpose:
Controlling the quality of the products and services offered by our Company; carrying out activities for the development and improvement of our products and services; performing risk detection and analysis; obtaining information technology and software services; quality control of services; complaint management; and risk analysis.

With Banks and Invoice Partners:
Personal data may be shared with our business partners, consultants, service providers, banks, e-invoice business partners, cargo and courier companies, private integrators, and independent audit, customs, and financial advisor/accounting services.
Legal Reasons for Processing:
Fulfilling the legal obligations of our company.
Purpose:
Carrying out invoicing processes, sending e-invoices to customers electronically, delivering physical contracts or invoices, managing financial and accounting processes, detecting and evaluating risks, and preventing fraud.

4. How Does the Company Protect Your Personal Data?
Personal data shared with the Company is under the supervision and control of the Company. The Company has undertaken the responsibility, as a data controller, to establish the necessary organization and to implement and adapt technical measures to protect the confidentiality and integrity of information in accordance with the provisions of the relevant legislation in force. Being aware of our obligations in this regard:

Penetration tests are conducted at regular intervals in accordance with international and national technical standards regarding data privacy.
Your personal data transmitted to the Company through the website, mobile site, and mobile application is protected using SSL (Secure Sockets Layer) technology.
Risk analyses are regularly performed regarding personal data processing activities, and actions are taken to mitigate risks.
Access and authorization controls are implemented to prevent unauthorized access to personal data.
Data processing policies are regularly updated.

5. Your Rights Regarding the Protection of Your Personal Data
By applying to our Company using the methods in the “Contact for Your Rights and Requests” section of this information text, you have the following rights:

To learn whether your personal data is being processed or not.
If it has been processed, to request information about it.
To learn the purpose of processing your personal data and whether they are used for their intended purpose.
To know the third parties to whom it is transferred domestically or abroad.
To request correction of personal data if it is incomplete or incorrectly processed.
To request the deletion or destruction of your personal data within the framework of the conditions stipulated in KVKK.
To request that the transactions carried out in accordance with your rights in the forms of correction, deletion, and destruction stated above be notified to third parties to whom personal data has been transferred.
To object to the emergence of a result against you by analyzing your processed personal data exclusively with automated systems.
If you suffer damage due to the processing of your personal data in violation of the relevant legislation, you have the right to request compensation for your damage.

6. Contact for Your Rights and Requests
You can submit your questions and requests regarding your personal data to the Data Controller with a petition prepared in accordance with the conditions specified in the Communiqué on Application Procedures and Principles or to “Levisell E-Ticaret Limited” using the following methods. You can access the application form here.

7. About Information Text
The Company reserves the right to update this Information Text on the Protection of Personal Data at any time in line with changes that may be made in the current legislation.

Updated Date: 11.09.2024