Clarification Text

La Mia Rosa Stoneware & Porcelain Studio

Information Text on the Protection of Personal Data

1. Entrance

As La Mia Rosa Studio (Sakine Esin Çulcu) (" Company "); the confidentiality and security of your personal data are among our top priorities. Our company processes your personal data in accordance with the Personal Data Protection Law No. 6698 (" KVKK ") and secondary legislation. Your personal data means any information that makes your identity specific or identifiable.

We would like to inform you about your personal data processed if you accept the Membership Agreement and become a “Platform Member” in order to benefit from the services (together, the “ Platform Services ”) offered on our company’s websites (together, the “ Platform ”).

2. What personal data do we process?

If you become a Platform Member, the following personal data is processed.

• Your User Account Information: your name, surname, membership e-mail address and, if you add it to your user information, your phone number, gender, date of birth,
• Your Customer Transaction Information: Your order and invoice information, transaction history regarding your purchases, request and complaint information, Platform usage information, cancellation/return information.
• Your Delivery Information : Your phone number and delivery address information you added for the delivery of the product you ordered, your delivery transaction information,
• Your Payment Information: Information regarding your payments and payment methods, your registered card information,
• Your Transaction Security Information: your device information, IP address information, password and passcode information, cookie information, platform access records,
• Your Legal Transaction Information: information in correspondence with authorized persons, institutions and organizations, information in lawsuit and enforcement files, information on legal information requests,

3. What are the legal reasons, purposes and collection methods for processing your personal data?

Your personal data is collected by our Company in electronic form through websites where you benefit from the Platform Service of our Company within the scope of our membership agreement, in a fully or partially automatic manner or non-automatic means provided that it is part of any data recording system; in electronic form through the channel you communicate with when you communicate via e-mail channels, and in physical form when it is transmitted to our Company via printed forms, notification, mail or notified by legal authorities. Your processed personal data, the purposes of processing and legal reasons are given below.

3.1. Membership and Account Creation Process:

Your personal data processed in this category: Your user account information, your customer transaction information, your transaction security information.

Our Processing Purposes:

• Carrying out the processes for the establishment and execution of the membership agreement,
• Managing the creation and closing processes of the platform member profile/account,
• Verification of contact information,
• Carrying out activities to carry out your purchase transactions through the Platform,
• Execution and supervision of the Company's business activities,
• Ensuring the security of platform operations,
• Fulfilling the obligations arising from the legislation to which our Company is subject, especially the Law on Regulation of Electronic Commerce No. 6563, the Turkish Commercial Code No. 6102, the Turkish Penal Code No. 5237 and the Consumer Protection Law No. 6502,
• Carrying out platform activities in accordance with the legislation,
• Fulfillment of data sharing and storage obligations by our Company in accordance with our obligations arising from the legislation.

Legal Reasons: It is clearly stated in the laws, It is mandatory for the fulfillment of our Company's legal obligations, It is necessary for the execution of our membership agreement with you.

3.2. Order, Delivery and Cancellation/Return Processes:

Your personal data processed in this category: Your user account information, your delivery information, your customer transaction information, your payment information, your transaction security information.

Our Processing Purposes:

• Placing orders and creating orders,
• Establishment and execution of distance sales contracts,
• Carrying out delivery and logistics activities,
• Carrying out cancellation/refund processes,
• Carrying out payment and invoice processes,
• Fulfilling the legal obligations specified in the legislation to which our Company is subject, especially the Regulation on Distance Contracts and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce, and/or in the decisions, guides and guides published by the competent authorities,
• Carrying out the purchasing processes of product/service groups on the Platform.

Legal Reasons: It is necessary for the fulfillment of our company's legal obligations, It is necessary for the execution of our membership agreement with you.

3.3. Customer Experience Improvement Processes:

Your personal data processed in this category: Your user account information, your customer transaction information, your delivery information, your transaction security information, your legal transaction information.

Our Processing Purposes:

• Ensuring that you can quickly and easily access products that suit your preferences and interests,
• Providing a better user experience in service transitions between our Company's Platform Services,
• Developing and improving our user experience,
• Improving our service quality,
• Conducting analysis and reporting studies,
• Carrying out communication activities,
• Evaluating requests, complaints and suggestions regarding our products and services,
• Carrying out after-sales support services for goods and services.

Legal Reasons: It is necessary for the performance of our membership agreement with you, and data processing is mandatory for the legitimate interests of our Company.

3.4. Company Information Security, Risk, Audit and Control Processes:

Your personal data processed in this category: Your user account information, customer transaction information, delivery information, payment information, transaction security information.

Our Processing Purposes:

• Execution and auditing of finance and accounting processes,
• Carrying out billing processes,
• Carrying out information security processes and investigating suspicious transactions,
• Ensuring the security of operations regarding the Platform,
• Controlling, developing and improving the quality of the products and services offered by our company,
• Conducting risk identification and analysis, complaint management,
• Preventing fraud.

Legal Reasons: It is necessary for the performance of our membership agreement with you, and data processing is mandatory for the legitimate interests of our Company.

3.5. Process of Carrying Out Legal Procedures:

Your personal data processed in this category: Your user account information, your customer transaction information, your delivery information, your payment information, your transaction security information, your legal transaction information.

Our Processing Purposes:

• Carrying out legal and litigation work, responding to your legal requests, examining and responding to your applications in accordance with the procedure as a relevant person,
• Carrying out activities in accordance with the legislation, fulfilling the obligations arising from the legislation to which our Company is subject,
• Carrying out legal consultancy processes,
• Sharing information with authorized persons, institutions and organizations upon request,
• The exercise and protection of a right in the event of a legal dispute.

Legal Reasons: Data processing is mandatory for the establishment, exercise or protection of a right, or it is mandatory for our Company to fulfill its legal obligations.

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 "need to know" and "need to use" principles, by ensuring the necessary data minimization and by taking the necessary technical and administrative security measures.

Our Company shares your personal data domestically with the recipient groups detailed below, based on the legal grounds of "being clearly prescribed by law, being mandatory for our Company to fulfill its legal obligations, being necessary for the establishment or execution of a contract, data processing being mandatory for the establishment, exercise or protection of a right and/or being mandatory for the legitimate interests of our Company" in accordance with Article 8 of the KVKK.

4.1. Membership and Account Creation Process:

• It is shared with our business partners who provide, operate or provide services for our IT infrastructure in order to carry out platform operations and to receive IT, technology and software services.

Legal Reason: Necessary for the establishment or execution of the contract.

4.2. Order, Delivery and Cancellation/Return Processes:

• In order to carry out logistics activities and follow up delivery processes , cargo companies and private couriers,
• With banks and other payment institutions that we have agreements with for the purpose of carrying out and monitoring your payment processes,
• It is shared with our business partners from whom we receive services for sending bulk SMS/e-mail in order to inform you about matters such as the delivery of the product you have purchased.

Legal reason: It is necessary for the fulfillment of our company's legal obligations and the establishment or execution of the Agreement.

4.3. Customer Experience Improvement Processes:

• It is shared with our service providers, business partners and consultants who provide IT infrastructure, software and technology services, in order to provide Platform services and to carry out Platform operations, in order to carry out activities aimed at developing and improving the products and services offered by our company .

Legal reason: It is necessary for the establishment or performance of the contract.

4.4. The company's information security, risk, audit and control processes:

• Our business partners, consultants and service providers, banks, cargo and courier companies, financial advisor/accounting service providers for the purposes of conducting billing processes, sending the invoice to the customer electronically, making physical contract or invoice delivery, managing financial and accounting processes, identifying and evaluating risks, and preventing fraud.
• It is shared with our business partners who provide financial advisory/accounting services, technology companies, our business partners and service providers for the purposes of ensuring the security of Company operations, controlling and improving the quality of the products and services offered by our Company and performing risk identification and analysis.

Legal reasons: It is necessary for the fulfillment of our company's legal obligations, the establishment or execution of the contract, it is mandatory for the legitimate interests of our company.

4.5. Process of Carrying Out Legal Procedures:

• Regulatory and supervisory institutions, courts and enforcement offices, mediators and other authorized public institutions and organizations for the purposes of fulfilling the obligations arising from the legislation to which our company is subject and carrying out the Platform activities in accordance with the legislation, providing information to authorized persons, institutions and organizations, following up and conducting legal affairs, exercising and protecting a right in case of a legal dispute,
• With lawyers, auditors, tax consultants, forensic computer experts, cyber security consultants, tax consultants, other third parties and business partners from whom we receive consultancy and services for the purposes of conducting our company's audit activities, conducting legal consultancy processes, ensuring the security of company operations, and conducting investigations into suspicious transactions,

• If requested, it is shared with authorized public institutions and organizations for the purposes of providing information to authorized persons, institutions and organizations abroad, and for the exercise and protection of a right in the event of a legal dispute.

Legal reasons: Being clearly prescribed by law, Fulfilling the legal obligations of our Company, Processing for the establishment, exercise or protection of a right, Being necessary for the establishment or execution of a contract.

5. How Does the Company Protect Your Personal Data?

Personal data shared with our Company is under the supervision and control of the Company. The Company has assumed responsibility as the data controller to establish the necessary organization and to take and adapt technical measures in order to protect the confidentiality and integrity of information in accordance with the relevant legislation in force. Being aware of our obligation in this regard;

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

6. Your Rights Regarding the Protection of Your Personal Data

By applying to our Company using the methods in the "Communication for Your Rights and Requests" section of this information text,

• To learn whether your personal data is being processed,
• Requesting information about your data if it has been processed,
• To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
• Knowing the third parties to whom the data is transferred, either domestically or abroad,
• To request correction of personal data if it is processed incompletely or incorrectly,
• Request the deletion or destruction of your personal data within the framework of the conditions set forth in the KVKK,
• Request that the actions taken in accordance with your rights of correction, deletion and destruction specified above be notified to third parties to whom personal data has been transferred,
• To object to a result that is to your detriment as a result of your processed personal data being analyzed exclusively by automated systems,
• If you suffer damages due to your personal data being processed in violation of the relevant legislation, you have the right to demand compensation for your damages.

7. Contact Us for Your Rights and Requests

You can submit your questions and requests regarding your personal data by submitting a petition prepared in accordance with the conditions specified in the Communiqué on the Procedures and Principles of Application to the Data Controller, using the following methods.

Application Method	Address to Apply
Written Application in Person*	Ahmetli District, Çubukcular Street, 3G, Şile, Istanbul, Istanbul, 34983
Notary	Ahmetli District, Çubukcular Street, 3G, Şile, Istanbul, Istanbul, 34983
From your e-mail address previously notified to our company and registered in the system.	gulum@lamiarosastudio.com

* It is mandatory for the Relevant Persons who will apply by "Personal Written Application" to submit documents proving their identity. In this context, in your personal written applications to Ahmetli Mah. Çubukcular Sok. 3G, Şile, İstanbul, Istanbul, 34983, we kindly request that only the front side of the ID photocopy (without blood type and religion section visible) be submitted along with the application form.

As personal data owners, if you submit your requests regarding your rights to the Company, the Company will finalize your request free of charge within 30 (thirty) days at the latest. However, if the response to your application requires a cost in accordance with the legislation, the Company may charge a fee in the tariff determined by the Personal Data Protection Board.

8. About the Information Text

The Company reserves the right to update this Information Text on the Protection of Personal Data at any time, within the framework of any changes that may be made to the current legislation.