*This following notice has been translated into English via ChatGPT for informational purposes. In case of legal use, the Turkish version and Turkish Laws shall prevail.

General Information about the Personal Data Protection Law
The Law on the Protection of Personal Data No. 6698 (hereinafter referred to as "KVKK") was adopted on March 24, 2016, and published in the Official Gazette No. 29677 dated April 7, 2016. Some parts of the KVKK came into force on the publication date, and some on October 7, 2016.

Information in the Capacity of Data Controller
In accordance with Law No. 6698 and in the capacity of Data Controller, your personal data may be recorded, stored, updated, disclosed or transferred to third parties where permitted by legislation, classified, and processed in ways outlined under KVKK, within the framework explained on this page.

How Your Personal Data May Be Processed
According to KVKK, the personal data you share with our company may be processed — wholly or partially, by automatic or non-automatic means — by being obtained, recorded, stored, altered, rearranged, or subjected to any action performed on data, provided it is part of a data recording system. Any operation performed on personal data is considered "processing of personal data" under the KVKK.

Purposes and Legal Grounds for Processing Personal Data
The personal data you share may be processed for the following purposes:

• To fulfill the requirements of the services we provide to our customers in accordance with the contract and technology and to improve our products and services;

• To identify the transaction owner’s identity, address, and other necessary information as required under the Law No. 6563 on Regulation of Electronic Commerce, Law No. 6502 on the Protection of Consumers, and related regulations (such as the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce published in the Official Gazette No. 29457 dated August 26, 2015, and the Distance Contracts Regulation published in Official Gazette No. 29188 dated November 27, 2014);

• To prepare all records and documents that are the basis for electronic or physical transactions in mandatory banking and electronic payment systems, electronic contracts, and as required by regulations or other authorities for legal obligations such as data retention, reporting, and information;

• To provide information to public prosecutors, courts, and relevant public officials in matters concerning public safety or legal disputes, upon request and in compliance with the law.

Your personal data will be processed in accordance with the KVKK and relevant secondary legislation.

Information on Third Parties to Whom Your Personal Data May Be Transferred
For the purposes outlined above, your personal data shared with our company may be transferred to the following parties: primarily IdeaSoft Yazılım San. ve Tic. A.Ş., which provides our e-commerce infrastructure; suppliers; shipping companies; other service providers related to the services offered; business partners; domestic or international organizations; and other third parties, either to operate our activities or as data processors.

Methods of Collecting Personal Data
Your personal data may be collected:

• Through forms on our website and mobile applications, including name, surname, ID number, address, phone number, work or personal email address; as well as through pages requiring username and password, IP logs of activities, cookie data collected by the browser, session durations, and location data;

• Verbally, in writing, or electronically via our sales and marketing employees, branches, suppliers, other sales channels, paper forms, business cards, digital marketing, and call centers;

• From individuals who share personal data for purposes such as establishing a business relationship, applying for a job, or submitting an offer (e.g., business cards, resumes), either physically or virtually, face-to-face or remotely, orally or in writing;

• Indirectly via websites, blogs, contests, surveys, games, campaigns, micro-websites, social media, newsletter read/click behaviors, public databases, and shared social media profile data.

Personal Data Obtained Before KVKK Came into Effect
Personal data lawfully obtained before the effective date of the KVKK (April 7, 2016) — such as through membership, electronic communication consent, product/service purchases — will continue to be processed and stored in accordance with the conditions specified in this document.

Transfer of Personal Data Abroad
Your personal data collected through any of the methods listed above may be transferred to service providers located abroad (in countries accredited by the Personal Data Protection Board and which provide adequate data protection), in accordance with the KVKK and for the purposes stated in relevant agreements.

Storage and Protection of Personal Data
Your personal data will be kept confidential in our company’s databases and systems in compliance with Article 12 of the KVKK. Except as legally required and as outlined in this document, they will not be shared with third parties. Our company is responsible for taking all necessary software and physical security measures to prevent unlawful processing and unauthorized access to personal data. In the event of illegal acquisition of personal data by others, this will be reported immediately to the Personal Data Protection Board in compliance with legal requirements.

Keeping Personal Data Accurate and Up-to-date
Under Article 4 of the KVKK, our company is obligated to keep your personal data accurate and up-to-date. Therefore, customers must ensure that their information is correct and current, or update it via our website or mobile app.

Rights of the Personal Data Owner under KVKK
Article 11 of the KVKK came into effect on October 7, 2016, granting the following rights to the personal data owner, who may apply to the Data Controller (our company) to:

• Learn whether personal data is being processed;

• Request information if personal data has been processed;

• Learn the purpose of processing and whether it is used in accordance with its purpose;

• Learn the third parties to whom personal data is transferred domestically or abroad;

• Request correction if personal data is incomplete or incorrect;

• Request deletion or destruction of personal data under the conditions set out in Article 7 of the KVKK;

• Request that corrections, deletions, or destruction be communicated to third parties to whom the data was transferred;

• Object to decisions made solely through automated processing that result in a negative outcome;

• Request compensation if they suffer damage due to unlawful processing of personal data.

Contact Information
Sargem Elektronik San. ve Tic. Ltd. Şti., registered with the Istanbul Chamber of Commerce under number 943338, with MERSIS number 0745039367700012 and located at Atatürk Mah. Tekel Sok. İldeş Sanayi Sitesi B Blok No:17 Lüleburgaz/Kırklareli, is the Data Controller under KVKK. Once the legal infrastructure is established, the appointed Data Controller Representative will be announced in the Data Controllers Registry and on this website.

Contact Channels for Data Subjects:

• Email: info@winklecamp.com

• Phone: +90 212 299 04 58