LOCK & KEY PRIVACY POLICY

Introduction

As Turkticaret.Net Software Services Industry and Trade Joint Stock Company ("Turkticaret.Net", the "Company", "we" or the "Data Controller"), we attach importance to the protection of the personal data and privacy of our users who use the Lock&Key mobile application (the "Application").

This Privacy Policy (the "Policy") has been prepared for the purpose of explaining the scope within which the personal data of the users who use the Application is collected, the purposes for which it is processed, with whom it may be shared, how long it is retained, and how the rights relating to personal data may be exercised.

Your personal data is processed in accordance with the applicable legislation in force, primarily the Personal Data Protection Law No. 6698 ("KVKK"). Detailed information regarding the processing of your personal data is additionally provided to you through the clarification texts prepared according to the relevant user group. This Policy, on the other hand, aims to explain the processes relating to the processing of personal data in a more understandable and transparent manner, and does not replace or supersede the clarification texts.

This Policy applies with respect to the personal data processing activities carried out within the scope of the use of the Application. In the event that links are provided within the Application, the respective privacy policies of third-party websites, applications or services shall apply, and Turkticaret.Net is not responsible for the data processing activities of those platforms.

Data Controller

The data controller with respect to your personal data processed within the scope of the Application is, pursuant to the KVKK, Turkticaret.Net Software Services Industry and Trade Joint Stock Company, whose information is set out below.

Title: Turkticaret.Net Software Services Industry and Trade Joint Stock Company

Address: Esentepe Mahallesi Harman 1 Sokak Harmancı Giz Plaza Apt. No: 5/28 Şişli / İstanbul

E-mail: info@turkticaret.net

Registered Electronic Mail (KEP) Address: turkticaret.net@hs01.kep.tr

MERSIS No: 0881026913300012

What Personal Data Do We Collect?

During your use of Lock&Key, depending on the nature of the services offered and your preferences within the Application, the following personal data may be processed:

3.1 Account Information

For the purposes of your membership to the Application and the creation of your account, information relating to the creation of an account such as;

name and surname
e-mail address
telephone number (in the event that the relevant membership method is used)
age range
title

may be processed. Membership may be created by using an Apple ID, a Google account, an e-mail address or the other membership methods offered within the Application.

3.2 Purchase and Subscription Information

In the event that you benefit from premium membership or paid services, information relating to payment transactions may be processed for the purpose of carrying out the purchase process. In the event that payment transactions are carried out through application stores or third-party payment service providers, your payment card information may be processed by the relevant payment institutions within the scope of their own privacy policies.

3.3 Device and Technical Information

For the purpose of enabling the Application to operate securely and properly, technical data such as;

device type
operating system information
application version
log records
crash records
time stamps
other technical system records

may be processed.

3.4 Application Usage Information

For the purpose of enabling Lock&Key to perform its core functions, usage data such as;

usage durations of applications
active usage information of applications
background running durations
device session durations
device inactivity durations
application usage statistics

may be processed.

3.5 Support and Contact Information

In the event that you contact us, submit a support request, or convey your suggestions or complaints, the information shared by you together with the content of your request may be processed.

For What Purposes Do We Process Your Personal Data?

Your personal data collected within the scope of Lock&Key may be processed for the following purposes, depending on the nature of the services offered and the manner in which you use the Application:

4.1 Creation and Management of Your Membership Account

Your personal data may be processed for the purposes of;

creating your user account
carrying out authentication processes
enabling you to log in to your account
managing your membership information
carrying out the transactions relating to your account

4.2 Provision of the Application Services

For the purpose of enabling the performance of the services offered by Lock&Key, your personal data may be processed for the purposes of;

operating the Application
enabling the use of the modules and features you have selected
generating Application usage statistics
preparing reports relating to screen time and usage habits
improving the performance of the Application
providing the services on a sustainable basis

4.3 Provision of Premium Services

In the event that you purchase a premium membership or benefit from paid services, your personal data may be processed for the purposes of;

carrying out purchase transactions
managing your subscription information
carrying out payment processes
providing the purchased services to you

4.4 Ensuring Information Security and System Security

Your personal data may be processed for the purposes of;

ensuring the security of the Application
carrying out information security processes
preventing unauthorized access
detecting system errors
resolving technical problems
generating log records
preventing misuse

4.5 Provision of Support Services

In the event that you contact us, your personal data may be processed for the purposes of;

evaluating your requests, suggestions and complaints
concluding your support requests
ensuring customer satisfaction
contacting you

4.6 Fulfillment of Our Legal Obligations

Your personal data may be processed for the purposes of;

fulfilling our obligations arising from the applicable legislation
responding to the requests of authorized public institutions and organizations
carrying out legal processes
establishing, exercising or protecting our rights
resolving disputes

4.7 Marketing and Commercial Communication Activities

In line with your preferences and, where necessary, based on your explicit consent or within the scope of the other legal grounds stipulated in the relevant legislation, your personal data may be processed for the purposes of;

sharing campaigns and announcements
sending commercial electronic messages
promoting our products and services
presenting content and recommendations suited to your areas of interest
carrying out marketing and targeting activities

With respect to the sending of commercial electronic messages and personalized marketing activities, you may change your preferences at any time or withdraw the consent you have given within the framework of the relevant legislation.

On What Legal Grounds Do We Process Your Personal Data?

Your personal data is processed, depending on the nature of the services offered within the scope of Lock&Key, based on the data processing conditions set out in Article 5 of the KVKK.

In this context, your personal data may be processed based on the following legal grounds:

The processing of personal data being necessary due to it being directly related to the establishment or performance of a contract (for example, the creation of your membership account, the use of the Application and the provision of premium services)
Being explicitly provided for by the laws
The fulfillment of our legal obligations
The processing of data being mandatory for the establishment, exercise or protection of a right
Our legitimate interests requiring it, provided that it does not harm your fundamental rights and freedoms
The existence of your explicit consent in the cases required or permitted by the legislation.

Your personal data is processed based on the legal ground applicable to each data processing activity, and in the cases where reliance on explicit consent is required, your personal data is processed only if your explicit consent is present. With respect to the data processing activities requiring your explicit consent, you may withdraw your explicit consent at any time within the scope of the relevant legislation. The withdrawal of explicit consent does not affect the lawfulness of the data processing activities carried out prior to the date of withdrawal.

With Whom Do We Share Your Personal Data?

Your personal data may be shared with the following recipient groups for the purpose of fulfilling the purposes specified in this Policy and in the relevant clarification texts, and in accordance with the applicable legislation:

suppliers and business partners from which services are received for the purpose of providing the services and operating the Application
providers of information technologies, hosting, cloud computing, maintenance, support and similar technical infrastructure services
payment service providers and the relevant financial institutions for the purpose of carrying out payment transactions
authorized public institutions and organizations and authorized private persons for the purpose of fulfilling our legal obligations
our advisors, lawyers, independent auditors and similar professional service providers for the purpose of carrying out legal processes
Your personal data is not shared with third parties other than the recipient groups specified above, except in the cases stipulated in the relevant legislation or where you have separately granted authorization.

Transfer of Your Personal Data Abroad

For the purposes of enabling the performance of the services offered within the scope of Lock&Key, ensuring that the Application operates securely and without interruption, operating the information technologies infrastructure, providing maintenance and support services, and carrying out other business processes, your personal data may be transferred, to the extent necessary, to service providers, business partners and other recipient groups located abroad.

In the event that your personal data is transferred abroad, the appropriate safeguards stipulated in the applicable legislation on the protection of personal data are provided and the necessary technical and administrative measures are taken.

The transfer of data abroad is carried out within the framework of the applicable legislative provisions for each specific case and to the extent necessary.

Security of Personal Data

In order to prevent the unlawful processing of or access to your personal data, and to ensure and maintain the security of your personal data, appropriate technical and administrative measures are implemented, taking into account the nature of the activity and the technological possibilities.

In this context, security measures such as, primarily, information security processes, access authorization, monitoring of records, ensuring system security, personnel authorization, risk management and similar measures are utilized for the protection of the confidentiality, integrity and accessibility of personal data. That being said, while we implement reasonable and appropriate security measures for the protection of your personal data, we would like to remind you that it may not always be possible to completely eliminate the risks that may arise due to the nature of electronic communication systems.

Retention of Personal Data

Your personal data is retained only for the period necessary for the fulfillment of the purposes specified in this Policy and in the relevant clarification texts, or for the retention periods stipulated in the applicable legislation.

In the event that the retention period expires or the legal grounds requiring the processing of the personal data cease to exist, your personal data is deleted, destroyed or anonymized in accordance with the applicable legislation.

Your Rights within the Scope of the KVKK

Pursuant to Article 11 of the KVKK, you have the following rights with respect to the processing of your personal data:

To learn whether your personal data is processed
To request information if your personal data has been processed
To learn the purpose of the processing of your personal data and whether it is used in accordance with its purpose
To learn the third parties to whom your personal data is transferred in Turkey or abroad
To request the rectification of your personal data in the event that it has been processed incompletely or inaccurately
To request the erasure or destruction of your personal data within the framework of the conditions stipulated in the KVKK
To request the notification of the third parties to whom your personal data has been transferred, in the event that your personal data is rectified, erased or destroyed
To object to the occurrence of a result to your detriment by means of the analysis of your processed data exclusively through automated systems
To request the compensation of the damage in the event that you suffer damage due to the unlawful processing of your personal data.

You may submit your applications relating to these rights to our Company in accordance with the applicable legislation. Your applications will be evaluated pursuant to the KVKK and the relevant legislation and will be concluded within the statutory periods.

Amendments to the Privacy Policy

This Policy may be updated from time to time in line with the changes occurring in the applicable legislation, the updates carried out in the technical infrastructure of the Application or in the services offered, or the changes that may occur in the personal data processing processes.

The current version of the Policy shall be effective as of the date on which it is published through the Application and/or the relevant website. In the event that significant changes are made, users may additionally be informed to the extent appropriate to the nature of such changes.

For this reason, we recommend that the Policy be reviewed at regular intervals.

Contact

For any questions, requests or applications relating to this Privacy Policy or to the processing of your personal data, you may contact us through the communication channels set out below.

Data Controller

Turkticaret.Net Software Services Industry and Trade Joint Stock Company

Address: Esentepe Mahallesi Harman 1 Sokak Harmancı Giz Plaza Apt. No: 5/28 Şişli / İstanbul

E-mail: info@turkticaret.net

Registered Electronic Mail (KEP) Address: turkticaret.net@hs01.kep.tr

MERSIS No: 0881026913300012