LeMarr Group (here in after referred to as LeMarr Group ) has prepared this “Privacy & Security Policy and Clarification Text in accordance with the Personal Data Protection Law” (here in after referred to as the Privacy Policy) to inform our valued visitors about how we collect and process your personal data, the legal grounds for the data collection, how we protect data security, and the methods we employ to ensure your fundamental rights and freedoms are protected. The personal data obtained by us is processed according to the legal requirements outlined by the 6698 Personal Data Protection Law (KVKK), which was published in the Official Gazette on April 7, 2016, and aims to protect the privacy of individuals as well as to define the obligations of data controllers.

LeMarr Group  reserves the right to update and modify this Privacy & Security Policy and the Clarification Text as per changes in legal regulations or the company’s economic and commercial decisions.

1. PERSONAL DATA

Personal data refers to any information related to an identified or identifiable natural person. This includes data such as name, surname, date of birth, gender, identification number, email address, residence/delivery address, phone number, etc. These are considered personal data due to their ability to identify a person.

2. PROCESSING OF PERSONAL DATA AND PURPOSE OF PROCESSING

Personal data processing refers to the collection, recording, storage, alteration, organization, disclosure, transfer, or destruction of data using automated or non-automated means. Personal data may be processed for specific purposes such as customer satisfaction, marketing, sales processes, and customer support, according to relevant laws including the Electronic Commerce Regulation Law No. 6563, the Consumer Protection Law No. 6502, and the Personal Data Protection Law No. 6698.

3. GENERAL PRINCIPLES IN PERSONAL DATA PROCESSING

While processing personal data, LeMarr Group commits to comply with the following fundamental principles:

• Lawful and fair processing
• Accurate and up-to-date
• Collected for specific, legitimate, and clear purposes
• Limited to the purpose for which it is collected
• Retained for no longer than necessary to fulfill its purpose

4. DATA SECURITY

LeMarr Group  ensures that personal data is protected by taking technical and administrative measures to prevent unauthorized access, unlawful processing, and data loss. If data is unlawfully accessed, it will be reported to the relevant parties.

5. TRANSFER OF PERSONAL DATA

Within Turkey: Personal data may be shared with third parties located in Turkey only with the explicit consent of the data subject, or when required by law.

Abroad: Personal data may be transferred abroad with the explicit consent of the data subject, provided the country offers adequate protection or guarantees are provided.

6. RIGHTS OF THE DATA SUBJECT

As per the KVKK, data subjects have the following rights:

• Learn whether personal data is being processed
• Request information about the processing of personal data
• Learn the purpose of processing and whether the data is used in compliance with that purpose
• Know the third parties to whom the data is transferred
• Request correction or deletion of data if it is incomplete or incorrect
• Object to automated decision-making processes

7. APPLICATION TO THE DATA CONTROLLER

Data subjects may apply to LeMarr Group  to exercise their rights. Requests may be made in writing, via registered mail, or by email. LeMarr Group  commits to responding to these requests within 30 days.

In case of rejection or insufficient response, the data subject may file a complaint with the Personal Data Protection Authority within 60 days.

This privacy policy also outlines the steps to be taken by LeMarr Group  in response to personal data access requests and potential appeals or complaints.

If you have further questions or need assistance, please don’t hesitate to ask.