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ALKEDOS TECHNOLOGY INC. PERSONAL DATA PROTECTION POLICY

Purpose

ARTICLE 1- (1) The purpose of this Law is to protect individuals’ fundamental rights and freedoms, particularly the privacy of private life, during the processing of personal data, and to regulate the obligations and principles to be observed by natural and legal persons processing personal data.


Scope

ARTICLE 2- (1) The provisions of this Law apply to natural persons whose personal data are processed and to natural or legal persons who process this data, either fully or partially by automatic means or non-automatic means provided it is part of any data recording system.


What Personal Data Do We Process?

We process the following personal data as part of the services we provide:

Identity and Contact Information:

Name-surname, customer ID, advertisement ID/identifiers, gender, age, nationality, profile photo, mobile phone, email, address, etc.

Financial Data:

Information about payments and payment methods, managing sales processes.

Product, Service, and User Operations:

Username and password, promotion and delivery of our products and services, managing sales processes, showcasing subscribers’ products on the Dibugo.com platform, providing and recording remote support services, tracking content, generating statistics, and analyzing customer usage and business processes.

Customer Transaction Data:

Shopping/order history, order information, invoice details, request/complaint information, all visual records including optional uploaded profile photos.

Transaction Security:

Device operating system and version, device type, IP address, user transaction records, cookies, browsing activity, shopping habits, and location data.


To Whom and For What Purposes Do We Transfer Your Personal Data?

Your personal data may be transferred to the following groups:

1. Business and Solution Partners:

For supporting marketing, sales, and product development activities both domestically and internationally.

2. Judicial Authorities and Public Institutions:

To comply with legal obligations, manage processes in line with court orders, and resolve legal disputes.

3. Official Authorities:

Personal data may be transferred to institutions such as Tax and Customs Administrations, Law Enforcement, and other regulatory authorities within the framework of legal obligations.

4. Group Companies and Commercial Service Providers:

To support the execution of our operations and services.


Why Do We Process Your Personal Data?

We process your personal data for the following purposes:

1. To create a membership record so you can benefit from our services.

2. To manage order, payment, and delivery processes.

3. To recommend products and campaigns based on your preferences and location.

4. To conduct customer satisfaction activities.

5. To carry out marketing and promotional activities.

6. To comply with regulatory obligations and conduct internal audits.


Legal Grounds for Processing Your Personal Data

Your personal data is processed based on the following legal grounds:

Contract Performance:

For the execution of service agreements.

Legal Obligations:

To comply with laws and regulations.

Legitimate Interests:

To improve service quality, ensure security, detect fraud, and protect our rights, provided it does not infringe your fundamental rights and freedoms.

Explicit Consent:

 When no other legal grounds apply, your personal data is processed based on your explicit consent, which you can withdraw at any time without retroactive effect.


Do We Transfer Your Personal Data Abroad?

Your personal data may be transferred abroad in the following circumstances:

1. Adequacy Decision:

When the receiving country is deemed to provide adequate protection by the European Commission or Turkish Personal Data Protection Authority.

2. Commitments and Agreements:

When adequate protection is ensured through standard contractual clauses and mutual agreements with the recipient.v


Your Rights Regarding Personal Data

Under the applicable laws, you have the right to:

• Learn whether your personal data is processed.

• Request access to your processed personal data.

• Request the correction of inaccurate or incomplete data.

• Request the deletion or anonymization of your personal data.

• Object to the processing of your data and request restriction.


Complaints and Further Information

To exercise your rights, raise complaints, or seek more information, you may contact us through the following channels:


ALKEDOS TECHNOLOGY A.Ş.

Adres: Ataköy 7-8-9-10. Kısım Mah. Çobançeşme E-5 Yanyol Cad. Ataköy Towers A Blok Apt. No: 20/1 Kat:3 Daire:70 Bakırköy / İstanbul

Web: https://www.alkedos.comhttps://www.dibugo.com


This policy has been prepared in compliance with legal regulations and industry standards.