Personal Data Law

This Clarification Text has been prepared by Winco Ltd ("Winco Ltd") for the purpose of enlightening Winco Ltd's customers and other third parties with whom it has business relations regarding the processing of their personal data within the scope of the Personal Data Protection Law No. 6698 (“Law”). . You can find detailed information on the processing of your personal data from the "Personal Data Processing and Protection Policy" at www.wincoltd.com. Click

1. Methods of Obtaining Personal Data and Legal Reasons

Your personal data is collected electronically or physically. Your personal data collected for legal reasons specified in this Clarification Text can be processed and shared within the framework of the personal data processing conditions specified in Articles 5 and 6 of the Law

2. Purposes of Processing Personal Data

Planning and executing the activities required to customize your personal data, products and services offered by Winco Ltd according to the tastes, usage habits and needs of the persons concerned, and to recommend and promote them to the relevant persons within the framework of the personal data processing conditions specified in Articles 5 and 6 of the Law. , the business units to carry out the necessary work to benefit the persons concerned from the products and services offered by Winco Ltd and the execution of the relevant business processes It is processed for the purposes of planning and executing commercial and/or business strategies and ensuring the legal, technical and commercial occupational safety of Winco Ltd and the related persons who have a business relationship with Winco Ltd.

3. Parties to which Personal Data can be Shared and Purposes of Sharing

Your personal data, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, the products and services offered by Winco Ltd. planning and execution of the products and services offered by Winco Ltd by the business units and carrying out the relevant business processes, carrying out the necessary work by the relevant business units for the realization of the commercial activities carried out by Winco Ltd and conducting the related business processes, Winco Ltd.'s group companies, business partners and suppliers for the purposes of planning and executing the commercial and/or business strategies of Winco Ltd and ensuring the legal, technical and commercial occupational safety of Winco Ltd and the related persons who have a business relationship with Winco Ltd. It can be shared with authorized institutions and organizations and legally authorized private law legal entities.

4. Disposal of Personal Data

Personal data within Winco Ltd, as stated in the "Personal Data Retention and Disposal Policy" published on www.wincoltd.com; In case of a right request of the person concerned, it is deleted, destroyed or anonymized ex officio on the first periodic destruction date, in the event that the reasons requiring its processing disappear or the legal storage period expires, although it has been processed in accordance with the Law and other relevant law provisions. 5. Rights of Data Owners and Use of These Rights

In case you submit your requests regarding your rights stated below as personal data owners to Winco Ltd using the methods specified in article 6, your requests will be evaluated and finalized by Winco Ltd as soon as possible and in any case within 30 (thirty) days.

Pursuant to Article 11 of the Law, you have the following rights as a personal data owner:
• Learning whether your personal data is processed,
• If your personal data has been processed, requesting information about it,
• Learning the purpose of processing your personal data and whether they are used in accordance with the purpose,
• Knowing the third parties to whom your personal data is transferred, at home or abroad,
• Requesting correction of your personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
• Requesting the deletion or destruction of your personal data in the event that the reasons requiring its processing cease to exist even though it has been processed in accordance with the provisions of the law and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
• Objecting to the emergence of a result against the individual by analyzing your processed personal data exclusively through automated systems,
• Requesting the compensation of the damage in case your personal data is damaged due to unlawful processing.
Paragraph 2 of Article 28 of the Law has listed the cases where data owners do not have the right to demand (except for the right to demand the compensation of the damage), and in this context;
• The processing of personal data is necessary for the prevention of crime or for criminal investigation,
• Processing of personal data made public by the person concerned,
• Personal data processing is required by the authorized and authorized public institutions and organizations and professional organizations in the nature of public institutions for the execution of inspection or regulation duties and for disciplinary investigation or prosecution, based on the authority granted by the law,
• In cases where the processing of personal data is necessary for the protection of the economic and financial interests of the State with regard to budget, tax and financial matters, the rights specified in Article 11 of the Law (except for the right to demand the compensation of the damage) cannot be used for personal data.

According to paragraph 1 of Article 28 of the Law, since personal data will be outside the scope of the Law in the following cases, requests of data owners will not be processed in terms of this data either:

• Processing of personal data by real persons within the scope of activities related to themselves or their family members living in the same residence, provided that they are not given to third parties and that the obligations regarding data security are complied with.
• Processing of personal data for purposes such as research, planning and statistics by anonymizing them with official statistics.
• Processing personal data for art, history, literature or scientific purposes or within the scope of freedom of expression, provided that they do not violate national defense, national security, public security, public order, economic security, privacy of private life or personal rights or constitute a crime. > • Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to ensure national defense, national security, public safety, public order or economic security.
• Processing of personal data by judicial authorities or enforcement authorities in relation to investigation, prosecution, trial or execution proceedings.

6. Exercise of Rights by Data Owners
• Data owners will be able to use the "Application Form" on the "Applications to be Made by the Personal Data Owner to the Data Controller" at www.wincoltd.com to exercise the above-mentioned rights. Click
• Applications will be made by one of the following methods, together with documents that will identify the relevant data owner:
• Filling the form and sending the wet signed copy by hand, via a notary public or by registered letter with return receipt, to the address “Ayazağa Mah, Azerbeycan Cad., 2A Blok No:3 Inner Door: 101 Sarıyer - İstanbul/Turkey”,
• Sending the form by e-mail to ik@wincoltd.com by signing the form with a secure electronic signature regulated under the Electronic Signature Law No. 5070,
• Following a method prescribed by the Personal Data Protection Board.

Winco Ltd responds to data owners who want to exercise such rights within the limits set forth in the Law, within a maximum of thirty (30) days, as stipulated in the Law. In order for third parties to request an application on behalf of personal data owners, a special power of attorney issued by the data owner through a notary public on behalf of the person who will apply.

Winco Ltd may request information from the data subject in order to determine whether the applicant is the owner of personal data, and may ask a question about the application of the personal data owner in order to clarify the issues specified in the application.

As a rule, data owner applications are processed free of charge, however, a fee may be charged based on the fee schedule stipulated by the Personal Data Protection Board.