KVKK DISCLOSURE TEXT AND PRIVACY POLICY

LPPD DISCLOSURE TEXT AND PRIVACY POLICY — bittimsabunu.tr

Effective Date: January 22, 2026 | Version: 1.0

1) Data Controller

Data controller according to LPPD Law No. 6698:

Hammed Cemil Gülçiçek / Nesly

Address: Afet Evleri Mahallesi Kurtalan Caddesi Badem Rezidans No:41/A Blok Kat:3 Daire:12 Merkez/SİİRT

Email: neslygroup@gmail.com

KEP: hammedcemil.gulcicek@hs01.kep.tr

2) Categories of Personal Data Processed (Example)

– Identity and contact: name, surname, phone, email, address

– Customer transaction: order, delivery, return/withdrawal, support records

– Payment/finance: payment method information (card data may be processed in payment institution infrastructure; card information is not stored by us)

– Transaction security: IP, log, device/session information

– Marketing (if any): consent/permission records, preference information

3) Processing Purposes

– Execution of order, delivery, return/withdrawal processes

– Execution of invoicing and accounting processes (e-Invoice/e-Archive)

– Execution of customer support processes

– Fulfillment of legal obligations

– Ensuring site security, preventing abuse

– Sending commercial electronic communications (only if consent/appropriate legal conditions exist)

4) Legal Grounds

Personal data may be processed based on legal grounds specified in the LPPD, such as the establishment/performance of the contract, fulfillment of legal obligations, legitimate interests, and explicit consent when necessary.

5) Transfer (Recipient Groups)

Data, limited to the purpose, may be transferred to:

– Cargo/logistics companies,

– Payment service providers/banks,

– Accounting and e-Invoice/e-Archive service providers,

– Legally authorized public institutions and organizations,

– Technical infrastructure/hosting and e-commerce platform providers.

6) Transfer Abroad

Due to e-commerce infrastructure, hosting, and cloud services, data may be transferred to service providers located abroad. In this case, necessary technical/administrative measures and appropriate safeguards are applied within the scope of the LPPD's provisions on transfer abroad.

7) Retention Period

Personal data is retained for the period required by the processing purpose and for the limitation/retention periods stipulated in the relevant legislation.

8) Data Subject Rights and Application

You can submit your applications under the LPPD through the following channels:

Email: neslygroup@gmail.com

KEP: hammedcemil.gulcicek@hs01.kep.tr Postal Address: Afet Evleri Mahallesi Kurtalan Caddesi Badem Rezidans No:41/A Blok Kat:3 Daire:12 Merkez/SİİRT