FX-CARD Privacy Policy Privacy Policy As Fx-card, we are highly committed and sensitive to the protection and confidentiality of your personal data. The purpose of this Privacy Policy and Personal Data Protection Notice is to fulfill our obligation to inform as the data controller under the Law No. 6698 on Protection of Personal Data (“KVKK”) and related legislation, with respect to the processing of personal data shared by users/customers/visitors (“Data Subject”) with Ahtapot Holding or generated by the Data Subject during the use of the https://fxcard.com.tr website (“Site”) operated by Ahtapot Holding. This Privacy Policy and Personal Data Protection Notice contains information on what personal data we collect, why we use it, and how we process it. Fx-card attaches utmost importance to protecting individuals' fundamental rights and freedoms, especially the right to privacy under Article 20 of the Constitution, in the protection and processing of personal data. Within this framework, Fx-card takes care to protect and process collected and processed personal data in accordance with the Law No. 6698 on Protection of Personal Data (“KVKK”), and acts with utmost care in all planning and activities. In this context, Fx-card takes necessary technical and administrative measures by using its technological and infrastructure capabilities to ensure the secure storage and processing of personal data in compliance with the current data protection legislation, both domestically and/or abroad. PROCESSABLE PERSONAL DATA Personal data refers to any kind of information about a real person with identified or identifiable identity. The categories of personal data that can be processed during the services provided to you by Fx-card are stated below: Identity Information: This data category includes name, surname, Turkish National ID number, tax ID number, passport number, nationality, place of birth, date of birth, gender data. Contact Information: This data category includes phone number, address, e-mail address data. Subscription Information: To personalize, target, and carry out advertising activities. For example, displaying ads related to visitors' interests through the pages and products viewed by users, making device-based targeting in mobile applications, conducting user-participatory surveys with brand collaborations. Demographic Data: This data category includes age, profession, title data. Payment and Financial Information: This data category includes invoice and debt information. Device Information: In this data category, data related to IMEI, device brand/model/serial number, device operating system, device usage movements, device accessed by mobile applications, network information are processed. Transaction Information: This data category includes transactions and declarations of will by subscribers/users; It refers to the types of data (such as transaction information made in channels such as a website or call center). Usage and Behavioral Information: This data category processes data on preferences regarding the use of products and services, usage habits, and online shopping information. 2. PURPOSE OF PROCESSING YOUR PERSONAL DATA As Fx-card we will have the right to collect, store, process and/or process your personal data in the database in any case within the scope of KVKK and for the purposes specified here. Your personal data may be processed in accordance with the legislation on the protection of personal data for the following purposes, but not limited to: Offering, charging and billing products and services and initiating subscriptions, Login in order to enable the user to access products and services via web and mobile applications, Making a Customer Registration application, Fx-cardcard transactions and related notifications. Completion of your orders, payment status and verification of your details, Ensuring international customer authentication compatible with all devices, To be informed about the promotion and marketing of products and services, the presentation of targeted advertising, targeted promotion and communication with you, offers, campaigns, discounts, benefits, conditions, pricing; providing opportunities such as membership, activities and benefiting from economic advantages and fulfilling the necessary procedures for their use, To be able to send commercial electronic messages by obtaining additional approval in accordance with the legal legislation, Sending personal celebrations, gifts, wishes and award opportunities and drawing draws, To be able to offer a job to people who have a job interview relationship with Fx-card if there is a suitable position, Training and developing people such as our employees and business partners in order to provide better service to users, To detect or prevent breach of contractual and/or contractual obligations in the use of products and/or services provided by Fx-card Carrying out studies such as the development, diversification, measurement, inspection and analysis of products and services; evaluating your interest in products and services, determining customer satisfaction; providing call center service; answering questions, complaints and notifications from the data owner, Performance evaluation processes with business partners and suppliers and organization of these processes, legal compliance process. Preservation of information that must be kept in accordance with the relevant legislation; copying, backing up to prevent loss of information; ensuring the consistency of your information; Taking the necessary technical and administrative measures for information security, Required by Law No. 5651 on Regulating Broadcasts Made on the Internet and Combating Crimes Committed Through These Broadcasts, Electronic Communications Law No. 5809, Information Technologies and Communication Authority regulations and other legislation, Fulfilling legal obligations required or mandated by legal regulations with regulatory and supervisory institutions, execution of legal proceedings and legal processes. 3. TRANSFER OF YOUR PERSONAL DATA Fx-cardwill be able to share your personal data collected under this Policy or provided by you as the Data Owner with other third parties listed below within the scope of KVKK and other legislation in accordance with Article 8 of the KVKK: To business partners; Limited to ensure the fulfillment of the purposes of the establishment of the business partnership, to fulfill the contractual requirements with the data owner as a user and to put them into practice, To its suppliers; Limited to provide Fx-cardservices outsourced from the supplier and necessary to fulfill the commercial activities of Fx-card Server service providers; Limited to ensure the active operation of the service provided, by keeping the personal data securely in the servers and databases used by FX-cardin the country and/or abroad, To its shareholders; Limited to the purposes of the activities carried out by Fx-cardwithin the scope of legal, event management and corporate communication processes in accordance with the relevant legislation provisions, To FX-cardofficials; limited to the purposes of designing strategies for FX-cards commercial activities, ensuring its management at the highest level and auditing in accordance with the provisions of the relevant legislation, Legally authorized public institutions and organizations; limited to the purpose requested by the relevant public institutions and organizations within the legal authority, To real or legal persons that we receive services and cooperate with in product/service comparison, analysis, evaluation, advertisement and the realization of the above-mentioned purposes; Limited to the provision of collaboration and service received, to select and serve advertisements displayed on the Site, and to allow third parties (such as ad servers) to do so on our behalf, to enable us to report on advertisements shown to you and how you interact. 4. COLLECTION METHODS AND LEGAL REASONS OF PERSONAL DATA Your personal data, in all kinds of verbal, written or electronic media, in order to provide the products and services we offer to you in line with the purposes specified in this Policy, within the determined legal framework, and in this context, FX-cardfully and appropriately fulfills its contractual and legal responsibilities. It is collected in the following ways in order to fulfill its purpose. Kişisel verileriniz, tamamen veya kısmen otomatik yollarla ya da veri kayıt sisteminin parçası olmak kaydıyla otomatik olmayan yöntemler ile; üyeliğiniz, sipariş vermeniz, aboneliğiniz sırasında elektronik olarak doldurulan veya çağrı merkezi, abone merkezi veya benzeri bir hizmet noktası üzerinden beyanınız ile doldurulan üyelik formu, abonelik formu, sipariş forumu, bilgi formu gibi formlar ile üyelik veya abonelik sözleşmeleri; sözleşmelerin veya formların ekindeki kimlik ve adres tespitine ilişkin belgeler; Site’de yaptığınız hareketler; duyuru ve iletişim sağlamak için onay ve iletişim bilgilerinizi almak için oluşturulan veya ürün ya da hizmetlerimize ilişkin memnuniyet veya şikâyetlerinizi toplamak için oluşturulan sistemler; web, mobil ve benzeri bir uygulama aracılığıyla ya da basılı olarak tarafınıza sunulan duyuru, elektronik bültene üye olunması, iletişim, şikayet, çekilişe, promosyona, elektronik haber bültenine katılım, ön kayıt, kampanya katılım formları, yüz yüze, telefonla veya başkaca bir iletişim aracı kullanarak gerçekleştirilen anket veya iletişimler; sosyal ağlar; cep telefonu, tablet veya sair mobil cihaz uygulamaları; üyelik ve abonelik başta olmak üzere FX-cardile imzalamış olduğunuz sözleşmeler ile FX-carda göndermiş olduğunuz elektronik postalar, faks ve mektuplar, FX-cardile yapılan yazılı veya sözlü iletişim kanalları aracılığıyla sözlü, yazılı veya elektronik ortamda toplanmaktadır. Your personal data is stated in Article 5 of the KVKK, a) It is clearly stipulated in the laws, b) It is mandatory for the protection of the life or physical integrity of the person or someone else, who is unable to express his consent due to actual impossibility or whose consent is not given legal validity, c) Establishing a contract or, provided that it is directly related to the performance of the contract, it is necessary to process the personal data of the parties of the contract, f) Provided that it does not harm the fundamental rights and freedoms of the data subject, it is collected due to the fulfillment of the conditions and purposes of the data processing being mandatory for the legitimate interests of the data controller. The processing of your personal data other than these conditions is carried out in connection with the purposes specified in article 2 of this Policy, in a limited and measured manner, in line with your consent. 5. ANONYMOUS DATA AND DATA DISPOSAL Fx-cardmay also process your personal data in aggregate as anonymous data in order to analyze and reveal statistics on habits, usage habits and demographics of user groups as a group or individual. Such anonymous data does not allow the identification of the users with which it is associated. The company may share such anonymous data with third parties.FX-card The Company records all processes related to the deletion, destruction, and anonymization of data provided by you and securely retains such records for a minimum period of ten years, except for other legal obligations. Upon your request regarding the processing of your personal data by FX-card, in the event that there is a requirement for destruction under the Law on the Protection of Personal Data (KVKK) either ex officio or due to legal obligations, the Company, in accordance with KVKK, will destroy personal data by selecting the appropriate method among the methods of deletion, destruction, or anonymization unless otherwise decided by the Board. However, upon your request, the appropriate method will be chosen and explained with its justification. In order to carry out the service offered by Fx-card the users are subject to the privacy policy by transferring their personal data to Fx-cards servers located in Turkey and/or abroad in accordance with the Law No. They accept that they expressly and freely consent to the user agreement, personal data processing-retention-destruction policies. 6. RIGHTS OF PERSONAL DATA SUBJECT Article 20 of the Constitution of the Republic of Turkey regulates that everyone has the right to be informed about the personal data related to him/her, and as per Article 11 of the KVKK, the right to "request information" is among the rights of the Personal Data owner. In this context, Fx-cardprovides the necessary information in case the personal data owner requests information, and with this Policy, Fx-cardinforms the data owner about how the right to request information is exercised and how the issues related to the information request will be evaluated. gives. As a Fx-carduser, in accordance with Article 11 of the KVKK; of this Policy "8. By applying to Fx-cardusing the methods in the "Contact" section, Learning whether your personal data is processed, If your personal data has been processed, requesting information about it, To learn the purpose of processing your personal data and whether they are used in accordance with the purpose, Knowing the third parties to whom it is transferred in the country or abroad, Requesting correction of your personal data if it is incomplete or incorrectly processed, To request the deletion/destruction of Personal Data within the framework of the conditions stipulated in Article 7 of the KVKK and to notify the third parties to which the Personal Data has been transferred, Objecting to the emergence of a result against you by analyzing your processed personal data exclusively with automated systems, In the event that you suffer damage due to the processing of your personal data in violation of the KVKK, you can exercise your right to demand the compensation of your damage. 7. CONTACT Data owners' requests for the exercise of the above-mentioned rights, in writing or by registered electronic mail (KEP) address, secure electronic signature, mobile signature or Fx-cardpreviously notified by the data owner, By using the e-mail address registered in the system a or by using a software or application developed for application purposes, the e-mail address of Fx-cardis …………… or the postal address is Kırcaali Mh. Kayalı Sk. Ortaklar İş Merkezi K.5 D.37 Osmangazi / Bursa address. In the applications of data owners; name, surname and, if the application is written, signature, for citizens of the Republic of Turkey, T.C. identification number, nationality for foreigners, passport number or identification number, if any, place of residence or workplace address for notification, e-mail address for notification, telephone and fax number, if any, and the subject of the request.