1- What personal data is processed by Exbani?

The individuals who accept the records on the Exbani platform, log in through the website or mobile application, and track and/or purchase products listed on the platform are classified as “Members”.

• Identity Information: your name, surname, National ID Number (only kept for certain product groups for compliance with relevant legislation), gender, date of birth, height, and weight information if shared voluntarily.
• Contact Information: your phone number, delivery address, email address.
• Customer Transaction Information: your order and invoice details, delivery transactions, transaction history information related to your purchases, complaints, and any information shared when you comment on or ask questions about the products on the platform.
• Transaction Security Information: IP address information, passwords, and information about cookie storage.
• Marketing Information: information about your purchase history, campaign participations, profiling, and segmentation.
• Legal Transaction Information: information in correspondences with authorized persons, institutions, and organizations; information in lawsuits and enforcement files; legal information requests.
• Auditory Record Information: if you communicate through the call center, you will be recorded.

2- What are the systems and methods for collecting personal data?

Identity, contact, and customer transaction data are collected automatically through electronic means in the context of our contractual relationship through the mobile application or internet.

• Expansions and fulfillments of contracts.
• Finance and accounting management and audits.
• Segregation and audits of business policies.
• Popularity of billing processes.
• Tracking logistics, shipment distributions, and deliveries.
• Completing purchase transactions through the website/mobile applications and verifying the identity of the person making the transaction.
• Upon having your explicit consent, using data in various marketing and advertising activities, providing you with a better shopping experience suited to your preferences.
• Expanding customer scope and being able to identify buyers on the platform; using it in customer service analysis, enhancing the system's products and services, and facilitating targeted growth.
• Ensuring stability in strategic analysis, isolation of communication.
• Taking into account your interests with welcome activities.
• In relation to virtual sales contracts and the conditions of contracts made through our platform under the applicable articles of the Consumer Protection Law, necessary communications and regulatory information will be delivered.
• If you have explicit consent, information will be provided to you about developments, opportunities, and innovations at Exbani.
• Conducting electronic or physical surveys through our partners for marketing and analysis by using customer data.
• Evaluating requests, complaints, suggestions related to products and services.
• Continuing information activities about products.
• Supporting after-sales services of goods and services.
• Distributing information security.
• Ensuring operational safety related to the Exbani platform.
• Continuing operations in accordance with legislation.
• Tracking and managing legal affairs; providing information to authorized individuals, public institutions, and financial authorities.

3- What is the legal reason for processing personal data?

The personal data details specified herein are processed based on the legal grounds outlined in the KVKK, categories 5, 8, and 9, particularly considering relevant provisions in the Law on Regulation of Electronic Commerce, the Turkish Commercial Code, the Turkish Penal Code, and the Law on the Protection of Consumers.

• It is regulated in the legal framework applicable to the company, primarily ensuring operational safety on the platform.
• Data collection is necessary for the execution of contracts and agreements.
• It is legally essential to fulfill the company’s obligations.
• Data processing is mandatory for protecting legal rights.
• Necessary data management for legitimate interests of the company, development of products and services.
• Upon having explicit consent, the transfer of personal data outside of the country.

4- To whom and for what reasons does Exbani transfer personal data?

Our company ensures data minimization and takes necessary technical and administrative security measures while processing personal data in accordance with the policies of “necessity to know” and “necessity to use.” Due to operational requirements, we may share personal data with certain users and third parties.

To fulfill our contractual and legal obligations properly, maintaining the accuracy and timeliness of personal data is essential. Therefore, we collaborate with various business partners and service providers.

The personal data, including but not limited to, is processed for the expansion of marketplace operations, support requests, and enhancement of our services and products.

In line with applicable laws, legal obligations, and the necessity to fulfill contractual requirements, personal data may be shared with:

• Sellers and service providers for cost management.
• Logistics and delivery firms for tracking shipments and deliveries.
• Our business partners for billing purposes.
• Call center service providers for after-sales support.
• Risk analysis service providers for quality control and complaint management.
• Relevant business partners in financial aspects for auditing and risk management.

HOW DOES EXBANI PROTECT YOUR PERSONAL DATA?

Exbani is responsible for ensuring compliance with legal regulations regarding your personal data. The company has implemented necessary financial and technical controls to protect personal data.

• Regular penetration tests are conducted to ensure data privacy.
• Personalized data submitted through the website and mobile application is protected using SSL (Secure Sockets Layer) technology.
• Regular risk assessments are conducted, and actions are taken to mitigate identified risks.
• Access and authorization controls are maintained to prevent unauthorized access.
• We always keep our data processing policies up to date.

YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA

• Learn whether your personal data is being processed.
• Request information about processed personal data.
• Learn the purpose of processing the personal data and whether it is used appropriately.
• Obtain information about third parties to whom your personal data is transferred.
• Request the correction of incorrect or incomplete personal data.
• Request deletion or destruction of personal data in accordance with the conditions set forth in the KVKK.
• Request notification to third parties regarding rectification, deletion, and objection.
• Object to the detrimental results arising from analysis of personal data solely through automated systems.
• Request compensation for damages in the event of unlawful processing of personal data.

For any requests concerning your rights about personal data, you can contact the specified address in the “Contact for Requests” section of this Notice.

Exbani will respond to your requests within 30 (thirty) days and these will be free of charge. However, if your request entails a cost under legislation, Exbani may charge you the fee determined by the Personal Data Protection Authority.