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Dağcı Natural Products Food Industry Trade Limited Company (“ Valerian Cosmetic ”)

BY THE COMPANY

WITHIN THE SCOPE OF THE PERSONAL DATA PROTECTION LAW NO. 6698

POLICY ON PROTECTION AND PROCESSING OF PERSONAL DATA

("POLICY")

Entrance

According to the Constitution of the Republic of Turkey, everyone has the right to demand the protection of personal data concerning him/her. This right includes being informed about personal data concerning him/her, accessing these data, requesting their correction or deletion, and learning whether they are being used in accordance with their purposes.

The Personal Data Protection Law No. 6698 ( “LPPD Law” ) regulates the protection of the fundamental rights and freedoms of individuals in the processing of personal data and the obligations of real and legal persons who process personal data and the procedures and principles they must comply with.

Regarding the protection of personal data, which is a constitutional right; Dağcı Doğal Ürünler Gıda Sanayi Ticaret Limited Şirketi (“ Valerian Cosmetic ”)

Governed by this Policy; shows due care in protecting the personal data of Personal Data Owners and makes this a policy.

In case of any conflict between the Personal Data Protection Law and other relevant legislation and the Valerian Cosmetic Personal Data Protection and Processing Policy, the current legislation will apply.

Information regarding the identity of the data controller for all personal data processing activities falling within the scope of this Policy is provided below.

Data controller : Dağcı Doğal Ürünler Gıda Sanayi Ticaret Limited Şirketi (“ Valerian Cosmetic ”)

Address : Bağlarçeşme Mh. Dogan Arasli Find. No:139b Esenyurt/Istanbul

Email : info@valeriancosmetic.com

Aim

https://valeriancosmetic.com/ (“ Website ”); is a website operated by Dağcı Doğal Ürünler Gıda Sanayi Ticaret Limited Şirketi (“ Valerian Cosmetic ”) (hereinafter referred to as “ Valerian Cosmetic ” or the “ Company ”). In the context of the Website, in order to protect the fundamental rights and freedoms of individuals, especially the right to privacy, in the processing of personal data and to regulate the obligations of real and legal persons processing personal data and the procedures and principles they will comply with, Valerian Cosmetic has prepared the Policy on the Protection and Processing of Personal Data within the scope of the Law on the Protection of Personal Data No. 6698.

This Policy is only related to personal data processed within the context of the Website operated by Valerian Cosmetic and its purpose is to provide explanations on personal data processing activities and systems adopted for the protection of personal data within the framework of legislation on personal data, and to ensure transparency by informing the persons whose personal data is processed by Valerian Cosmetic, especially the Personal Data Owners.

Scope

This Policy has been prepared for the purpose of informing the real persons whose personal data Valerian Cosmetic processes as the data controller within the specified scope. The subject of this Policy is related to Members/Users, Visitors and Suppliers whose data is processed in the context of Valerian Cosmetic's activities.

This Policy is related to all personal data of Personal Data Owners processed by automatic means or non-automatic means provided that it is part of any data recording system.

The scope of application of this Policy to the Personal Data Owner groups in the categories specified below may be the entire Policy or only some of its provisions.

Definitions

The definitions used in this Policy are as follows:

Explicit consent	Consent on a specific subject, clear, informed and expressed with free will
Anonymization	Making personal data incapable of being associated with an identified or identifiable natural person in any way, even when matched with other data.
Personal data	Any information relating to an identified or identifiable natural person
Special Personal Data	Data regarding race, ethnic origin, political views, philosophical beliefs, religion, sect or other beliefs, appearance and dress, membership in associations, foundations or unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.
Processing of personal data	Any operation performed on personal data, such as obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, either fully or partially by automatic means or non-automatic means provided that it is part of any data recording system.
Personal Data Protection Law	Personal Data Protection Law No. 6698
Personal Data Protection Board	Personal Data Protection Board
Personal Data Protection Authority	Personal Data Protection Authority
Turkish Penal Code	Turkish Penal Code No. 5237
Data processor	A natural or legal person who processes personal data on behalf of the data controller based on the authority granted to him.
Personal data owner	The natural person whose personal data is processed, who is deemed as the "related person" in the Personal Data Protection Law.
Personal Data Owner Application Form	The application form that personal data owners whose personal data is processed by Valerian Cosmetic will use when applying for their rights explained in Article 11 of the Personal Data Protection Law.
Data controller	The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system - Valerian Cosmetic-
Data Controllers Registry	Data controllers registry kept by the Presidency under the supervision of the Personal Data Protection Board
Data Inventory	Inventory created and detailed by Valerian Cosmetic by associating the personal data processing activities it carries out in connection with its business processes with the personal data processing purposes, the recipient group to which the personal data is transferred and the relevant personal data owner group.

General Principles Regarding the Processing of Personal Data

Valerian Cosmetic complies with the following principles in processing personal data:

Being in compliance with the law and the rules of honesty

While fulfilling its obligation to process and protect personal data, Valerian Cosmetic acts in accordance with the general principles of law and the rule of honesty regulated in the Turkish Civil Code.

Being accurate and up to date when necessary

While Valerian Cosmetic is processing personal data, all administrative and technical measures are taken to ensure the accuracy and up-to-dateness of personal data.

Processing for specified, explicit and legitimate purposes

Before starting the processing of personal data, Valerian Cosmetic clearly and precisely determines the purpose of processing personal data.

Being connected, limited and proportionate to the purpose for which they are processed

Valerian Cosmetic processes personal data to the extent necessary to achieve the specified purposes. In this context, Valerian Cosmetic takes into account the requirements of proportionality in the processing of personal data and does not use personal data for purposes other than those required.

Retention for the period required by the relevant legislation or for the purpose for which they are processed.

Valerian Cosmetic stores personal data for a limited period of time as required by the PDP Law and related legislation or as required by the purposes of data processing. In this context, Valerian Cosmetic first determines whether a period of time has been set forth in the relevant legislation for the storage of personal data, if a period has been set forth, it complies with this period, and if no period has been set forth, it stores personal data for the period required for the purpose for which it is processed. In the event that the period expires or the reasons requiring processing cease to exist, personal data is deleted, destroyed or anonymized by Valerian Cosmetic. Data processing is not carried out with the assumption that it can be used later.

Processing of Personal Data

Valerian Cosmetic may process personal data with the explicit consent of the personal data owner or without explicit consent in the cases stipulated in Articles 5 and 6 of the Personal Data Protection Law.

6.1 Categorization of Owners of Personal Data Processed by Valerian Cosmetic

Data subjects whose personal data are processed within the scope of this Policy are categorized as follows:

Member/User	Real person/persons who become a member of the Website in order to benefit from the services of the Website and benefit from the Services offered by Valerian Cosmetic.
Visitor	Real person/persons who use the Website without becoming a member and visit the Website.
Suppliers	Natural or legal persons who establish a supply chain of goods and services with Valerian Cosmetic.

6.2 Conditions for Processing Personal Data

Valerian Cosmetic carries out its personal data processing activities in accordance with the data processing conditions set forth in Article 5 of the Personal Data Protection Law. In the cases set forth below, your personal data may be processed without explicit consent within the limits established by the legal reason. Valerian Cosmetic obtains the explicit consent of the data owner except for the cases listed below.

It is clearly provided for in the laws.
If it is necessary for the protection of the life or physical integrity of a person or someone else who is unable to give his consent due to a physical impossibility or whose consent is not legally valid.
The processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
It is necessary for Valerian Cosmetic to fulfill its legal obligations.
Personal data has been made public by the owner himself.
Data processing is necessary for the establishment, exercise or protection of a right.
Data processing is necessary for the legitimate interests of Valerian Cosmetic, provided that it does not harm the fundamental rights and freedoms of the personal data owner.

One or more personal data processing conditions that make a personal data processing activity lawful may be applied at the same time.

6.3 Categories of Personal Data Processed by Valerian Cosmetic

Personal Data Category	Description	Data Subject Category to Which the Relevant Personal Data is Associated
Identity Data	Name-Surname, TR ID number, date of birth, gender	Member, Supplier
Contact Information	Telephone number, address, e-mail, fax number and similar information processed to communicate with the Data Owner	Member, Visitor, Supplier
Location/Location Information	Province, district and neighborhood etc. information	Member
Service History and Navigation Gestures	History of products and services purchased through the Website, browsing activities	Member, Visitor

Ensuring the Security and Confidentiality of Personal Data

In accordance with Article 12 of the Personal Data Protection Law, Valerian Cosmetic takes all necessary technical and administrative measures to prevent the unlawful processing of personal data it processes and unlawful access to personal data, and to ensure the appropriate level of security to ensure the preservation of personal data.

7.1 Technical Measures Taken to Ensure Lawful Processing of Personal Data and to Prevent Unlawful Access to Personal Data

Access and authorization technical solutions are implemented in accordance with legal compliance requirements determined on a business unit basis.
Personal data processing activities carried out within Valerian Cosmetic are supervised by established technical systems.
Personnel knowledgeable in technical matters are employed.
Network security and application security are provided.
A closed system network is used for personal data transfer via network.
Security measures are taken within the scope of information technology systems procurement, development and maintenance.
The security of personal data stored in the cloud is ensured.
Firewalls are used.

7.2 Administrative Measures Taken to Ensure Lawful Processing of Personal Data and to Prevent Unlawful Access to Personal Data

The main administrative measures taken by Valerian Cosmetic to prevent unlawful access to personal data are listed below:

The authority of employees who change their duties or leave their jobs is revoked in this area.
Necessary security measures are taken regarding entry and exit to physical environments containing personal data.
Employees are trained on technical measures to prevent unlawful access to personal data.
In accordance with business unit-based legal compliance requirements, personal data access and authorization processes are designed and implemented within Valerian Cosmetic.
Employees are informed that they cannot disclose the personal data they have learned to anyone else in violation of the provisions of the Personal Data Protection Law and cannot use it for purposes other than processing, and that this obligation will continue after they leave office, and the necessary commitments are obtained from them in this regard.
Provisions are added to the contracts concluded by Valerian Cosmetic with the persons to whom personal data is lawfully transferred, stating that the persons to whom personal data is transferred will take the necessary security measures to protect personal data and ensure that these measures are complied with in their own organizations.
Valerian Cosmetic carries out the necessary audits within its own organization in accordance with Article 12 of the Personal Data Protection Law.
Valerian Cosmetic operates a system that ensures that personal data processed in accordance with Article 12 of the Personal Data Protection Law is notified to the relevant personal data owner and the Personal Data Protection Board as soon as possible in the event that the personal data is obtained by others through illegal means.

7.3 Measures to be Taken in Case of Unlawful Disclosure of Personal Data

If the processed personal data is obtained by others through illegal means, Valerian Cosmetic will notify the relevant data owner and the Board as soon as possible.

Purposes of Processing Personal Data and Storage Periods

8.1 Purposes of Processing Personal Data

Valerian Cosmetic may process personal data for the following purposes within the scope of the personal data processing conditions specified in Articles 5 and 6 of the Personal Data Protection Law:

To customize, measure and improve the Website and the services offered through the Website for you,
To recommend products and services offered by the Website to you, customized according to your tastes, usage habits and needs,

Planning and execution of corporate communication activities,
Execution of corporate governance activities,
Resolving Data Owner problems and complaints,
Responding to requests for information from administrative and judicial authorities,
Planning of reporting and business development activities within Valerian Cosmetic,
Ensuring information and transaction security and preventing malicious use,
Planning and execution of operational activities required to ensure that Valerian Cosmetic's activities are carried out in accordance with the policies prepared within the scope of the Personal Data Protection Law,
Making the necessary arrangements to ensure that the processed data is up-to-date and accurate,
Creating data owner satisfaction and loyalty,
Planning and execution of data owner information change and/or cancellation processes,
Corporate reputation management, media communication, promotion and advertising of Valerian Cosmetic,
Obtaining necessary information from documents, digitizing contracts.

If the processing activity carried out for the aforementioned purposes does not meet any of the conditions stipulated under the PDP Law, Valerian Cosmetic obtains the explicit consent of the personal data owner for the relevant processing process.

8.2 Storage Periods of Personal Data

Valerian Cosmetic determines whether a period is foreseen in the relevant legislation for the storage of personal data. If a period is foreseen in the relevant legislation, it complies with this period; if a period is not foreseen, it stores personal data for the period necessary for the purpose for which they are processed. If the purpose of processing personal data has ended and the storage periods determined by the relevant legislation and/or Valerian Cosmetic have expired, they may only be stored for the duration of the limitation periods foreseen in the laws in order to constitute evidence in possible legal disputes, to assert the relevant right related to personal data or to establish a defense.

Deletion, Destruction and Anonymization of Personal Data

Your data stored within the scope of the law will be stored for the maximum period specified in the relevant legislation or required for the purpose for which it is processed, and in any case, for the duration of the statutory limitation periods. As regulated in Article 138 of the Turkish Penal Code and Article 7 of the Personal Data Protection Law, if the reasons requiring processing are eliminated, personal data will be deleted, destroyed or anonymized ex officio or upon your request under the conditions determined by the Regulation on the Erasure, Destruction or Anonymization of Personal Data published in the Official Gazette No. 30224 dated 28.10.2017.

Deletion, Destruction and Anonymization of Personal Data

10.1 Transfer of Personal Data Domestically

In accordance with Article 8 of the Personal Data Protection Law, the transfer of personal data within the country will be possible provided that one of the conditions specified in section 6.2 titled “Conditions for Processing of Personal Data” of this Policy is met.

10.2 Groups of Persons to Whom Personal Data is Transferred by Valerian Cosmetic

Valerian Cosmetic may transfer personal data of personal data owners within the scope of this Policy and in accordance with Articles 8 and 9 of the Personal Data Protection Law to the following groups of people in Turkey and abroad for the specified purposes:

GROUPS OF PEOPLE	DEFINITION	PURPOSE OF TRANSFER
Legally Authorized Public Institutions and Organizations	Public institutions and organizations authorized to receive Valerian Cosmetic's information and documents in accordance with the relevant legislation.	Limited to the purpose requested by the relevant public institutions and organizations within the framework of their legal authority.
Legally Authorized Private Law Persons	Private legal entities authorized to receive information and documents from Valerian Cosmetic in accordance with the relevant legislation.	Limited to the purpose requested by the relevant private legal persons within their legal authority.
Hosting Provider	Private legal entity providing hosting services to Valerian Cosmetic	To ensure platform operability and sustainability
Suppliers	Real and legal persons who provide products/services required for Valerian Cosmetic to be able to carry out its activities and are procured from external sources.	In order to ensure that the activities specified by Valerian Cosmetic are carried out as required.

Obligation to Disclose

In accordance with Article 10 of the PDP Law, Valerian Cosmetic informs personal data owners during the collection of personal data. In this context, Valerian Cosmetic informs personal data owners about the identity of the person, the purpose for which personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method and legal reason for collecting personal data, and the rights of the personal data owner within the scope of Article 11 of the PDP Law during the collection of personal data. In accordance with Article 11 of the PDP Law, Valerian Cosmetic provides the necessary information in case the personal data owner requests information.

However, Valerian Cosmetic does not have an obligation to inform in accordance with Article 28 of the Personal Data Protection Law in the following cases:

Processing of personal data is necessary for the prevention of crime or criminal investigation,
Processing of personal data made public by the relevant person,
Personal data processing is necessary for the execution of supervisory or regulatory duties or disciplinary investigation or prosecution by authorized public institutions and organizations and professional organizations with the status of public institutions, based on the authority granted by law.
The processing of personal data is necessary to protect the economic and financial interests of the state in relation to budgetary, tax and financial matters.

Rights of Personal Data Owners and Exercise of These Rights

In accordance with Article 13 of the Personal Data Protection Law, the evaluation of the rights of personal data owners and the information that needs to be provided to personal data owners are carried out through this Policy as well as the Valerian Cosmetic Personal Data Owner Application Form. Personal data owners can submit their requests regarding the processing of their personal data to us within the framework of the principles specified in the relevant form.

12.1 Right to Apply

In accordance with Article 11 of the Personal Data Protection Law, anyone whose personal data is processed may apply to Valerian Cosmetic and make requests regarding the following matters:

To learn whether your personal data is being processed,
To request information regarding the processing of personal data,
To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
To learn the third parties to whom personal data is transferred domestically or abroad,
To request correction of personal data if it is processed incompletely or incorrectly and to request notification of the action taken to third parties to whom personal data is transferred,
To request that personal data be deleted, destroyed or made anonymous if the reasons requiring processing of personal data are eliminated and to request that the action taken within this scope be notified to third parties to whom personal data has been transferred,
To object to a result that is detrimental to the data owner, as a result of the analysis of processed personal data exclusively through automated systems,
To request compensation in case of damages due to unlawful processing of personal data.

If you wish, you can submit your applications and requests regarding your personal data using the Personal Data Owner Application Form.

By sending your signed petition by post or by other means to Valerian Cosmetic's address,
By applying in person to Valerian Cosmetic with your ID document,
By sending it to our registered e-mail address using your registered e-mail (KEP) address and secure electronic signature or mobile signature [●] ,
You can send a petition signed with a mobile signature or secure electronic signature or the “Concerned Person Application Form” by sending an e-mail to info@valeriancosmetic.com and forward it to Valerian Cosmetic.

According to the Communiqué on the Procedures and Principles of Application to the Data Controller, the Data Subject must include the name, surname, signature if the application is in writing, Turkish identity number, (passport number if the applicant is a foreigner), place of residence or workplace address for notification, e-mail address for notification, if any, telephone number and fax number, and information on the subject of the request in their application. Therefore, regardless of the method your application is made, make sure that it includes the above information.

The applicant must state all the requested issues clearly and understandably. Information and documents related to the application must be attached to the application.

If the application is made on behalf of someone else, information and documents showing that the person acting on behalf of someone else is authorized to do this and documents verifying the identity of the person represented must be attached to the application. Requests made by unauthorized third parties on behalf of someone else will not be taken into consideration.

Requests submitted to us and meeting the required qualifications will be finalized within 30 (thirty) days, depending on the nature of the request.

In accordance with Article 28, paragraph 2 of the Personal Data Protection Law, it will not be possible for personal data owners to assert their rights (excluding the right to demand compensation for damages):

Processing of personal data is necessary for the prevention of crime or criminal investigation.
Processing of personal data made public by the person concerned.
The processing of personal data is necessary for the performance of supervisory or regulatory duties or disciplinary investigation or prosecution by authorized public institutions and organizations and professional organizations with the status of public institutions, based on the authority granted by law.
The processing of personal data is necessary to protect the economic and financial interests of the State in relation to budgetary, tax and financial matters.

12.2 Response Procedure

In accordance with Article 13 of the Personal Data Protection Law, Valerian Cosmetic will finalize the application requests made by the personal data owner free of charge, as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request.

The application of the personal data owner may be rejected in the following cases:

Obstructing the rights and freedoms of other people
Requires disproportionate effort
The information is publicly available information
Compromising the privacy of others
One of the situations that are not covered by the Personal Data Protection Law is present.

12.3 Right to Complain to the Personal Data Protection Board

In case the application is rejected, the response is found insufficient or the response is not given in a timely manner, the applicant has the right to complain to the Personal Data Protection Board within 30 (thirty) days from the date of learning the response and in any case within 60 (sixty) days from the date of application.

This Policy may be revised by Valerian Cosmetic in order to keep it up-to-date and in compliance with the relevant legislation. In cases of revision, the most current version of the Policy will be published on the Website and if you continue to use Valerian Cosmetic's Website after the current Policy is changed, you will be deemed to have accepted the changes. The provisions of the Policy amended by Valerian Cosmetic will come into force on the date they are published on the Website.

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