GDPR

Fine by Mer”s PERSONAL DATA PROTECTION POLICY

1. Purpose of the Policy

This policy has been prepared to ensure the processing, storage, transfer and protection of personal data within the scope of Fine by Mer”s in accordance with the Personal Data Protection Law No. 6698 ("KVKK") and related legislation.

2. Processed Personal Data, Purpose and Legal Grounds

Within the scope of the Fine by Mer”s membership program, the following personal data may be requested from our esteemed members:

• Identity Information: Name, surname, date of birth, gender
• Contact Information: Mobile phone, e-mail, address
• Shopping and Transaction Information: Shopping point, time, amount, product information, campaign information, discount amount
• Marketing and Digital Footprint Information: Application usage data (navigation, clicks, location)

Purposes of Processing:

Your personal data;

• Carrying out membership transactions,
• Providing discounts, campaigns and loyalty programs,
• Sending commercial electronic communications (with explicit consent),
• Statistical analyses and customer service processes,
• Fulfilling legal obligations

may be processed for these purposes in accordance with KVKK articles 5 and 6, based on legal grounds such as explicit consent or legitimate interest, performance of contract, legal obligation.

3. Personal Data Storage Period

Your personal data,

Your personal data will be kept for the period during which they are processed for the purposes mentioned above and for the retention periods stipulated in the relevant legislation.
Electronic communication consent, content of the communication and delivery records under Law No. 6563 are kept for
5 years from the date the consent ends. At the end of this period, the data is deleted, destroyed or anonymized in accordance with our destruction policy.

4. Transfer of Personal Data

Your personal data;

•May be shared with domestic service providers (call center, IT services, SMS/e-mail providers) if you give explicit consent,

•May be shared with public institutions (e.g., BTK, courts) upon request and as required by legal obligation. Your personal data is not transferred abroad. In case of transfer, your explicit consent will be obtained.

5. Rights of the Data Subject

Within the scope of Article 11 of the KVKK;

• Learning which of your personal data is processed,
• Learning the purpose of processing and whether it is used appropriately,
• Knowing the third parties to whom data is transferred domestically/abroad,
• Requesting correction of incomplete/incorrect data,
• Requesting deletion or destruction,
• Requesting notification of transactions made to third parties to whom data is transferred,
• Objecting to an outcome against you resulting from the analysis of processed data,
• Requesting compensation if you suffer damage

you have these rights.

To exercise these rights, you can send an e-mail to fine@finebymers.com.tr or access the application form at www.finebymers.com/kvkk.

6. Measures Regarding Data Security

Fine by Mers, to protect your personal data:

• SSL encryption,
• Firewall systems,
• Access control mechanisms,
• Software measures to prevent unauthorized access,
• Confidentiality agreements and KVKK awareness trainings for employees

implements administrative and technical measures such as these.

In case of possible breaches that may occur despite data security, the Personal Data Protection Board and the relevant individuals will be notified as required by legislation.

7. Policy Changes

FinebyMers reserves the right to update this policy. The current text is published at www.finebymers.com/kvkk. Changes become effective from the date they are implemented and our members are informed accordingly.