Privacy and Personal Data Protection Policy

Our company, Şehriban Ezim - Kos Living (“Kos Living”), aims to ensure the secure use of the services offered on our e-commerce website with the domain www.kosliving.com (“Website”), including transactions made via mobile device applications, and to protect the personal data you provide and your privacy. Accordingly, this privacy and personal data protection policy (“Privacy Policy”) has been prepared to ensure that your personal data is processed fully in compliance with the Personal Data Protection Law No. 6698 (“PDPL”) and to inform you in this context.

The purpose of this Privacy Policy is to set out the rules and conditions applicable to both our company and you regarding transaction security on the Website, protection, confidentiality, processing, use of information, and commercial electronic communications.

The Cookie Policy prepared by Kos Living and available at https://www.kosliving.com/pages/cerez-politikasi is an integral part of this Privacy Policy.

This Privacy Policy has been prepared in accordance with the Customer Information Text available at https://www.kosliving.com/pages/musteri-aydinlatma-metni.

WHAT DATA IS PROCESSED? WHAT IS THE PURPOSE OF PROCESSING PERSONAL DATA?

Personal data obtained and/or requested during your membership and purchases on the Website (such as name, surname, email address, phone number, gender, date of birth, Turkish ID number, tax ID number, personal interests, billing and delivery addresses, and in case of linking with social media accounts, information shared by the relevant member through those channels with consent, including but not limited to any personal information that directly or indirectly identifies the user) is requested and processed.

These data may be shared, recorded, processed, stored in accordance with legal periods, updated if necessary, transferred, and used within the scope of our legal obligations arising from relevant legislation such as Law No. 5651 on Regulation of Publications on the Internet and Combating Crimes Committed through These Publications, Law No. 6563 on Regulation of Electronic Commerce (“Law on Regulation of Electronic Commerce”), Turkish Penal Code No. 5237, and the PDPL, as well as service standards, with current and future companies within our group, for product supply, all kinds of information, advertising-promotion, communication, promotion, sales, marketing, store card, credit card, and membership applications, and for electronic and other commercial-social communications. Additionally, we may collect and process non-personal aggregated statistical data such as the frequency and times of Website visits, order times, IP addresses at the time of order, statistics of visited product pages and ordered products to analyze and understand visitor behavior and preferences.

By accepting the Privacy Policy and the commercial communication consent below, you consent and permit the use, sharing, processing, and sending of commercial and non-commercial electronic communications and other communications to you within the scope described above, in compliance with personal data protection and electronic commerce legislation, using your existing and new personal and non-personal information.

PROTECTION AND TRANSFER OF PERSONAL DATA

Necessary measures for the security of the information and transactions you enter and/or record on the Website have been taken by us within our system infrastructure, according to the nature of the information and transaction, to the extent of technical possibilities. However, since this information is entered through the device you use, it is your responsibility to take necessary precautions, including protection against viruses and similar harmful applications, to prevent unauthorized access.

Kos Living commits to keeping your personal data confidential, taking all necessary technical and administrative measures to ensure confidentiality and security, and exercising due care. Despite Kos Living’s security measures, if personal data is damaged or accessed by third parties due to attacks on the Website or system, this will be immediately reported to you and the Personal Data Protection Board, and necessary measures will be taken.

Your personal data, as stated above, may be shared with third parties we cooperate with to provide our services (such as cargo, delivery, call center, database, and similar service providers) and, as required by legal obligations, with authorized private or public institutions and organizations, judicial authorities, and official institutions/organizations to fulfill information and document provision obligations and other related duties, and to exercise our legal rights such as lawsuits and defense rights. Kos Living may share your personal data related to your visit or membership on the Website and traffic information such as browsing data with public institutions and organizations legally authorized to request this information for your security and to fulfill Kos Living’s obligations under applicable laws. However, your personal data will not be used for commercial purposes or shared with third parties except for the activities listed above and as required by relevant legislation.

Your personal data may occasionally be transferred directly or indirectly to our domestic or international shareholders, subsidiaries, and/or affiliates; contractual service providers, collaborators, domestic or international organizations, and other third parties to conduct our activities. Within this scope, data sharing may occur with Shopify Inc. (Canada/USA) for e-commerce infrastructure and Meta Platforms Inc. (USA) for WhatsApp Business communication. These transfers are made with the necessary safeguards in accordance with Article 9 of the PDPL.

WHAT ARE THE RIGHTS OF THE PERSONAL DATA OWNER?

According to Article 11 of the PDPL, visitors have the right to apply to Kos Living to:

• Learn whether their personal data is being processed;
• Request information if their personal data has been processed;
• Learn the purpose of processing personal data and whether it is used in accordance with that purpose;
• Know the third parties to whom personal data is transferred domestically or abroad;
• Request correction of incomplete or inaccurate personal data and request notification of this correction to third parties to whom the data has been transferred;
• Request deletion or destruction of personal data if the reasons requiring processing no longer exist, despite lawful processing, and request notification of this to third parties to whom the data has been transferred;
• Object to the emergence of a result against themselves by exclusively analyzing the processed data through automated systems; and
• Request compensation for damages in case of unlawful processing of personal data.

If you wish to exercise any of the rights listed here, you can submit your request to Kos Living in writing or by other methods determined by the Personal Data Protection Board, pursuant to Article 13, paragraph 1 of the PDPL. You can send your written request clearly and understandably, including your name, surname, contact information, and documents proving your identity regarding your personal data, with a secure electronic signature, mobile signature, or wet signature to the addresses below.

Data Controller	:	Şehriban Ezim - Kos Living
Email Address	:	info@kosliving.com
Address	:	Ertuğrulgazi Mah. Özkervan Sokak No:5 D/E İnegöl/Bursa

HOW LONG ARE PERSONAL DATA RETAINED?

According to the Law on Regulation of Electronic Commerce; records of withdrawal of consent are kept for 1 (one) year from the date of withdrawal; all other records related to the content and sending of commercial electronic messages are kept for 3 (three) years to be presented to the relevant ministry if necessary; according to the Tax Procedure Law, invoices, orders, and accounting records are kept for 5 (five) years. After these periods expire, your personal data will be deleted, destroyed, or anonymized by Kos Living or upon your request.

Kos Living is free to keep all records related to terminated membership accounts provided they are anonymized. When data is anonymized, it loses its characteristic of identifying a person and is not considered personal data. The relevant person cannot claim any rights or compensation regarding anonymized records.

You can always stop the use-processing of your data and/or the electronic communications sent to you by contacting us through the communication channels specified in this Privacy Policy and exercising your right to opt-out of communications. According to your explicit notification, personal data processing and/or electronic communications with you will be stopped within the legal maximum period. Additionally, upon your request, information that is not legally required to be retained and/or possible to delete will be removed from the data recording system or anonymized so that identity cannot be determined. You can always apply to us through the above communication channels for information and requests regarding the processing of your personal data, the parties to whom it is transferred, correction of incomplete or inaccurate data, notification of corrected data to relevant third parties, deletion or destruction of data, objection to automated system analysis resulting in adverse outcomes, and compensation for damages due to unlawful processing. Your applications and requests will be fulfilled within legal maximum periods or may be rejected with legal justification explained to you.

CHANGES AND ENFORCEMENT OF THE PRIVACY POLICY

Kos Living may change the provisions of the Privacy Policy at any time. The updated Privacy Policy will take effect on the date it is published on the Website.

COMMERCIAL COMMUNICATION CONSENT

By accepting this Privacy Policy, you consent to the collection, storage, processing, use, and transfer to third parties with whom Kos Living has contractual relationships of your personal data shared with us, for the purpose of providing you with various benefits and sending you personalized promotional, advertising, sales, marketing, survey, and similar electronic communications via phone, SMS, email, and similar channels, as well as other communication messages.

Following your purchase on our site, we will send non-periodic informational emails containing details about your purchase and product delivery to the email address you provided. Therefore, by registering on our site, you are deemed to have accepted the accuracy of the email address you provided.

Communication via WhatsApp Business

As Kos Living, communications with our customers via WhatsApp Business may be processed on the infrastructures of Shopify Inc. and Meta Platforms Inc. for order tracking, customer service, and marketing communication purposes. Personal data transmitted in this context (name, phone number, message contents) is used only for the specified purposes, is not shared with third parties for commercial purposes without your explicit consent, and is deleted after legal retention periods. WhatsApp marketing communications are sent only with your explicit opt-in consent. You can contact us at info@kosliving.com regarding your rights related to your personal data.