PDPA

MARKETING PROCESSES INFORMATION TEXT

Your personal data is processed by MAKRO TRAVELS (“Company”), registered with the Istanbul Trade Registry Office with the registration number 873420 and headquartered at Ercüment Batanay Sk. 14/C Ataşehir / Istanbul / Turkey, as the data controller, within the scope of the provisions of the Law on the Protection of Personal Data No. 6698 (“KVKK”) and within the framework of this Marketing Processes Informative Text (“Informative Text”).

Our Company respects your privacy and your rights regarding the protection of your personal data and works to establish and maintain a relationship based on trust with you. In this context, our Company processes your personal data in accordance with all legislation provisions regarding the protection of personal data, especially KVKK, ensures that your data is stored securely and takes all necessary security measures against possible unlawful access. This Disclosure Text explains the scope of processing of your personal data collected within the scope of activities related to the marketing processes of products and/or services offered by our Company or on behalf of our Company. This disclosure text has been prepared for our real person merchant customers and real person employees of our legal entity customers who are parties to marketing activities.

Your personal data is collected by our Company in electronic and/or physical environments, primarily through demonteprefabrik.com, our Company's website, campaigns, surveys, our Company's mobile applications, customer services, e-mail, telephone, fax, cargo / mail, cookies and other definition technologies, request / complaint platforms, authorized public institutions and organizations and other related third party integrated systems and social media platforms, and other methods (channels) that may be added to these in the future.

Fulfillment of Company obligations arising from marketing processes; customer relations and satisfaction management; request and/or complaint management; storage and archive management; management of legal and consultancy affairs including fulfillment of legal obligations and making mandatory legal notifications; information security management; management of quality standards including product / service / process improvement; communication, audit and reporting management within the scope of compliance with the global policies and procedures of our group companies and shareholders; audit and internal audit management processes and, if you have express consent, planning and/or carrying out direct and/or indirect personal / mass marketing activities including promotions, campaigns, surveys, sweepstakes, competitions, e-bulletins / website memberships organized by the Company on electronic and/or physical media, primarily on social media platforms (e.g. YouTube, Instagram and Twitter); publication of product / service evaluations / comments offered by the Company on the Company's electronic platforms; corporate communication management aimed at increasing the brand value and awareness of the Company; planning and management of activities to create / increase loyalty to products / services and planning and management of communication and other interaction activities via social media platforms. The categories of personal data processed within the scope of these processes and the purposes and legal reasons for processing your personal data are explained in detail below.

Personal Data Category    Purposes of Processing Personal Data and Legal Reasons for Processing
Visual and Audio Data
Your personal data in this category is processed within the scope of personal data processing conditions (legal reasons) and for the following purposes: Conducting Audit / Ethics Activities Conducting Activities in Accordance with Legislation Following and Conducting Legal Affairs Conducting Internal Audit / Investigation / Intelligence Activities Conducting Customer Relationship Management Processes Conducting Activities Aimed at Customer Satisfaction Conducting Storage and Archive Activities Ensuring the Security of Data Controller Operations Authorized Providing Information to Persons, Institutions and Organizations Your personal data in this category is also processed within the scope of the explicit consent personal data processing requirement (legal reason) if it exists in accordance with the first paragraph of Article 5 of the KVKK and for the following purposes: Carrying out Loyalty Processes to Company / Products / Services Carrying out Communication Activities Carrying out Activities Aimed at Customer Satisfaction Carrying out Advertisement / Campaign / Promotion Processes Carrying out Storage and Archive Activities Carrying out Marketing Processes of Products / Services
Legal Transaction Data
Your personal data in this category is processed in accordance with the provisions of the second paragraph of Article 5 of the KVKK, in the event that it is mandatory for the data controller to fulfill its legal obligation, in accordance with the provisions of the (c) clause, data processing is mandatory for the establishment, exercise or protection of a right, in accordance with the provisions of the (e) clause, and in the event that data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person, in accordance with the provisions of the (f) clause. (reasons) and for the following purposes: Carrying out Information Security Processes Carrying out Audit / Ethics Activities Carrying out Activities in Accordance with the Legislation Following and Carrying out Legal Affairs Carrying out Internal Audit / Investigation / Intelligence Activities Carrying out Storage and Archive Activities Carrying out Contract Processes Providing Information to Authorized Persons, Institutions and Organizations
Communication Data
Your personal data in this category are processed in cases where (a) it is clearly foreseen in the laws of Article 5, paragraph 2 of the KVKK, (c) it is directly related to the establishment or execution of a contract, and the processing of personal data belonging to the parties to the contract is necessary, (ç) it is mandatory for the data controller to fulfill its legal obligation, (e) it is mandatory for the establishment, exercise or protection of a right, and (f) it is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person, and Your personal data in this category is also processed within the scope of the explicit consent personal data processing requirement (legal reason) and for the following purposes: Carrying out Information Security Processes Carrying out Audit / Ethics Activities Carrying out Activities in Accordance with the Legislation Following up and Carrying out Legal Affairs Carrying out Internal Audit / Investigation / Intelligence Activities Carrying out Communication Activities Carrying out / Auditing Business Activities Receiving and Evaluating Suggestions for the Improvement of Business Processes Carrying out Customer Relationship Management Processes Carrying out Activities for Customer Satisfaction Carrying out Storage and Archive Activities Carrying out Contract Processes Following up on Requests / Complaints Providing Information to Authorized Persons, Institutions and Organizations Your personal data in this category is also processed within the scope of the explicit consent personal data processing requirement (legal reason) and for the following purposes, if available in accordance with the first paragraph of Article 5 of the KVKK: Carrying out Loyalty Processes for the Company / Products / Services Carrying out Communication Activities Carrying out Customer Satisfaction Conducting Activities Organization and Event Management Conducting Marketing Analysis Studies Conducting Advertising / Campaign / Promotion Processes Conducting Marketing Processes of Products / Services

Transaction Security Data
Your personal data in this category is processed within the scope of personal data processing conditions (legal reasons) and for the following purposes: Conducting Information Security Processes Conducting Audit / Ethics Activities Conducting Activities in Accordance with Legislation Following and Conducting Legal Affairs Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities Conducting Customer Relationship Management Processes Conducting Customer Satisfaction Activities Carrying out storage and archive activities Carrying out contract processes Tracking requests/complaints Ensuring the security of data controller operations Providing information to authorized persons, institutions and organizations Your personal data in this category is also processed within the scope of the explicit consent personal data processing requirement (legal reason) in accordance with the first paragraph of Article 5 of the KVKK and for the following purposes: Carrying out processes of loyalty to companies/products/services Carrying out activities aimed at customer satisfaction Carrying out marketing analysis studies Carrying out advertising/campaign/promotion processes Carrying out storage and archive activities Carrying out marketing processes of products/services

Identity Data
Your personal data in this category is processed within the scope of personal data processing conditions (legal reasons) and for the following purposes: Conducting Information Security Processes Conducting Audit / Ethics Activities Conducting Activities in Accordance with Legislation Following and Conducting Legal Affairs Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities Conducting Business Activities Conducting / Auditing Business Processes Receiving Suggestions for the Improvement of Business Processes and Evaluation Conducting Customer Relationship Management Processes Conducting Activities Aimed at Customer Satisfaction Conducting Storage and Archive Activities Conducting Contract Processes Tracking Requests / Complaints Providing Information to Authorized Persons, Institutions and Organizations Your personal data in this category is also processed within the scope of the explicit consent personal data processing requirement (legal reason) in accordance with Article 5, paragraph 1 of the KVKK and for the following purposes: Conducting Loyalty Processes to Company / Products / Services Conducting Communication Activities Conducting Activities Aimed at Customer Satisfaction Organization and Event Management Conducting Marketing Analysis Studies Conducting Advertisement / Campaign / Promotion Processes Conducting Storage and Archive Activities Conducting Marketing Processes of Products / Services
Customer Transaction Data (Includes natural persons.)
Your personal data in this category is processed in accordance with Article 5, paragraph 2, subparagraph (c) of the KVKK in the context of the execution of a contract The personal data processing is carried out within the scope of the personal data processing conditions (legal reasons) and for the following purposes: Conducting Information Security Processes Conducting Audit / Ethics Activities Conducting Activities in Accordance with the Legislation Following and Executing Legal Affairs Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities Conducting / Auditing Business Activities Receiving and Evaluating Suggestions for the Improvement of Business Processes Conducting Customer Relationship Management Processes Conducting Activities for Customer Satisfaction Conducting Storage and Archive Activities Conducting Contract Processes Execution Tracking of Requests / Complaints Providing Information to Authorized Persons, Institutions and Organizations Your personal data in this category is also processed within the scope of the explicit consent personal data processing requirement (legal reason) in accordance with the first paragraph of Article 5 of the KVKK and for the following purposes: Execution of Loyalty Processes to the Company / Products / Services Execution of Communication Activities Execution of Activities Aimed at Customer Satisfaction Organization and Event Management Execution of Marketing Analysis Studies Execution of Advertising / Campaign / Promotion Processes Execution of Storage and Archive Activities Execution of Marketing Processes of Products / Services

Customer Transaction Data (Includes natural persons.)
Your personal data in this category is processed within the scope of personal data processing conditions (legal reasons) and for the following purposes: Conducting Information Security Processes Conducting Audit / Ethics Activities Conducting Activities in Accordance with Legislation Following and Conducting Legal Affairs Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities Conducting Business Activities Conducting / Auditing Business Processes Receiving and Evaluating Suggestions for Improvement Conducting Customer Relationship Management Processes Conducting Activities Aimed at Customer Satisfaction Conducting Storage and Archive Activities Conducting Contract Processes Following Up Requests/Complaints Providing Information to Authorized Persons, Institutions and Organizations Your personal data in this category is also processed within the scope of the explicit consent personal data processing requirement (legal reason) in accordance with Article 5, paragraph 1 of the KVKK and for the following purposes: Conducting Loyalty Processes to Company/Product/Services Conducting Communication Activities Conducting Activities Aimed at Customer Satisfaction Organization and Event Management Conducting Marketing Analysis Studies Conducting Advertisement/Campaign/Promotion Processes Conducting Storage and Archive Activities Conducting Marketing Processes of Products/Services
MarketingData
Your personal data in this category is processed in accordance with Article 5, paragraph 2, clause (ç) of the KVKK It is mandatory for the controller to fulfill his/her legal obligation, it is mandatory for the establishment, exercise or protection of a right in accordance with clause (e) and it is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person in accordance with clause (f). Personal data processing is processed within the scope of personal data processing conditions (legal reasons) and for the following purposes: Conducting Audit / Ethics Activities Conducting Activities in Accordance with the Legislation Following and Executing Legal Affairs Conducting Internal Audit / Investigation / Intelligence Activities Conducting Business Activities / Conducting Audit Storage and Archive Activities Conducting Contract Processes Providing Information to Authorized Persons, Institutions and Organizations Your personal data in this category is processed within the scope of the explicit consent personal data processing condition (legal reason) in accordance with the first paragraph of Article 5 of the KVKK and for the following purposes: Conducting Loyalty Processes to the Company / Products / Services Conducting Communication Activities Customer Satisfaction Carrying out activities related to the organization and event management, carrying out marketing analysis studies, carrying out advertising / campaign / promotion processes, carrying out storage and archive activities, carrying out marketing processes of products / services.

Request / Complaint Data
Your personal data in this category is processed within the scope of personal data processing conditions (legal reasons) and for the following purposes: Conducting Audit / Ethics Activities Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities Conducting / Auditing Business Activities Receiving and Evaluating Suggestions for the Improvement of Business Processes Conducting Customer Relations Management Processes Conducting Customer Satisfaction Activities Carrying Out Storage and Archive Activities Tracking Requests / Complaints Providing Information to Authorized Persons, Institutions and Organizations Your personal data in this category is also processed within the scope of the explicit consent personal data processing requirement (legal reason) if it exists in accordance with the first paragraph of Article 5 of the KVKK and for the following purposes: Carrying Out Loyalty Processes to Company / Products / Services Carrying Out Communication Activities Carrying Out Activities Oriented to Customer Satisfaction Carrying Out Storage and Archive Activities Carrying Out Marketing Analysis Studies
Finance Data (includes natural persons)
Your personal data in this category is processed within the scope of the personal data processing requirements (legal reason) if the data processing is mandatory for the establishment, exercise or protection of a right in accordance with the second paragraph of Article 5 of the KVKK and provided that it does not harm the fundamental rights and freedoms of the relevant person in accordance with the (f) clause, data processing is mandatory for the legitimate interests of the data controller. The following are processed: Conducting Information Security Processes Conducting Audit / Ethics Activities Following and Executing Legal Affairs Conducting Internal Audit / Investigation / Intelligence Activities Conducting / Auditing Business Activities Conducting Customer Relations Management Processes Conducting Storage and Archive Activities Following Requests / Complaints Providing Information to Authorized Persons, Institutions and Organizations Your personal data in this category is also processed within the scope of the explicit consent personal data processing requirement (legal reason) in accordance with the first paragraph of Article 5 of the KVKK and for the following purposes: Conducting Company / Product / Service Loyalty Processes Conducting Customer Satisfaction-Oriented Activities Organization and Event Management Conducting Advertising / Campaign / Promotion Processes Conducting Storage and Archive Activities Conducting Product / Service Marketing Processes