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PERSONAL DATA DISCLOSURE NOTICE FOR CUSTOMERS, MEMBERS, AND VISITORS

I. Data Controller

Pursuant to the Law on the Protection of Personal Data No. 6698 ("KVKK"), your personal data is processed by PAN DENİZ TAŞIMACILIĞI LOJİSTİK FAALİYETLERİ VE TURİZM LTD. ŞTİ. ("Company") as the data controller.

Address: Küçük Piyale Mahallesi, Yolcu Sokak, No:16 Beyoğlu / İstanbul

Website: www.simoom.com

Email: [email protected]

Protecting your personal data is one of our top priorities. Accordingly, this Disclosure Notice has been prepared to fulfill our obligation to inform you under Article 10 of the KVKK.

This Notice explains the procedures and principles applicable to the processing of personal data within the scope of services offered via www.simoom.com.

1. Legal Basis for Collecting Personal Data

Your personal data is processed in accordance with the Turkish Constitution, KVKK, Turkish Penal Code, and other applicable legislation. For customers who shop through the Website/Mobile App, data is also processed per the Law on the Regulation of Electronic Commerce No. 6563.

Your data may be processed based on the following legal grounds under Articles 5 and 6 of the KVKK:

Processing is necessary for the establishment or performance of a contract,

Processing is necessary for the Company to fulfill its legal obligations,

Processing is necessary for the establishment, exercise, or protection of a right,

Processing is necessary for the legitimate interests of the Company,

Explicit consent, where required.

2. Methods of Collecting Personal Data

Depending on the nature of the services and your interaction, personal data may be collected:

Through stores, customer service units, call centers

Website and mobile applications

Social media channels

Loyalty program applications

Written, verbal, or electronic communication

The Site uses cookies to improve service quality, provide personalized content, and fulfill legal obligations. Upon your first visit, information regarding cookies is provided through a pop-up notification.

You may disable or delete cookies via your browser settings or through platforms such as www.allaboutcookies.org and www.youronlinechoices.eu. However, disabling cookies may limit some Website/App functions.

The Company may record user activity within the Site to provide personalized experience and display relevant content.

3. Purposes of Processing Personal Data

Your personal data may be processed for the following purposes:

Operational Purposes

Verifying the identity of the transaction owner,

Recording contact information to enable communication,

Creating all contractual and legal documentation,

Executing sales contracts, distance sales contracts, invoicing obligations,

Ensuring customers can exercise their legal rights (withdrawal, return, etc.).

Marketing & Personalization (based on explicit consent)

Personalized advertising, campaigns, and benefits,

Segmenting users/members based on data,

Surveys, telesales, data analytics, user quality improvement,

Loyalty program management, cross-selling, and win-back actions.

Customer Relations

Evaluating complaints, feedback, and suggestions.

Security

Ensuring building, facility, and store security,

Monitoring operational safety.

Corporate Activities

Determining and implementing Company strategies,

Fulfilling obligations and exercising rights arising from the KVKK and other applicable laws.

Processed data categories include identity, contact, customer transaction, financial, security, marketing data, and cookie records.

4. How the Company Protects Your Personal Data

Your personal data is processed in compliance with KVKK principles:

Lawfulness and fairness

Accuracy and being kept up-to-date

Specific, explicit, and legitimate purposes

Limited and proportionate to the purpose

Retention for the period required by law or purpose of processing

Your data is stored under Company oversight and control. We take all technical and administrative measures necessary to ensure data confidentiality, integrity, and security.

5. Sharing Personal Data

Personal data is not shared with third parties without your explicit consent, unless legally required.

Data may be shared:

With courts, prosecutors, and public authorities when required by law,

With contracted service providers for quality control and service delivery,

With business partners, banks, payment institutions, logistics companies, marketing agencies, survey companies, and cloud providers (domestic or international) under Articles 8 and 9 of the KVKK,

With email/SMS service providers and card centers (e.g., Bankalararası Kart Merkezi) for operational needs.

The Company takes necessary precautions during data transfers, but cannot be held responsible for breaches occurring due to third-party systems' policies or risks under their control.

6. Your Rights Under KVKK

You have the following rights regarding your personal data:

a) To learn whether your data is processed,

b) To request information if processed,

c) To learn the purpose of processing and whether it is used accordingly,

d) To learn third parties to whom data is transferred domestically or abroad,

e) To request correction of incomplete/incorrect data,

f) To request deletion/destruction of data within Article 7,

g) To request notification of corrections/deletions to third parties,

h) To object to outcomes arising from automated data processing,

i) To request compensation for damages if data is processed unlawfully.

Requests will be answered within 30 days. If processing requires additional cost, a fee may be charged according to the tariff set by the Personal Data Protection Board.

You may submit your requests:

In writing,

Via notary,

Or from your registered email address to [email protected] .

You may also submit the KVKK request form via the Website and send it to:

Küçük Piyale Mahallesi, Yolcu Sokak, No:16 Beyoğlu / İstanbul

or through a notary.

7. Updates to the Personal Data Policy

Legal updates will be reflected in this Notice. You may always access the latest version on www.simoom.com.

8. Ensuring Data Accuracy and Updates

You are responsible for keeping your personal data accurate and up to date. Please notify us of any changes through the contact channels provided.

The Company reserves the right to update the Membership Agreement, Privacy Policy, and Personal Data Protection Policy at any time.

Contact

PAN DENİZ TAŞIMACILIĞI LOJİSTİK FAALİYETLERİ VE TURİZM LTD. ŞTİ.

Küçük Piyale Mahallesi, Yolcu Sokak, No:16 Beyoğlu / İstanbul

Email: [email protected]