CLARIFICATION TEXT ON THE PROCESSING AND PROTECTION OF PERSONAL DATA

This Clarification Text has been drafted by NOV Atelier (“Our Company”), acting in the capacity of data controller, in accordance with the Law No. 6698 on the Protection of Personal Data, in order to provide explanations and information regarding the processing of Personal Data belonging to our Company’s customers/users and all persons associated with our Company, including those who benefit from our products and services.

Purposes of Processing Personal Data

Within the scope of your legal relationship with our Company; Personal Data you have shared in accordance with the law and the purpose of the Law on the Protection of Personal Data and the processing purposes listed below may be processed by our Company. In this direction, carrying out the necessary work by the business units of our Company in order to benefit the Personal Data Owners from the products and services offered by our Company; Carrying out operations with our Company’s Business Partners and / or suppliers; Accessing the records of Personal Data Owners created by our Company in their subsequent shopping, similarity of name / surname with this data, etc. To ensure that customers benefit from general or personalised campaigns regarding the products and services subject to sale through the records created by our Company; to communicate campaigns related to the products and services offered to customers by mail, e-mail, SMS and telephone; to recommend and deliver the products and services offered to the Personal Data Owners by customising them according to the tastes, usage habits and needs of the Personal Data Owners; carrying out the necessary work to recommend and deliver catalogues and campaigns to the customers, taking into account the continuity and continuity of the customers’ use of our Company’s products and services; in the purchasing and after-sales processes of the products and services offered and in new purchases; modifying the purchased products and services in accordance with the needs and uses of the customers, meeting the complaints or review requests regarding the purchased products and services and informing the customers in this regard; carrying out one-to-one or integrated marketing activities, sales and after-sales operations and purchasing operations; Fulfilling the obligations and taking the necessary measures within the framework of occupational health and safety in order to carry out the human resources policies of our Company; in order to ensure the legal and commercial security of our Company and the persons who have a business relationship with our Company; carrying out and managing the administrative and legal transactions regarding the communication carried out by our Company and the activities to ensure the physical security and control of the locations of our Company and the financial affairs processes; Carrying out and managing internal system and application management operations, communication, market research and social responsibility activities, financial operations and product/project/manufacturing/investment quality processes by our Company for the purpose of determining and implementing the commercial and business strategies of our Company; planning and/or execution of customer relationship management processes, including the planning and/or execution of customer satisfaction activities; reaching customers by mail, e-mail and telephone in this direction; contacting Personal Data Owners who submit their requests and complaints to our Company and ensuring the follow-up and management of requests and complaints; limited to the purposes of creating and tracking visitor records. and processes Personal Data within the scope of the Personal Data processing conditions specified in Articles 5 and 6 of the Personal Data Protection Law.

To whom and for what purpose personal data can be transferred

8. and 9. of the Personal Data Protection Law Within the scope of the Personal Data transfer conditions specified in Articles 8 and 9 of the Personal Data Protection Law, to ensure the fulfilment of the establishment purposes of the business partnership established for purposes such as carrying out various projects and receiving services while our Company carries out its commercial activities; to carry out activities carried out within the scope of legislation, event management and corporate communication processes; to design strategies for commercial activities, to ensure management and supervision at the highest level; to modify the products in accordance with the needs and usage of the customers in line with their sales and after-sales demands; to notify the customers of the campaigns by mail, e-mail and/or telephone, to print and deliver the catalogues, and to transfer Personal Data to the Company’s Business Partners, Company Stakeholders, Company Officials and/or third parties/organisations to be determined by them. In addition, if requested by the relevant public institutions and organisations within their legal authority and if requested by the relevant private law persons within their legal authority in accordance with the provisions of the legislation; Our Company may transfer Personal Data to legally authorised Public Institutions and Organisations and legally authorised Private Law Persons and / or third parties / organisations to be determined by them.

In the event that the processing activity carried out for the aforementioned purposes does not meet any of the exceptions stipulated under the law, your explicit consent is obtained by our Company regarding the relevant processing process.

Method and Legal Grounds for Collecting Personal Data

Supervision of compliance with Article 1 of the Law on the Protection of Personal Data, Article 1 regulating the purpose of the Law and Article 2 regulating the scope of the Law, Articles 5 and 6 of the Law on the Protection of Personal Data. Articles 5 and 6 of the Law on the Protection of Personal Data and the Policy and in order to fulfil the responsibilities arising from the law in a complete and accurate manner within the framework of legislation, contract, request and optional legal reasons, Personal Data; It is collected by various means such as all kinds of verbal, written and electronic media, technical and other methods and / or electronic media via social media accounts that you allow our Company to access and processed by our Company or data processors assigned by the Company.

Rights of the Personal Data Owner Pursuant to the Law on the Protection of Personal Data

Pursuant to Article 10 of the Law on the Protection of Personal Data, our Company informs you of your rights as a Personal Data Owner; provides guidance on how to exercise such rights and carries out the necessary internal operation, administrative and technical arrangements for all these. Pursuant to Article 11 of the Law, our Company informs the persons whose Personal Data is received; to learn whether Personal Data has been processed, to request information if Personal Data has been processed, to learn the purpose of processing Personal Data and whether they are used in accordance with their purpose, to know the third parties to whom Personal Data is transferred domestically or abroad, to request correction of Personal Data in case of incomplete or incorrect processing, to request correction of Personal Data within the framework of the conditions stipulated in Article 7 of the Law on the Protection of Personal Data. To request the deletion or destruction of Personal Data within the framework of the conditions stipulated in Article 7 of the Law on the Protection of Personal Data, to request notification of the transactions made pursuant to subparagraphs (d) and (e) of Article 11 of the Law on the Protection of Personal Data to third parties to whom Personal Data is transferred, to object to the occurrence of a result to the detriment of the person himself/herself by analysing the processed data exclusively through automated systems, to demand the compensation of the damage in case of damage due to unlawful processing of Personal Data.

Personal Data Owners may submit their requests regarding their rights listed below to our Company free of charge by filling out and signing the Application Form in the Annex with the information and documents that will identify their identity and by the methods specified below or by other methods determined by the Personal Data Protection Board:

• Filling out the form and sending the wet signed copy to Şişli/ISTANBUL address by hand, through a notary public or by registered letter with return receipt,
• Signing the form with a secure electronic signature issued within the scope of the Electronic Signature Law No. 5070 and sending it by registered e-mail to info@novatelier.com,
• Following a method prescribed/to be prescribed by the Personal Data Protection Board.

In order for third parties to make an application request on behalf of Personal Data Owners, there must be a special power of attorney issued by the Personal Data Owner through a notary public on behalf of the person who will make the application.
Our Company will finalise the request free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, our Company reserves the right to charge a fee over the tariff determined by the Personal Data Protection Board.

ANNEX : Application Form

EXPLICIT CONSENT FORM FOR THE PROCESSING OF PERSONAL DATA

Tarafıma verilen Kişisel Verilerin İşlenmesi ve Korunmasına İlişkin Aydınlatma Metnini okudum. 6698 sayılı Kişisel Verilerin Korunması Kanunu hakkında bilgilendirildim, yasal haklarımı anladım ve bu şekilde alınan aşağıdaki rızamın geçerli olduğunu ve özgür irademe dayandığını kabul ediyorum.
Şirketinizin ürün ve hizmetlerinden faydalanmak ve bunlar hakkında bilgi almak üzere ilettiğim kişisel bilgilerimin ve Şirketiniz tarafından ilgili kişi ve kurumlardan sağlanacak kişisel bilgilerimin, ihtiyaçlarım doğrultusunda bana uygun ürün, uygulama, avantaj veya kampanyalardan yararlanabilmem, genel bilgilendirme yapılması ve tarafımla her türlü iletişimin sağlanması amacıyla işlenmesine ve bu doğrultuda kişisel bilgilerimin gerekli olması halinde Şirketiniz İş Ortakları, Şirketiniz Paydaşları, Şirketiniz Yetkilileri, Hukuken Yetkili Kılınan Kamu Kurum ve Kuruluşları, Hukuken Yetkili Özel Hukuk Kişileri ve/veya bunların belirleyeceği üçüncü kişiler/kuruluşlar ile paylaşılmasına ve dilediğim zaman reddetme hakkına sahip olduğumun bilinciyle Şirketiniz tarafından, doğrudan ya da SMS, MMS, telefon, faks, otomatik arama makineleri, elektronik posta ve benzeri iletişim kanallarından iletilecek veri, ses ve görüntü içerikli bilgilendirme, tanıtım ve pazarlama iletilerinin tarafıma gönderilmesine açık rızam ile tarafıma sms yoluyla iletilen kodu şirket çalışanına söylemek suretiyle elektronik olarak onay verdiğimi beyan ederim.

ELUCIDATION WORDING ON THE PROCESSING AND PROTECTION OF THE PERSONAL DATA

This public disclosure text is drawn up by NOV Atelier (“Our Corporation”) for the purpose of explicating and providing information for the customers/users of the Corporation and the entire individuals related to our Corporation including the ones benefiting from our products and services regarding the processing of the Personal Data, acting with the capacity of data supervisor in accordance with the Law on Protection of Personal Data No. 6698. You may access detailed information regarding the processing of your Personal Data disclosed by you to our Corporation on our website www.manuatelier.comand the Policy on the Processing and Protection of the Personal Data that you find in our Corporation’s Showroom.

PURPOSE OF PROCESSING OF PERSONAL DATA

In the context of your legal relation established with our Corporation; the Personal Data you disclosed shall be processed by our Corporation in accordance with the law and the Law on Protection of Personal Data and the processing purposes stated hereinafter. Accordingly, to be limited with the following purposes; our Corporation processes the Personal Data for the purpose of the performance of the endeavors by the business units of our Corporation that are required for the Personal Data Holders to benefit from the products and services offered by our Corporation; realization of operations with the Business Associates and/or suppliers of our Corporation; accessing to the records of the Personal Data Holders within our Corporation for the further shopping transactions, issuing invoice by automated means with this data by not giving rise to confusion due to reasons name/surname resemblance; ensuring that the customers benefit from the general or customized campaigns and offers related to the merchantable products and services by means of records generated within our Corporation; communicating the campaigns related to the products and services offered to the customers through mail, e-mail, SMS and phone calls; recommending and communicating our products and services to the Personal Data Holders upon customization thereof based on the appreciation, habit and pattern of use and requirements; performance of the required endeavors aiming for the catalogs and campaigns to the customers to be offered and communicated to the customers in consideration of the customers’ continuation and sustainability of using the products and services of our Corporation; amending and altering the products and services offered to be compliant with the requirements and uses of the customers both within the purchasing and the post-sales processes and for the new purchases of the products and services offered; responding to the complaints or requests for inspection related to the products and services purchased and notifying customers in this respect; execution and performance of one-to-one or integrated marketing operations, sales and post-sales operations and purchasing operations; fulfillment of the obligations within the scope of the occupational health and safety and taking the required precautions and measures for the purpose of execution and performance of the human resources policies of our Corporation; performance and steering the financial affair processes and activities for the purpose of ensuring the physical security and auditing of the locations of our Corporations along with the administrative and legal processes towards the communication executed by our Corporation; execution and management of the intracompany system and application management operations by our Corporation, communication, market survey and social responsibility activities and finance operations as well as the product/project/manufacturing/investment quality processes in line with the purpose of determination and implementation of the commercial and business strategies of our Corporation, planning and/or execution of the customer relationship management processes to include the planning and/or execution process of the customer satisfaction activities; contacting with the customers through mail, e-mail and phone calls accordingly; contacting with the Personal Data Holders communicating their requests and complaints to our Corporation and ensuring the following up and management of the requests and complaints; establishment and tracking of the visitor records within the scope of the terms and conditions of the Personal Data processing set forth in Article 5 and 6 of the Law on Protection of Personal Data.

RECIPIENTS AND GROUND OF PERSONAL DATA DISCLOSURE

Within the scope of the terms and conditions of the Personal Data set forth in Article 8 and 9 of the Law on Protection of Personal Data, our Corporation can transfer the Personal Data to the Corporation Business Associates, Corporation Stakeholders, Corporation Officials and/or the third parties/organizations to be designated thereof to serve the purposes of ensuring the establishment objectives of the business partnership established for the purposes such as execution and performance of miscellaneous projects and receiving services while sustaining the commercial operations of our Corporation; realization of the operations and activities performed within the scope of the regulation, effectiveness management and corporate communication processes; designing the strategies with respect to the commercial operations and ensuring the optimal management and supervision thereof; alteration and modification of the products based on the requirements and use of customers upon their requests communicated during the sales and post-sales process; notifying the customers regarding the campaigns by means of mail, e-mail and/or phone calls and printing and deliverance of the catalogs. Furthermore, upon required by the relevant public institutions and organizations within the scope of their legal authorities and by the relevant private legal entities within the scope of their legal authorities in accordance with the provisions of the legislation, our Corporation is entitled to transfer and disclose the Public Institutions and Organizations that are legally authorized and Private Legal Entities and/or third parties/organizations designated by those that are legally authorized.
In the event that the process activity realized for the above-cited purposes fails to fulfil any of the exemptions and exceptions anticipated within the scope of Law, your expressed consent shall be sought by our Corporation related to the relevant process.

METHODS OF PERSONAL DATA COLLECTION AND LEGAL GROUNDS

For the purpose of auditing and supervision of the compliance of the Law on Protection of Personal Data with the Article 1 regulating the purpose of the Law and Article 2 regulating the scope of the Law, realization of the objectives set forth in the Article 5 and 6 of the Law on Protection of Personal Data and the Policy and accurately and complete fulfilment of the obligations arising from the law within the frame of the legal grounds based on legislation, agreement, claim and request, the Personal Data are collected through various means such as on sorts of verbal, printed and electronic media through technical and other methods and/or social media accounts that you authorize to be accessed by our Corporation and processed by our Corporation or data processors appointed by our Corporation.

RIGHTS OF THE PERSONAL DATA HOLDERS PURSUANT TO THE LAW ON PROTECTION OF PERSONAL DATA

Our Corporation, in accordance with the Article 10 of the Law on Protection of Personal Data, informs you, regarding your rights as the Personal Data Holders, provides guidance how the said rights are exercised and realizes the internal mechanism, administrative and technical regulations required for all those. Our Corporation, in accordance with Article 11 of the Law, informs the individuals with their Personal Data collected, regarding finding out whether the Personal Data is processed, requesting information in this regard in the event that their Personal Data was processed, eliciting the purpose of Personal Data processing and whether it is used as intended, knowing the third party recipients of the Personal Data both inland and outland, requesting for the correction in case of inaccurate or flawed processing of the Personal Data, requesting for the deletion or destruction of the Personal Data within the scope of the requirements set forth in Article 7 of the as Law on Protection of Personal Data, requesting for the notification of the processes performed in accordance with paragraph (d) and (e) of Article 11 of the Law on Protection of Personal Data to the third parties that are the recipient of the Personal Data, raising objection to an outcome to be revealed against that particular person by means of analyzing the data processed through exclusive automated systems, claiming for damages to be compensated in the case of sustaining damages due to processing of the Personal Data in breach of the Law.
The Personal Data Holders are entitled to communicate their requests related to their above-cited rights by completing the Application Form enclosed on APPENDIX and delivering to our Corporation free of charge along with the information and the documents for identity purposes by means of the methods hereinafter or other methods stated by the Board of Personal Data Protection:

• Deliverance of the copy of the form upon completion bearing wet signature through notary public or registered letter with return receipt to Şişli/İSTANBUL.
• Deliverance of the form bearing secure electronic signature within the scope of Electronic Signature Law No. 5070 to info@novatelier.com  by means of registered e-mail.
• Through any other method anticipated/to be anticipated by the Board of Personal Data Protection.

In order for the third parties to request for application on behalf of the Personal Data Holders, Special Power of Attorney is required to be issued by the Personal Data Holder through the notary public empowering the entity to file the application.
Our Corporation shall finalize the request as earliest as possible based on the nature of the request and no later than 30 (thirty) days without applying any charges. However, in case the process requires an additional cost, our Corporation is entitled to request for a fee to be calculated based on the tariff set forth by the Board of Personal Data Protection.

APPENDIX : APPLICATION FORM

FORM OF EXPRESS CONSENT ON PERSONAL DATA PROCESSING

I have read the elucidation wording on the Processing and Protection of the Personal Data provided to me. I have further been informed on the Law on Personal Data Protection, comprehended by legal rights and I hereby agree and acknowledge that the following consent of mine obtained in this regard is valid and based on my freewill.
I hereby grant my approval with my express and written consent for my personal data that I have disclosed to benefit from the products and services of your Corporation and be informed on such and my personal data to be acquired by your Corporation from the relevant real and legal entities to be processed to allow me to benefit from the products, applications, advantages or campaigns that are convenient for me in line with my requirements and for the purposes of general information and ensuring all sorts of communications to be established with me and to be disclosed to the Business Associates of your Corporation, Stakeholders of your Corporation, Officials of your Corporation, legally authorized Public Institutions and Organizations, legally authorized Private Legal Entities and/or third parties/organizations to be designated by such in the event that my Personal Data is required and the deliverance of information, promotional and marketing communications and messages with data, audio and image content to be directly transmitted or through SMS, MMS, telephone, fax, dialer devices, electronic mail and similar communication channels by your Corporation with the awareness that I am entitled to reject such at any time.

Personal Data Holder
Name & Surname:
Date:
Signature