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HAVLOO TEKNOLOJİ ARAŞTIRMA GELİŞTİRME ANONİM ŞİRKETİ COOKIE AND OTHER TRACKING TECHNOLOGIES DISCLOSURE STATEMENT

Information Notice on Cookies and Other Tracking Technologies**

Havloo Teknoloji Araştırma Geliştirme Anonim Şirketi (“Havloo Technology” or the “Company”) uses cookies and other online identification technologies (such as pixels, web beacons, GIFs, etc.) (collectively referred to as “Cookies”) in order to provide you with the best possible shopping experience.

Cookies are small text files placed on your computer, smartphone and/or tablet and stored by your browser. Even if Cookies are pseudonymous or do not directly identify an individual, they may be considered personal data where they enable an individual to be identifiable when combined with other information.

Our Company respects your privacy and your rights regarding the protection of your personal data and works to establish and maintain a trust-based relationship with you. Within this scope, we process your personal data, including Cookies, in compliance with all applicable data protection legislation, primarily the Turkish Personal Data Protection Law No. 6698 (“KVKK”), ensure that your data is stored securely, and implement all necessary technical and administrative safeguards against unlawful access.

Through this Information Notice on Cookies and Other Tracking Technologies (“Notice”), we aim to inform you transparently and in detail about the processing of your Cookie data.

Data Controller

Your personal data is processed by Havloo Teknoloji Araştırma Geliştirme Anonim Şirketi, registered with the Istanbul Trade Registry under registration number 1100853, with its registered office located at Göktürk Merkez Mah. Çamlık Cad. No: 36/1A Eyüpsultan / Istanbul, acting as the data controller within the scope of this Notice.

Categories of Personal Data Processed, Purposes of Processing and Legal Grounds

The following data may be processed:

  • Visitor identity information

  • Referrer information (the website you came from)

  • Date and time of visit

  • Regional settings and language preferences

  • Device operating system

  • Browser and browser version

  • IP address

  • Pages viewed / links clicked

  • Time spent on pages

  • Device type

  • Geolocation data

  • Search keywords

  • Mouse movements and behavioral analytics

Your personal data is processed within the scope of:

1. Transaction Security Data (Strictly Necessary Cookies)

Processed based on the legal grounds set forth under Article 5/2 of the PDPL (legal obligation and legitimate interest) for purposes such as:

  • Conducting information security processes

  • Performing audit and ethical compliance activities

  • Ensuring compliance with legislation

  • Legal follow-up and management

  • Internal audit and investigation activities

  • Archiving and retention processes

  • Ensuring operational security

  • Providing information to authorized public authorities

2. Marketing Data

Processed based on your explicit consent pursuant to Article 5/1 of the PDPLfor purposes such as:

  • Customer loyalty activities

  • Customer satisfaction processes

  • Marketing analysis

  • Advertising, campaigns, promotions

  • Marketing of products and services

Additionally, where required by law or legitimate interest, such data may also be processed for legal compliance, security, audit, and operational purposes.

Methods of Collecting Personal Data

Your personal data is collected fully or partially through automated means via:

  • Our websites

  • Browsers

  • Third-party advertising partners

  • Social media platforms

  • Other electronic channels that may be added in the future

Cookies and Their Purposes of Use

Both first-party Cookies (placed by our website) and third-party Cookies (placed by service providers or business partners) are used.

Strictly Necessary Cookies

Enable core website functionality such as page navigation and access to secure areas. These Cookies cannot be disabled.

Functional Cookies

Allow personalization and improved user experience (e.g., remembering language or region preferences). Used only with your explicit consent.

Analytics Cookies

Help us analyze website performance and traffic to improve services and user experience. Used with your consent.

Marketing / Targeting Cookies

Used to track visitor behavior and deliver personalized advertisements and marketing content. May be placed by our business partners such as search engines, social media platforms, and digital advertising providers. Used only with your explicit consent.

For details regarding third-party processing activities, please review the relevant third parties’ privacy or cookie policies.

Managing Your Cookie Preferences

Except for strictly necessary Cookies, Cookies are only activated with your consent through the Cookie Preference Panel.

You may:

  • Accept all Cookies

  • Customize preferences

  • Withdraw consent at any time

Most browsers also allow you to block or delete Cookies directly through browser settings.

Disabling Cookies may result in certain parts of our website not functioning properly.

You may also use third-party tools such as Ghostery, AdBlock, or similar software to manage tracking technologies.

Push Notifications

Push notifications are not sent unless you provide explicit consent. If enabled, related transaction security data is processed solely to deliver notifications about campaigns and updates. You may disable notifications at any time through your browser settings.

Transfer of Personal Data

Your personal data may be shared domestically or internationally, in compliance with Articles 8 and 9 of the PDPL, where legally permitted, with:

  • Suppliers and service providers

  • Business partners (advertising and marketing platforms)

  • Group companies and shareholders

  • Authorized public institutions and authorities

Transfers are limited to the purposes stated in this Notice.

Your Rights Under the PDPL

Pursuant to Article 11 of the PDPL, you have the right to:

  • Learn whether your personal data is processed

  • Request information regarding processing

  • Learn the purposes of processing

  • Know third parties to whom data is transferred

  • Request correction of inaccurate or incomplete data

  • Request deletion or destruction where legal grounds cease

  • Object to automated decision-making

  • Claim compensation for unlawful processing

You may submit your requests regarding the rights listed above in accordance with the provisions of the Communiqué on the Principles and Procedures for Application to the Data Controller, either in writing or electronically via registered electronic mail (KEP), secure electronic signature, mobile signature, or the email address previously notified to our Company and registered in our systems.

In order for our Company to verify your identity and confirm that you are the rightful data subject, your application must be submitted together with information and/or documents verifying your identity (such as your Turkish ID number, or passport number for foreign nationals, residential or business address for notification, mobile phone/telephone/fax number, and email address, etc.) by completing the Data Subject Application Form available through the relevant channels or by using the communication methods specified in the Application Form.

Depending on the nature of your request, your application will be finalized as soon as possible and no later than thirty (30) days, free of charge. However, if the process requires additional costs, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.

  • Please note that your application documents should not include any special categories of personal data (e.g., information relating to religion or blood type).