Annalisa Diamond

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UNDER PERSONAL DATA PROTECTION LAW NO. 6698 (KVKK)

COOKIE PRIVACY NOTICE

This Privacy Notice has been prepared by ÖZKAN KIYMETLİ MADENLER VE KUYUMCULUK ANONİM ŞİRKETİ, based at Levent Mah. Begonya Sk. No: 2, Interior Door No: 1, Beşiktaş / Istanbul, Türkiye, as data controller under Personal Data Protection Law No. 6698 (KVKK), about the processing of personal data obtained through cookies and to fulfil its obligation to inform you about its use of cookies under the KVKK and other applicable legislation. Our personal data protection policies are available on our website.

A. TYPES OF COOKIES

We use cookies to help you make the most of our services at https://annalisadiamond.com and to improve your user experience. Cookies are small text files stored on your device or a network server through your browser by websites you visit.

Types of cookies by duration: Session cookies are used to maintain the continuity of a session and are deleted when you close your browser. Persistent cookies are not deleted when the browser closes; they are deleted automatically on a specified date or after a specified period. Accordingly, our website uses both session and persistent cookies.

First-party and third-party cookies: First-party cookies are placed directly by the website you visit. Third-party cookies are placed by a domain other than the website address you visit. Accordingly, our website uses both first-party and third-party cookies.

Types of cookies by purpose: Depending on their purpose, cookies are used for strictly necessary, functional, performance/analytics or advertising/marketing purposes.

B. METHODS OF COLLECTING PERSONAL DATA AND LEGAL GROUNDS

When you first visit the website, a pop-up informs you about the cookies used to collect browsing information. Strictly necessary and functional cookies are used without explicit consent on the legal ground of the data controller's legitimate interests under Article 5(2)(f) of the KVKK, as they are necessary for the website to function. Performance/analytics and advertising/marketing cookies are activated only if you give explicit consent through the cookie management panel. You may withdraw your consent at any time through the same panel.

C. COOKIES USED ON OUR WEBSITE, PURPOSES OF PROCESSING AND LEGAL GROUNDS

Processing is defined in Article 3 of the KVKK as recording, storing, retaining, altering, rearranging, disclosing, transferring, taking over, making available and classifying personal data. The cookies used at https://annalisadiamond.com, their processing purposes and the legal grounds for processing are set out below.

A technical review of the live site found that, before a cookie preference was submitted, a PostHog configuration cookie and PostHog browser storage entries were created alongside strictly necessary and functional entries. After all cookies were accepted, Google Analytics, Google Ads and Meta Pixel entries were added. “Before acceptance” and “After acceptance” below describe this observed state.

Cookie name	Provider	Duration	Type	Purpose of processing	Legal ground
Ticimax_Member_Data	Ticimax (first party)	Session	Strictly necessary / Before acceptance	Storing membership data and operating membership functions.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
SERVERID	Ticimax (first party)	Session	Strictly necessary / Before acceptance	Managing the server session identifier.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
TcmxSID	Ticimax (first party)	Session	Strictly necessary / Before acceptance	Keeping the visitor's technical session identifier and maintaining session continuity.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
Ticimax_Cart_SessionID	Ticimax (first party)	1 month	Strictly necessary / Before acceptance	Storing the cart session identifier and linking cart information to the user's session.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
lastVisitInfo	Ticimax (first party)	Session	Strictly necessary / Before acceptance	Retaining previous visit information to provide website functions.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ticimax-Cart-ProductNotice	Ticimax (first party)	Session	Strictly necessary / Before acceptance	Displaying notices and messages about products added to the cart.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
__cf_bm	Cloudflare (third party)	30 minutes	Strictly necessary / Security / Before acceptance	Detecting malicious or automated bot traffic and ensuring website security.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject; no current legal basis for transfer abroad has been identified.
CultureSettings	Ticimax (first party)	Session	Functional / Before acceptance	Remembering language, country or regional display preferences.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
__RequestVerificationToken	Ticimax (first party)	Session	Functional / Before acceptance	Storing a verification token for security purposes.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
TicimaxReferer	Ticimax (first party)	7 days	Functional / Before acceptance	Retaining referral/source information.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
SonZiyaretEdilenUrunler	Ticimax (first party)	7 days	Functional / Before acceptance	Remembering recently viewed products.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ticimax_PopupSettings	Ticimax (first party)	30 days	Functional / Before acceptance	Remembering pop-up display status and technical preferences.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ticimax-UrunVaryasyon	Ticimax (first party)	Session	Functional / Before acceptance	Displaying selected product variations on product pages.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ticimax-HeaderCart	Ticimax (first party)	Session	Functional / Before acceptance	Operating the shopping cart component in the header.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ticimax-HeaderDesignCart	Ticimax (first party)	Session	Functional / Before acceptance	Preserving the design and display state of the cart component in the header.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ticimax-urunItem	Ticimax (first party)	Session	Functional / Before acceptance	Operating product cards and product display components.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ticimax-Cart-RightSideV3	Ticimax (first party)	Session	Functional / Before acceptance	Operating the cart panel displayed on the right.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ticimax-headerMemberContentV2	Ticimax (first party)	Session	Functional / Before acceptance	Displaying the membership and account section correctly.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ticimax-Cart-Top	Ticimax (first party)	Session	Functional / Before acceptance	Operating the cart components in the header.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
_ga	Google LLC (Google Analytics)	13 months (approximately 400 days)	Performance / Analytics / After acceptance	Distinguishing visitors, measuring visits and sessions, and compiling statistics on website use.	KVKK Article 5(1) – Explicit consent. For transfers abroad, KVKK Article 9(4)(c) – the Standard Contract published by the Board (signed with Google LLC).
_ga_*	Google LLC (Google Analytics)	13 months (approximately 400 days)	Performance / Analytics / After acceptance	Maintaining session state and measuring page views and website use.	KVKK Article 5(1) – Explicit consent. For transfers abroad, KVKK Article 9(4)(c) – the Standard Contract published by the Board (signed with Google LLC).
postHogApi	PostHog (third party)	30 minutes	Performance / Analytics / Before acceptance	Measuring and analysing visitor behaviour and interactions.	KVKK Article 5(1) – Explicit consent; no current legal basis for transfer abroad has been identified.
ph_phc_… _posthog	PostHog (third party)	Browser storage; until deleted by the user	Performance / Analytics / Before acceptance	Distinguishing visitors and sessions; analysing usage and interaction data.	KVKK Article 5(1) – Explicit consent; no current legal basis for transfer abroad has been identified.
ph_phc_… _primary_window	PostHog (third party)	Session	Performance / Analytics / Before acceptance	Identifying the primary browser window/tab.	KVKK Article 5(1) – Explicit consent; no current legal basis for transfer abroad has been identified.
ph_phc_… _window_id	PostHog (third party)	Session	Performance / Analytics / Before acceptance	Identifying the current browser window/tab.	KVKK Article 5(1) – Explicit consent; no current legal basis for transfer abroad has been identified.
_fbp	Meta Platforms (Meta Pixel)	3 months	Advertising / Marketing / After acceptance	Measuring visits and user interactions, and tracking advertising performance and conversions.	KVKK Article 5(1) – Explicit consent; no current legal basis for transfer abroad has been identified.
lastExternalReferrerTime	Meta Platforms (Meta Pixel)	Browser storage; until deleted by the user	Advertising / Marketing / After acceptance	Retaining the time at which the user arrived from an external source for advertising measurement.	KVKK Article 5(1) – Explicit consent; no current legal basis for transfer abroad has been identified.
lastExternalReferrer	Meta Platforms (Meta Pixel)	Browser storage; until deleted by the user	Advertising / Marketing / After acceptance	Retaining information about the external source from which the user arrived for advertising measurement.	KVKK Article 5(1) – Explicit consent; no current legal basis for transfer abroad has been identified.
cc_cookie	Annalisa Diamond (first party)	6 months	Strictly necessary / After acceptance	Recording the cookie preference, its scope and its time.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
meta-consent-active	Annalisa Diamond (first party)	Session	Strictly necessary / After acceptance	Recording that the cookie preference given for Meta Pixel has been technically activated.	KVKK Article 5(2)(f) – Processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
_gcl_au	Google LLC (Google Ads)	3 months	Advertising / Marketing / After acceptance	Measuring advertising conversions and assessing advertising performance.	KVKK Article 5(1) – Explicit consent; the legal basis for transfer abroad must be confirmed.
test_cookie	Google LLC (DoubleClick)	15 minutes	Advertising / Marketing / After acceptance	Checking whether the browser supports cookies.	KVKK Article 5(1) – Explicit consent; the legal basis for transfer abroad must be confirmed.

D. PURPOSES OF TRANSFERRING PERSONAL DATA AND RECIPIENTS

We process your personal data in accordance with the “need to know” and “need to use” principles, applying the necessary data minimisation and technical and administrative security measures.

Your personal data may be shared with authorised persons, institutions and organisations to provide information where processing is necessary for the data controller to fulfil a legal obligation under KVKK Article 5(2)(ç); and with authorised lawyers and judicial and administrative courts to pursue and conduct legal matters where processing is necessary for the establishment, exercise or protection of a right under KVKK Article 5(2)(e).

We use Ticimax and the Cloudflare services required by Ticimax to operate the website infrastructure. Google LLC, PostHog and Meta Platforms services are used for measurement and advertising activities. No current legal basis for the transfers abroad to Cloudflare, PostHog or Meta Platforms, other than Google LLC, has been identified.

The transfer abroad to Google LLC is carried out through the signing of the Standard Contract published by the Personal Data Protection Board and its notification to the Personal Data Protection Authority under KVKK Article 9(4)(c). If website visitors are signed in to their Google accounts and have granted the necessary permissions, device and behavioural information collected through Google Analytics measurement tools used on our website for statistical reporting may be matched by Google LLC with personal data in its records and used for reporting purposes.

E. DATA SUBJECT RIGHTS AND HOW TO EXERCISE THEM

Under Article 11 of Law No. 6698, everyone has the right to apply to our Company as data controller. Pursuant to Article 13(1) of the KVKK and the Communiqué on the Procedures and Principles of Application to the Data Controller published in Official Gazette No. 30356 of 10 March 2018, applications must be submitted to us by one of the following methods.

In writing;

With a secure electronic signature;

Via a registered electronic mail (KEP) address;

With a mobile signature;

From an email address previously notified to the data controller by the data subject and registered in the data controller's system;

Applications must include the following:

Name, surname and signature if the application is made in writing;

For citizens of the Republic of Türkiye, Turkish identity number; for foreigners, nationality, passport number or identity number, if any;

Residential or workplace address for service of notices;

Email address, telephone and fax number for notifications, if any;

The subject of the request.

Supporting information and documents, if any, should be attached to the application. For written applications, the application date is the date the document is served on the data controller or its representative; for other methods, it is the date the application reaches the data controller. Applications will be concluded free of charge as soon as possible and within no more than 30 days, depending on the nature of the request. If the procedure entails an additional cost, the fee in the tariff set by the Board may be charged.

CONTACT INFORMATION

Data controller: ÖZKAN KIYMETLİ MADENLER VE KUYUMCULUK ANONİM ŞİRKETİ

Address: Levent Mah. Begonya Sk. No: 2, Interior Door No: 1, Beşiktaş / Istanbul, Türkiye

Email: [email protected]

Telephone: +90 212 812 92 45

Website: https://annalisadiamond.com

Registry details: MERSİS No. 0698100991400001 | Trade Registry No. 1125097 | Tax Office / No. Beşiktaş / 6981009914

UNDER PERSONAL DATA PROTECTION LAW NO. 6698 (KVKK)

DATA SUBJECT APPLICATION PRIVACY NOTICE

METHOD OF COLLECTING PERSONAL DATA

Your personal data is obtained from you through an application form, email, registered electronic mail (KEP) or a written application. The personal data obtained is processed, within the scope of this Privacy Notice, wholly or partly by automated means or by non-automated means provided that the processing forms part of a data filing system.

PURPOSES OF PROCESSING PERSONAL DATA AND LEGAL GROUNDS

Article 3 of the KVKK defines processing of personal data as recording, storing, retaining, altering, rearranging, disclosing, transferring, taking over, making available and classifying operations. The personal data we process as data controller, the purposes of processing and the legal grounds relied on are shown in the table below.

Legal ground	Data category	Personal data	Purpose of processing
KVKK Article 5(2)(ç) – Processing is necessary for the data controller to fulfil a legal obligation.	Legal matters	Application date; subject of the request and attached documents; information about the relationship with the data controller; preferred response method; relevant department information	Conducting activities in compliance with legislation; tracking requests/complaints; carrying out retention and archiving activities; providing information to authorised persons, institutions and organisations
KVKK Article 9(4)(c) – Existence of a Standard Contract published by the Board.	Legal matters	Application date; subject of the request and attached documents; information about the relationship with the data controller; preferred response method; relevant department information	Conducting communications
KVKK Article 5(2)(ç) – Processing is necessary for the data controller to fulfil a legal obligation.	Identity	Name and surname; Turkish identity number/passport number; identity and power-of-attorney details of a representative; signature/electronic signature	Conducting activities in compliance with legislation; tracking requests/complaints; carrying out retention and archiving activities; providing information to authorised persons, institutions and organisations
KVKK Article 9(4)(c) – Existence of a Standard Contract published by the Board.	Identity	Name and surname; Turkish identity number/passport number; identity and power-of-attorney details of a representative; signature/electronic signature	Conducting communications
KVKK Article 5(2)(ç) – Processing is necessary for the data controller to fulfil a legal obligation.	Employment	Job application date/years of employment	Tracking requests/complaints; carrying out retention and archiving activities; providing information to authorised persons, institutions and organisations
KVKK Article 9(4)(c) – Existence of a Standard Contract published by the Board.	Employment	Job application date/years of employment	Conducting communications
KVKK Article 5(2)(a) – Processing is expressly provided for by law.	Contact	Email or KEP address; address for service of notices; telephone number	Conducting activities in compliance with legislation
KVKK Article 5(2)(ç) – Processing is necessary for the data controller to fulfil a legal obligation.	Contact	Email or KEP address; address for service of notices; telephone number	Tracking requests/complaints; carrying out retention and archiving activities; providing information to authorised persons, institutions and organisations
KVKK Article 9(4)(c) – Existence of a Standard Contract published by the Board.	Contact	Email or KEP address; address for service of notices; telephone number	Conducting communications
KVKK Article 5(2)(e) – Processing is necessary for the establishment, exercise or protection of a right.	Legal matters	Application date; subject of the request and attached documents; information about the relationship with the data controller; preferred response method; relevant department information	Pursuing and conducting legal matters
KVKK Article 5(2)(e) – Processing is necessary for the establishment, exercise or protection of a right.	Identity	Name and surname; Turkish identity number/passport number; identity and power-of-attorney details of a representative; signature/electronic signature	Pursuing and conducting legal matters
KVKK Article 5(2)(e) – Processing is necessary for the establishment, exercise or protection of a right.	Employment	Job application date/years of employment	Pursuing and conducting legal matters
KVKK Article 5(2)(e) – Processing is necessary for the establishment, exercise or protection of a right.	Contact	Email or KEP address; address for service of notices; telephone number	Pursuing and conducting legal matters

PURPOSES OF TRANSFERRING PERSONAL DATA AND RECIPIENTS

We process your personal data on a “need to know” and “need to use” basis, applying the necessary data minimisation and technical and administrative security measures. Your personal data will be processed within the conditions and purposes of processing under the KVKK and transferred to the third parties specified below in the circumstances stated.

Recipient / Recipient groups	Reason for transfer	Data transferred
Google LLC – Google Workspace (abroad)	Services obtained from a data processor to operate the corporate email and office infrastructure	Legal matters (application date); Legal matters (subject of the request and attached documents); Legal matters (information about the relationship with the data controller); Legal matters (preferred response method); Legal matters (relevant department information); Identity (name and surname); Identity (Turkish identity number/passport number); Identity (representative's identity and power-of-attorney details); Identity (signature/electronic signature); Employment (job application date/years of employment); Contact (email or KEP address); Contact (address for service of notices); Contact (telephone number)
Personal Data Protection Authority	Providing information to authorised persons, institutions and organisations	Legal matters (application date); Legal matters (subject of the request and attached documents); Legal matters (information about the relationship with the data controller); Legal matters (preferred response method); Legal matters (relevant department information); Identity (name and surname); Identity (Turkish identity number/passport number); Identity (representative's identity and power-of-attorney details); Identity (signature/electronic signature); Employment (job application date/years of employment); Contact (email or KEP address); Contact (address for service of notices); Contact (telephone number)
Lawyers; judicial and administrative courts	Pursuing and conducting legal matters	Legal matters (application date); Legal matters (subject of the request and attached documents); Legal matters (information about the relationship with the data controller); Legal matters (preferred response method); Legal matters (relevant department information); Identity (name and surname); Identity (Turkish identity number/passport number); Identity (representative's identity and power-of-attorney details); Identity (signature/electronic signature); Employment (job application date/years of employment); Contact (email or KEP address); Contact (address for service of notices); Contact (telephone number)

Because our corporate email and office infrastructure is operated through Google LLC (Google Workspace), your personal data is transferred abroad. This transfer is made under the Standard Contract published by the Personal Data Protection Board, signed with Google LLC and notified to the Authority, pursuant to KVKK Article 9(4)(c) for transfers to countries without an adequacy decision.

DATA SUBJECT RIGHTS AND HOW TO EXERCISE THEM

Under Article 11 of Law No. 6698, everyone has the right to apply to our Company as data controller regarding the following matters:

a) To learn whether personal data is being processed;

b) To request information if their personal data has been processed;

c) To learn the purpose of processing and whether the data is used in accordance with that purpose;

ç) To know the third parties to whom personal data has been transferred in Türkiye or abroad;

d) To request correction of incomplete or inaccurate personal data;

e) To request deletion or destruction of personal data under the conditions set out in Article 7 of Law No. 6698;

f) To request notification of the actions taken under items (d) and (e) to third parties to whom personal data has been transferred;

g) To object to a result against them arising from analysis of processed data exclusively by automated systems;

ğ) To claim compensation for damage resulting from unlawful processing of personal data.

Applications to exercise the rights listed above must be submitted by one of the following methods in accordance with applicable legislation.

In writing;

With a secure electronic signature;

Via a registered electronic mail (KEP) address;

With a mobile signature;

By sending an email from the address registered in the data controller's system.

Applications must include the following:

Name, surname and signature if the application is made in writing;

For citizens of the Republic of Türkiye, Turkish identity number; for foreigners, nationality, passport number or identity number, if any;

Residential or workplace address for service of notices;

Email address, telephone and fax number for notifications, if any;

The subject of the request.

Supporting information and documents, if any, should be attached to the application. Applications will be concluded free of charge as soon as possible and within no more than 30 days, depending on the nature of the request. If the procedure entails an additional cost, the fee in the tariff set by the Board may be charged.

CONTACT INFORMATION

Data controller: ÖZKAN KIYMETLİ MADENLER VE KUYUMCULUK ANONİM ŞİRKETİ

Address: Levent Mah. Begonya Sk. No: 2, Interior Door No: 1, Beşiktaş / Istanbul, Türkiye

Email: [email protected]

Telephone: +90 212 812 92 45

Website: https://annalisadiamond.com

Registry details: MERSİS No. 0698100991400001 | Trade Registry No. 1125097 | Tax Office / No. Beşiktaş / 6981009914

UNDER PERSONAL DATA PROTECTION LAW NO. 6698 (KVKK)

NEWSLETTER SUBSCRIBER EXPLICIT CONSENT TEXT

Data controller	ÖZKAN KIYMETLİ MADENLER VE KUYUMCULUK ANONİM ŞİRKETİ
Address	Levent Mah. Begonya Sk. No: 2, Interior Door No: 1, Beşiktaş / Istanbul, Türkiye
Website	annalisadiamond.com
Contact	[email protected]
MERSİS No.	0698100991400001
Trade Registry No.	1125097
Tax Office / No.	Beşiktaş / 6981009914
Telephone	+90 212 812 92 45

1. General Information

This text is presented to obtain your freely given, specific and informed explicit consent regarding personal data processed in your capacity as a newsletter subscriber under Personal Data Protection Law No. 6698. Other personal data processed in connection with your newsletter registration is based on legal grounds other than explicit consent and is outside the scope of this text. Your explicit consent is requested only for the processing activities shown below.

2. Personal Data and Processing Purposes Based on Explicit Consent

Legal basis	Data category	Personal data	Purpose of processing
KVKK Article 5(1) – The data subject's explicit consent.	Contact	Email address, telephone number	Conducting advertising/campaign/promotion activities
KVKK Article 5(1) – The data subject's explicit consent.	Contact	Email address, telephone number	Conducting communications

By approving this text, you give your explicit consent to the processing of your data within the scope set out above. Your consent is obtained through an unticked checkbox on the website.

The processing of this data is not necessary for your newsletter registration. If you do not give explicit consent, your newsletter registration and the services provided to you will not be affected.

3. Sending Commercial Electronic Messages

If you consent to the processing of your email address and telephone number for sending commercial electronic messages, your consent, together with your chosen channel, will be recorded in the Message Management System (İYS) under Law No. 6563 on the Regulation of Electronic Commerce. You may view and withdraw your consent at iys.org.tr. You may opt out of commercial electronic messages at any time, free of charge, through the unsubscribe link in each message, through İYS or through the contact channels below. Your opt-out request will be implemented within three business days.

4. Transfer Abroad

Because the corporate email and office infrastructure is operated through Google LLC (Google Workspace), the data listed above is transferred abroad. The transfer is made under the Standard Contract published by the Personal Data Protection Board, signed with Google LLC and notified to the Authority, pursuant to KVKK Article 9(4)(c) for transfers to countries without an adequacy decision.

5. Your Right to Withdraw Consent

You may withdraw your explicit consent at any time, without giving a reason and free of charge. Withdrawal does not make processing carried out before withdrawal unlawful. You may submit your request through the following channels:

Email:	[email protected]
Written application:	Levent Mah. Begonya Sk. No: 2, Interior Door No: 1, Beşiktaş / Istanbul, Türkiye
Membership account:	My Account > Preferences
Telephone:	+90 212 812 92 45

6. Your Rights

Under Article 11 of the KVKK, you may use the contact channels above to request information about your personal data, ask for its correction or deletion, and exercise your other statutory rights.

I acknowledge and declare that I give my informed and freely given explicit consent to the processing of my personal data specified above and that I am aware I may withdraw this consent at any time. A record of my consent is retained for evidential purposes together with its date, time, IP address, chosen channel and the environment in which consent was obtained.

UNDER PERSONAL DATA PROTECTION LAW NO. 6698 (KVKK)

NEWSLETTER SUBSCRIBER PRIVACY NOTICE

This Privacy Notice has been prepared by ÖZKAN KIYMETLİ MADENLER VE KUYUMCULUK ANONİM ŞİRKETİ, based at Levent Mah. Begonya Sk. No: 2, Interior Door No: 1, Beşiktaş / Istanbul, Türkiye, as data controller under Personal Data Protection Law No. 6698 (KVKK), to fulfil its obligation to inform data subjects who subscribe to the email newsletter and consent to receiving commercial electronic messages.

METHOD OF COLLECTING PERSONAL DATA

Your personal data is obtained when you provide it electronically through the website. The personal data obtained is processed, within the scope of this Privacy Notice, wholly or partly by automated means or by non-automated means provided that the processing forms part of a data filing system.

PURPOSES OF PROCESSING PERSONAL DATA AND LEGAL GROUNDS

Legal ground	Data category	Personal data	Purpose of processing
KVKK Article 5(2)(ç) – Processing is necessary for the data controller to fulfil a legal obligation.	Legal matters	Records of consent and opt-out for commercial electronic messages	Conducting activities in compliance with legislation; carrying out retention and archiving activities; providing information to authorised persons, institutions and organisations
KVKK Article 9(4)(c) – Existence of a Standard Contract published by the Board.	Legal matters	Records of consent and opt-out for commercial electronic messages	Conducting communications
KVKK Article 5(1) – The data subject's explicit consent.	Contact	Email address, telephone number	Conducting advertising/campaign/promotion activities; conducting communications
KVKK Article 9(4)(c) – Existence of a Standard Contract published by the Board.	Contact	Email address, telephone number	Conducting communications
KVKK Article 5(2)(ç) – Processing is necessary for the data controller to fulfil a legal obligation.	Contact	Email address, telephone number	Carrying out retention and archiving activities; providing information to authorised persons, institutions and organisations
KVKK Article 5(2)(e) – Processing is necessary for the establishment, exercise or protection of a right.	Legal matters	Records of consent and opt-out for commercial electronic messages	Pursuing and conducting legal matters
KVKK Article 5(2)(e) – Processing is necessary for the establishment, exercise or protection of a right.	Contact	Email address, telephone number	Pursuing and conducting legal matters

PURPOSES OF TRANSFERRING PERSONAL DATA AND RECIPIENTS

Recipient / recipient groups	Reason for transfer	Data transferred
Email and SMS delivery service provider	Services obtained from a data processor to send transactional notifications and, where consent exists, commercial electronic messages	Legal matters (records of consent and opt-out for commercial electronic messages); Contact (email address); Contact (telephone number)
Google LLC – Google Workspace (abroad)	Services obtained from a data processor to operate the corporate email and office infrastructure	Legal matters (records of consent and opt-out for commercial electronic messages); Contact (email address); Contact (telephone number)
Ticimax – ecommerce infrastructure provider	Services obtained from a data processor to host the website and operate membership and order functions	Legal matters (records of consent and opt-out for commercial electronic messages); Contact (email address); Contact (telephone number)
Message Management System (İYS) A.Ş. and the Ministry of Trade	Recording consent, permission and opt-out records in the Message Management System under Law No. 6563 and the Regulation on Commercial Communication and Commercial Electronic Messages	Legal matters (records of consent and opt-out for commercial electronic messages); Contact (email address); Contact (telephone number)
Message Management System (İYS) A.Ş. and the Ministry of Trade	Providing information to authorised persons, institutions and organisations	Legal matters (records of consent and opt-out for commercial electronic messages); Contact (email address); Contact (telephone number)
Lawyers; judicial and administrative courts	Pursuing and conducting legal matters	Legal matters (records of consent and opt-out for commercial electronic messages); Contact (email address); Contact (telephone number)

DATA SUBJECT RIGHTS AND HOW TO EXERCISE THEM

Under Article 11 of Law No. 6698 (KVKK), everyone has the right to apply to our Company as data controller regarding the following matters: