The Almond Garden

Clarification Text Regarding the Processing of Personal Data

The primary objective of Law No. 6698 on the Protection of Personal Data (“KVKK”), which came into effect upon publication in the Official Gazette on April 7, 2016, is to protect individuals’ fundamental rights and freedoms, particularly the privacy of personal life, in the processing of personal data. As THE ALMOND GARDEN (or “THE COMPANY”), we place the utmost importance on individuals’ fundamental rights and freedoms. We are committed to processing all personal data related to individuals connected to the Company, including those who benefit from our products and services, in compliance with KVKK and ensuring its confidentiality and security.

How and on What Basis Do We Collect and Use Your Personal Data?

Your personal data may be collected through:

• Physical Channels: Face-to-face interactions and printed forms.
• Call Channels: Call centers, emails, SMS, and digital platforms.
• Digital Channels: Our websites, mobile applications, commercial agreements, and the communication, reservation, and other request forms on these platforms.
• Social Media Channels: Our social media accounts.

We process your personal data based on the following conditions:

• To Fulfill a Contract (KVKK Art. 5/2/c): We must fulfill various obligations to both new and existing customers before and after the sale. To provide the services we promise, we need to process certain personal data. This may include information necessary for the completion of the sale (such as identity details, contact information, and vehicle registration details) and information needed for after-sales services (such as vehicle details, license plate number, and usage information), which may be collected directly via printed forms, photocopies, or the vehicle itself.
• To Comply with Legal Obligations (KVKK Art. 5/2/ç): We are required to fulfill obligations arising from various regulations during our service operations. This includes compliance with consumer laws related to contract formation and maintenance, sales and service information, after-sales support, assistance services, product safety, and service records, as well as financial obligations such as invoice issuance and maintenance. Additionally, handling and managing complaints received through physical, call, digital, and social media channels is part of fulfilling our legal obligations.
• Based on Legitimate Interests (KVKK Art. 5/2/f): To enhance our effectiveness, understand our customers better, and continuously improve our services, we process your personal data in accordance with our legitimate interests, while respecting your privacy and ensuring a balanced and proportionate approach. This includes measuring and evaluating service quality, customer relationships, complaint management, and service areas to generate general reports and assessments. We use your preferences, habits, and feedback to customize, update, and redesign our products and services to best meet customer needs (without creating personalized products or conducting promotions without your explicit consent). We also use personal data to manage requests from digital and social media channels, but this information is not used for marketing or communication purposes without your explicit consent.
• With Your Explicit Consent (KVKK Art. 5/1): In some cases, we can only use your personal data if we have your explicit consent. This includes: (i) reaching you through the communication channels you provide for offers, information, and callback requests, (ii) using your personal data for marketing activities such as campaigns, promotions, contests, and draws, (iii) creating personalized offers based on your personal data. For such cases, we provide customized texts outlining the scope and purpose of explicit consent and limit our processing activities accordingly. You can always withdraw your consent.

Who Can We Share Your Personal Data With and For What Purposes?

In some cases, we may need to share your personal data with third parties. This may include:

• To Fulfill Legal Obligations: Sharing with public institutions and financial advisors for financial processes, and with service providers for technical support due to consumer regulations.
• To Fulfill Contractual Obligations: Sharing with organizations providing technical infrastructure support within THE ALMOND GARDEN, third-party service providers for technical support, insurance companies and agents if required by contract, banks and other financial institutions based on your requests.
• Based on Legitimate Interests: Sharing with consultants and other technical service providers for services we procure.
• With Your Explicit Consent: Sharing with business partners for marketing and promotional activities, provided we have your explicit consent.

What Are Your Rights Regarding Your Personal Data?

Under Article 11 of KVKK, you have the right to:

1. Learn whether your personal data is being processed.
2. Request information about your personal data if it has been processed.
3. Learn the purpose of processing your personal data and whether it is used in accordance with its purpose.
4. Know the third parties to whom your personal data is transferred, both domestically and internationally.
5. Request correction of any incomplete or incorrect personal data and have such corrections communicated to third parties to whom the data has been transferred.
6. Request deletion or destruction of personal data when the reasons for processing it have ceased to exist, and have this action communicated to third parties to whom the data has been transferred.
7. Object to any outcome that is detrimental to you resulting from the exclusive analysis of processed data through automated systems.
8. Submit your applications to us via our website at www.thealmondgarden.com.tr.