Electronic Commercial Messages Information Text

COMMERCIAL ELECTRONIC COMMUNICATION DISCLOSURE STATEMENT IN ACCORDANCE WITH LAW NO. 6563

Data Controller:
ANADOLU JAPAN TRADE INC.

This Privacy Notice has been prepared to inform you about the storage and transfer of your personal data during the services we provide to you in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”) and related legislation, regarding the Shoptheswiss website operated by ANADOLU JAPAN.

A. METHOD OF COLLECTION, LEGAL BASIS AND PURPOSES OF PROCESSING YOUR PERSONAL DATA:

Your personal data will be processed by our Company for the following purposes and legal grounds, within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK (Law on Protection of Personal Data):

Data Category	Legal reason	Purpose of Processing
Identity	Explicit consent (If consent for commercial electronic communication has been given, SMS or email messages are sent during advertising and campaign processes.) (KVKK Article 5, paragraph 1) Processing personal data of the parties to a contract is necessary provided that it is directly related to the establishment or performance of the contract (Article 5, paragraph 2, subparagraph c of the KVKK - Turkish Personal Data Protection Law). It is necessary for the data controller to fulfill its legal obligations (KVKK, Article 5, paragraph 2, subparagraph ç). Data processing is necessary for the establishment, exercise, or protection of a right (KVKK, Article 5, paragraph 2, subparagraph e). Data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (KVKK, Article 5, paragraph 2, subparagraph f).	- Ensuring that activities are carried out in accordance with the legislation. - Implementing Company/Product/Service Loyalty Processes - Conducting Communication Activities - Execution of Goods/Services Procurement Processes - Providing After-Sales Support Services for Goods/Services - Execution of Goods/Services Sales Processes - Execution of Goods/Services Production and Operation Processes - Execution of Customer Relationship Management Processes - Conducting activities aimed at customer satisfaction. - Conducting Marketing Analysis Studies - Execution of Advertising / Campaign / Promotion Processes - Conducting Storage and Archiving Activities - Execution of Contract Processes - Tracking Requests/Complaints
Communication	Processing personal data of the parties to a contract is necessary provided that it is directly related to the establishment or performance of the contract (Article 5, paragraph 2, subparagraph c of the KVKK - Turkish Personal Data Protection Law). It is necessary for the data controller to fulfill its legal obligations (KVKK, Article 5, paragraph 2, subparagraph ç). Data processing is necessary for the establishment, exercise, or protection of a right (KVKK, Article 5, paragraph 2, subparagraph e).	- Ensuring that activities are carried out in accordance with the legislation. - Implementing Company/Product/Service Loyalty Processes - Conducting Communication Activities - Execution of Goods/Services Procurement Processes - Providing After-Sales Support Services for Goods/Services - Execution of Goods/Services Sales Processes - Execution of Goods/Services Production and Operation Processes - Execution of Customer Relationship Management Processes - Conducting activities aimed at customer satisfaction. - Conducting Marketing Analysis Studies - Execution of Advertising / Campaign / Promotion Processes - Conducting Storage and Archiving Activities - Execution of Contract Processes - Tracking Requests/Complaints - Execution of Marketing Processes for Products/Services
Marketing	Explicit consent (If consent for commercial electronic communication has been given, SMS or email messages are sent during advertising and campaign processes.) (KVKK Article 5, paragraph 1) Data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (KVKK, Article 5, paragraph 2, subparagraph f).	- Implementing Company/Product/Service Loyalty Processes - Execution of Goods/Services Sales Processes - Conducting Marketing Analysis Studies - Execution of Advertising / Campaign / Promotion Processes - Conducting Storage and Archiving Activities - Tracking Requests/Complaints - Execution of Marketing Processes for Products/Services

B. PARTIES TO WHOM PERSONAL DATA IS TRANSFERRED AND THE PURPOSES OF TRANSFER:

Your personal data may be transferred to the third parties listed below, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK (Law on Protection of Personal Data), and for the purposes stated below:

Third Party	Data Categories	Legal Basis for Transfer
Natural Persons and Private Legal Entities (Including IYS)	Identity, Communication, Customer Transactions, Finance, Audiovisual Recordings, Marketing	- Data processing is necessary for the establishment, exercise, or protection of a right (KVKK, Article 5, paragraph 2, subparagraph e). - Data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (KVKK, Article 5, paragraph 2, subparagraph f). - The existence of a standard contract announced by the Board, which includes matters such as data categories, purposes of data transfer, recipients and recipient groups, technical and administrative measures to be taken by the data recipient, and additional measures taken for special categories of personal data (KVKK Article 9, paragraph 4, subparagraph c).

Third Party

Data Categories

Legal Basis for Transfer

Natural Persons and Private Legal Entities

(Including IYS)

Identity, Communication, Customer Transactions, Finance, Audiovisual Recordings, Marketing

- Data processing is necessary for the establishment, exercise, or protection of a right (KVKK, Article 5, paragraph 2, subparagraph e).
- Data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (KVKK, Article 5, paragraph 2, subparagraph f).
- The existence of a standard contract announced by the Board, which includes matters such as data categories, purposes of data transfer, recipients and recipient groups, technical and administrative measures to be taken by the data recipient, and additional measures taken for special categories of personal data (KVKK Article 9, paragraph 4, subparagraph c).

C. RIGHTS OF THE DATA SUBJECT AS LISTED IN ARTICLE 11 OF LAW NO. 6698

You may submit your applications and requests regarding your personal data through the Data Subject Application Form;

You can send it with your wet signature and a photocopy of your ID to the following address: Vişnezade mah. Acısu sk. No:19 Maçka/Beşiktaş/İstanbul.

You can apply in person with a valid identification document at the following address: Vişnezade mah. Acısu sk. No:19 Maçka/Beşiktaş/İstanbul.

If you wish to submit your applications via KEP (Registered Electronic Mail), please send them to anadolujapan@hs03.kep.tr You can send it to our KEP address.

You can send your email address registered with Shop the Swiss or a secure electronic signature to kvkk.istanbul@swissotel.com .

You can forward it.

According to the Communiqué on the Procedures and Principles for Applications to the Data Controller, the Data Subject must include the following information in their application: name, surname, signature (if the application is in writing), Turkish Republic Identity Number (or passport number if the applicant is a foreigner), residential or business address for notification purposes, email address (if any), telephone number, fax number, and information regarding the subject of the request.

The relevant person must clearly and understandably state the request in their application, which should include explanations regarding the right they wish to exercise as mentioned above. All relevant information and documents must be attached to the application.

While the subject of the request must relate to the applicant personally, if acting on behalf of someone else, the applicant must be specifically authorized to do so and this authorization must be documented (power of attorney). Furthermore, the application must include identity and address information, and supporting documents verifying identity must be attached.

Requests made by unauthorized third parties on behalf of another person will not be considered.

Your requests regarding your personal data will be evaluated and answered within a maximum of 30 days from the date we receive them. If your application is rejected, the reasoned reasons for rejection will be communicated to you via email or postal service to the address you provided in your application, or, if possible, through the same method you used to submit your request.