INFORMATION TEXT ON THE PROTECTION OF PERSONAL DATA ### 1 - Introduction As {{siteName}} ("Company"), the confidentiality and security of your personal data are among our top priorities. Our Company processes your personal data in compliance with the regulations of the Personal Data Protection Law No. 6698 ("KVKK") and secondary legislation. Your personal data means any information that determines or makes your identity determinable. In order to benefit from the services (collectively, "Platform") offered in our Company's mobile applications and/or websites (collectively, "Platform"), we would like to inform you about your personal data processed if you accept the Membership Agreement and become a "Platform Member". ### 2 - Which personal data do we process? If you become a Platform Member, the following personal data will be processed. 1. Your User Account Information: Your name, surname, customer number, membership e-mail address and, if you add it to your user information, your phone number, gender, date of birth, height and weight information, TR Identity Number (It is processed in accordance with the relevant legislation only if you purchase certain product groups.), 2. Your Customer Transaction Information: Your order and invoice information, transaction history information regarding your purchases, request and complaint information, Platform usage information, information you personally share in your comments and questions if you comment and/or ask questions regarding the products on the Platform, your score and evaluation information, information regarding the content of the conversations made through the chat channel, your cancellation/return information. 3. Delivery Information: the phone number and delivery address information you added for the delivery of the product you ordered, your delivery transaction information, 4. Payment Information: information regarding payments made by you and payment methods, your registered card information, 5. Transaction Security Information: your device information, IP address information, password and passcode information, cookie information, platform access records, your login method (via Google/Facebook), 6. Legal Transaction Information: information in correspondence with authorized persons, institutions and organizations, information in lawsuit and enforcement files, information regarding legal information requests, 7. Auditory Recording Information: your voice recording in case you contact the call center. 8. Personal data processed within the scope of additional services: Your data processed if you benefit from additional services offered on the Platform such as food, market, financial services, insurance, lucky draw, buy and sell and win (Cabinet). ### 3 - What are the legal reasons, purposes and collection methods for processing your personal data? Your personal data is collected electronically by our Company, in whole or in part, through automatic means or non-automatic means provided that it is part of any data recording system, through mobile applications or websites where the Platform Service belonging to our Company that you benefit from is located, within the scope of our membership agreement; electronically through the channel you contact when you contact us through live help, call center or e-mail channels, and in physical environment when it is sent to our Company via printed forms, notification, mail or notified by legal authorities. Your processed personal data, the purposes of processing and legal reasons are given below. #### 3.1 Membership and Account Creation Process: Your personal data processed in this category: Your user account information, customer transaction information, transaction security information. Purposes: 1. Carrying out the processes for establishing and performing the membership agreement, 2. Managing the creation and closing processes of the platform member profile/account, 3. Verifying contact information, 4. Carrying out activities for the realization of your purchase transactions through the Platform, 5. Carrying out and auditing the Company's business activities, 6. Ensuring the security of Platform operations, 7. Fulfilling the obligations arising from the legislation to which our Company is subject, especially the Law on Regulation of Electronic Commerce No. 6563, the Turkish Commercial Code No. 6102, the Turkish Penal Code No. 5237 and the Law on Consumer Protection No. 6502, 8. Carrying out platform activities in accordance with the legislation, 9. Fulfilling our Company's data sharing and storage obligations in accordance with our obligations arising from the legislation. Legal Reasons: Being clearly prescribed by the laws, Being mandatory for the fulfillment of our Company's legal obligations, Being necessary for the performance of our membership agreement with you. If you benefit from the Platform Services as a Guest member, you can access detailed information about your processed personal data from the information text on the screen that appears when you click on the "Continue without becoming a member" button. #### 3.2 Order, Delivery and Cancellation/Return Processes: Your personal data processed in this category: Your user account information, delivery information, customer transaction information, payment information, transaction security information. Purposes: 1. Placing the order and creating the order, 2. Establishing and ensuring the execution of the distance sales contract, 3. Carrying out delivery and logistics activities, 4. Carrying out cancellation/return processes, 5. Carrying out payment and invoice processes, 6. Fulfilling the legal obligations specified in the legislation to which our Company is subject, especially the Distance Contracts Regulation and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce and/or in the decisions, guides and guides published by the competent authorities, 7. Carrying out the purchasing processes of the product/service groups on the Platform. Legal Reasons: It is mandatory for the fulfillment of our Company's legal obligations, It is necessary for the execution of our membership agreement with you. #### 3.3 Customer Experience Improvement Processes: Your personal data processed in this category: Your user account information, customer transaction information, delivery information, transaction security information, legal transaction information, audio recording information. Purposes: 1. To ensure that you can quickly and easily access products that suit your preferences and interests, 2. To provide a better user experience in service transitions between our Company's Platform Services, 3. To develop and improve our user experience, 4. To improve our service quality, 5. To conduct analysis and reporting studies, 6. To carry out communication activities, 7. To evaluate requests, complaints and suggestions regarding our products and services, 8. To provide after-sales support services for goods and services. Legal Reasons: Being necessary for the performance of our membership agreement with you, data processing being mandatory for the legitimate interests of our Company. #### 3.4 The Company's Information Security, Risk, Audit and Control Processes: Your personal data processed in this category: Your user account information, customer transaction information, delivery information, payment information, transaction security information. Objectives: 1. Execution and auditing of finance and accounting processes, 2. Execution of billing processes, 3. Execution of information security processes and investigation of suspicious transactions, 4. Ensuring the security of operations regarding the Platform, 5. Control, development and improvement of the quality of products and services offered by our Company, 6. Conducting risk detection and analysis, complaint management, 7. Prevention of fraud, 8. Conducting legal and financial investigation activities of our Company in possible mergers, acquisitions, joint ventures, divisions and other structural changes. Legal Reasons: It is necessary for the execution of our membership agreement with you, it is mandatory for the legitimate interests of our Company to process data. #### 3.5 Process of Carrying Out Legal Transactions: Your personal data processed in this category: Your user account information, customer transaction information, delivery information, payment information, transaction security information, legal transaction information, audio recording information. Purposes: 1. Carrying out legal and litigation work, responding to your legal requests, examining and responding to your duly submitted applications as the relevant person, 2. Carrying out activities in accordance with the legislation, fulfilling the obligations arising from the legislation to which our Company is subject, 3. Carrying out legal consultancy processes, 4. Sharing information with authorized persons, institutions and organizations upon request, 5. Exercising and protecting a right in the event of a legal dispute. Legal Reasons: Data processing is mandatory for the establishment, exercise or protection of a right, and it is mandatory for our Company to fulfill its legal obligations. #### 3.6 Processes Based on Explicit Consent: Your personal data processed in this category: Your user account information, customer transaction information, delivery information, payment information. Purposes: 1. Conducting marketing, advertising and promotional activities, 2. Conducting financial offer processes, 3. Presenting advantageous offers special to you, conducting activities to increase your satisfaction by getting to know you better, and sending commercial electronic messages within this scope. Legal Reason: Your explicit consent. We would like to emphasize that if you wish to withdraw your consent, you can convey your request in this regard to the Company using the methods listed under the heading “7-Communication for Your Rights and Requests”. #### 3.7 Additional Service Processes Offered on the Platform: Your personal data is also processed within the scope of different additional services offered on the Platform. If you wish to benefit from these additional services, we have process-specific disclosure texts in the area where the relevant service is offered. In addition, information on the relevant services is also provided below so that you can easily access the relevant texts. ### 4 - To whom and for what reasons does the Company transfer your personal data? Our Company takes care to process your personal data in accordance with the "need to know" and "need to use" principles, by ensuring the necessary data minimization and by taking the necessary technical and administrative security measures. Our Company shares your personal data domestically with the recipient groups specified in detail below based on the legal reasons “It is clearly prescribed by the laws, it is mandatory for our Company to fulfill its legal obligations, it is necessary for the establishment or execution of a contract, data processing is mandatory for the establishment, exercise or protection of a right and/or it is mandatory for the legitimate interest of our Company” in accordance with Article 8 of the KVKK. In cases where your personal data is transferred abroad by our Company, it is shared with the recipient groups specified in detail below based on the legal reasons “Provision of appropriate security with a standard contract or, provided that it is incidental, the existence of one of the situations regulated in Article 9, paragraph 6 of the KVKK” regulated in Article 9 of the KVKK and the Regulation on the Procedures and Principles Regarding the Transfer of Personal Data Abroad. #### 4.1. Membership and Account Creation Process: 1. In accordance with our contractual relationship, your personal data is shared with our subsidiaries and group companies for the purposes of ensuring that you benefit from the Platform Services within the scope of the services we receive related to the Platform, and for the establishment and execution of the membership agreement, 2. With our subsidiaries, group companies, business partners and service providers that provide, operate or provide our IT infrastructure and our subsidiaries and group companies abroad for the purposes of carrying out Platform operations and receiving IT, technology and software services . Legal Reason: Being necessary for the establishment or execution of the agreement, Providing appropriate security with the standard agreement. #### 4.2. Order, Delivery and Cancellation/Return Processes: 1. With the seller of the product you want to purchase or the service provider for the purposes of ensuring that you benefit from the Platform Services, conducting the purchasing and invoicing processes, and fulfilling the obligations arising from the legislation to which our Company and the seller you purchased the product are subject, 2. With the product seller, cargo companies, private couriers for the purposes of conducting logistics activities and monitoring delivery processes, 3. With the banks and other payment institutions we have agreements with for the purpose of conducting and monitoring your payment processes, 4. With our business partners from whom we receive services regarding bulk SMS / e-mail sending in order to inform you about matters such as the delivery of the product you purchased, 5. If you order a product from abroad, the order is shared with cargo and logistics companies located abroad, the seller of the product you purchased and customs consultancy companies for the purposes of carrying out delivery and return processes, carrying out logistics and supply chain processes, carrying out customs processes, and carrying out Platform operations . Legal reason: Fulfillment of our company's legal obligations, Being necessary for the establishment or execution of the contract, Providing appropriate security with the standard contract. #### 4.3. Customer Experience Improvement Processes: 1. With our business partners that provide call center services, and service providers that provide customer support services for the purposes of providing goods and service sales and after-sales support services, ensuring customer satisfaction, and meeting their demands and complaints, 2. With our service providers located abroad from whom we receive service in order to provide Platform services and carry out Platform operations, and with our affiliates, group companies, business partners and consultants that provide IT infrastructure, software and technology services . Legal reason: Being necessary for the establishment or performance of the contract, Providing appropriate assurance with a standard contract, The existence of one of the situations regulated in Article 9, Paragraph 6 of the KVKK, provided that it is incidental. #### 4.4. The company's information security, risk, audit and control processes: 1. For the purposes of carrying out invoicing processes, sending e-invoices to customers electronically, delivering physical contracts or invoices, managing financial and accounting processes, identifying and assessing risks, and preventing fraud, with our business partners, consultants and service providers, banks, e-invoice business partners, cargo and courier companies, special integrators, independent auditing, customs, financial advisor/accounting service providers, 2. For the purposes of ensuring the security of company operations, controlling and improving the quality of the products and services offered by our company, and identifying and analyzing risks, with our business partners, community companies, affiliates, group companies, special integrators, technology companies, business partners and service providers, 3. In order to carry out the legal and financial review activities of our Company in possible mergers, acquisitions, joint ventures, divisions and other structural changes, it is shared with potential buyers, sellers or other parties to whom the transaction is addressed and their employees, consultants and database service providers involved in the relevant process who are under a confidentiality obligation. Legal reasons: It is necessary for the fulfillment of the legal obligations of our Company, the establishment or execution of the Agreement, It is mandatory for the legitimate interests of our Company. #### 4.5. Process of Carrying Out Legal Transactions: 1. With regulatory and supervisory authorities, courts and enforcement offices, mediators and other authorized public institutions and organizations for the purposes of fulfilling the obligations arising from the legislation to which our company is subject and carrying out the Platform activities in accordance with the legislation, informing authorized persons, institutions and organizations, following up and carrying out legal affairs, exercising and protecting a right in case of a legal dispute, 2. With lawyers, auditors, tax consultants, forensic computer experts, cyber security consultants, tax consultants, our group companies, our affiliates, other third parties and business partners from whom we receive consultancy and service for the purposes of carrying out the audit activities of our company, carrying out legal consultancy processes, ensuring the security of company operations, and conducting investigations into suspicious transactions, 3. Upon request, with authorized public institutions and organizations for the purposes of informing authorized persons, institutions and organizations abroad, exercising and protecting a right in case of a legal dispute . Legal reasons: Being clearly prescribed by law, Fulfilling our Company's legal obligations, Processing to establish, exercise or protect a right, Being necessary for the establishment or execution of a contract, The existence of one of the situations regulated in Article 9, Paragraph 6 of the KVKK, provided that it is incidental. #### 4.6. Processes Based on Explicit Consent: 1. It is shared with subsidiaries, group companies, service providers and business partners for the purposes of carrying out marketing, advertising and promotional activities, presenting advantageous offers special to you, and carrying out activities to increase your satisfaction by getting to know you better. Legal Reason: Having your explicit consent. ### 5 - How Does the Company Protect Your Personal Data? Personal data shared with our Company is under the supervision and control of the Company. The Company has assumed responsibility as the data controller to establish the necessary organization and to take and adapt technical measures in order to protect the confidentiality and integrity of information in accordance with the relevant legislation in force. Being aware of our obligations in this regard; 1. Penetration tests are conducted at periodic intervals in accordance with international and national technical standards regarding data confidentiality. 2. Your personal data that you transmit to the Company through the website, mobile site and mobile application is protected using SSL (Secure Sockets Layer) technology. 3. Risk analyses are regularly conducted regarding personal data processing activities and actions are taken to reduce risks. 4. Access and authorization controls are applied to prevent unauthorized access to personal data. 5. Data processing policies are updated at regular intervals. ### 6 - Your Rights Regarding the Protection of Your Personal Data By applying to our Company through the methods provided in the "Communication for Your Rights and Requests" section of this disclosure text, you have the right to: 1. Learn whether your personal data has been processed, 2. Request information if processed, 3. Learn the purpose of processing your personal data and whether they are used in accordance with their purpose, 4. Know the third parties to whom they are transferred domestically or abroad, 5. Request correction of personal data if they are processed incompletely or incorrectly, 6. Request deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK, 7. Request notification of the transactions carried out in accordance with your rights of correction, deletion and destruction specified above to third parties to whom personal data is transferred, 8. Object to the emergence of a result against you by means of analysis of your processed personal data exclusively by automated systems, 9. Request compensation for your damages in the event that you suffer damages due to the processing of your personal data in violation of the relevant legislation. ### 7 - Contact for Your Rights and Requests You can forward your questions and requests regarding your personal data to the Data Controller by submitting a petition prepared in accordance with the conditions specified in the Communiqué on Application Procedures and Principles or by using the "Hobyle.com Application Form" using the following methods. You can access the application form here. | Application Method | Application Address | |----------------------------------------|--------------------------------------------------------| | Written Application in Person | {{address}} | | Notary | {{address}} | | Registered Electronic Mail (KEP) by Signing with Secure Electronic Signature or Mobile Signature | {{details.kep}} | | From your e-mail address previously notified to our company and registered in the system | {{kvkkEmail}} | *We kindly request that "Personal Data Protection Law Related Person Request" be written on the notification envelope of the application form or in the subject section of the e-mail. It is mandatory for the Related Persons who will apply by "Written Application in Person" to present documents proving their identity. In this context, we kindly request that only the front side of the ID photocopy (blood type and religion box will not be visible) be presented along with the application form in your written applications to Maslak Mahallesi Saat Sokak Spine Tower No:5 iç kap:19 Sarıyer İstanbul. As personal data owners, if you submit your requests regarding your rights to the Company, the Company will finalize your request free of charge within 30 (thirty) days at the latest. However, if the response to your application requires a cost in accordance with the legislation, the Company may request a fee in the tariff determined by the Personal Data Protection Board. ### 8 - About the Information Text The Company reserves the right to update this Information Text on the Protection of Personal Data at any time within the framework of possible changes in the current legislation.
Last updated: 03/14/2026