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PRIVACY NOTICE ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

1. DATA CONTROLLER

Under Law No. 6698 on the Protection of Personal Data (the “KVKK”), your personal data may be processed, in the capacity of data controller, by;

Company name: COMPONENTCI ELEKTRONIK MAKINE KIMYA SANAYI TICARET ANONIM SIRKETI

Address: MASLAK MAH. AOS 55. SK. 42 MASLAK B BLOK NO:4 IC KAPI NO:542, 34485 SARIYER / ISTANBUL

Phone: 0533 526 72 82

E-mail: info@componentci.com

Tax office / Tax no: Maslak / 2111411208

(“COMPONENTCI” or the “Company”), to the extent described below.

This Privacy Notice has been prepared to inform you about the purposes for which your personal data is processed, the legal grounds relied upon, to whom and for what purposes it may be transferred, the methods by which it is collected, and the rights you hold under the KVKK.

The obligation to inform is fulfilled irrespective of whether the personal data processing activity is based on explicit consent.

2. PERSONAL DATA THAT MAY BE PROCESSED

Depending on the nature of the activities carried out and the services offered by COMPONENTCI, the following categories of personal data may be processed:

Identity Data

Name, surname and, where necessary, identity data that may be processed for identity verification purposes.

Contact Data

Telephone number, e-mail address, billing address, delivery address and other contact details.

Customer and Membership Data

Membership details, customer number, user account information, user preferences and customer transaction records.

Transaction Data

Order details, order number, products purchased, order date, delivery details, return and exchange records, customer requests and complaints.

Finance and Payment Data

Information relating to payment transactions and financial transaction records.

Where card details are processed by payment institutions or payment service providers, those institutions own data processing procedures and notices may additionally apply.

Transaction Security Data

IP address, website entry and exit records, transaction records, log records, device and connection details, and technical information required to ensure information security.

Request and Communication Data

E-mail correspondence, customer service conversations, customer requests, notifications relating to products and services, and other communication records.

Marketing and Preference Data

Where processing is permitted by legislation, information relating to product, service, campaign and communication preferences.

3. PURPOSES OF PROCESSING PERSONAL DATA

Depending on the nature of the transaction carried out, your personal data may be processed for the following purposes:

  • Creating and managing the membership account,

  • Receiving and fulfilling orders,

  • Carrying out sales and contractual processes,

  • Carrying out the sourcing, preparation and delivery processes of products,

  • Carrying out the order processes of products supplied from domestic stock or specially sourced from abroad,

  • Carrying out payment transactions,

  • Carrying out invoicing and accounting operations,

  • Carrying out return, withdrawal, exchange and defective product processes,

  • Evaluating customer requests and complaints,

  • Carrying out customer relations and support processes,

  • Ensuring the security of the Site and the membership account,

  • Operating information security and technical infrastructure,

  • Developing the Site and improving the user experience,

  • Preventing fraud, misuse and unauthorised transactions,

  • Fulfilling legal and regulatory obligations,

  • Responding to requests from authorised public institutions and organisations,

  • Conducting and following up legal proceedings,

  • Carrying out the legal and commercial activities of the Company,

  • Establishing, exercising and protecting the rights of the Company,

  • Providing information about products and services to the extent permitted by legislation,

  • Where the necessary legal conditions exist, carrying out marketing, campaign and customer satisfaction activities.

Your personal data is processed for specific, explicit and legitimate purposes and only to the extent required by the data processing activity carried out.

4. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

Depending on the nature of the data processing activity carried out, your personal data may be processed under one or more of the processing conditions set out in Article 5 of the KVKK.

In this context, in particular;

  • being expressly provided for by law,

  • being directly related to the conclusion or performance of a contract,

  • processing being mandatory for the Company to fulfil its legal obligation,

  • processing being mandatory for the establishment, exercise or protection of a right,

  • processing being mandatory for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the data subject,

  • the data having been made public by the data subject,

  • the explicit consent of the data subject being present

may be relied upon as legal grounds.

For example, personal data required in order, payment, delivery and invoicing processes may be processed for the conclusion or performance of the contract and/or for the fulfilment of the legal obligations of the Company.

Personal data required for purposes such as information security, operation of the Site and prevention of unauthorised transactions may be processed within the scope of the legitimate interest of the Company, provided that it does not harm the fundamental rights and freedoms of the data subject.

For processing activities that require explicit consent, explicit consent is obtained from the data subject separately and specifically for that processing activity.

Where special categories of personal data must be processed, the conditions set out in the relevant provisions of the KVKK are additionally complied with.

5. METHODS OF COLLECTING PERSONAL DATA

Depending on the nature of the data processing activity carried out, your personal data may be collected;

  • via the www.componentci.com website,

  • membership and account creation forms,

  • order and sales transactions,

  • payment transactions,

  • e-mail and other electronic communication channels,

  • telephone calls,

  • customer requests and support processes,

  • shipping and delivery processes,

  • cookies and similar technical technologies,

  • the information technology systems used by the Company,

  • suppliers and service providers from which services are received,

  • authorised public institutions and organisations

by electronic or physical means.

The method by which personal data is collected may vary depending on the nature of the data processing activity carried out.

6. TRANSFER OF PERSONAL DATA

Where necessary for the realisation of the processing purposes and the fulfilment of the relevant legal obligations, your personal data may be transferred to the following groups of recipients in accordance with the conditions set out in the KVKK and the relevant legislation:

  • Shipping and logistics service providers,

  • Payment institutions and banks,

  • Persons or organisations from which accounting and finance services are received,

  • Information technology and software service providers,

  • Technical support and infrastructure service providers,

  • Persons or organisations from which legal, financial advisory and consultancy services are received,

  • Manufacturers, distributors or suppliers,

  • Authorised public institutions and organisations,

  • Judicial authorities and legally authorised persons or organisations,

  • Other service providers from which services are received in order to carry out the activities of the Company.

Your personal data is transferred only to the extent necessary for the relevant processing purpose and in accordance with the legal conditions set out in the applicable legislation.

7. TRANSFER OF PERSONAL DATA ABROAD

Where there is a data processing activity that requires your personal data to be transferred abroad, the transfer is carried out in accordance with Article 9 of the KVKK and the conditions set out in the applicable legislation on the transfer of personal data abroad. Under the current provisions of the KVKK, different transfer mechanisms are available for transfers abroad, such as an adequacy decision, appropriate safeguards, or the exceptional circumstances set out in the law.

Sourcing products from abroad does not, in itself, mean that personal data belonging to the BUYER or to customers is transferred abroad.

Sourcing products from abroad and transferring personal data abroad are assessed separately from one another.

Where your personal data is transferred abroad through a particular service, software, technical infrastructure or service provider, that transfer is carried out in accordance with the conditions set out in Article 9 of the KVKK.

8. RETENTION PERIOD OF PERSONAL DATA

Your personal data is retained for the period required by the purposes of processing and taking into account the statutory retention periods set out in the relevant legislation.

Upon expiry of the retention period or where the legal ground requiring the processing of personal data ceases to exist, your personal data is deleted, destroyed or anonymised in accordance with the applicable legislation and the retention and destruction procedures of the Company.

Information and records that must be retained by law may be kept for the periods specified in the relevant legislation.

9. SECURITY OF PERSONAL DATA

COMPONENTCI takes the necessary technical and administrative measures to prevent the unlawful processing of and access to the personal data it processes, to ensure that personal data is stored securely and to safeguard data security.

In this context, access authorisations, information security practices, system controls, backup and access security practices, and other technical and administrative measures appropriate to the nature of the data processed may be applied.

Measures relating to personal data security may be updated taking into account technological developments, data processing activities and the nature of the personal data processed.

10. RIGHTS OF THE DATA SUBJECT

Under Article 11 of the KVKK, as a data subject you have the right, in relation to your personal data, to;

  • learn whether your personal data is processed,

  • request information if your personal data has been processed,

  • learn the purpose of processing and whether the data is used in accordance with that purpose,

  • know the third parties to whom the personal data is transferred, in Türkiye or abroad,

  • request the rectification of personal data where it has been processed incompletely or incorrectly,

  • request the erasure or destruction of personal data where the conditions set out in the KVKK are met,

  • request that rectification, erasure or destruction operations be notified to the third parties to whom the personal data has been transferred,

  • object to an outcome to your detriment arising from the analysis of the processed data exclusively by automated systems,

  • request compensation where you suffer damage due to unlawful processing of data.

you hold these rights.

11. APPLICATION METHOD

In order to exercise your rights under Article 11 of the KVKK, you may submit your requests to COMPONENTCI through the following communication channels, in accordance with the procedures and principles set out in the KVKK and the relevant legislation:

E-mail: info@componentci.com

Address: MASLAK MAH. AOS 55. SK. 42 MASLAK B BLOK NO:4 IC KAPI NO:542, 34485 SARIYER / ISTANBUL

Applications are evaluated and concluded within the period set out in the KVKK and the relevant legislation, depending on the nature of the request.

12. COOKIES AND SIMILAR TECHNOLOGIES

Cookies and similar technologies may be used for the operation of the www.componentci.com website, to ensure its security, to improve the user experience and, where necessary, to remember user preferences.

Depending on the type and purpose of the cookies used, the necessary information and preference management mechanisms are applied.

Detailed information on the use of cookies is explained in the Cookie Policy published separately on the Site.

13. COMMERCIAL ELECTRONIC COMMUNICATION

Commercial electronic messages containing product, service, campaign and promotional content are sent in accordance with the conditions set out in the applicable legislation.

Where the sending of commercial electronic messages requires explicit consent or separate approval, the necessary approval is obtained in accordance with the relevant legislation.

The obligation to inform and the approval and explicit consent processes relating to the sending of commercial electronic messages are assessed separately from one another.

This Privacy Notice does not, in itself, constitute an explicit consent text or an approval for commercial electronic messages. Where a personal data processing activity must be based on the legal ground of explicit consent, explicit consent is obtained separately. Pursuant to Principle Decision No. 2026/347 of the KVKK Board dated 18.02.2026, information notices and explicit consent texts must be drawn up separately from one another.

14. UPDATES

COMPONENTCI may update this Privacy Notice in line with changes in the applicable legislation, changes in data processing activities, the introduction of new services or operational requirements.

The current Privacy Notice is published on the www.componentci.com website.

Text update date: 28.09.2026

Effective date: 28.09.2026