PRIVACY, SECURITY AND PERSONAL DATA PROTECTION POLICY

("Policy")

As RG Labs, the privacy, security, and protection of personal data of you, our users ("User"), is of great importance and priority to us.

In this context; We request that you carefully read all the information, explanations, terms, and conditions contained in our Privacy, Security, and Personal Data Protection Policy, prepared regarding the processing (obtaining, recording, storing, keeping, transferring, preserving, and other similar processes), prevention of use, anonymization, and destruction of all kinds of personal data that you transmit to us, use, and produce while using our website www.rglabs.io ("Website"), and approve it with your free will after understanding it completely without any doubt, within the framework of our obligation to inform and enlighten you.

Subject and Scope:

This Policy contains the terms and conditions regarding the type of personal data collected in line with the information you share with RG Labs ("Data Controller"), how and for what purpose such personal data is used, processed, preserved, protected, how privacy and security are ensured, with whom your personal data and confidential information may be shared, what your rights are as a User ("Data Subject"), and how you can use these rights.

RG Labs and the User will hereinafter be referred to individually as "Party" and collectively as "Parties".

RG Labs Company Information:

Name: RG Internet Advertising and Information Technologies Limited Company Trade Registry Office

Trade Registry Office and No: 16300-8
Mersis No: 0011004304800012

Address: Küçükbakkalköy mah. Selvili Sok No:4/79 Ataşehir / Istanbul

Tel. No: 0540 400 00 74
E-mail: [email protected]

Information About Personal Data Protection:

Law No. 6698 on the Protection of Personal Data ("PDPL") aims to protect the fundamental rights and freedoms of individuals, especially the privacy of private life, in the processing of personal data and regulates the obligations and procedures to be followed by real and legal persons processing personal data. According to the PDPL, personal data is defined as any kind of information relating to an identified or identifiable natural person.

RG Labs attaches great importance to the processing of the User's personal data in accordance with the PDPL, Regulations published based on the PDPL, Communiqués published by the Personal Data Protection Board (hereinafter referred to as the "Board"), Board decisions, commitments, and other legislation related to personal data (hereinafter all referred to as "Law and Legislation") and shows a high degree of sensitivity in this regard. In this context, RG Labs always and continuously takes necessary measures to process the User's personal data in accordance with the Law and Legislation.

Processed Personal Data:

RG Labs can only access personal data shared, used, and produced by the User within the scope of the Website, or personal data that the User has given RG Labs access permission to in line with the requirements of the Website. The User's personal data can only be processed by RG Labs in accordance with explicit consent, approval, and permissions within the scope of this Policy.

As a User, in accordance with the approval you have given with your explicit consent within the scope of this Policy; ● your name, ● your surname, ● your contact information, ● your phone number, ● your e-mail address, ● your invoice information for the products and/or services you purchase (sales amount, invoice address, name-surname information appearing on the invoice, account information, and others), ● your shopping information, ● your address information, ● your company information where you are a member, ● your membership date, ● your payment amounts, ● campaign information you benefit from, ● your discount amounts, ● information about the product/service subject to shopping, ● information you allow and approve to be shared through your social media account when you choose to connect to the Website with your social media accounts, ● your browsing and clicking information on the Website, ● your location information when using the Website

includes all kinds of direct and/or indirect personal information and data that fall within the scope of the legal definition in accordance with the current PDPL, Law on Regulation of Publications on the Internet and Combating Crimes Committed Through These Publications, Law on the Regulation of Electronic Commerce, Turkish Penal Code, Turkish Commercial Code, Turkish Code of Obligations, and relevant Law and Legislation. In this context, all personal and/or special personal data and information shared with and/or made accessible to RG Labs by you will be considered correct.

Purpose and Basis of Personal Data Processing:

Your personal data may be processed by RG Labs in accordance with Article 5 of the PDPL, even without your explicit consent;

● If expressly provided for by laws, ● If it is necessary for the protection of the life or physical integrity of the person or of another person who is incapable of giving consent due to physical impossibility or whose consent is not legally recognized, ● If it is necessary for the processing of personal data of the parties to a contract, provided that it is directly related to the establishment or performance of a contract, ● If it is necessary for the Data Controller to fulfill its legal obligation, ● If it has been made public by the Data Subject, ● If data processing is necessary for the establishment, exercise, or protection of a right, ● If 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.

In this direction, your personal data is processed by RG Labs for the following purposes:

● To provide you with better, increasing quality, and high standard services at all times, ● To ensure that RG Labs' businesses and services work correctly, effectively, and properly, ● To carry out communication activities, ● To ensure the continuity and sustainability of the service provided, ● To be able to carry out necessary studies to improve and develop these services, ● To be able to carry out commercial activities by RG Labs, ● To carry out your product and/or service purchases, memberships, and subscriptions in line with your request within the scope of RG Labs, ● To ensure the planning, execution, continuity, and effective usability of the membership and subscription process, ● To enable operational activities, ● Customer relationship management, ● To plan, monitor, and develop sales, marketing, and/or after-sales support processes, ● To ensure that you can benefit from and/or be informed about the advantages and campaigns offered/to be offered by RG Labs within the scope of the commercial electronic message permission you have given/will give, ● To carry out promotion and marketing activities, ● To carry out Customer Relationship Management (CRM studies) studies, ● To examine and respond to the requests, suggestions, and complaints you have submitted to RG Labs in writing, ● To carry out verification, registration, and other procedures in this regard, ● To ensure information security, ● Management of user relations, ● To design and/or execute advertising and/or promotion and/or marketing activities in digital and/or other media, ● To ensure the realization of corporate communication activities, social responsibility, and/or civil society activities, ● To be able to measure customer satisfaction, ● To ensure the legal and commercial security of RG Labs and 3rd natural and legal persons connected/affiliated with RG Labs, ● To carry out finance, accounting, and legal processes, ● To ensure the creation of necessary records and financial reports in this regard, ● To provide and share relevant information and documents in line with the requests, demands, and inspections of official authorities, audit institutions, and relevant authorities and offices, ● To fulfill legal obligations, ● To be able to fulfill the obligations of preservation, presentation, reporting, storage, examination for this purpose, ● To be able to carry out RG Labs internal/external control and audit processes.

Transfer and Sharing of Personal Data:

Your personal data may be transferred in accordance with Articles 8 and 9 of the PDPL, in line with the realization of the purposes stated above;

● To authorized public institutions and organizations in order to fulfill legal obligations, ● To suppliers and business partners from whom services are received, ● To lawyers and consultants for the follow-up of legal processes.

In this context, your personal data is not shared with third parties except for the following situations and Parties:

● Service Providers Users' information may be shared with suppliers and service providers who provide services on behalf of RG Labs and act in accordance with our privacy policy (for example; web hosting, data analysis, payment processing, order fulfillment, customer service, email distribution, marketing).

● Business Partners Personal data belonging to the User may be transferred to our affiliated companies and/or direct/indirect, domestic/foreign subsidiaries, third parties inside and/or outside the country from whom RG Labs receives services or cooperates with to carry out its activities, based on your explicit consent and approval given within the scope of this Policy, in cases stipulated by the relevant Law and Legislation, by taking measures regarding data security and limited to the data processing purpose and legal reasons, in order to provide you with better service, and may be processed by the said persons and institutions only within the specified rules.

● Legal Requirements Personal data and browsing and traffic information belonging to the User may be shared with relevant official institutions and organizations that are legally authorized to request this information in cases where our legal or administrative notification and/or information obligation arises due to the relevant Law and Legislation, for reasons such as, but not limited to, combating crime, general health, public order, threat to state and public security.

● Business Transfers Your personal data may be shared in the event of a company merger, acquisition, sale of assets, or another business transfer.

● International Data Transfers User personal data may be transferred to, stored, and/or processed in countries outside the country within which it is located, including but not limited to countries where RG Labs, its subsidiaries, service providers, or business partners are located. RG Labs is obliged to take appropriate protective measures to ensure the protection of User personal data when such transfers are made.

● Permitted Sharing Your personal data may be shared when you have given explicit consent in cases where explicit consent is required according to the nature of the personal data.

Rights and Obligations of the Parties Regarding the Protection of Personal Data:

RG Labs has the authority and right to process your personal data by taking all necessary measures within the framework of the relevant Law and Legislation in line with your explicit consent, permission, and approval given within the scope of this Policy. This processing authority and right includes obtaining, recording, storing, keeping, transferring, preserving, and other processes.

The User has the following rights in accordance with Article 11 of the PDPL:

➔ To learn whether your personal data is being processed, ➔ If your personal data has been processed, to request information about this, ➔ To learn the purpose of processing your personal data and whether it is being used in accordance with this purpose, ➔ To know the third parties to whom your personal data is transferred, domestically or abroad, ➔ To request correction of your personal data if it has been processed incompletely or incorrectly and to request that the process carried out in this context be notified to third parties to whom the personal data has been transferred, ➔ To request the deletion, anonymization, or destruction of your personal data if the reasons requiring its processing have disappeared, despite it being processed in accordance with the relevant Law and Legislation, ➔ To object to the occurrence of a result against you by analyzing the processed personal data exclusively through automated systems, ➔ To request compensation for damages if you suffer damage due to the processing of your personal data contrary to the relevant Law and Legislation.

The User can contact RG Labs to exercise these rights.

Within the scope of this Policy, RG Labs is only obliged to preserve and keep confidential the personal information shared with it by the User or to which it is allowed access within the scope of the Website. In this context, it takes appropriate technical and organizational measures to protect your personal data. However, RG Labs will not be held responsible in any way, shape, or form for any violation, negligence, disclosure, and illegality that may occur or has occurred as a result of the User's personal data sharing with other Users or any third person/institution within or outside the Website. Besides, since no internet transmission or electronic storage method can be 100% secure, absolute security guarantee cannot be given to the User by RG Labs.

RG Labs is only responsible to the extent of its direct fault and intention, if proven by a court decision, for the disclosure, leakage, illegal acquisition, processing of the User's personal data by other third parties and/or institutions, and in any case, violations, negligence, and illegalities that have occurred or may occur in the User's opinion within the scope of the relevant Law and Legislation.

RG Labs has the right to make changes, revisions, additions, and removals at any time in the scope and content of this Policy if required by changes and updates made in the relevant Law and Legislation or in other cases deemed necessary. Every change; update, revision, addition, and/or removal will be clearly visible in this Policy text on the Website, and will be deemed to have been accepted with free will by the Users unless any written objection is made to RG Labs.

Your personal data is kept by RG Labs for as long as necessary to fulfill the purposes stated in this Policy or for the period required to fulfill legal obligations.

You can always reach us at the address and contact information in this Policy for your questions, opinions, suggestions, and information requests.

E-mail: [email protected] Address: Selvili Sok no: 4 / 79 Canan Business - Ataşehir Phone: [0540 400 00 74]