Corporate Sales

GÜRMEN GİYİM SANAYİ VE TİCARET A.Ş.

Privacy Notice on the Protection of Personal Data

of Customers, Members and Visitors

GÜRMEN GİYİM SANAYİ VE TİCARET A.Ş. (“GÜRMEN, RAMSEY, KİP or collectively GÜRMEN GROUP”), in its capacity as data controller, takes security measures at the highest possible level in order to ensure that your personal data are processed lawfully and to protect your privacy.

This notice aims to inform you, in the most transparent manner and pursuant to Article 10 of the Personal Data Protection Law No. 6698 (the “Law”), of the methods by which your personal data are collected, the purposes for which they are processed, the groups of recipients to whom they are transferred, the legal grounds for the processing and your rights, where you visit the stores of the brands of GÜRMEN GİYİM SANAYİ VE TİCARET A.Ş. or shop at the stores of those brands; visit the websites of GÜRMEN at www.gurmen.com.tr, of KİP at www.kip.com.tr and of Ramsey at www.ramsey.com.tr (the “Websites”), use the mobile applications of those brands or become a member; shop through the websites/mobile applications on which the brands’ products are sold or send products/gifts on behalf of third parties; or take part in campaigns, contests, prize draws and other events organised by GÜRMEN.

1. Personal Data Processed

IDENTITY	Name, Surname, Date of birth, Gender, Nationality, Turkish ID Number (T.C. Kimlik No.), Signature
CONTACT	E-mail Address, Telephone, Address
TRANSACTION SECURITY	Password, login/logout records of the membership page
LOCATION	Your location data, obtained automatically by the website if you grant permission through your browser settings, or which you may add manually
CUSTOMER TRANSACTION INFORMATION	Purchase history information, Message type, message subject, subject title, contact telephone, order number, product name, message content, alteration, exchange and return data, loyalty card information
MARKETING	Cookie records, Information obtained through marketing – campaign activities; favourites, likes, behaviours, preferences, search activity, segments, cookie and advertising identifier/ID information, communication preferences, survey responses, demographic information, customer requests/complaints, location
AUDIO-VISUAL RECORDS	CCTV footage
OTHER	Passport, Flight Information, Sole Proprietorship Information, Body Size and Measurement Information

2. Purposes of Processing Personal Data

NAME, SURNAME	Conducting Marketing Analysis Activities (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Advertising/Campaign/Promotion Processes (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Marketing Processes for Products/Services (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Goods/Services After-Sales Support Processes Conducting Goods/Services Sales Processes Conducting Customer Relationship Management Processes Conducting Finance and Accounting Processes Tracking Requests and Complaints Conducting Contract Processes
DATE OF BIRTH, GENDER, NATIONALITY	Conducting Marketing Analysis Activities (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Advertising/Campaign/Promotion Processes (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Marketing Processes for Products/Services (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Contract Processes Conducting Activities in Compliance with Legislation
TURKISH ID NUMBER	Conducting Goods/Services After-Sales Support Processes Conducting Goods/Services Sales Processes Conducting Activities in Compliance with Legislation
E-MAIL ADDRESS	Conducting Marketing Analysis Activities (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Advertising/Campaign/Promotion Processes (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Marketing Processes for Products/Services (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Contract Processes Conducting Goods/Services After-Sales Support Processes (Where You Contact Us via the Contact Us – Contact Form Section) Conducting Goods/Services Sales Processes Conducting Customer Relationship Management Processes (Where You Contact Us via the Contact Us – Contact Form Section) Tracking Requests and Complaints (Where You Contact Us via the Contact Us – Contact Form Section) Conducting Finance and Accounting Processes
TELEPHONE	Conducting Marketing Analysis Activities (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Advertising/Campaign/Promotion Processes (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Marketing Processes for Products/Services (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Goods/Services After-Sales Support Processes Conducting Goods/Services Sales Processes Conducting Customer Relationship Management Processes Tracking Requests and Complaints Conducting Contract Processes Conducting Finance and Accounting Processes
ADDRESS	Conducting Goods/Services Sales Processes Conducting Goods/Services After-Sales Support Processes Conducting Advertising/Campaign/Promotion Processes Conducting Marketing Processes for Products/Services Conducting Finance and Accounting Processes
PASSWORD, MEMBERSHIP PAGE LOGIN/LOGOUT RECORDS	Conducting Contract Processes Cookie Records, Information Obtained Through Marketing – Campaign Activities; Favourites, Likes, Behaviours, Preferences, Search Activity, Segments, Cookie and Advertising Identifier/ID Information Conducting Advertising/Campaign/Promotion Processes Conducting the Loyalty Card Membership Process Conducting Marketing Analysis Activities (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Marketing Processes for Products/Services (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications), Segments, Cookie and Advertising Identifier/ID Information, Communication Preferences, Survey Responses, Demographic Information
CUSTOMER REQUESTS/COMPLAINTS	Conducting Advertising/Campaign/Promotion Processes Conducting Marketing Analysis Activities (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications) Conducting Marketing Processes for Products/Services (Where You Have Given Explicit Consent to Receive Commercial Electronic Communications)
CUSTOMER TRANSACTION INFORMATION	Conducting Goods/Services After-Sales Support Processes (Where You Contact Us via the Contact Us – Contact Form Section) Conducting Customer Relationship Management Processes (Where You Contact Us via the Contact Us – Contact Form Section) Tracking Requests and Complaints (Where You Contact Us via the Contact Us – Contact Form Section)
LOCATION	Conducting Customer Relationship Management Processes (Where the Store Nearest to Your Location Is Identified via the Stores – Use My Location Feature)
PASSPORT INFORMATION, FLIGHT INFORMATION, SOLE PROPRIETORSHIP INFORMATION, SIGNATURE	Conducting Goods/Services Sales Processes Conducting Activities in Compliance with Legislation Conducting Contract Processes
BODY SIZE AND MEASUREMENT INFORMATION	Conducting Goods/Services After-Sales Support Processes Conducting Customer Relationship Management Processes Conducting Advertising/Campaign/Promotion Processes Conducting Marketing Processes for Products/Services
AUDIO-VISUAL RECORDS	Conducting Activities in Compliance with Legislation Ensuring the Security of Physical Premises Conducting Occupational Health / Safety Activities Creating and Monitoring Visitor Records
PASSPORT, FLIGHT INFORMATION, SOLE PROPRIETORSHIP INFORMATION	Conducting Activities in Compliance with Legislation Conducting Contract Processes Conducting Goods/Services Sales Processes

3. Methods of Collecting Your Personal Data and the Legal Grounds

Your personal data are collected by automated means through GÜRMEN, KİP and RAMSEY stores, by our employees, business partners or suppliers, via security cameras and devices, through the recording in our systems of all kinds of purchases, collections, deliveries, transactions, survey completions, registrations and operations, through the Loyalty Card membership agreement form and through the recording of the requests and complaints you submit; by partially automated means, such as the recording in our systems of the information you verbally provide to sales consultants in our stores; by non-automated means, such as the recording of information/documents concerning you received from official institutions, organisations and judicial/administrative authorities and the recording of entries relating to your return/inspection processes in the relevant documents; and by automated means when you visit the GÜRMEN, KİP and RAMSEY websites and mobile applications and shop through those channels, and through the recording of the requests and complaints you submit and of your calls with our call centre.

Your name and surname are processed on the basis of the following legal grounds:

• The explicit consent of the data subject;
• Processing of personal data belonging to the parties to a contract being necessary, provided that it is directly related to the establishment or performance of that contract;
• Processing being necessary for the establishment, exercise or protection of a right;
• Processing being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Your date of birth and gender are processed on the basis of the following legal grounds:

• The explicit consent of the data subject;
• Processing being necessary for the establishment, exercise or protection of a right;
• Processing of personal data belonging to the parties to a contract being necessary, provided that it is directly related to the establishment or performance of that contract.

Your passport information, flight information, sole proprietorship information, nationality, Turkish ID number and signature (where you shop at our airport stores) are processed on the basis of the following legal grounds:

• Processing of personal data belonging to the parties to a contract being necessary, provided that it is directly related to the establishment or performance of that contract;
• Processing being necessary for the data controller to fulfil its legal obligation.

Your e-mail address is processed on the basis of the following legal grounds:

• The explicit consent of the data subject;
• Processing being necessary for the establishment, exercise or protection of a right;
• Processing of personal data belonging to the parties to a contract being necessary, provided that it is directly related to the establishment or performance of that contract.

Your telephone number is processed on the basis of the following legal grounds:

• The explicit consent of the data subject;
• Processing of personal data belonging to the parties to a contract being necessary, provided that it is directly related to the establishment or performance of that contract;
• Processing being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Your address is processed on the basis of the following legal ground:

• Processing of personal data belonging to the parties to a contract being necessary, provided that it is directly related to the establishment or performance of that contract.

Your password and membership page login/logout records are processed on the basis of the following legal grounds:

• Processing of personal data belonging to the parties to a contract being necessary, provided that it is directly related to the establishment or performance of that contract;
• Processing being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Your location data are processed on the basis of the following legal ground:

• The explicit consent of the data subject.

Your cookie records and information obtained through marketing – campaign activities, such as favourites, likes, behaviours, preferences, search activity, segments, cookie and advertising identifier/ID information, communication preferences, survey responses, demographic information and customer requests/complaints, are processed on the basis of the following legal grounds:

• The explicit consent of the data subject;
• Processing being necessary for the establishment, exercise or protection of a right.

Your purchase history information, message type, message subject, subject title, message content, order number, product name and invoice number are processed on the basis of the following legal grounds:

• Processing of personal data belonging to the parties to a contract being necessary, provided that it is directly related to the establishment or performance of that contract;
• Processing being necessary for the establishment, exercise or protection of a right;
• Processing being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Your body size and measurement information is processed on the basis of the following legal ground:

• Processing of personal data belonging to the parties to a contract being necessary, provided that it is directly related to the establishment or performance of that contract.

Your audio-visual records are processed on the basis of the following legal grounds:

• Processing being necessary for the data controller to fulfil its legal obligation (where you shop at our airport stores);
• Processing being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

4. Transfer of Personal Data

Your personal data such as name and surname, e-mail address, telephone number, body size and measurement information, passport information, flight information, Turkish ID number, nationality and sole proprietorship information may, in accordance with the conditions set out in Articles 8 and 9 of the Law, be transferred for the purposes of:

• Conducting advertising/campaign/promotion processes,
• Conducting marketing processes for products/services,
• Conducting request and complaint processes,
• Conducting goods/services after-sales support processes,
• Conducting activities in compliance with legislation.

Your personal data may be transferred by GÜRMEN GROUP, provided that adequate and effective measures are taken in accordance with the security and confidentiality principles set out in the legislation, to public institutions or organisations authorised by law to request such data, and to the business partners and suppliers with whom we cooperate, as GÜRMEN GİYİM SAN. TİC. A.Ş., the GÜRMEN GROUP company to which our company belongs, in order to deliver our products and services (such as cargo companies for the delivery of products and call centres for customer relations), pursuant to Article 8 of the Law and within the scope of the processing purposes stated above.

Your Rights under the Law

As data subjects, pursuant to Article 11 of the Personal Data Protection Law, you have the right to: learn whether your personal data are processed; request information if your personal data have been processed; learn the purpose of the processing of your personal data and whether they are used in accordance with that purpose; know the third parties in Türkiye or abroad to whom your personal data are transferred; request the rectification of your personal data if they are incomplete or inaccurately processed, and request that the action taken in this respect be notified to the third parties to whom your personal data have been transferred; request the erasure or destruction of your personal data where the reasons requiring their processing no longer exist, even though they have been processed in accordance with Law No. 6698 and other relevant legislation, and request that the action taken in this respect be notified to the third parties to whom your personal data have been transferred; object to any result to your detriment arising from the analysis of your processed data exclusively through automated systems; and claim compensation for damages if you suffer loss as a result of the unlawful processing of your personal data. For this purpose, you may find further details in the personal data processing policy available at www.gurmen.com.tr. If you submit your requests in writing by e-mail to gurmen@gurmen.com.tr, by hand delivery to our company address (Mehmet Nesih Özmen Mahallesi, Keresteciler Sitesi Kızılcık Sokak No: 23 34173 Merter, Güngören İstanbul/Türkiye), or via our registered electronic mail (KEP) address gurmengiyimas@hs01.kep.tr, a secure electronic signature, a mobile signature or the e-mail address you have previously notified to Gürmen, your request will be concluded within thirty days at the latest, depending on its nature.

GÜRMEN reserves the right to verify your identity before responding.

Your application must include:

• Your name, surname and, if the application is made in writing, your signature;
• For citizens of the Republic of Türkiye, your Turkish ID number; for foreign nationals, your nationality, passport number or, if any, identity number;
• Your residential or business address for the service of notifications;
• If any, your e-mail address, telephone and fax number for notifications;
• The subject of your request. Any information and documents relating to the subject, if any, must also be attached to the application.

Data subjects who have given consent to GÜRMEN for the sending of commercial electronic communications may, at any time and without giving any reason, refuse to be contacted via the contact details they have provided regarding general and special campaigns, benefits, product and service promotions, advertising, market research surveys and other customer satisfaction activities.

Data subjects/members may submit such a refusal notice at Gürmen, KİP and Ramsey stores or through the other relevant channels mentioned above.

In accordance with the explicit notice of the data subject/member on this matter, communications to them via the channels specified will be stopped within the maximum period prescribed by law (transactions and communications that are permitted or required by law will continue).