Personal Data Protection Notice

The processing and protection of personal data is among the top priorities of Küçükler Tekstil Sanayi ve Ticaret Anonim Şirketi (hereinafter referred to as the “Company”), and utmost effort is made to carry out operations in compliance with the applicable legislation.

This policy explains the principles adopted in the processing activities carried out by our Company and the fundamental principles our Company follows regarding data processing in accordance with the Personal Data Protection Law No. 6698 (the “Law”).

1. Scope

This policy applies to all personal data of our Company’s employees and officers, as well as other individuals, processed either automatically or manually as part of any data recording system.

2. Matters Regarding the Processing of Personal Data

2.1 Principles of Processing Personal Data

• In accordance with the law and principles of honesty,
• Accurate and up-to-date,
• For specific, explicit, and legitimate purposes,
• Relevant, limited, and proportionate to the purposes for which they are processed,
• For the duration prescribed or required by the relevant legislation.

2.2 Processing of Personal Data

Explicit consent of the data subject is only one of the legal grounds that make lawful processing of personal data possible. Personal data may be processed without explicit consent in the following cases:

1. Explicitly stipulated by laws,
2. Consent cannot be obtained due to actual impossibility,
3. Directly related to the establishment or performance of a contract,
4. Fulfillment of a legal obligation,
5. Data has been made public,
6. Required for the establishment or protection of a right,
7. Processed within the scope of legitimate interest.

2.3 Special Categories of Personal Data

Special categories of personal data are under extra protection because unlawful processing may cause victimization or discrimination. These data are processed with administrative and technical measures determined by the Board.

The categories of personal data processed by our Company include: identity information, contact information, financial information, legal transaction information, personnel records, customer and transaction information, marketing information, request and complaint information, location data, special categories of personal data, and similar data.

3. Transfer of Personal Data

3.1 Transfer of Personal Data

Personal data may be transferred to third parties in accordance with Articles 8 and 9 of the Law, provided that necessary security measures are taken.

3.2 Parties to Whom Personal Data is Transferred

• Suppliers
• Business partners
• Legally authorized public institutions
• Legally authorized private institutions

4. Rights of the Data Subject

Under Article 11 of the Law, data subjects have the right to learn whether their personal data is processed, request correction or deletion, know the third parties to whom it is transferred, and demand the elimination of any resulting damage.

To exercise your rights, you can fill out the application form on www.comfytex.com.tr or send an email to kvkk@comfytex.com.tr.