CLARIFICATION TEXT

CLARIFICATION TEXT TO THE LAW ON THE PROTECTION OF PERSONAL DATA (THE "CLARIFICATION TEXT")

Welcome, and thank you for your interest in the products and services provided by 3 STARS TUR. GID. İNŞ. TAŞ. PAZ. İTH. VE İHR. LTD. (visit our website www.3-stars.com for more information).
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PREAMBLE
This "Clarification Text" is prepared by 3 STARS TURİZM GIDA İNŞAAT TAŞIMACILIK TİCARET PAZARLAMA İTHALAT VE İHRACAT LİMİTED ŞİRKETİ (the "3 STARS Ltd."), acting as the "Data Controller" under Article 10 of the Personal Data Protection Law No. 6698, effective 07.04.2016 (the "Law"), and the Communiqué on the principles and procedures to be followed in fulfilling obligations to inform you regarding your processed personal data, submitted and collected within operating activities "3 STARS Ltd." in accordance with your fundamental rights established by the Constitution of the Republic of Turkey (the "Constitution").

Your data is processed and protected by "3 STARS Ltd." within the framework of the “Constitution”, the "Law", the General Data Protection Regulation, effective 25.05.2016 (the "GDPR"), and Federal Law No. 152 "On the Protection of Personal Data", effective 27.07.2006 (the "FZ-152").

"3 STARS Ltd." is obliged to inform the person concerned during the collection of personal data in accordance with Article 10 of the "Law":
— the identity of the "Data Controller" and his representative, if any,
- about the purpose of processing "Personal data", to whom and for what purposes the processed "Personal Data" may be transferred,
— on the methods and legal basis for the collection of "Personal Data",
— about other rights listed in Article 11 of the "Law",
and aims to inform you by submitting applications for "Personal Data" to data processing operations carried out by "3 STARS Ltd.", which has the status of "Data Controller" under the "Law" through this explanatory text.
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"3 STARS LTD." AS "DATA CONTROLLER"
"Data Controller" is defined under Article 3-1 of the "Law", as the natural or legal person who determines the purposes and means of processing "Personal Data" and is responsible for the establishment and management of the data filing system, and "3 STARS Ltd." is a "Data Controller" in terms of your data our esteemed clients/potential clients.
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THE PURPOSE OF PROCESSING YOUR "PERSONAL DATA"
“Personal Data” of our clients such as name and surname, date of birth, place of birth, mother's name, father's name, mobile phone number, e-mail address, identification number/numbers, other identification information, photos, bank account numbers, address, occupation information, device type, and other “Personal Data” in the form of tracking information about usage, IP address and information obtained from WLAN (Wireless Local Area Network), transaction history, access date and time, browser type and version and location information within the scope of all stages, including the conclusion, execution, and termination of the agreements you will make shall be processed in accordance with Article 20 of the “Constitution” and Article 4 of the “Law” for the following purposes:
3.1 providing our services and verifying your customer identity within the same scope,
3.2 protection of customer accounts and archives,
3.3 compliance with legal and administrative measures,
3.4 use of the products and services that you receive/to be received, communication of offers for new products and services to you,
3.5 maintaining customer satisfaction at a high level by measuring the performance of our systems,
3.6 planning commercial/business strategies,
3.7 ensuring the security of our website, mobile applications, other online applications, and products,
3.8 modeling, reporting, scoring, risk monitoring, intelligence, current or new product studies, and potential customer detection,
3.9 drafting information and documents that will be the basis for the work and operations to be performed,
3.10 compliance with the information retention, reporting and disclosure obligations stipulated by all judicial and administrative authorities in accordance with the relevant legislation and ensuring the execution of the requests or decisions made by these authorities,
3.11 notifying such authorities thereof for the purpose of investigation, detection, prevention of breach of contract and violation of “Law”,
3.12 settlement of current and potential legal disputes,
3.13 ensuring customer account security and system security; fulfilling our legitimate interests such as fulfilling obligations under anti-money laundering legislation and prevention of fraud and crime,
3.14 ensuring that our systems, services, and interface are accessible for users using all platforms (iOS, Android).

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TRANSFERRING YOUR "PERSONAL DATA"
Your “Personal Data” is stored safely under the control of the “3 STARS Ltd.” and not transferred to third parties except for the following cases:
— Your “Personal Data” shall be transferred by “3 STARS Ltd.” to its business partners, consultants, and competent courts and/or enforcement offices and public institutions and organizations for the purpose of legal and financial audits in Turkey in accordance with Article 8 of the “Law”, in order to realize the purposes of processing the “Personal Data” herein.
— In addition, your “Personal Data” may be transferred by “3 STARS Ltd.” directly or indirectly to any third party who has received or intends to receive or will receive consultancy, support, or other services, competent institutions and organizations within the framework of specified “Personal Data” processing conditions and purposes.

Specifically, “3 STARS Ltd.” can transfer, process, or store your “Personal Data” to:
4.1 persons, institutions, and/or organizations obliged/permitted by the provisions of the “Law” and other legislation,
4.2 all kinds of public legal entities and authorities authorized to receive “Personal Data”,
4.3 projects and startups owned by "3 STARS Ltd.", and wit it affiliated companies or groups of companies,
4.4 third parties from whom "3 STARS Ltd." receive services in the fields of “Law”, tax, etc. to carry out our activities,
4.5 the partners, institutions, organizations, domestic/foreign banks, funds, organizations with whom cooperated,
4.6 domestic/foreign/international organizations from which service/support/consultancy is provided or which are project/program/financing partners, and organizations from which independent audit and support services are provided,
4.7 provided that the necessary security measures are taken, electronic media such as servers, hosting companies, programs, cloud information technology, etc. located in Turkey or abroad, particularly the United Kingdom, Russian Federation, and countries of EU, OECD, and EMEA from which storage, archiving and information technology support are provided.

Your “Personal Data” can be transferred only under legal limitations due to legal obligations.
“3 STARS Ltd.” takes all the necessary technical and administrative measures in case your “Personal Data” is transferred to home or abroad. The data processing activity in the form of transferring the data abroad will be carried out on the condition that the “explicit consent” of the person concerned is obtained.
“3 STARS Ltd.” will make a reasonable effort to procure such third parties to take necessary technical and administrative measures to protect the “Personal Data” being transferred.
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COLLECTION OF YOUR "PERSONAL DATA"
Your “Personal Data” is processed:
5.1 with all agreements/information forms and other documents,
5.2 by means of your notifications,
5.3 through our website, mobile applications, other online applications, and products,
5.4 through your calls to our call center or call center where we receive services,
5.5 through third-party service providers,
5.6 through channels such as SMS, electronic mail, provided that in oral, written, or electronic media,

by means of various methods which are fully or partially automated, or non-automated as part of any data recording system, our collaborative partner organizations and institutions, government agencies, including domestic/international and the other 3rd persons other than “3 STARS Ltd.” and stored within the statutory legal periods set out within the framework of the legislation.

“Personal Data” collected for these legitimate reasons shall be processed and transferred by “3 STARS Ltd.” in accordance with the basic principles stipulated by the “Law”, “Personal Data” processing conditions and purposes specified in Article 5 and Article 6 of the “Law” for the purposes specified herein.
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YOUR RIGHTS UNDER ARTICLE 11 OF THE “LAW”
By applying to “Data Controller”, you have the right to:
6.1 learn whether “Personal Data” is processed,
6.2 request information if “Personal Data” has been processed,
6.3 learn the purpose of processing “Personal Data” and whether they have been used in accordance with the purpose,
6.4 be informed of the third parties from which “Personal Data” is transferred domestically or abroad,
6.5 request “Personal Data” to be corrected if it is incompletely or improperly processed,
6.6 request the deletion or destruction of “Personal Data” within the framework of the conditions stipulated in the Article 7 of the “Law”,
6.7 requesting the transactions made in accordance with paragraphs (5.5) and (5.6) to be notified to third parties to whom “Personal Data” has been transferred,
6.8 object to the appearance of a result against you by analyzing the processed data exclusively through automated systems,
6.9 claim to recover damages in case of damage caused by “Personal Data” illegal processing.
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APPLICATION OF "PERSONAL DATA" OWNER
You may submit your requests regarding your rights mentioned above at privacy@3-stars.com or 3stars@hs01.kep.tr addresses or from our address below in the written form.
If the action in question incurs another cost, the price set by the Personal Data Protection Board may be collected by 3 STARS Ltd.
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"CLARIFICATION TEXT" LANGUAGE
The “Clarification Text” has been arranged in three languages, namely English, Russian, and Turkish hence in case there is a conflict/contradiction between the three versions, the Turkish version shall prevail.
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"data controller" INFORMATION
Full Company Name: 3 STARS TURİZM GIDA İNŞAAT TAŞIMACILIK TİCARET PAZARLAMA İTHALAT VE İHRACAT LİMİTED ŞİRKETİ

Short Company Name: 3 STARS LTD. ŞTİ.

MERSIS No.: 0001190718700001

Address: 07980 Arslanbucak Mah. Çamarsı Cad. No:2/6 Kemer/Antalya

Website: https://www.3-stars.com

Registered Email: 3stars@hs01.kep.tr

Email: destek@3-stars.com