PRIVACY AND COOKIE POLICY

PRIVACY POLICY

As Passus Global, we work to protect the privacy of our members who use our site in order to ensure that our users can benefit from our services in a safe and complete manner. Accordingly, this Passus Global Privacy Policy (“Policy”) has been prepared in order to process the personal data of our members in full compliance with the Law on the Protection of Personal Data No. 6698 (“Law”) and to inform our users in this context. www.passusglobal.com cookie policy is an integral part of this Policy.

The purpose of this Policy is to be used by Platform members/visitors/users (collectively referred to as “Data Owner”) during the operation of the www.passusglobal.com website and mobile application (collectively referred to as “Platform”) operated by Passus Global. It determines the terms and conditions regarding the use of personal data shared with Global or generated by Passus Global during the use of the Platform by the Data Owner.

Which Data is Processed?

The data processed by Passus Global and considered as personal data in accordance with the Law are listed below. Unless expressly stated otherwise, the term “personal data” within the scope of the terms and conditions provided under this Policy will include the information below.

Credentials Communication information User Information User Transaction Information Transaction Security Information Financial Information Marketing Information Request/Complaint Management Information

Data that has been irreversibly anonymized pursuant to Articles 3 and 7 of the Personal Data Protection Law will not be considered as personal data in accordance with the provisions of the aforementioned law, and the processing activities regarding this data will be carried out without being bound by the provisions of this Policy.

Personal Data Processing Purposes

Passus Global manages the personal data provided by the data owner, creating the membership registration and account and keeping the related records, making use of the services provided on the Platform by the Data Owner, detecting system errors and monitoring the performance and improving the operation of the Platform, maintenance and support services and backups. Necessary work is carried out by the business units in order to benefit from the products and services offered by Passus Global, including for the purposes of providing services, and the relevant business processes are carried out; Planning and execution of the activities, carrying out the commercial activities carried out by Passus Global, carrying out the necessary work by the relevant business units and conducting the related business processes, ensuring the legal, technical and commercial-occupational security of Passus Global and the people with whom it has business relations, and It may be processed for the purposes of planning and executing commercial and/or business strategies.

Personal Data to be Processed in accordance with the Explicit Consent of Data Owners and Purposes of Processing

Within the scope of the explicit consent of the Data Owner, Passus Global monitors the Data Owners' movements on the Platform to increase the user experience, to create statistics, to profile, to direct marketing and remarketing, to create and transmit special promotional offers to the Data Owner. and in order to use the data obtained in this context in all kinds of advertisement and material content, it may process data and share this data with the parties mentioned below.

Transfer of Personal Data

Passus Global may transfer the personal data of the Data Owner and the new data obtained using this personal data to third parties from whom Passus Global's services are used in order to achieve the purposes set out in this Privacy Policy, limited to the provision of such services. Passus Global aims to improve the Data Owner experience (including improvement and personalization), to ensure the security of the Data Owner, to detect fraudulent or unauthorized use, to investigate operational evaluation, to correct errors regarding Platform services, and to fulfill any of the purposes in this Privacy Policy. It will be able to share it with third parties such as outsourcing service providers, hosting service providers (hosting services), law firms, research companies, call centers, including those sending SMS.

Personal data may be shared with Passus Global Company officials, shareholders, business partners, suppliers, legally authorized public institutions and organizations and legally authorized private institutions within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, limited to these purposes. Blood

It can be transferred abroad within the framework of the procedural principles indicated in Article 9 of the UN and the decisions of the Personal Data Protection Board.

Personal Data Collection Method and Legal Reason

Personal data is collected through the Platform and electronically. Personal data collected for the above-mentioned legal reasons can be processed and transferred for the purposes specified in Articles 5 and 6 of the Law No. 6698 and this Privacy Policy.

Rights of Personal Data Owner

Pursuant to Article 11 of the Law, data owners are required to learn whether personal data is processed about them, to request information if their personal data has been processed, to learn the purpose of processing personal data and whether they are used in accordance with its purpose, to learn about third parties in the country or abroad to whom personal data is transferred. To know, to request correction of personal data in case of incomplete or incorrect processing and to notify the third parties to whom the personal data has been transferred, to delete or destroy the personal data in case the reasons requiring its processing disappear even though it has been processed in accordance with the provisions of the law and other relevant laws. to request and to notify the third parties to whom the personal data has been transferred, to object to the emergence of a result against the person by analyzing the processed data exclusively through automatic systems, and to demand the compensation of the damage in case of damage due to the unlawful processing of personal data. Requests regarding the exercise of these rights can be submitted by the personal data owners through the methods specified in the Policy on the Processing and Protection of Personal Data prepared by Passus Global within the scope of the law numbered 6698 at www.passusglobal.com. Passus Global will conclude such requests within thirty days. Passus Global reserves the right to charge a fee based on the fee schedule (if any) determined by the Personal Data Protection Board.

COOKIE POLICY:

As Passus Global, we work to protect the privacy of the people who use our site in order to ensure that our users can benefit from our services in a safe and complete manner.

As with most websites, Cookies are used to display personal content and advertisements to visitors, to perform analytical activities on the site and to track visitor usage habits, in www.passusglobal.com (“Site”) and mobile application (collectively referred to as “Platform”).

This Cookie Policy is an integral part of the www.passusglobal.com Privacy Policy.

Passus Global has prepared this Cookie Policy (“Policy”) to explain which Cookies are used on the Site and how users can manage their preferences in this regard. For more detailed information on the processing of your personal data by Passus Global, we recommend that you review the www.passusglobal.com Privacy Policy.

What is a cookie (“Cookie”)?

Cookies are small text files that are stored on your device or network server via browsers by the websites you visit. Cookies are created by servers associated with the website you are visiting. In this way, the server can understand when the visitor visits the same site.

Which Cookies Are Used?

Cookies can be categorized in terms of their owner, lifetime and intended use: Platform cookies and third-party Cookies are used, depending on the party placing the cookie. Platform cookies are created by Passus Global, while third-party cookies are managed by different companies in cooperation with Passus Global. Session cookies and persistent cookies are used according to the duration of the activity. Session cookies are deleted when the visitor leaves the Platform, while permanent cookies may remain on the visitors' devices for various periods depending on the usage area. According to usage purposes, technical cookies, verification cookies, targeting/advertising cookies, personalization cookies and analytical cookies are used on the Platform.

Why Are Cookies Used?

Cookies are used on the Platform for the following purposes: To perform the basic functions necessary for the Platform to work. For example, Passus Global members do not lose the products in the shopping cart during their visit. The logged-in members do not need to enter passwords again while visiting different pages on the Platform. Analyzing the Platform and improving its performance. For example, the integration of different servers that the Platform works on, determining the number of visitors to the Platform and adjusting performance accordingly, or making it easier for visitors to find what they are looking for. Increasing the functionality of the Platform

MEMBERSHIP AGREEMENT 1. Parties a) Yaşamkent Mah., which carries out the activities of the website www.passusglobal.com. 3250 Cad. Passus Global, located at Building No: 24/A No: 13/27 Çankaya/Ankara

b) Internet user who is a member of the www.passusglobal.com website ("Member")

2. Subject of the Contract The subject of this Agreement is to determine the terms of use of the member from the website of Passus Global, www.passusglobal.com.

3. Rights and Obligations of the Parties 3.1. The member declares and undertakes that the personal and other information provided while becoming a member of the www.passusglobal.com website is correct before the law, and that Passus Global will indemnify all damages incurred due to the untrueness of this information.

3.2. The member cannot give the password given to him by Passus Global to other persons or organizations, the member has the right to use the password in question. Passus Global reserves the right to claim all kinds of compensation and other claims arising from such unauthorized use against all claims and demands that may be brought against Passus Global by third parties or authorized authorities with all liability that may arise for this reason.

3.3. The member accepts and undertakes in advance to comply with the provisions of the legal regulations and not to violate them while using the www.passusglobal.com website. Otherwise, all legal and penal obligations to arise will bind the member completely and exclusively.

3.4. The member may not use the www.passusglobal.com website in any way that disrupts public order, violates public morals, disturbs and harass others, for an unlawful purpose, infringing on the intellectual and copyright rights of others. In addition, the member may not engage in activities (spam, virus, etc.) and actions that prevent or make it difficult for others to use the services.

3.5. The ideas and thoughts expressed, written and used by the members on the www.passusglobal.com website are completely the personal views of the members and bind the opinion holder. These views and thoughts have no interest or connection with Passus Global. Passus Global has no responsibility for the damages that the member may incur due to the ideas and opinions expressed by the member, and the damages that the member may incur due to the ideas and opinions expressed by the third parties.

3.6. Passus Global will not be liable for unauthorized reading of member data and any damage to member software and data. The Member has agreed in advance not to claim compensation from Passus Global for any damage he may incur due to the use of the www.passusglobal.com website.

3.7. The member agrees not to access or use other internet users' software and data without permission. Otherwise, the legal and penal responsibilities arising from this will belong to the member completely.

3.8. The member who violates one or more of the articles listed in this membership agreement is personally liable criminally and legally for this violation and will keep Passus Global free from the legal and penal consequences of these violations. Moreover; In the event that the incident is referred to the legal field due to this violation, Passus Global reserves the right to claim compensation against the member for non-compliance with the membership agreement.

3.9. Passus Global always has the right to unilaterally delete the membership of the member and delete the files, documents and information of the customer when necessary. The member accepts this savings in advance. In this case, Passus Global has no responsibility.

3.10. The name and Internet Protocol (IP) address of the Internet service provider used by Passus Global for the improvement and development of the www.passusglobal.com website and/or to access the site within the framework of legal regulations, the date and time the site was accessed, the pages accessed while on the site and the site. Some information may be collected, such as the Internet address of the Web site that provides a direct connection.

3.11. Passus Global may use the personal information of the members to provide better service to its users, to improve its products and services, to facilitate the use of the site, to work on the special preferences and interests of its users. Passus Global reserves the right to keep a record of the member's actions on the www.passusglobal.com website.

3.12. The person who is a member of Passus Global declares and accepts that he/she allows product and service promotions, advertisements, campaigns, advantages, surveys and other customer satisfaction practices to be presented to him/her by Passus Global and all its affiliate companies within the scope of the practices in force and/or to be implemented. . The member collects all personal and shopping information and shopping and/or consumer behavior information that he/she has given in the past and/or will give in the future while becoming a member of Passus Global and/or in other ways, for the above purposes.