Privacy Policy

Last updated: January 28, 2026

1. Introduction

As eteklifim (hereinafter referred to as "eteklifim", "we", "us", "our" and similar words), we respect your privacy and are committed to providing a secure online experience through our service ("service") while adhering to a global privacy perspective. This Privacy Policy ("Policy") describes our practices and policies regarding the use and processing of personal information when providing the services ("services"). In this context, this policy explains the types of personal information we collect through our services, how we use this information, the legal basis for doing so, with whom we share it, your rights and choices regarding this matter, how you can contact us about our privacy practices, and your ability to control certain uses of such personal information. This policy does not apply to third-party sites, products, or services, even if they link to our services, and you should carefully evaluate the privacy practices of these third parties.

1. Service

eteklifim is a service that enables companies (hereinafter referred to as "Company", "you" or "your" depending on the context) to easily prepare catalogs, share these catalogs, and receive orders through catalogs (hereinafter referred to as "service").

1. Acceptance of the Policy

By accepting this policy, you acknowledge that you have learned about the practices described in this policy and the terms of service ("terms") that govern this policy and include all warranty disclaimers and limitations of liability. If you do not accept the processing activities foreseen in this policy, please do not access the services further and/or delete your account immediately.

1. Applicability of the Policy

Since our activities target the Turkish market, we aim to reflect our compliance with national legislation regarding privacy and data protection. Therefore, while following general principles and other regulations worldwide, we make great efforts to act in accordance with KVKK (Personal Data Protection Law).

1. Personal Information We Collect

We only retain personal information that you share with us regarding yourself to provide the services. We do not collect information from third parties. However, please note that if you refuse to provide any of the mandatory information requested for the provision of the service, you may not be able to fully benefit from the Services and features or may not be able to make a purchase from us.

We may use and store different types of personal information about you described below solely to identify your account.

a) Personal Information We Collect Directly from You

Personal information you may provide includes:

Registration and Account Information

If you wish to access the services, you must create a subscription. Since your subscription-related transactions will be conducted through your email account, the email account you specify will be retained, and information regarding the services and promotions may be shared with you through this email.

Invoices and Commercial Information Related to Subscription Fees

For the invoice to be issued to you regarding subscription fees, it is necessary to share with us the company name (natural or legal person), tax number, tax office, and address information. The relevant information will not be used except for billing purposes and will be retained solely for this purpose.

Other

All transactions made on the service, including catalogs prepared by you on the service, orders placed to you, and approval or rejection information regarding these, will be stored on our servers and kept ready for your use, and this information will not be used by us in any way outside the service.

Additionally, you may prefer to send information through other methods, including:

• Providing your email and other contact information; • Teleconferences, video conferences, and other meetings; your preferences, feedback, opinions, and business needs, and recordings of these sessions if you give your consent, • In connection with a real or potential business relationship with us.

1. How Is Your Personal Information Used?

We base our use of your personal information on various legal grounds to ensure that our use complies with applicable laws. We will most commonly use your personal information in the following situations:

• When necessary for the performance of a contract with you or to take necessary steps to enter into a contract with you (e.g., terms of service). • When you have consented to the processing of your personal data for a specific purpose (e.g., when you consent to promotional communications for email marketing purposes). • When necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. (For example, when there is fraudulent activity related to your transactions) • When we need to comply with a legal or regulatory obligation (e.g., when we are legally required to disclose your personal information).

Purposes for which we will use your personal information;

Our purposes for processing your personal information and the legal basis on which we rely are explained below:

Pre-contractual, contractual, and post-contractual business relationships. We process personal information to enter into a legal relationship with counterparts and fulfill contractual obligations under the terms. The activities we carry out in this context include:

• To provide you with the Service, for example • To register you as a company and create your account so you can access our Services, • To manage and support the Services you request, including sending service notifications, managing and supporting the provision of our services, managing payments, and exercising our legal rights, • To share orders created with catalogs produced as a requirement of the service with the company and enable the company to communicate its approval-rejection mechanism, • To ensure that the information about companies' approval or rejection of orders reaches the persons who placed the orders, • To manage our relationship with you, which will include: (a) informing you about changes to our Terms or Privacy Policy (b) requesting that you update your information (c) addressing any issues or feedback you may have, • To process, maintain, and service your account(s), • To respond or communicate with you, for example when you • Open an account, • Make a request or inquiry through a contact form or another channel reserved for such use, • When there is suspicion of fraudulent activity against you, • When you share a comment/review or concern regarding any of our services.

Legal and regulatory compliance. We use personal information to verify the identity of service users to comply with applicable laws. These obligations are imposed on us by the operation of laws, industry standards, and may require us to report our compliance to Third Parties and be subject to third-party verification audits. Examples of how we use information under this condition include:

• Accounting, auditing, and billing activities; • Responding to court decisions, lawsuits, court summons, and government requests; addressing legal and regulatory compliance, • Communications regarding payments and related pre-sale and post-sale communications as required by applicable laws.

Legitimate business interests. We may have legitimate business interests in processing certain personal information about you. The list below sets out the business purposes we have identified as legitimate. In determining the content of this list, we have balanced our own interests against the legitimate interests and rights of the natural/legal persons whose personal information we process. Examples of how we use information under this condition include:

• Reducing financial loss, claims, liability, or other damages to companies and us; • Protecting the security or integrity of the service and our business; for example, protecting against and preventing fraud, unauthorized transactions, claims, and other liabilities, and managing risk probabilities, including detecting potential hackers and other unauthorized users; • Answering questions, sending service notifications, and providing customer support; • Introducing, analyzing, modifying, and improving our systems and tools and developing new services;

Data processing based on your explicit consent given in advance. We rely on your explicit consent given in advance to process your personal information for the following purposes:

• To send you marketing and commercial emails, • To include you in our newsletter,

Marketing and Advertising Activities

We may send you marketing and advertising communications about services; we may invite you to participate in our events or surveys, or we may otherwise communicate with you for marketing purposes.

To offer you all the advantages of our Service, we ask for your permission to send you information about the latest news, special events, offers, promotions, and other advantages. We also ask for your permission to send you our newsletter. With your permission, we will use your email address to communicate with you with this information.

If you decide at any time that you no longer wish to receive such marketing communications from us, please follow the unsubscribe instructions provided in any communication. You can also stop receiving commercial emails from us by sending your request to us via email.

Please contact us to update your preferences, request that we remove your information from our mailing lists, delete your account, or request to exercise your rights under applicable laws.

1. How Is Personal Information Shared?

Your personal information cannot be rented or sold. Access to your information will only be for the purpose of enabling you to use the service. We also limit sharing to authorized employees only in case of support requests and do not share your information with Third Parties.

Sharing with Users as Required by the Service

Companies that create catalogs on the service will determine the information to be included in these catalogs themselves. Companies will have the opportunity to share their own company/personal information, email, phone, website, and other information in the catalogs they will share. They can choose whether to share the information shared here or share more information. The responsibility for the use of the information shared here by the persons to whom the catalogs are sent lies entirely with the company. To clarify, eteklifim has no responsibility regarding the accuracy of the information produced and shared on the service, with whom it is shared, or the use of the shared information by the shared persons.

Employees and Authorized Contractors

Our employees and authorized contractors may need to access information about you when they need this information to do their jobs. For example, a customer support representative may need to access your account to verify your identity and respond to your question or request; our email communication team may need to access your contact information to ensure that this information is sent correctly and that unsubscribe requests are managed properly, and our security personnel may need to review information to investigate denial of service attacks, fraudulent account activity, or other attempts to compromise the Services. All our employees and contractors must agree to protect and maintain the confidentiality of your information.

Law Enforcement, Government Agencies, and Professional Advisors

We may need to disclose information about you when we reasonably believe it is necessary to comply with a law or regulation or when we are legally required to do so otherwise, for example (i) to comply with applicable laws or payment method rules; (ii) to enforce our rights arising from the contract, including our Terms and this Privacy Policy; (iii) to protect our, your, or others' rights, privacy, security, and property, and (iv) to respond to requests from courts, law enforcement, regulatory agencies, and other public and government authorities, which may include authorities outside the country where you reside. For official data access requests concerning you or your organization, we will try to forward the request to you first and/or inform you first, unless we are legally prohibited from doing so. We also use professional advisors, including lawyers and accountants, and we may need to disclose information about you when engaging them for their services and when necessary for audits, financial, and other regulatory reviews.

1. Your Communication Options

Legal Communication and Service Announcements

By providing us with your email address and/or using the Website/Platform, you consent to the use of your email address for legal and service notifications or to send you notifications via pop-ups, etc., regarding important service announcements and other legal and administrative communications related to your use of the application or service. We may send you the following via email or by posting in the Application; this policy, including legal disclosures, our terms; future changes to this policy, terms, and other notifications, legal communications or disclosures, and information about services. Such communications are part of the services you cannot opt out of. However, if you do not wish to receive certain service and other administrative and legal notifications, the only way to opt out of such messages is to stop using the service and delete your account.

Promotional Communication

You may receive marketing and advertising communications (for example, to inform you about service features, new features, or developments, to offer you promotion codes or coupons) with your prior explicit consent. You can subscribe to our newsletter, contact us via email, or give your explicit consent in the relevant fields to receive marketing and advertising communications. Due to our privacy practices, we offer companies the option to "opt-in" and "opt-out" of receiving marketing and advertising communications, except for purposes directly related to transactions you make with us and general legal and administrative communications regarding your account.

If you choose to participate in promotional communications, you may receive periodic promotions and other offers or materials that we think may interest you until you cancel or opt out of your subscription.

Withdrawing Your Consent

If you later decide that you do not want to receive future promotional communications electronically, you can withdraw your consent. You can cancel promotional communications at any time by (i) following the instructions described in this policy or (ii) following the unsubscribe instructions included in each message or (iii) changing the communication preferences in your account. In any case, you can send us an email at support@eteklifim.com.tr. Your withdrawal of consent will be effective within a reasonable time (and within 3 days at the latest) after we receive your withdrawal notice described above.

Updating Your Information

You can access and update certain personal information you have provided to us by logging into your online account and using the features and functions available there.

1. How Are Your Personal Information Protected?

We make reasonable efforts to provide you with an appropriate level of security against the risk related to the processing of your personal information. We use organizational, technical, and administrative measures designed to appropriately protect your personal information against unauthorized access, destruction, accidental loss, unauthorized modification, or misuse. Only a limited number of personnel who need access to this information to perform their duties can access your personal information. Please remember that no security measure is perfect or impenetrable. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you think your account has been compromised), please contact us immediately.

We will make all legally required disclosures regarding a breach of the security, privacy, or integrity of your personal information stored electronically in unencrypted form, consistent with (i) the legitimate needs of law enforcement or (ii) measures necessary to determine the scope of the breach and restore reasonable integrity of the data system and other disclosures that may be required under applicable laws, at the most appropriate time possible and without unreasonable delay, via email or by posting prominently on our Service. Additionally, unless we are legally required to retain this information for a longer period, we take measures to delete your personal information or store it in a form that does not allow identification when this information is no longer necessary for the purposes for which we process it. In determining the retention period, we consider various criteria such as the type of products and services requested by you or provided to you, the nature and length of our relationship with you, the likelihood of re-registration with our products or services, the impact on the services we provide to you if we delete some information from you or about you, mandatory retention periods provided by law, and statute of limitations.

We conduct service provider security and privacy reviews to ensure that service providers comply with our strict requirements to protect your information, and we also sign data protection agreements with our service providers.

1. Retention

Your personal information may be retained for as long as reasonably necessary to achieve the purposes listed in the "How Personal Information Is Used" section. For example, if you open an account, we will retain all personal information associated with your account for as long as you remain registered or we believe we can provide you with service.

After we stop providing you with the Service, even if you close your account, we retain personal information to the extent necessary to comply with our legal and regulatory obligations. We also retain personal information when we need to retain data to comply with our tax, accounting, and financial reporting obligations, due to our contractual commitments to our financial and business partners, and when data retention is required by applicable laws. When we retain data, we do so in accordance with the limitation periods and record retention obligations brought by applicable laws.

The servers and databases where information may be stored may be located outside the country from which you access our Services and in a country where data protection and other laws may differ from those in your country of residence. Your personal information may be disclosed in response to questions or requests from official authorities or to respond to legal proceedings in the countries where we operate.

1. Deletion of Personal Data

Your personal data specified in the privacy policy and data created in relation to the service (Catalogs, approval and rejection information, etc.) are deleted when the cases specified below occur. Your data will be retained until the specified situations occur, and you are responsible for doing what is necessary to prevent your data from being lost when the situations specified below occur.

• Your Request: All your data will be deleted within 72 hours at the latest if you have a written request. • Termination of subscription: If you terminate your subscription or do not renew it, all your data will be retained for 14 more days and then deleted. • Legal requirements: Your data may also be deleted immediately if there is a situation requiring the deletion of your relevant data due to the regulations to which eteklifim is subject.

1. International Data Transfer

Your personal information will be processed by us within the European Economic Area (EEA). Specifically, our servers are located at AWS, Frankfurt, Germany. Server service is provided to us by an organization called Supabase. Email services are obtained from an organization called Loops. Users of the service are advised to also learn about the Privacy Policies of the relevant organizations.

1. Updates and Notifications to This Policy

We may change this Policy from time to time in response to changing legal, technical, or commercial developments. Any changes will become effective when we publish the updated Policy on the webpage. When we update our Privacy Policy, we will take appropriate measures to inform you in a manner consistent with the importance of the changes we make. If required by applicable data protection laws and in cases required by these laws, we will obtain your consent for any significant privacy policy changes. You can see when this privacy policy was last updated by checking the "last updated" date displayed at the top of this privacy policy.

1. Links to Other Websites

Services may provide the ability to link to other sites. These sites may operate independently from us and may have their own privacy notices or policies, which we strongly recommend you review. If any linked website is not owned by us or is not controlled by us, we are not responsible for its content, use of the website, or the privacy practices of the website operator.

As a security measure, we recommend that you do not share any personal information with these third parties unless you have checked their privacy policies and are sure about their privacy practices.

1. Applicable Law and Competent Court

eteklifim ensures that privacy is not something to be concerned about but something to be "referred to" by following global developments with a focus on Law No. 6698 on the Protection of Personal Data. Turkish Law will apply to disputes arising from this contract, and the jurisdiction is Istanbul Courts.

1. Contact Us

If you have any questions or concerns about our privacy practices or to request a copy of this Policy in another format, you can reach us. Please do not hesitate to contact us at support@eteklifim.com.tr provided on the webpage and below this Policy.

EXERCISING YOUR KVKK RIGHTS

You have the rights specified below in accordance with KVKK Article 11 and other provisions. You can send an email to support@eteklifim.com.tr to exercise the relevant rights. Everyone has the following rights regarding themselves by applying to the data controller;

• a- Learning whether personal data is processed,

• b- Requesting information if personal data has been processed,

• c- Learning the purpose of processing personal data and whether they are used in accordance with their purpose,

• ç- Knowing the third parties to whom personal data is transferred domestically or abroad,

• d - Requesting correction of personal data if it is incomplete or incorrectly processed,

• e- Requesting deletion or destruction of personal data within the framework of the conditions foreseen in Article 7,

• f- Requesting that the operations carried out in accordance with subparagraphs (d) and (e) be notified to the third parties to whom personal data has been transferred,

• g- Objecting to the emergence of a result against the person by analyzing the processed data exclusively through automated systems,

• ğ) Requesting compensation for damage in case of damage due to unlawful processing of personal data.