KVKK - Tre Tasarım

Data Controller

The website with the domain name www.tre.com.tr (“Website”) is operated by TRE Tasarım LTD. ŞTİ. (“Company”), located at Antalya Organize Sanayi Bölgesi 3. Kısım, 31. Cadde No: 11, Döşemealtı/Antalya. As the data controller, the COMPANY is responsible for determining the purposes and means of processing personal data, as well as for establishing and managing the data filing system.

We attach importance to the protection of your personal data. In accordance with the Law on the Protection of Personal Data (“KVKK”), we wish to inform you regarding the processing—including, but not limited to, the collection, storage, and transfer—of data obtained in connection with your use of the Company Website, as well as the purpose of such processing.

Processing and Transfer of Personal Data

The COMPANY requests certain personal data from customers who use the Company Website, either during the membership stage or while using the Company Website. Personal data refers to any information that makes a person identified or identifiable. Such information may include, for example, your name, address, e-mail address, or telephone number. Information collected via cookies that does not directly allow for your identification—such as how you use the Company Website—may also be classified as personal data if it is based on an identifier assigned to the user and is consequently collected, stored, and evaluated in an individualized manner. Non-personal data consists of information that cannot be linked to a real person because it has been aggregated, summarized, collected, and evaluated—potentially qualifying as “big data”—and rendered anonymous.

Your personal data is collected by our Company—inherent to the nature of the business—through information provided by the Data Subject via demo request forms, contact forms, e-newsletter forms, support systems, call centers, and membership forms. To identify system-related issues and rapidly resolve any problems or disputes arising from the service provided, our Company records and utilizes its members’ IP addresses. IP addresses may also be used to identify users in a general sense and to gather comprehensive demographic information.

Beyond the purposes and scope defined in the Membership Agreement, our Company may use the requested information—either directly or through its business partners—for direct marketing purposes. Personal information may also be used to contact the user when necessary. Information requested by our Company, provided by the user, or generated through transactions on the Company’s website may be used by our Company and its business partners—even outside the scope of the Membership Agreement—for various statistical evaluations, database creation, and market research, without disclosing the members’ identities.

From time to time, our Company may send notifications to its customers and members regarding campaign details, new packages, and promotional offers. Members may make choices regarding the receipt of such information during the sign-up process; subsequently, they may modify this preference via the management panel after logging in or by using the link provided in the notification messages they receive.

Purposes of Processing Personal Data

Our Company processes Personal Data for specific, explicit, and legitimate purposes. In this context, Personal Data may be processed for the purposes listed below:

• Provision and modification of services offered via the website,

• Customization of offered products and services in accordance with requests; and their updating and improvement due to customer needs as well as legal and technical developments,

• Defining users within the systems regarding the products and services offered,

• Announcing new or existing products, services, and campaigns, and conducting sales and marketing activities,

• Conducting market research,

• Generating statistics and analyzing usage patterns,

• Paying and collecting fees for products and services, and selecting collection methods,

• Fulfilling information obligations arising from the Law on the Regulation of Electronic Commerce (Law No. 6563) and other relevant legislation,

• Conveying advertisements for the Company website and for products and services aligned with the data processing purpose to the Data Subject, and providing information regarding products, services, promotions, and campaigns,

• Facilitating the resolution of issues encountered during website usage,

• Improving the experience regarding website visits, usage, page navigation, and purchasing, and providing higher quality service,

• Establishing contact/communication,

• Managing commercial relationships with partner companies, suppliers, resellers, and service providers,

• Conducting reporting within the scope of collaborations,

• Developing and planning the Company’s commercial strategies,

• Contacting Data Subjects for customer satisfaction surveys,

• Registering participants for events, training sessions, or competitions organized by the Company; issuing certificates or certificates of participation; determining prize or gift recipients; and delivering prizes or gifts,

• Managing judicial/administrative processes and responding to requests from public institutions and organizations,

• Fulfilling legal obligations in accordance with regulations and resolving legal disputes,

• Managing investor relations,

• Ensuring the execution of consequences arising from legal transactions such as the Company’s merger with another company, its division, or the transfer of all or part of its assets,

• Featuring Company employees, individual customers, and relevant parties in social media posts,

• Conducting job interviews and evaluating job applications,

• Establishing, managing, and terminating the employment relationship/contract,

• Enabling Company employees to benefit from primary and ancillary rights arising from employment contracts, and evaluating their performance and work,

• Creating user accounts for employees,

• Registering participants for events attended on behalf of the Company,

• Maintaining records of employee participation in training sessions and certifications,

• Ensuring the security of the Company Website and Applications,

• Analyzing usage of the Website,

• Creating a personal data inventory,

• Evaluating and responding to all inquiries, requests, suggestions, complaints, and applications—including those regarding personal data—transmitted in writing, verbally, or electronically.

• Data is transferred—for the performance of the contract, data security, compliance with company policies, and the other purposes mentioned above—to systems located domestically or in other relevant countries, particularly within the European Union (you may apply to our company in writing for more detailed information).

Method and Legal Basis for Personal Data Collection

Data concerning current and potential Company Website users is collected—via methods that are wholly or partially automated or non-automated—due to the requirements of our business operations, based on contractual grounds or other reasons established within the legal framework.

Personal Data Processed Without Explicit Consent

Pursuant to the KVKK (Personal Data Protection Law):

We may process personal information that you have made public (manifestly made public by you) and share it with third parties within this scope, without requiring your explicit consent.

We may process your personal data without your explicit consent and share it with third parties within this scope if there are provisions in the legislation that expressly authorize such processing without explicit consent.

We may process your personal data without your explicit consent if it is necessary to fulfill a legal obligation—including the disclosure of information required by applicable laws, regulations, court orders, or administrative directives.

We may process your personal data without your explicit consent where such processing is necessary for the establishment, exercise, or protection of a right.

Data Transferred to Third Parties

Without prejudice to our rights under the KVKK (Personal Data Protection Law), we may share your personal data—within the scope of commercial activities conducted via the Company Website—with Company employees, officials, legal, financial, and tax advisors, and auditors. We may also share this data with entities performing data processing activities (such as major search engine analytics applications and advertising/marketing agencies engaged by the Company) and with natural or legal persons for the purpose of presenting advertisements of potential interest to the Data Subject (provided the data is anonymized). You hereby grant your explicit consent to the Data Controller regarding such sharing.

Web Server Data Log

When you access the Company Website, your web browser is technically configured to automatically transmit the following data (“data log”) to our internet server; we subsequently record this information in our data logs, even without your specific consent:

Date of access

Time of access

URL of the referring website

Files retrieved

Volume of data transmitted

Browser type and version

Operating system

IP address

Domain name of your internet service provider

This information is technically required to ensure the accurate delivery of the content you request, and its collection is an unavoidable aspect of using websites. The data log is analyzed solely for statistical purposes to improve our website and its underlying technology, and is subsequently deleted.

Data logs are stored separately from other data collected as part of your use of the Company Website.

Like many other websites, we utilize “cookies.” Cookies are small text files transmitted to your hard drive by a web page server. Through this method, we automatically obtain certain data such as your IP address, the browser used, the operating system on your computer, and your internet connection details. This technical communication file facilitates internet usage by storing status and preference information regarding the site. The technical communication file is not designed to retrieve data from your main memory or email, nor to access any other personal information. Furthermore, cookies cannot be used to run programs or transmit viruses to your computer.

We use cookies and similar technologies to recognize you across different Services; to gain insight into your interests both on and off our Services; to enhance your experience; to improve security; to measure the usage and effectiveness of our Services; to obtain statistical data regarding visitor numbers, purposes of visits, and duration of stays; and to assist in dynamically generating advertisements and content via user pages tailored to specific users. We may track your navigation on the Company Website and your activities within your membership account using cookies; we may also analyze—using various methods—your personal data collected via the Company Website alongside data collected from third-party sites and mobile applications in order to present various discounts and promotional offers, conduct advertising and marketing, personalize the Company Website for you, provide a personalized Company.com experience, and deliver targeted content.

In any case, the data we collect cannot be shared with third parties without your consent. You can, of course, view our website without cookies. Internet browsers are typically configured to accept cookies by default. You can control cookies and stop their use at any time via browser settings and other tools. Please use your browser’s help function to learn how to change these settings. Please note that certain features of our website may not function if you disable the use of cookies.

Use of Social Plugins in the Context of Social Media

The COMPANY uses social plugins (“plugins”) from the following social networks: Facebook (operated by Facebook Inc., Palo Alto, CA, USA), YouTube (video platform operated by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA), Twitter (operated by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA), and Instagram (operated by Instagram, LLC, 1601 Willow Rd., Menlo Park, CA 94025, USA).

If you visit a page on our website containing such plugins, they are initially inactive. The plugins do not become active unless you click the designated button. By activating the plugins, you establish a connection with these social networks and consent to the transfer of data to them. If you are logged into these social networks, they may associate your visit with your account on the respective network. Upon clicking the relevant button, the corresponding information is transmitted directly from your browser to the respective social network and stored there.

Please refer to the data protection policies of the respective social networks for information regarding the scope and purpose of data collection, the subsequent processing and use of data by those networks, your rights, and the settings available to protect your privacy. If you do not wish for these social networks to collect data about you via our website, you must log out of the respective social networks before visiting our site.

Your Rights Regarding Your Personal Data

In accordance with the legislation concerning your processed personal data: You have the right to learn whether your personal data is being processed; to request information regarding such processing if it has taken place; to learn the purpose of the processing and whether the data is being used in accordance with that purpose; to know the third parties to whom your personal data has been transferred, whether domestically or abroad; to request the correction of your personal data if it has been processed incompletely or inaccurately; to request the deletion or destruction of your personal data; to request that the correction, deletion, or destruction of your personal data be notified to the third parties to whom the data was transferred; to object to any outcome adverse to you resulting from the analysis of processed data exclusively through automated systems; and to claim compensation for damages incurred due to the unlawful processing of your personal data.

Exercise of Rights, Applications, and Contact

You may submit requests regarding the rights specified above under the KVKK (Law on the Protection of Personal Data) to the COMPANY in writing—either in person (subject to identity verification) or via methods compliant with applicable regulations (e.g., through a notary)—at the address indicated above.

Data Security

The COMPANY has implemented technical and administrative measures regarding data security to the extent permitted by available means under the KVKK. Details regarding the measures taken are set out under the heading “Personal Data Protection, Storage, Processing, and Destruction Policy.”

Data Concerning Minors

Personal data of minors should not be submitted without the consent of their parents or legal guardians.

Links to Other Websites

The Company Website contains links to other websites. We have no control over whether the operators of these sites comply with data protection regulations. The COMPANY is not responsible for the content of linked sites (or the content of sites linked to by those sites) and has no authority to intervene in the content of such sites.

Amendments to the Data Privacy Statement and the Clarification Text on the Personal Data Protection and Processing Policy

This “Data Privacy Statement and Clarification Text on the Personal Data Protection and Processing Policy” will be amended as necessary to announce changes to our data protection-related services—for instance, upon the introduction of new services or to comply with applicable legal requirements. User Access

No one is granted access to your account unless invited by you. Only in the event of a technical or system malfunction—and subject to your permission—will authorized COMPANY personnel access the relevant data for support purposes.

Data Sharing

Data is not shared with business partners lacking adequate security measures without your consent.

Data Backup

Daily backups of your data are performed to protect against potential technical issues.

Response to Security Breaches

Despite our best efforts, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security. However, should the COMPANY become aware of a security breach, we will notify affected users so that they may take appropriate protective measures. Our breach notification procedures align with our obligations under legal regulations and any industry rules or standards to which we adhere. Notification procedures include sending email notifications or posting a notice on our website in the event of a breach.

Your Responsibilities

Keeping your data secure also depends on you ensuring the security of your account by using sufficiently complex passwords and storing them securely. You must ensure that the computer, tablet, or phone used to access the COMPANY’s service maintains adequate security.