Privacy Notice

PRIVACY NOTICE

Leather Club Tekstil ve Deri Turizm İnş. San. Tic. Ltd. Şti. Privacy Notice on the Protection of the Personal Data of Customers, Members and Visitors

Dear Visitors, Customers and Members,

We would like to inform you about our practices concerning the processing of your personal data and about the personal data that we, Leather Club Tekstil ve Deri Turizm İnş. San. Tic. Ltd. Şti. (“Leather Club”), process in our capacity as “Data Controller” under the Turkish Personal Data Protection Law No. 6698 (KVKK) (the "Law").

This document contains the privacy notice on the use of your personal data in the following cases:

• Where you visit Leather Club stores or shop at the Stores,

• Where you visit the website lcleatherclub.com or use the Leather Club application downloaded to your mobile phone,

• Where you shop via the Site/Mobile Application or through the Contactless Payment system, where purchases made by third parties are sent to you, or where you become a member of the Site/Mobile Application,

• Where you consent to receiving general and personalised campaign communications through commercial communication channels,

• Where we communicate with each other through our communication channels,

• Where you contact Leather Club and/or make purchases in connection with corporate sales processes, or where gifts, products, etc. are sent to you in connection with corporate sales processes,

• Where you participate in campaigns, competitions, prize draws and other events organised by Leather Club,

The notice below applies to the use of your personal data in each of the cases listed above.

1) What Are Our Purposes for Processing Your Personal Data and Which of Your Personal Data Do We Process?

Store Visits

We process your security camera footage for the purposes of ensuring the safety of you, Leather Club and its employees, and other third parties against any act, offence or conduct contrary to legislation that may occur in the Stores, and of fulfilling our obligations to provide information and documents to judicial authorities and our other related obligations.

In-Store Purchases and After-Sales Processes

• Your identity (name and surname) and contact details (e-mail address, telephone number) and your purchase details (purchase date, amount, purchase content, payment method and payment details), for the purposes of completing the purchase transaction, distinguishing the records we create for you in our system from the records of other customers, enabling you to benefit from after-sales operational services (alterations, exchanges, returns, product inspection, etc.) without having to present an invoice/receipt and carrying out these operational services, sending the e-invoice/e-archive invoice relating to your purchase to you, and procuring products not available in our stores and delivering them directly to you; and, in addition to this information, your Turkish ID number, for the purpose of exercising our legal rights in the event of a possible legal dispute concerning purchases made from the Stores on an order basis and paid for subsequently, where the necessary conditions are met,

• Where you make your purchase from our airport store, in addition to the above, your passport number, nationality, date of birth, gender and flight details, in order to fulfil our legal obligations,

• Where necessary, your bank account details so that refunds can be made to your bank account during return processes,

• Your identity, contact and invoice details for the purposes of issuing invoices and, in some cases, carrying out current account and reconciliation transactions, as well as certain additional invoice details if you are a taxpayer (Turkish ID/tax number, sole proprietorship details),

• Where you wish to pay by credit card, your credit card details for the purpose of collecting the payment (credit card details are transmitted to the payment institution without being stored by us.)

• Where you wish to pay by mail order, your name and surname, credit card details, telephone number, product details, order amount, signature and a photograph of the front of your identity document,

• Where you wish to benefit from Leather Club's made-to-measure tailoring/bespoke product service, your name and surname, order details and the body measurements relating to your order, and, where you give your explicit consent, the same information for the purpose of storing it for use in your future orders so that your measurements need not be taken again with each order,

We process the above personal data for the purposes stated.

• Your marketing data (date of birth, gender, province, district, demographic information, location data where location sharing is enabled, your responses to notifications/surveys/offers/campaigns within the Site and Mobile Application, habits, favourites, likes, behaviour, preferences, search activity, segments, past purchases, cookie records, cookie and advertising identifier/ID data and device ID, payment methods and preferences, Mobile Application usage time, Mobile Application version, communication preferences, purchase amount, payment channels, the bank through which payment was made, brand, model, technical specifications and operating system of the device used, your mobile operator, survey responses, etc.), for the purposes of creating general or personalised campaigns, benefits, promotions and advertisements, organising campaigns, competitions, prize draws and other events, carrying out segmentation, reporting, profiling, marketing and analysis activities, and conducting Leather Club's advertising and marketing/communication activities on the Mobile Application, the Site or other third-party platforms (notifications on the Mobile Application and the Site, pop-up displays, personalised offers, customisation of user screens, advertising, search, surveys, etc.),

We process the above personal data for the purposes stated.

Use of the Site/Mobile Application and Purchases via the Site/Mobile Application or Contactless Payment (as a member or without membership)

Where you use the Site/Mobile Application or wish to place an order via the Site/Mobile Application or our Contactless Payment system, the personal data we process are as follows:

• Your identity (name and surname) and contact details (e-mail address, telephone number, address) and your purchase details (purchase date, time, amount, purchase content, payment method and payment details), for the purposes of completing the purchase transaction, preparing and packaging the order, preparing the dispatch note, shipping, updating delivery information, delivering your order to you or, where you wish to collect your order from the Stores, arranging appropriate delivery at the Stores, distinguishing the records we create for you in our system from the records of other customers, carrying out after-sales operational services (alterations, exchanges, returns, product inspection, etc.), and sending the e-invoice relating to your purchase to you,

• Your identity and invoice details for the purpose of issuing invoices, as well as certain additional invoice details if you are a taxpayer (Turkish ID number, tax number, sole proprietorship details),

• Where you wish to pay by credit card, your credit card details for the purpose of collecting the payment (credit card details are transmitted to the payment institution without being stored by us.)

• Where products are sent to you by third parties via the Site/Mobile Application, we process your name and surname, mobile telephone number and address details so that the order can be delivered to you.

• Your usage data relating to the Site and Mobile Application, for the purpose of identifying and remedying technical/software errors and deficiencies encountered during your visit to and use of the Site and Mobile Application,

We process the above personal data for the purposes stated.

Site Membership (Site/Mobile Application)

• Your identity (name and surname), contact (e-mail address, telephone number) and password details, for the purposes of completing membership procedures, performing the membership agreement to be concluded with you, enabling member sign-in and providing membership-related information,

• Your identity (name and surname) and contact details (telephone number, e-mail address, delivery and invoice address details), for the purpose of enabling you, when shopping via the Site/Mobile Application as a member, to make purchases using your member details without having to re-enter your information for each transaction,

• Your purchase details (purchase date, time, amount, purchase content, payment details), for the purpose of providing you, as a member, with the ability to view your order history,

• Your details of purchases made from the stores and the Site, for the purposes of enabling you to benefit from special membership programmes, to take advantage of the opportunities and offers created specifically for you based on your purchases from the stores and the Site, and to earn and redeem points; and your marketing data (date of birth, gender, province, district, demographic information, location data where location sharing is enabled, your responses to notifications/surveys/offers/campaigns within the Site and Mobile Application, habits, favourites, likes, behaviour, preferences, search activity, segments, past purchases, cookie records, cookie and advertising identifier/ID data and device ID, payment methods and preferences, Mobile Application usage time, Mobile Application version, communication preferences, purchase amount, payment channels, the bank through which payment was made, brand, model, technical specifications and operating system of the device used, your mobile operator, survey responses, etc.), for the purposes of creating general or personalised campaigns, benefits, promotions and advertisements, organising campaigns, competitions, prize draws and other events, carrying out segmentation, reporting, profiling, marketing and analysis activities, conducting Leather Club's advertising and marketing/communication activities on the Mobile Application, the Site or other third-party platforms (notifications on the Mobile Application and the Site, pop-up displays, personalised offers, customisation of user screens, advertising, search, surveys, etc.), creating and sending you the nearest and most suitable offers where location sharing is enabled on your mobile device, and improving the user experience on the Site and Mobile Application,

We process the above personal data for the purposes stated.

Corporate Sales Processes

Where you contact our corporate sales unit, we process your identity (name and surname), contact (e-mail, mobile telephone), customer transaction (quotation, order, shipping details) and invoice details, as well as details of the organisation you work for, for the purposes of preparing a quotation at your request and sending it to you, forwarding your details to the relevant store if you accept the quotation, sending your products to you, and communicating with you where necessary and in relation to new order processes. (The data to be processed in relation to your order are set out above in the section on in-store purchases.)

Where gifts, products, etc. are sent to you by third parties as part of corporate sales processes, we process your name and surname, mobile telephone number, address and details of the organisation you work for so that the order can be delivered to you.

Call Centre/Customer Relations Processes/Live Style and Sales Consultancy

Where you contact us through our communication channels (call centre, e-mail, the Site, the Mobile Application, social media, online messaging/voice call applications, etc.), we process your identity (name and surname), contact (address, e-mail address, telephone number) and customer transaction details (your appointment details, requests and complaints, purchases, use of gifts/discounts/benefits), visual records (photographs, videos and video call recordings) where they are contained in the messages you send us or where you join a video call with your camera on as part of the live consultancy service provided to you, and, where necessary, your legal transaction details, for the purposes of resolving the problems and complaints you submit to us, answering your questions about fashion and style, contacting you in relation to these where necessary, and providing online video style and sales consultancy services from Leather Club stores in accordance with the appointment you have made; we also process video call recordings and call centre voice recordings for our customer satisfaction activities and for use as evidence in any disputes that may arise between us.

Legal Processes and Internal Activities

We process your identity, contact, purchase, invoice and transaction security (log records) data for the purposes of fulfilling our obligations arising from legislation and our other legal obligations towards authorised and competent public institutions and organisations.

We process your identity (name and surname), contact (telephone number, e-mail address, address), purchase, invoice and camera footage data, your transaction security data (log records relating to Site membership, Site/Mobile Application purchases, and permission/explicit consent/agreement approvals in the context of commercial communications) and your legal transaction data (correspondence and file records relating to dispute processes), for the purposes of exercising all rights of action, defence and objection before official institutions and bodies such as courts, enforcement offices and arbitration committees in any disputes that may arise, conducting negotiation and settlement processes relating to disputes, and providing you with the necessary information where you request information from us, and within the scope of internal audit, internal control and reporting, testing, development and improvement activities.

We process your identity, contact and credit card details (the first 6 and last 4 digits only), your purchase and order details and your transaction security data in order to prevent the use of the Mobile Application, the Site and other Leather Club systems in a manner contrary to the membership agreements, legislation or public morals, to detect suspicious transactions and unlawful use, and to carry out blocking and unblocking operations.

2) To Whom and for What Purposes May We Transfer Your Personal Data?

We share your personal data:

• With our company's domestic service providers and business partners (call centre, those collecting personal data via devices, marketing/advertising/analytics service providers, database and server service providers, providers of Site and Mobile Application usage monitoring services, e-mail server service providers, e-invoice and e-archive invoice service providers, electronic message intermediary service providers, cargo and courier companies, suppliers providing bespoke product tailoring services, card printing service providers, printing houses, warehouse service provider, banks and electronic payment institutions, legal and financial consultancy service providers, independent audit service providers, archiving service providers, customer support and video call service providers, and online messaging/voice call service providers), for the purposes of obtaining product and service support in matters such as information technologies, marketing/advertising/analytics activities, logistics services, payment services or consultancy requiring expertise,

• With authorised public institutions and organisations and judicial authorities, to the extent of the information requested from us, for the purposes of fulfilling our obligations to provide information and documents to such institutions, organisations and authorities and our other related obligations, and exercising our legal rights such as the rights of action and defence,

• Where necessary, with the suppliers from whom we receive consultancy services and the payment institutions involved in the relevant transaction, for the purposes of monitoring and detecting suspicious transactions and preventing unlawful transactions,

• Where necessary, your security camera footage from the stores with the security units of the shopping centre in which the store is located,

• With our business partners, within the scope of activities aimed at increasing visitor traffic to the Site and Mobile Application,

• Transfer Abroad: With service providers located abroad (insurance services in the context of cyber security, server/maintenance and development services) for the purposes of obtaining product and service support in matters such as information technologies, marketing/advertising/analytics activities or consultancy requiring expertise, and with business partners in order to fulfil the requirements of the agreements we have concluded with them, and accordingly, because the servers of the relevant domestic and/or foreign suppliers are located abroad, your identity, financial, contact, marketing, location, customer transaction and transaction security data are transferred abroad,

• With Google (Google Ads, Google Analytics), Meta (Facebook and Instagram advertising tools) and Yandex (Metrica) for online measurement and advertising services; the servers of these providers are located abroad, and cookie-based measurement operates only if you give your explicit consent via our cookie notice (see the cookie table below),

• Where you contact us via WhatsApp, your telephone number and the content of your messages are transmitted via the WhatsApp infrastructure operated by Meta Platforms, whose servers are located abroad; we process them solely for the purpose of responding to your request and handling your order processes,

• Where you use the optional "Style Advisor" chat feature on our Site, the messages you type are transmitted to our artificial intelligence service provider, whose servers are located abroad, solely for the purpose of generating product recommendations; chat content is not stored by us. We recommend that you do not enter personal information such as your name, telephone number or address in this field,

• Cloudflare bot protection is used on our forms (wholesale application, account operations) to prevent abuse; during this verification, your IP address and browser information are processed by Cloudflare, whose servers are located abroad, solely for security purposes,

Such sharing is carried out for the purposes stated above.

In addition, where you have given your explicit consent, your e-mail address may be shared, protected by a secure and irreversible encryption (hashing) method, with online advertising platforms whose servers are located abroad (search engine and social media advertising service providers), solely for matching purposes, so that more relevant campaigns and recommendations can be presented to you on advertising channels. This sharing is based exclusively on your explicit consent; you may withdraw your consent at any time via the link in our e-mails or by contacting us, upon which you will be removed from the matching lists.

3) What Are the Method and Legal Basis for Collecting Your Personal Data?

We collect your personal data, through Leather Club, its affiliates, suppliers or business partners, by automated means such as: the security cameras located in the Stores; the recording in our systems, by our sales consultants, of the information you provide to them verbally in the Stores; the recording in our systems of the information you share in relation to purchases made through the Stores, the Site or the Mobile Application or in relation to membership procedures; the recording in our systems of data generated by/obtained from the use of your fixed and mobile internet and communication devices and/or mobile applications in various environments and locations; the collection of your location data by the beacon devices located in our Stores or by the Mobile Application where you are a Site Member and location sharing is enabled in the Mobile Application and/or the Bluetooth feature is enabled on your mobile device; the recording in our systems of the requests relating to the products you wish to order under the Contactless Payment system and the information required for the order, as communicated by you to our employees through various communication channels (such as telephone calls and e-mail); the recording in our systems of all purchases, collections, deliveries, transactions, survey completions, registrations and behavioural actions on the Store, the Site and the Mobile Application; the recording of redirections to the Site and the Mobile Application from the websites of our business partners; cookies and similar technologies operating on the Site or the Mobile Application, as explained in detail in the cookie policy; the recording of the requests, complaints and fashion and style questions you submit to us during mutual communication via the call centre, the Mobile Application, the Site, our e-mail addresses, social media and other communication channels; the recording of the video calls you make as part of the live style and sales consultancy service; the recording of your calls with the call centre; and the updating and enrichment of the data you share on the Leather Club side where you give your explicit consent as part of Site membership; and by non-automated means, namely the recording of information/documents concerning you received from official institutions, organisations and judicial/administrative authorities, the recording of your mail order forms, and the recording of the records and related documents relating to your special order processes or return processes.

We collect your personal data on the following legal bases: in relation to sales processes on the Site, in the Stores and on the Mobile Application, “processing being necessary for the establishment and performance of a contract”, “fulfilment of a legal obligation” and “processing being mandatory for the legitimate interests of the data controller”; in relation to our retention obligations arising from legislation, “fulfilment of a legal obligation”; in relation to recording by security cameras in the stores, “processing being mandatory for the legitimate interests of the data controller” and “processing and transfer being mandatory for the establishment, exercise or protection of a right”; in relation to Site Membership processes, “processing being necessary for the establishment and performance of a contract” and the “explicit consent” you provide; in relation to Call Centre/Customer Relations Processes/Live Style and Sales Consultancy processes, “processing being necessary for the establishment and performance of a contract” and “processing being mandatory for the legitimate interests of the data controller”; and, in relation to commercial communication processes or where you request that your information be stored in special order processes, the “explicit consent” you provide. You may withdraw your explicit consent at any time and without giving any reason, thereby terminating the personal data processing activities based on explicit consent.

Where you upload a photograph using the optional visual search / "product recognition by camera" feature on our Site, the image you upload is processed by artificial intelligence systems solely for the purpose of matching products from our catalogue; this image is not stored or saved by us and is deleted once the process is complete. Such image processing may take place abroad through our technical service providers. Your use of this optional feature constitutes your explicit consent to the processing of the relevant image data for this purpose and, where necessary, to its transfer abroad; if you prefer, you may search for your product manually without using the feature.

When you visit our Site, even before you have indicated your cookie preference and without any cookie being placed on your device, anonymous/cookieless technical data (such as IP address, browser and device information, and the page visited) may be processed for the purposes of measurement and advertising conversion modelling, and such data may be transferred to our measurement service provider (Google), whose servers are located abroad. Cookies and personalised measurement operate only if you give your explicit consent via our cookie notice; if you do not give consent, only this cookieless, anonymous measurement continues, and your right to object is reserved at all times.

Cookies and similar technologies

The table below lists the cookies and browser storage records used on our site. Those marked "Necessary" are required for the site to function and do not require explicit consent; those marked "consent-based" operate only if you select "Accept" in our cookie notice. You may change your preference at any time via the "Cookie preferences" link at the bottom of the page; when you select "Only necessary cookies", any measurement cookies previously set are also deleted.

4) What Are Your Rights?

You may at any time submit a request to us regarding your rights under Article 11 of the Law in relation to your personal data processed by us. You may submit your requests by applying in writing to the address of Leather Club Tekstil ve Deri Turizm İnş. San. Tic. Ltd. Şti., as Data Controller, specified below, or by sending an e-mail from the e-mail address registered in our system. (We would like to remind you that the relevant request must comply with the conditions set out in the Communiqué on the Procedures and Principles for Applications to the Data Controller.)

Address: Gökalp Mah. Zübeyde Hanım Cad. No:62 Zeytinburnu / İstanbul

E-mail: info@leatherclub.com.tr

Legal Name: Leather Club Tekstil ve Deri Turizm İnş. San. Tic. Ltd. Şti. · MERSIS No: 0608051479500016 · Tax Office/No: Antalya Kurumlar V.D. / 6080514795

For all matters other than your personal data, you may contact us at info@leatherclub.com.tr.