Clarification Text Regarding the Processing of Personal Data

Data Controller : Smart Electronics Inc.

Within the framework of the Law No. 6698 on the Protection of Personal Data (“KVKK”) and the relevant legislation and our work arising from legal regulations, we, as Akıllı Elektronik A.Ş., have prepared this Clarification Text on the Processing of Personal Data (“Clarification Text”) in order to enlighten the data subjects regarding the processing, storage and transfer of personal data.

The Clarification Text shall be valid as of the date of its publication. The Clarification Text may be amended at any time if necessary. The amendments to be made shall be deemed to have made the Clarification Text ” www.grungard.com” address, it becomes valid when it starts to be published at the address. Everyone who uses the site, mobile application is deemed to have accepted this.

Consent Text Regarding the Processing of Personal Data

We would like to inform you about the activities carried out by Akıllı Elektronik A.Ş. through the website “www.grungard.com”. There is no membership requirement to shop from www.grungard.com, which is a direct sales and electronic commerce website. Membership is not a prerequisite for purchasing products and shopping on our website. Unlike the option to shop without being a member, the membership option is designed for users who wish to automatically fill in their data for repeat purchases for customers who wish. In order to benefit from these facilities and advantages, some of your personal data may need to be processed for the purposes specified as detailed below, shared with our contracted professional business partners and recorded in our programs and/or systems provided by our stakeholders in the field of technology.

Some of your personal data that need to be processed in order to ensure the satisfaction of our customers; Since it is not within the scope of the data processing conditions in the Personal Data Protection Law that are not subject to consent, it is only subject to the explicit consent of our customers. If you do not want to give consent, you can shop as you wish without being a member of our site with the “Continue Without Opening an Account” option.

Your Rights Regarding Processed Personal Data:

Within the scope of Article 11 of the KVKK;

• Learn whether your personal data is being processed,
• Request information if your personal data has been processed,
• To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
• To know the third parties to whom your personal data is transferred domestically or abroad,
• To request correction of your personal data in case of incomplete or incorrect processing,
• To request the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK legislation,
• When you request the correction of your incomplete or inaccurate data and the deletion or destruction of your personal data, to request that this situation be notified to third parties to whom your personal data has been transferred,
• To object to the result in case an unfavorable result arises by analyzing your processed data exclusively through automated systems and
• In the event that your personal data is damaged due to unlawful processing of your personal data, to demand the compensation of this damage,

you have the right

By clicking the “create my account” button on the product purchase page, you will be accepting that you explicitly consent to the processing of all your personal data above, limited to the specified processing purposes, without being under any pressure.

For what purpose is your personal data processed?

Your personal data may be processed by ThinTells Ltd. as the data controller in accordance with the Personal Data Protection Law No. 6698 (“Law”) within the scope described below.

• Provision of products and services and after-sales support services,
• Creating a customer card for the provision of services,
• Execution of customer relations processes,
• Management of communication channels,
• Realization of appointment, on-site promotion and sales processes,
• Realization of campaigns, sweepstakes and competitions,
• Evaluation of your requests and complaints,
• Organizing events and trainings and identifying participants,
• Execution of authorized service processes,
• Increasing customer satisfaction, measuring and improving brand perception,
• Carrying out the necessary work by our relevant business units for the realization of the commercial activities carried out by our Company and carrying out the related business processes,

purposes and within the scope of the legal reasons specified in Article 5 of the Law.

For what purpose is your personal data processed in case of your explicit consent?

Your collected personal data may be processed within the scope of your explicit consent for the purposes of conducting campaigns, sweepstakes and competitions, increasing customer satisfaction, measuring and improving brand perception, conducting market research and survey processes, customizing the products and services offered by the Company according to your tastes, usage habits and needs, and sending advertisements, promotions, campaigns and similar messages to the communication channel you share that you prefer to be contacted in this context and sharing them with third parties that we receive services for this purpose.

To whom and for what purposes can your personal data be transferred?

Your collected personal data may be transferred to our dealers, suppliers, legally authorized public institutions and private legal entities within the framework of the personal data processing conditions specified in Article 8 of the Law in line with the realization of the above-mentioned purposes.

What is the Method and Legal Reason for Collecting Your Personal Data?

Your personal data are collected and processed for the following legal reasons in electronic environment through the website, call center, mobile application, social media, telephone, in-house systems and in physical environment through dealers and authorized dealers/services where you will come into contact with our Company;

Products and services and after-sales service

based on the legal grounds of provision of support services and provision of services and performance of the contract,

Based on the legal reason that data processing is mandatory for the establishment, exercise or protection of a right in order to evaluate your requests and complaints,

In case you give your explicit consent, conducting campaigns, sweepstakes and competitions, increasing customer satisfaction, conducting customer relations processes, conducting necessary studies by our relevant business units for the realization of commercial activities carried out by our Company and carrying out related business processes, organizing events and trainings and determining participants, managing communication channels, measuring and improving brand perception, conducting market research and survey processes, providing gifts with reference,

It can be processed based on the legal reason of explicit consent for the purposes of customizing the products and services offered by the Company according to your tastes, usage habits and needs and sending advertisements, promotions, campaigns and similar messages to the communication channel you share that you prefer to be contacted in this context.

What are your rights as a Data Subject?

As a Data Subject, we hereby inform you that you have the following rights pursuant to Article 11 of the Law:

1. Learn whether personal data is being processed,
2. Request information if their personal data has been processed,
3. To learn the purpose of processing personal data and whether they are used for their intended purpose,
4. To know the third parties to whom personal data are transferred domestically or abroad,
5. To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
6. Although it has been processed in accordance with the provisions of the Law and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
7. To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
8. In case of damage due to unlawful processing of personal data, to demand compensation for the damage.

You can submit your applications for your rights listed above to our Company by filling out the Data Owner Application Form available at www.grungard.com/yasalmetinler/aydinlatmametni. Depending on the nature of your request, your applications will be finalized free of charge as soon as possible and within thirty days at the latest; however, if the transaction requires an additional cost, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Board.