CLARIFICATION TEXT

Clarification Text Regarding the Protection and Processing of Personal Data

Ensuring the security and protection of your personal data is among the top priorities of Nubo Global Tekstil Sanayi ve Ticaret Limited Şirketi (“Nubo”). We place great importance on the processing and storage of all types of personal data belonging to individuals associated with Nubo, including those who benefit from our products and services, in accordance with the Personal Data Protection Law numbered 6698 (“KVKK”). In this regard, as the “Data Controller” as defined in the KVKK, and in compliance with Article 10 of the KVKK and the Communiqué on Principles and Procedures to Be Followed in Fulfillment of the Obligation to Inform published in the Official Gazette dated March 10, 2018, and numbered 30356 (“Communiqué”), we provide this clarification to inform personal data owners about the identity of Nubo, the purposes of processing personal data, to whom and for what purposes processed personal data may be transferred, the method and legal basis for collecting personal data, and the rights of personal data owners under Article 11 of the KVKK.

Article 1. Concept of Personal Data and Processing of Personal Data

Personal data, as defined under KVKK, refers to “any information relating to an identified or identifiable natural person.” Examples include your name, surname, Turkish ID number, address, phone number, email address, date of birth and IP address. Additionally, under KVKK, sensitive personal data includes information on race, ethnic origin, political opinions, philosophical beliefs, religion, or other beliefs, attire, association or union memberships, health, sexual life, criminal convictions, security measures, biometric data, genetic data, etc. In this context, anonymized information, data rendered anonymous, and other data not associated with an identified individual are not considered personal data.

According to Article 3/I(e) of the KVKK, processing of personal data refers to any operation performed on personal data, whether wholly or partially by automated means or by non-automated means provided that the process is part of a data recording system. This includes obtaining, recording, storing, retaining, altering, reorganizing, disclosing, transferring, acquiring, making available, classifying, or preventing the use of personal data.

Article 2. Identity of the Data Controller

Under the KVKK, the “Data Controller” is defined as the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system. The corporate identity details of Nubo, acting as the “Data Controller” under the KVKK, are as follows:

Trade Registry Number:	410544-5, Istanbul Trade Registry Directorate
Mersis Number:	0632132928300001
Tax Number:	6321329283 - Maslak Tax Office
Registered Address:	Ayazağa Mah. Mimar Sinan Sk. Seba Office Blok No: 21d İç Kapı No: 73 Sarıyer / İstanbul
Website:	www.nubobaby.com
Email Address:	hello@nubobaby.com

Article 3. Processed Personal Data

Your personal data collected during purchases will only be processed with your explicit consent or under one of the lawful circumstances specified in Article 5 of the KVKK. The personal data processed by Nubo includes:

• Identity information (name, surname),
• Contact information (address, phone number, email address),
• Shopping information (shopping date, time, amount, content, payment method [credit card, cash], and payment details), including credit card information if the purchase is made via credit card,
• Tax-related details (e.g., Turkish ID number, passport number, foreign ID number, tax number, personal company details) if requested to appear on the invoice,
• Marketing-related information (e.g., date of birth, gender, website usage, shopping habits, address, demographic customer/member information, shopping habits and preferences regarding all products and services, campaigns utilized, surveys, and their contents, invoice contents, payment details [installment amount, etc.], old and new mobile/home/work phone numbers, email addresses, responses to commercial and other electronic communications, identifiers such as cookies, browser information, IP, wired/wireless network connection details, advertisement identifiers).

Article 4. Purposes for Processing Your Personal Data

Nubo may process your personal data for the following purposes and legal reasons:

• Ensuring communication and managing relationships with you, as well as completing your membership registration,
• Executing production, sales, shipment, and other operational processes for goods/services,
• Preparing and managing all records and documents (invoices, delivery notes, tax-related documents, etc.) as required for transactions,
• Recording your information for budget management and financial accounting purposes (e.g., preparing files, using accounting software) and sharing it with relevant units (e.g., banks, tax offices),
• Processing customer data into our computer systems to ensure continuity and control of operations,
• Storing and archiving documents and records that are required to be retained by law,
• Evaluating sales data, product, and package figures related to your commercial relationship with us, conducting necessary audits to obtain quality management certifications, and carrying out improvement processes,
• Sharing customer visual and audio data on Nubo’s social media accounts to ensure continuity of operations,
• Preparing and verifying agreements and reconciliations with you,
• Evaluating complaints from you, preparing complaint reports, conducting necessary surveys, and working on improvements in this regard,
• Fulfilling all legal obligations and exercising rights arising from legislation. 

Article 5. Transfer of Personal Data

Your collected personal data may be shared with third parties in compliance with the KVKK in the following cases: (i) If explicitly stipulated in the legislation, (ii) if necessary for the establishment or performance of a contract, (iii) if required for the fulfillment of our legal obligations as a data controller, (iv) if necessary for the establishment, exercise, or protection of a right, (v) for transfers abroad, with your explicit consent.

The reasons for transferring your personal data and the recipients are as follows:

• To fulfill the performance of contracts, with our business partners connected to the organization (e.g., contracted domestic and/or international cargo and customs companies),
• For auditing and reporting financial transactions related to budget management, account creation, invoicing, etc., with our affiliated companies and audit firms,
• To exercise our right to defense and for the execution and follow-up of legal affairs, with our legal advisors,
• To obtain quality certifications, with authorized institutions and organizations,
• To fulfill contractual obligations and legal requirements, with authorized institutions, organizations, and judicial bodies,
• For software programs hosted on servers abroad and for the website www.nubobaby.com, with domestic and/or international intermediary service providers contracted by Nubo.

Article 6. Method and Legal Basis for Collecting Personal Data

As Nubo, your personal data is collected during verbal communications, signed agreements, documents requested to fulfill obligations, postal and email correspondence, and the presentation of invoices and payment documents issued at the end of shopping transactions, in accordance with the legal grounds specified in Article 5 of the KVKK:

• Provided that it is directly related to the establishment or performance of a contract,
• For the protection of legitimate interests without harming your fundamental rights and freedoms,
• If necessary for the data controller to fulfill its legal obligations,
• If processing is mandatory for the establishment, exercise, or protection of a right, or
• With your explicit consent for transfers abroad.

Article 7. Your Rights Regarding the Processing of Personal Data

7.1. Pursuant to Article 11 of the KVKK, as a personal data owner, you may submit your requests regarding the application of the KVKK and any inquiries or requests concerning the processing of your personal data. You may send your questions and requests related to your personal data via an email signed with your secure electronic or mobile signature to hello@nubobaby.com or by submitting a written application (in person, via notary public, or registered mail with return receipt) to the address Ayazağa Mah. Mimar Sinan Sk. Seba Office Blok No: 21d, Interior Door No: 73, Sarıyer / Istanbul. Additionally, if you have previously notified us of your email address, which is registered in our system, you may also communicate your requests through this email address.

7.2. According to Article 5 of the Communiqué, your application must include your name, surname, signature (if in written form), Turkish ID number (or passport number or other identification number for foreigners), your residential or business address for notification purposes, email address and telephone, and the subject of your request. Applications submitted in this scope will be finalized as soon as possible and within a maximum of 30 (thirty) days, free of charge. However, if the processing requires additional costs, a fee may be charged according to the tariff determined by the Personal Data Protection Board.

7.3. As a personal data owner, as detailed in Article 11 of the KVKK, you have the right to:

• Learn whether your personal data has been processed,
• Request information about the processing activities,
• Learn the purposes of processing your personal data,
• Learn the third parties to whom your personal data has been transferred, domestically or abroad,
• Request the correction of incomplete or inaccurate personal data,
• Request the deletion or destruction of personal data if the reasons for processing no longer exist,
• Request that any corrections or deletions be communicated to third parties to whom the data has been transferred,
• Object to unfavorable results arising from the automated processing of your personal data, and
• Request compensation for damages incurred due to unlawful processing of your personal data. 

Furthermore, even if your personal data is processed in compliance with KVKK and other relevant legislation, it will be deleted, destroyed, or anonymized by us when the reasons for processing cease to exist, either automatically or upon your request. Additionally, Nubo may request additional verification (such as sending a message to your registered phone number or contacting you) to confirm that the application belongs to you and to ensure the protection of your rights depending on the nature of your request and application method.