Privacy Statement on Cookies and Other Identification Technologies

LOTTE CHEMICAL TURKEU YÜZEY TASARIMLARI SAN. VE TİC. A.Ş.

PRIVACY STATEMENT ON COOKIES AND OTHER IDENTIFICATION TECHNOLOGIES

PLotte Chemical Turkey Yüzey Tasarımları San. ve Tic. A.Ş. (“Lotte” or the “Company”) uses cookies and other online identification technologies (e.g., pixels, web beacons, GIFs) (to be briefly referred to collectively as “Cookie(s)”) to offer you the best possible website experience. Cookies are small sized rich text formats which are placed on your computer, smart phone, tablet, wearable device, smart tv and/or other terminal devices and which are stored by your browser. Cookies are considered as personal data if they make any natural person identifiable when combined with other information, even if pseudonymized or not directly identify a natural person.

Our Company respects your rights regarding your privacy and the protection of your personal data, and aims to establish and maintain a relationship with your party that is based on trust. Within this scope, our Company processes your personal data in accordance with all legal regulations on the protection of personal data, particularly the Law No. 6698 on the Protection of Personal Data (the “LPPD”), and adopts all security measures which are required to ensure the security of your data. In this regard, this Lotte Chemical Turkey Yüzey Tasarımları San. ve Tic. A.Ş.’s Privacy Statement on Cookies and Other Identification Technologies (the “Privacy Statement”) is intended to provide clarifications - in a thorough and transparent manner - on the scope of the processing of your personal data which are automatically collected by placing - on your device - cookies used on our website (www.belenco.com/en/), and the types of cookies used and their purposes for use, and the method of management of cookies. For further details on the processing of your personal data by our Company, please visit Lotte Chemical Turkey Yüzey Tasarımları San. ve Tic. A.Ş.’s Policy on the Protection and Processing of Personal Data, which is accessible from https://www.belenco.com/en/policy-on-the-protection-and-processing-of-personal-data.aspx .

1.     Data Controller

Your personal data are processed by Lotte Chemical Turkey Yüzey Tasarımları San. ve Tic. A.Ş., a joint stock company registered at Manisa Trade Registry Directorate with the registration number of 14936 and having its registered office situated at Manisa OSB IV. Kısım Keçiliköy OSB Mah. Ahmet Nazif Zorlu No: 22 Yunusemre / Manisa, in its capacity as a data controller, in accordance with this Privacy Statement.

2.     The Methods of Collection of Your Personal Data

Your personal data are collected by our Company wholly or partly by automated means or provided that the process is a part of any data filing system, through non-automated means, from electronic environments, our websites, via our browsers, third party advertisement partners, third party cookie applications and social media platforms and Cookies as well as other methods (channels) which may be included in the future.

3.     Cookie Types

3.1. Cookie Types in Terms of Duration:

(i)    Session (Transient) Cookies

Session Cookies (which are also called as Transient Cookies) are used to ensure the continuity of the session and are deleted when the web browser is closed.

(ii)   Persistent Cookies

Persistent Cookies are Cookies which do not expire when the web browser is closed and which are automatically deleted on a specific data or after a specific period of time. The user’s personal data which are processed are transmitted to the server - via these Cookies - on each website visit by the user concerned. Persistent Cookies are also referred to as Tracking Cookies because they can be used by the advertisers to record information about a user’s web browsing habits over an extended period of time. In addition, these Cookies also store login credentials (depending on the users’ preferences), whereby users avoid having to re-enter such information every time they sign-in to their accounts on the website.

3.2. Cookie Types in Terms of Source (Owner):

(i)    First Party Cookies

First Party Cookies are directly set by our website – i.e., our URL addresses shown in your browser’s address bar – upon your visit.

(ii)   Third Party Cookies

Third Party Cookies are set by a third party (i.e., domain), other than our website (or domain) visited.

3.3. Cookie Types in Terms of Purpose of Use:

(i)    Strictly Necessary (Essential) Cookies

Strictly Necessary Cookies are Cookies which are essential for the proper operation of our website and the performance of the information society services (such as logging in, filling in forms, remembering your privacy preferences, counting visits and measuring traffic etc.) as requested by your party, and are therefore based on the legal condition of the existence of explicit consent. You can set your browser to block or alert you about these cookies. However, please note that if you disable cookies, some parts of our website may not function. On the other hand, first party Performance / Analytical Cookies which have the sole purposes of the measurement of the target audience of the website or application and the generation of anonymized statistics may be considered to fall within the scope of Strictly Necessary Cookies, if the functioning or day-to-day management of a website or application is associated with the requested service (such as the performance measurement, detection of navigation problems, optimization of technical performance or its ergonomics, estimation of the power of the necessary servers etc.). Within this scope, while processing your personal data via Performance / Analytical Cookies, the Company complies with the general principles, in particular the principle of being relevant, limited and proportionate to the purpose, and anonymizes personal data which are not required to be processed, and ascertains reasonable retention periods which are proportionate to the purpose for use. First party Performance / Analytical Cookies which are considered to fall within the scope of Strictly Necessary Cookies are not used for cross tracking of website navigation between different websites and applications under any circumstances, and in case of the existence of any Performance / Analytical Cookies with such a purpose, they can be used solely upon the attainment of your explicit consent.

(ii)   Functional Cookies

Functional Cookies are Cookies which are used – other than in case of Strictly Necessary Cookies and circumstances where information society services were clearly requested – for making our websites and applications easier to use and for personalization in relation to your preferences (e.g., to remember your language settings or region of access – which alter the behavior or appearance of our website). These Cookies may be placed by Lotte or third-party service providers upon your explicit consent.

(iii)  Performance / Analytical Cookies

Performance and Analytical Cookies are Cookies which are used to analyze the user behaviors on our websites and applications, to improve our websites and applications, to predict the number of unique visitors, to detect the most preeminent search engine key words, to track website navigation, and to measure the impact of advertisements on the users; and which facilitate the measuring of statistical data. These Cookies may be placed by Lotte or third-party service providers upon your explicit consent, and allow us to continuously optimize our websites, applications, services and offers in order to provide you the best possible website experience to you.

(iv)  Advertisement / Marketing Cookies

Advertisement / Marketing Cookies are Cookies which are used to track the users’ online activities, to analyze such activities and to present more attractive and customized contents which are suitable to the users’ preferences and tastes. These Cookies may be placed by Lotte or third-party service providers upon your explicit consent, and are only intended to allow us to offer advertisements, campaigns, products and services which may be of more interest to you.

4.     The Purposes for and the Legal Basis of the Processing of Personal Data

4.1. Strictly Necessary Cookies

Your personal data which are collected via Strictly Necessary Cookies are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes. Detailed information on the Strictly Necessary Cookies used on our website (including their purpose for use) are provided in the chart below.

4.2.  Functional Cookies

Your personal data which are collected via Functional Cookies are processed on the basis of the personal data processing conditions (legal grounds) of the existence of explicit consent, as stipulated in article 5(1) of the LPPD. Detailed information on the Functional Cookies used on our website (including their purpose for use) are provided in the chart below.

4.3. Performance / Analytical Cookies

Your personal data which are collected via Performance / Analytical Cookies are processed on the basis of the personal data processing conditions (legal grounds) of the existence of explicit consent, as stipulated in article 5(1) of the LPPD. Detailed information on the Performance / Analytical Cookies used on our website (including their purpose for use) are provided in the chart below.

5.     The Management of Cookie Preferences

When you visit our website, only the aforementioned Strictly Necessary Cookies are used without your consent. Within this scope, you can view the Cookie types which are used on our website over the “Cookie and Other Identification Technologies Management Panel” which appear on your first visit to our website and on further visits if necessary, and set your preferences at any time by enabling or disabling the “Accept All”, “Reject All” or “Save My Preferences” button with the “on/active” or “off/passive” options for the Cookie types other than Strictly Necessary Cookies. Additionally, you can always access the aforesaid panel from the “Cookies and Other Identification Technologies Panel” button on the footer of the homepage of our website and our personal data protection web page.

Furthermore, most browsers accept their own cookies automatically, without Lotte’s control or intervention; however, they offer the option of rejecting cookies or displaying a warning prior to storing. The help function in the menu list of most web browsers explains how you can instruct your browser not to accept new Cookies, how you can be informed by the browser that you are receiving a new Cookie or how you can disable Cookies. For further information thereon, please directly contact the relevant browser service provider or review their privacy / cookie policies. The said deactivation will be recorded by a Cookie on your computer, smartphone or tablet in the browser on which the blocking was made and will not be associated with your customer account. Therefore, the deactivation must be carried out separately for each device and for each browser. Please bear in mind that if your browser automatically deletes cookies after each session, the opt-out cookies (deactivation function) will also be deleted. Detailed information on the management of Cookies in common browsers are available from the following links:

Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=tr

Mozilla Firefox: https://support.mozilla.org/tr/kb/masaustufirefox-surumunde-gelismis-izlenme-koruma

Safari: https://help.apple.com/safari/mac/9.0/#/sfri40732

Opera: https://help.opera.com/en/latest/web-preferences/

However, we recommend that you activate or accept all Cookies to be able to use all functions on our online services. Our cookies do not store any passwords, credit card data or similar sensitive data. Cookies do not cause any damage to your terminal device or do not contain any virus.

Nevertheless, if you do not wish or are not able to activate Cookies, you may place orders for our products and/or services from our customer service department (by dialing 0850 808 4321) between 08.00 – 17.00 on weekdays or buy our products and/or services from the physical (brick-and-mortar) sale points of our distributors.

6.     The Domestic and Cross-Border Transfer of Your Personal Data to Third Parties

Your personal data which are retained by our Company may be accessed solely by our personnel who have been granted with restricted access authorization for the aforementioned purposes, to the extent as is necessary to fulfill their duties, and will not be transferred to third parties located in Turkey and/or abroad in cases where the conditions for transfer which are regulated in articles 8 and/or 9 of the LPPD are not satisfied. Nevertheless, your personal data which are processed within the scope of each personal data category listed hereinabove may be transferred to the following recipient groups if the aforesaid personal data processing conditions (legal grounds) for the data category concerned are further satisfied in terms of the purposes for transfer, and in accordance with articles 8 and/or 9 of the LPPD:

·       to our service providers located in Turkey and/or abroad including our group companies acting as a service provider, for the purposes as specified hereinabove for each Cookie type, and particularly, in order to ensure the purchase of products and/services for the execution of our Company’s operations;

·       to our business partners (e.g., search engines, data management platforms and digital advertising platforms) located in Turkey and/or abroad, for the purposes as specified hereinabove for each Cookie type, and particularly, in order to establish and maintain collaborations, the analysis of user behavior on our websites and mobile applications, and the conducting of activities to improve our websites and mobile applications;

·       to our group companies and shareholders located in Turkey and/or abroad, for the purposes as specified hereinabove for each Cookie type, and particularly, in order to enable the planning and/or materialization of the communication, audit and reporting activities for compliance with regional/global policies and procedures of our group companies and shareholders; and

·       to the authorized public institutions and organizations in Turkey, for the purposes as specified hereinabove for each Cookie type, and particularly, in order to fulfill our Company’s statutory obligations and the follow-up the legal affairs thereof.

8.     Your Rights under the LPPD

Pursuant to article 11 of the LPPD, you possess the following rights, as a data subject:

• being informed of whether your personal data are processed by our Company or not;
• requesting information thereon if your personal data have been processed;
• being informed of the purpose for the processing of your personal data and whether such data were used in conformity with such purpose or not;
• knowing the third parties in Turkey or abroad to whom/which personal data are transferred;
• requesting the rectification of incomplete or inaccurate personal data which were processed and the notification, of the operation carried out within this scope, to third parties to whom/which personal data were transferred;
• requesting the deletion or destruction of personal data despite the processing in accordance with the law and other applicable legal provisions, once the reasons necessitating the processing cease to exist, and within this scope, if the personal data were processed incompletely and inaccurately, the notification, of the operation carried out within this scope, to third parties to whom/which personal data were transferred;
• objecting to any outcomes to your detriment by means of the analysis of the processed data exclusively through automated means;
• claiming the compensation of your damages, in case you incur any damages due to the unlawful processing of personal data.

You may submit your application regarding your aforementioned rights, in accordance with the provisions of the Communiqué on the Procedures and Principles of Application to the Data Controller (in writing or electronically, via registered electronic mail (KEP) address, signed with secure electronic signature or mobile signature, or via your e-mail address which had previously been notified to our Company and which is recorded in our system - along with the information / documentation* verifying your identity in order to enable our Company to confirm your status as an actual right-holder/beneficiary (e.g., Turkish ID number or passport number for citizens of other countries, residential address / workplace address for notification/service, mobile phone / landline /facsimile number, e-mail address) by filling in the Data Subject Application Form which is accessible from https://www.belenco.com/en/data-subject-application-form.aspx or through the channels which are indicated in the Data Subject Application Form as pertaining to the data controller, in accordance with the procedures and principles which are mentioned hereinabove and which are laid down in the applicable legislation. Your application will be concluded free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of your request; however, in case the transaction requires an additional cost, you may be charged according to the tariff determined by the Personal Data Protection Board.

* Please note that no special categories of personal data (e.g., religion or blood type information) should be included in the said documentation.