PRIVACY POLICY

Last updated: [10.04.2024]

The purpose of this Privacy Policy (“Policy”) is to set out the terms and conditions for the processing by Vestel Ticaret A.Ş. (‘’Vestel’’), located at Levent 199, Buyukdere Cad. No: 199 34394 Sisli / Istanbul, Turkey, as the data controller of all kinds of data generated during the use of the application (“Vfit+ Application”) for smart watch, smart fitness wristlet, smart scale, smart light, air purifier and other devices (“Vfit+ Devices”) or disclosed before use by members.

Vestel designs products and tools that monitor the daily health and fitness conditions of users to ensure that they have healthier and more active life and encourage them in this direction. Vestel is responsible for providing sales and user support services for the Vfit+ devices in the Turkish market. This Privacy Policy is valid for Vfit+ Devices for personal fitness and electronic body monitoring, and its scope includes the use of Vfit+ devices only. Vfit+ Devices and the Vfit+ Application is jointly referred to as the “Vfit+ Service” for the purposes of this Policy.

When we use the term “personal data”, we are referring to any information that can be used, directly or indirectly, to identify you personally. We process your personal data in accordance with the Turkish Data Protection Regulation (numbered 6698) (“TDPR”)

This Policy may be updated to notify you when a new feature is installed, or the Application is updated. Your personal data will be processed in accordance with the old version of the Policy until you use the new features. If necessary, the updated Policy will be sent to you through the email address you provided.

1. WHEN DO WE COLLECT THE DATA?

1.1 DURING THE ACTIVATION OF YOUR DEVICES

While your Vfit+ Devices are activated, you will be required to download the Vfit+ Application and enter personal information including height, weight, and sex, which will be then used to personalize your fitness statistics such as the calorie burned, and distance covered.

Depending on the type of Vfit+ device you are using, data including your step count, distance, calories burned, weight, fat, muscle and bone ratios and change in water consumption may be collected and your sleep quality and dynamic heart rate may be measured.

1.2 DURING THE CREATION OF THE VFIT+ ACCOUNT

You need to create a Vfit+ account, if you want to have access to the data collected by your Vfit+ Devices. While the Vfit+ account is created, you are requested to enter certain personal information including your e-mail address and date of birth.

Your e-mail address will be used as your Vfit+ account user’s name for logging in your account. Vfit+ does not allow other users to have access to your e-mail address and other users will be only able to see your name or nickname you will define in your profile settings.

1.3 DURING THE MATCHING OF YOUR VFIT+ DEVICES

When you match your Vfit+ Devices by use of the application, the data to be recorded by your Vfit+ Devices about your physical activities will be transferred to our servers. These data will be associated with your Vfit+ account, and they will be stored and used for providing the Vfit+ Service. Time and date of use and device charge level are some examples of the data recorded.

2. THE PURPOSE OF COLLECTING PERSONAL DATA AND LEGAL BASIS

We as well as our service providers process your personal data we have collected or been provided with for the following purposes:

a) Creating and managing accounts, as well as updating information.

o Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 5 (2) lit. c TDPR).

b) Carrying out information verification procedures.

o Legal Basis: It is legal responsibility to ensure that personal data is accurate and up to date. Therefore, the data processing is necessary for compliance with a legal obligation to which we are subject (Art. 5 (2) lit. ç TDPR).

c) Ensuring that your phone is connected to your Vfit+ Devices, allowing you to monitor and control your Vfit+ Devices from anywhere, recording our fitness activities, estimating (according to height, weight, sex, and age information) the number of calories burned and enabling you to use the services the Application has to offer.

o Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 5 (2) lit. c TDPR).

d) Sleep data are used to determine your sleeping pattern and quality and inform you on the matter.

o Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 5 (2) lit. c TDPR).

e) Dynamic heart rate is used to determine and analyze your real-time heart rate during fitness activities.

o Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 5 (2) lit. c TDPR).

f) Contacting you regarding assistance, maintenance, or other services Vestel provides for your Vfit+ Devices.

o Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 5 (2) lit. c TDPR).

g) Ensuring Users satisfaction and responding to complaints and requests from Users.

o Legal Basis: The data processing is needed for the purposes of the legitimate interests pursued by Vestel, the controller, or a third party, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (Art. 5 (2) lit. f TDPR).

h) Improving the Appliance usage experience of the User and developing the services as well as creating new services.

i) Making statistical evaluations and creating a database to ensure the Application and product development and to carry out commercial activities.

o Legal Basis: The data processing is needed for the purposes of the legitimate interests pursued by Vestel, the controller, or a third party, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (Art. 5 (2) lit. f TDPR).

j) As part of our customer satisfaction initiatives, we aim to gather your inquiries related to predefined and categorized topics (such as purchase orders, assembly, membership, or promotional campaigns) before you contact us. This allows us to offer responses that are tailored to your needs. Additionally, we will maintain a record of your conversation history in order to facilitate your access to information and make it easier for you to find answers to your questions.

o Legal Basis: The data processing is needed for the purposes of the legitimate interests pursued by Vestel, the controller, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (Art. 5 (2) lit. f TDPL).

3. CREATING A USER ACCOUNT ON ALL PLATFORMS

When you create a membership on any of Vestel's websites (vestel.com.tr; regal-tr.com; vsoutlet.com.tr; cozumuvar.vestel.com.tr) or through Vestel’s applications (Evin Aklı Application; Vfit+ Application), you can use the same membership credentials to access all these platforms.

If your membership be terminated, either automatically or by your request, it will be concurrently revoked across all platforms.

Please note that all platforms where membership is available are owned by Vestel. Membership is exclusive to Vestel-owned channels; thus, it is not possible to register on channels outside of Vestel’s network. Moreover, we do not share your data with any third parties for the purpose of membership.

o Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 5 (2) lit. c TDPL).

4. PROCESSING IP ADDRESS INFORMATION OF THE USERS

Vestel may determine and use the IP address of the user when required to detect the issues regarding the Vfit+ Devices or the Vfit+ Application and to forthwith settle the issues that may arise. IP addresses may also be used to identify the user in a general way and to collect comprehensive demographic information.

5. PROCESSING OF THE LOCATION INFORMATION

In the event of user approval, Vestel or our service providers process location information to achieve the following purposes:

(a) The Vfit+ Service incorporates features that necessitate the collection of specific location data (GPS signals). The Vfit+ Devices only gather such data when you activate the location feature for the running mapping and emergency notification system service. If you disable the feature, Vestel ceases the collection of such data. This information is securely stored in your Vfi+t account.

(b) During the device installation phase, we acquire wifi SSID information crucial for the remote control of your device by connecting to the internet. This allows you to effortlessly make selections by listing wifi devices closest to you.

By enabling access to your location, your location information is shared with our authorized mapping service providers for the aforementioned purposes. These providers are contractually prohibited from using or sharing this data for any other purpose. It's important to note that we only collect information when you actively engage with the Vfit+ Service."

o Legal Basis: Your consent is required only for the processing of some of your personal data or the use of your processed personal data for certain purposes. As a result, your location data can only be processed with your permission (Art. 5 (1) TDPR).

You can always prevent the Vfit+ Application from accessing your location by navigating to the location services section of your phone. Your location information is obtained instantly, and no tracking activity is conducted.

6. ANSWERING SMS OR CALLS VIA VFIT+ DEVICES

With Vestel Smart Watch and smart fitness wristlet, you can effortlessly handle incoming calls and read SMS notifications directly from your wrist. If you choose to use these features, your personal data will be processed for call management and SMS notification reading.

o Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 5 (2) lit. c TDPR).

7. EMERGENCY NOTIFICATION SYSTEM

Your Vfit+ Device, if the feature is available, offers you the service of alerting the emergency contacts that you have predetermined in case of an emergency.

If you do not cancel the emergency notification system that comes on the screen when you keep pressed the button on your smart watch for 5 seconds, the emergency notification system of your Vfit+ Device is activated.

If you gave Vfit+ Application permission to access your location information as soon as your emergency notification system is activated, your Vfit+ Device sends SMS messages to your emergency contacts letting them know you are in a situation that requires help and containing your location and your phone number for identification purposes.

Do not forget that your location will continue to be shared with your emergency contacts until you stop sharing by clicking the stop sharing button. Additionally, even if you stop it, your emergency contacts will still have your previous location information.

The purpose of the emergency information system is to provide quick and easy notification to the people on your emergency contact list in case of an emergency. Your contact information will be shared to the third party from which Vestel receives the SMS messaging services.

You can deactivate the access of the Vfit+ Application to your location services at any time in the location services access menu of your smart phone.

When you activate the access to your location services by the Vfit+ Application, you accept that your location data can be processed by Vestel and shared with third party service providers to allow you to use the services offered through the emergency notification system.

You can modify the emergency contact person list at any time in the dedicated menu of your smart phone.

o Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 5 (2) lit. c TDPR).

8. PROCESSING OF YOUR PERSONAL DATA WITHIN THE SCOPE OF ERROR REPORTING FEATURE

The error reporting feature was created solely to identify Appliance issues. Your specified personal information will only be used for product development, and you will not receive any feedback regarding the error you encountered.

In this regard, your personal information, including information about your Appliances (device ID, MAC address, local IP, software version, model), will be processed and transferred to hosting providers.

9. PARTIES TO WHOM PERSONAL DATA IS TRANSFERRED

Your personal will be shared only with the following persons and for the following purposes:

· Suppliers from whom services are provided in terms of software, maintenance, and security and hosting personal data within the scope of information technologies.

· Suppliers from whom services are provided in terms of software, maintenance, and security, as well as hosting personal data within the scope of information technologies.

· Our suppliers that facilitate sending SMS or email to you such as validation or marketing.

· Business partners we are doing business with on contract basis for providing services such as using additional services provided by business partners through the Application, e-mail management. Such business partners are responsible for the protection of your personal data based on the contracts made.

· Personal data is shared when it is reasonably necessary to comply with any law, regulations, or valid legal notification (e.g., summons or writs notified to us) or a request made by an official or regulatory agency, fulfil Service Use Conditions or Sales Conditions, ensure the security or integrity of the Vfit+ Service and/or to protect the rights, properties, or safety of Vestel, its employees, users or third persons.

· Personal information is shared with our legal advisor to protect Vestel's or third parties' legal rights.

· We may disclose or transfer your personal data in relation to any sale, merger, bankruptcy, asset sales or restructuring of our company. Please note that your personal will be processed by another company and this Privacy Policy will continue to apply for your personal data transferred to such company in such cases.

Data that does not identify you (anonymous data)

We may share your anonymous data with our partners and the public in various ways by presenting research or reports about health or fitness, and we may generate an income by use of such data. When we share anonymous data, we will implement proper procedures for the prevention of identification and prohibit the processing of the data-by-data acquirers for identification purposes with contracts.

In addition, we may share your anonymous data with Vestel Group Companies without disclosing your identity for the development of customer, product and service evaluations and analyses and performance of various statistical evaluations. After the anonymization of such details and information, Vestel Group Companies may also use the same for all kinds of income generating activities.

10. INFRASTRUCTURE OF ANALYTICS PROVIDERS

We may use third-party Web analytics services in connection with the services provided relating,

o Mobile application performance metrics and crash reports.

o Remote configuration for software update mechanism.

o Mobile application installation statistics.

o Sending push notifications to users.

o Segment audience, report and intents and actions of customers.

o Integration with third party services to facilitate the application.

o Infrastructure Services to build and maintain the app.

o Grow and engage user base.

11. HOW LONG ARE YOUR DATA STORED?

Your personal data will be stored if you maintain your Vfit+ account. When you close your Vfit+ account and decide not to benefit from the Vfit+ service, we will store your data for 5 years. At the end of this period, your all-personal data will be irrevocably removed from our all systems.

12. YOUR LEGAL RIGHTS UNDER THE PROTECTION OF PERSONAL DATA

Pursuant to Article 11 of the Personal Data Protection Law number 6698, you have the following rights:

a) Receive information whether your personal data have been processed or not.

b) Request related information if your personal data have been processed.

c) Receive information about the purpose of processing of your personal data and whether the data have been exactly used for the intended purposes.

d) Receive information about the third persons to whom his or her personal data have been transferred locally or internationally.

e) Request correction if your personal data have been processed deficiently or wrong.

f) Request the deletion or destruction of your personal data.

g) Request the communication of the correction, deletion, or destruction requests to third persons to whom your personal data have been transferred.

h) Object to conditions against you, which have resulted from the analyzing of your personal data by use of nonexclusive automatic systems.

i) Demand the compensation of your damages that have resulted from the unlawful processing of your personal data.

13. EDITING AND MODIFICATION OF YOUR DATA

In your Vfit+ account preferences, you can modify the data you disclosed on the Vfit+ Application. Any modification you will make regarding the data in your Vfit+ account cannot be seen by you or other persons using the Vfit+ Service.

14. DELETION OF YOUR VFIT+ ACCOUNT

You have the right to delete your account at any time by selecting the 'Delete My Account' button within the application. Once you submit your account removal request to us, it will be promptly processed. You can reactivate your account within ten days by logging into the application using your username and password. IF you do not login within ten days, your account will be permanently removed from our systems. Deleting your account will also remove all associated accounts on our

Vestel's websites (vestel.com.tr; regal-tr.com; vsoutlet.com.tr; cozumuvar.vestel.com.tr) or through Vestel’s applications (Evin Aklı Application).

To exercise your rights concerning your personal data, you can submit relevant requests to our company via the form available at https://statik.vestel.com.tr/webfiles/veri-sahibi-basvuru-formu.pdf"

15. CONTACT INFORMATION

In order to ensure the security of your data, Vestel employs a combination of technical and administrative security controls. In case you have any concern regarding data security, please contact our Customer Support Unit.

Turkey Customer Support Unit

Contact Details:

E-mail: vfit@vestel.com.tr

Phone: 0850 222 41 23

Address: Organize Sanayi Bolgesi 45030 Manisa-TURKEY

I hereby declare that I have read privacy policy and I have made the necessary notifications in line with the applicable legislation for the processing of the personal data about the persons included in my emergency contact persons list I have shared with Vestel, in order for the communication of emergency text messages by Vestel, under the utilisation of the Emergency Location Service by me, and that the data related to such persons are current and accurate.