PRIVACY POLICY

Data privacy is highly significant for MODANİSA and we want to be open and transparent with our processing of your personal data. 
We therefore have a policy setting out how your personal data will be processed and protected. It’s important, so please read it and make sure you control your privacy.
 

Before you start, we would like to explain our privacy principles:

• We take your privacy seriously.
• We are committed to protecting the security of your personal data.
• We comply with data privacy laws when using your personal data.
• We only use your personal data in the way we explain to you in this document.
• We will not collect your personal data, if it is not necessary.
• We will stop collecting your personal data where they are no longer necessary for the purposes they were collected for. 
• We will explain your rights to control your personal data.

 

Scope of our Privacy Policy

1. Who is the controller of your personal data?

2. Who is the Data Protection Officer?

3. What type of personal data does MODANISA collect?

4. For what purpose does MODANİSA process your personal data?

5. Does MODANİSA share your personal data?

6. Does MODANİSA send marketing messages to you?

7. Your information and countries outside Europe

8. How long does MODANİSA process your personal data?

9. What are your rights?

10. What about cookies and similar tracking technologies?

11. Update of this Privacy Policy due to improvement of our Services

12. How to contact us?

13. Reporting A Security Vulnerability

1.Who is the controller of your personal data?

The data controller for the processing of the data is MODANİSA ELEKTRONİK MAĞAZACILIK VE TİCARET ANONİM ŞİRKETİ (“MODANİSA”), with Corporate Tax ID number [6220586224]. The contact details of MODANİSA are as follows:

• Postal address: Altunizade Mahallesi Kuşbakışı Cad. No:27/1 Üsküdar/İstanbul (TURKEY)
• Telephone: (+9) 0850 333 64 72
• e-mail: info@modanisa.com

 ​​​​​​2.Who is the Data Protection Officer?

We have appointed a Data Protection Officer to ensure that we continuously process your personal data in an open, accurate and legal manner. You can contact our Data Protection Officer via the following contact details:

• dpo@modanisa.com

3.What type of personal data does MODANISA collect?

We use your personal data in a number of different ways — what we do depends on the information. The tables below set this out in detail, showing which type of personal data we collect and the purpose of collecting them.

 

Category of Personal Data	Examples of the Personal Data
Credentials & Contact Information	Such as your name, date of birth, national ID number, nationality, email address, postal address, telephone number and any other personal data
Order Information	Such as purchase, delivery and payment details, name and address of the recipient- if different from the customers
Payment / Card Information	Such as name of the card holder, card type, card number, expiry date and cvv code, invoice information, bank account number, etc.
Preference Information	Such as customer’s marketing preferences, account settings including any default preferences, any preferences indicated; such as country, language and currency, the type of products that the customer interested in or the areas of our website that the customer visits
Purchase History and Saved Items	Such as the products bought by the customer and/or stored in the customer’s basket for another time
Contact History	Such as the conversation made between Modanisa and the customer via phone, social media and instant chat whether related with an order or not
Device Information	Such as the IP address, internet provider, operating system and browser used, type of device; such as laptop or smart phone, device cookie settings and other device details, the geographic region which customer’s device reports to us
Legal Transactions and Compliance Information	Such as criminal records

 

You don’t have to give us any of this personal data but if you don’t, you may not be able to buy from the site, and you are unlikely to receive our optimal overall customer experience.  But that is your choice – and we respect that.

We also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis, improving our site and app, and developing new products and services. We also share this information with third parties. 

4. For what purpose does MODANİSA process your personal data?

MODANİSA processes your personal data for the following purposes and based on the following legal basis: 

The Purpose of Processing your Personal Data	Legal Basis for the Processing
To meet requests or applications that you make through the Corporate Contacts and Customer Contacts channels	Performance of a contract and our legitimate interest in keeping our customers/prospects updated about our services and products
To analysis of usability and quality to improve our services	Performance of a contract and our legitimate interest in keeping our customers/prospects updated about our services and products
To process your purchases and to provide you with the services and information offered through the website and which you request	Performance of a contract
To verify and carry out financial transactions in relation to payments you make	Performance of a contract
To improve and customize our website, products, services and business in general, such as by tracking your product preferences, shopping history and interactions through the website	Our legitimate interest to improve our products and services
To identify visitors of the website	Our legitimate interest to get to know our customers better and improve our services accordingly
To carry out data analytics and market research	Your prior explicit consent and our legitimate interest in keeping our customers/prospects updated about our services and products
To carry out data enrichment, such as by analyzing your product preferences, shopping history and interactions with the Website together with data collected from third parties, such as data that you agree to share with us on social networks (e.g., Facebook, Instagram, etc.) and/or that we may collect from publicly accessible databases	Your prior explicit consent and our legitimate interest in keeping our customers/prospects updated about our services and products
To resolve your queries or complaints	Your prior explicit consent
To send the marketing communications containing news, information and updates about our products and services, offers, promotions and special events, and other marketing communications that may be of interest to you (by SMS, email or telephone), and customize your experience with us to your interests and shopping habits and improving our services, notably via profiling. We also may use the data we collect about you to assist us in advertising our products and services on third party websites – please see our Cookie Policy for additional information.	Your prior explicit consent and our legitimate interest in keeping our customers/prospects updated about our services and products (for marketing via SMS and phone, Your prior and appropriate consent is required).

 
5. Does MODANİSA share your personal data?

We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or credit card information. We want to earn and maintain your trust, and we believe this is absolutely essential in order do that.

However, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this statement: 

• Business partners and shareholders of MODANİSA, as sometimes different bits of our group are responsible for different activities
• Companies that do things to get your purchases to you, such as payment service providers, warehouses, order packers, and delivery companies
• Professional service providers, such as marketing agencies, advertising partners and website hosts who help us run our business
• Legally competent public institutions and organizations, credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud
• Companies approved by you, such as social media sites (if you choose to link your accounts to us)

 

We may provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.

6. Does MODANİSA send marketing messages to you?

If you have said we can, we’ll send you marketing messages by email, SMS, to keep you aware of what we’re up to and to help you see and find our products. If you would like to stop receiving marketing messages from us you can do following;

• Go through your account
• Unmark your previously selected preference
• Click “Update” button.

Once you do this, we will update your profile to ensure that you don’t receive further marketing messages. Please note that, as MODANİSA comprises a complex web of many inter-connecting services, it might take a few days for all our systems to be updated, so you might get messages from us while we process your request.

7. Your information and countries outside Europe

We have a fulfilment centre in the Turkey, which we may use for processing orders from customers in the EU. The Turkey is not a country in respect of which there is a European Commission decision of adequacy, and we protect your privacy and your rights through the use of the European Commission’s standard data protection clauses. More information about these is available here:

http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32010D0087

8. How long does MODANİSA process your personal data?

We’ll only hold on to your information for as long as you are a customer. If you no longer wish to be a customer, you can also contact our Customer Experience team and request to delete all the information we have on you.

If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms & Conditions, we may also keep hold of some of your information as required, even after you have closed your account or it is no longer needed to provide the services to you.

9. What are your rights?

You have the following rights, which may be exercised via sending and e-mail to the e-mail addres dpo@modanisa.com:

• Right of access: You have the right to access to and obtain information regarding your personal data MODANİSA may hold, and how MODANİSA use your personal data; to request a copy of any of your personal data from MODANİSA hold about you. You may see most of your personal data yourself online.

• Right of rectification: You have the right to complete your Personal Data whenever they are incomplete and to request MODANİSA to rectify your personal data which whenever they are inaccurate. You may also prefer to correct or complete your Personal data directly by modifying your profile via website/app of MODANİSA. Please note that, you will be liable for any loss or damage caused to MODANİSA or to the person responsible for the MODANİSA by reporting erroneous, inaccurate or incomplete information in the registration forms.
• Right to erasure: You have the right to request the deletion or destruction of your personal data where your personal data is no longer necessary for the purposes they were collected for.
• Right to restriction: You have the right to request the restriction of the processing of your personal data for so long as we are considering any request you have made to us to correct or complete your personal data, or you have objected to processing justified on legitimate interests. If you use your right to restriction, we will only process it with your consent or for the establishment, exercise or defense of legal claims.

• Right to data portability: You have right to receive the personal data you will provide to us in a structured, commonly-used and machine-readable, and also to transmit them to another controller whenever the processing is based on consent or on a contract and is carried out by automated means.
• Right to withdrawal of consent: Where applicable, you have the right to withdraw your consent at any time.  For instance, if you wish to opt-out of receiving electronic marketing communications, you may change your settings in your account on the Website, use the 'unsubscribe' link provided in our emails or text the STOP number in our SMS, or you may contact us directly via e-mail written above.
• Right to object: You may object to the processing of your personal data based on the public or legitimate interest pursued by MODANİSA, including profiling. In this case, MODANİSA will stop to process your personal data, except for compelling legal grounds or the exercise or defense of possible legal claims.
• Automated individual decisions: You have the right not to be the object of a decision based solely on automated processing, including profiling, while produces a legal effect on you or significantly affects you in a similar manner. However, it will not be possible to exercise said right in cases where the decision is necessary for the formalization or execution of a contract between you and MODANİSA; it is authorized by the law applicable to MODANİSA provided it establishes the appropriate measures to safeguard its rights, freedoms and legitimate interests; or where it is based on your explicit consent. 
• Right to lodge a complaint: You have the right to lodge a complaint with a data protection authority if you consider that the processing of your personal data infringes applicable law. 

10. What about cookies and similar tracking technologies?

• We use cookies and similar technologies to deliver a tailored and smoooth online experience. For detailed information about how MODANİSA uses cookies and similar, please read our [Cookie Policy].

11. Update of this Privacy Policy due to improvement of our Services

We constantly work to improve our offerings in order for you to get an even smoother user experience. This includes both changes in existing services and new services over time. Thus, we may change this page from time to time, to reflect how we are processing your data.

If we make significant changes, we will make that clear on the MODANİSA website or other MODANİSA services, or by some other means of contact such as email, so that you are able to review the changes before you continue to use MODANİSA. 

12. How to contact us?

We always want to hear from our customers (especially if you feel we’ve let you down or could do better).

If you,

• Have any questions or feedback about this Privacy Policy,
• Would like us to stop using your personal data,
• Want to exercise any of your rights as set out above, or have a complaint

please don’t hesitate to contact our Customer Experience team, who will be happy to answer any questions you may have, thought telephone and or email determined above.

13. Reporting A Security Vulnerability

We’re all about taking risks when it comes to our designs, just not our security. If you’ve noticed something’s up with our tech, let us know. Drop an email to dpo@modanisa.com with your contact details, including your company name and details of the vulnerability and what we need to do to reproduce or validate it.

Modanisa Elektronik Mağazacılık ve Ticaret Anonim Şirketi ("Holding Company") and its Group Companies (Holding Company and its Group Companies together referred as “Modanisa”) are subject to the legal requirements of the jurisdictions in which it does business, including the Republic of Turkey. Among these requirements are international conventions and other applicable regulations relating to human trafficking, slavery, servitude, child labor and forced or compulsory labor, immigration, recruitment, working hours, minimum pay and workplace conditions.

It is therefore vital for Modanisa and all Modanisa Employees understand and comply with this Supply Chain and Working Conditions Policy (“SCWC Policy”) and consult the Compliance Officer if they have any doubts about whether an activity is permitted. Modanisa is committed to avoiding any activity that would result in modern slavery, servitude child labor, forced or compulsory labor or human trafficking.

Modanisa is also committed to having high standards for supply chain and working conditions. Therefore, Modanisa maintains a policy of zerotolerance towards human trafficking, slavery, servitude, child labor and forced or compulsory labor. Any evidence of violations of applicable laws or of the principles outlined in this SCWC Policy will be investigated and appropriate disciplinary measures may be taken.

2.Definitions

“Business Partners” means any Suppliers, contractors, sub-contractors, agents, joint venture partners, non-controlled subsidiaries, consortium partners, representatives, brokers, custom brokers, real persons or legal entities concluding intermediary, teaming or similar agreements with Modanisa, nominated sub-contractors, consultants, advisers, lawyers and other intermediaries who have a business relationship with Modanisa.

“Compliance Officer” means the full-time employee appointed by the Holding Company reporting directly to the CEO of the Holding Company. The Compliance Officer is responsible from supervision and the application of this SCWC Policy.

“Group Companies” means any entity owned or controlled, directly or indirectly, by the Holding Company, or any entity, directly or indirectly, under common control with the Holding Company.

“Holding Company” means Modanisa Elektronik Mağazacılık ve Ticaret Anonim Şirketi.

"Hotline" means the secure and accessible channels through which Modanisa Employees, Business Partners and other parties can anonymously raise concerns with Modanisa and report suspicious circumstances (i.e., any potential violation of this SCWC Policy) in confidence and without risk of reprisal.

“Modanisa” refers to the Holding Company together with its Group Companies.

“Modanisa Employees” means any board of director, executive, manager, officer, employee, agent, contractor, worker, consultant or representative of Modanisa.

“Modern Slavery and Human Trafficking Laws” means all applicable anti-slavery or human trafficking laws, statutes, regulations and codes from time to time in force applicable to Modanisa including laws, statutes and regulations relating to immigration, recruitment, slavery, servitude, forced or compulsory labor, child labor, working hours, minimum pay and work place conditions.

“SCWC Policy” means Modanisa's Supply Chain and Working Conditions Policy.

“Supplier” means Modanisa's suppliers providing products, raw materials or services which are required for Modanisa to carry out its business activities. Suppliers should be interpreted as key Business Partners while interpreting this SCWC Policy.
 

3.Priority between the SCWC Policy and Legislation

Modanisa and Modanisa Employees may be subject to the laws of many countries around the world. Modanisa and Modanisa Employees are expected to act in accordance with the laws of the Republic of Turkey, the applicable laws of the concerned countries and this SCWC Policy. In case of a discrepancy between the provisions of this SCWC Policy and the applicable laws, the applicable laws will prevail.

4. Scope

This SCWC Policy applies to (i) Modanisa, (ii) all Modanisa Employees regardless of their position and (iii) all Business Partners (where applicable) including any suppliers of Modanisa and any persons and organizations carrying out activities for or on behalf of Modanisa. All Modanisa Employees are required to sign the statement attached in Annex-1 in which they undertake to comply with Modanisa's SCWC Policy.

5.  General Rules
  
Modanisa undertakes to comply with all Modern Slavery and Human Trafficking Laws including but not limited to Turkish Labour Law No. 4857, Turkish Regulation on the Procedure and Principles of the Working Conditions of Children and Young Workers, UK Modern Slavery Act 2015. Modanisa will endeavor to comply with all global standards on this issue determined by the international organizations, all international conventions issued by the International Labour Organisation including but not limited to (i) Freedom of Association and Protection of the Right to Organise Convention, 1948, (ii) Forced Labour Convention, 1930, (iii) Abolition of Forced Labour Convention, 1957, (iv) Minimum Age (Industry) Convention, (v)Equal Remuneration Convention, 1951, and (vi) Discrimination (Employment and Occupation) Convention, 1958.

 

All Modanisa's Suppliers and other Business Partners will endeavor to comply with the above mentioned rules while they carry out their activities. Any violation may lead to unilateral termination of the agreements between Modanisa and that specific Supplier other Business Partner as explained in Article 13 below.

6. Forced Labor, Human Trafficking and Modern Slavery

According to ILO Forced Labour Convention, 1930, forced or compulsory labour is all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.

According to the Protocol to Prevent, Suppress and Punish Trafficking in Persons, human trafficking is the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation.

Modanisa is against any kind of involuntary work. Modanisa acknowledges that employment must be on voluntary basis and chosen on free will. Modanisa, its Suppliers and other Business Partners cannot take any action which would result in modern slavery, servitude, child labor, forced or compulsory labor or human trafficking.

 

7. Child Labour

Modanisa, its Suppliers and other Business Partners acknowledge that children under 15 years old cannot be employed under any circumstances. A child above 15 years can only be employed if applicable local regulations including but not limited to Turkish Regulation on the Procedure and Principles of the Working Conditions of Children and Young Workers permit. In any event, if a child above 15 years is planned to be employed, extra caution must be given both before and during the employment to ensure the continued compliance with the applicable regulations. All applicable regulations on the children's working conditions should be strictly followed at all times.

8.Wages and Working Hours

Modanisa, its Suppliers and other Business Partners must comply with all applicable laws regarding wages and working hours, including minimum wage, overtime, maximum working hours, meal and rest periods, and provide the subsidiary rights that are legally required. In the cases where local industrial standards exceed applicable legal requirements, Modanisa, its Suppliers and other Business Partners are encouraged to meet these higher local industrial standards.
 

9. Freedom of Association and Collective Bargaining

Modanisa, its Suppliers and other Business Partners respect the right of their employees to be or not to be members of a union, or the right to accept the employee representation in accordance with the local laws. Modanisa, its Suppliers and other Business Partners do not discriminate against their employees based on their union choice or membership.

 

10. Discrimination

According to the International Labour Organization, discrimination in employment and occupation means treating people differently and less favorably because of characteristics that are not related to merit or the requirements of the job. These characteristics include race, color, sex, religion, political opinion, national extraction and social origin (as well as any other set out under applicable local law). Modanisa, its Suppliers and other Business Partners do not tolerate any discrimination based on the above characteristics and will not discriminate against their employees or their business partners based on any of the abovementioned characteristics.

11.Health and Safety

Modanisa, its Suppliers and other Business Partners must comply with all applicable laws, rules, regulations and industrial standards related to health and safety to preserve their employees' physical and mental wellbeing. Modanisa, its Suppliers and other Business Partners will take measures required by applicable law for preventing accidents and injuries.
 

12.Engagement with Suppliers and other Business Partners

Modanisa is required to carry out due diligence before engaging with a Supplier to determine whether they comply with Modern Slavery and Human Trafficking Laws. In the event that an issue or red flag is uncovered as part of this due diligence process, Modanisa may not engage with the relevant Supplier until the relevant risk is adequately addressed or rectified. If any issues identified during the due diligence process cannot be adequately addressed or rectified, then Modanisa may not engage with that specific Supplier at all.

Once the due diligence is completed and no issues have been identified, or any issues that have been identified have been adequately addressed or rectified, then Modanisa can engage with the relevant Supplier. Before any such engagement, the relevant Supplier will be provided with this SCWC Policy and they will be required to sign the template statement attached in Annex-2 in which they undertake to use their reasonable efforts to comply with this SCWC Policy and the Modern Slavery and Human Trafficking Laws.

Modanisa will also provide a copy of this SCWC Policy to its current Suppliers and request that they sign the statement attached in Annex-2 in which they undertake to use their reasonable efforts to comply with this SCWC Policy and the Modern Slavery and Human Trafficking Laws. In case of failure to sign the statement attached in Annex-2, the relationship with that Supplier may be terminated.

In the event that Modanisa suspects that any of its potential Business Partners violate the Modern Slavery and Human Trafficking Laws, Modanisa carries out the same engagement process mentioned above for the Suppliers to ensure its potential Business Partner's compliance with the this SCWC Policy and the Modern Slavery and Human Trafficking Laws.

 

13. Expectations from Suppliers

All Suppliers are expected to comply with the SCWC Policy and the Modern Slavery and Human Trafficking Laws at all times. In the case of a failure to comply, Modanisa reserves the right to immediately terminate its relationship with that specific Supplier. In order to ensure its Suppliers' compliance with the SCWC Policy and the Modern Slavery and Human Trafficking Laws, Modanisa may audit its Suppliers from time to time.
 

14. Audits over Suppliers

Modanisa audits its Suppliers' facilities from time to time to determine whether they comply with this SCWC Policy and the Modern Slavery and Human Trafficking Laws. Modanisa also carries out audits when it receives any report or allegation regarding violation of this SCWC Policy or the Modern Slavery and Human Trafficking Laws by one of its Suppliers. During these audits, the Suppliers' employees working conditions are audited.

If any deficiency or violation of this SCWC Policy and the Modern Slavery and Human Trafficking Laws is determined during these audits, the violations and deficiencies are reported to the relevant Supplier with a suggested action plan. The relevant Supplier is given a 30 day period to cure the violation or deficiency. If no substantial improvement is made within 30 days, then Modanisa may unilaterally terminate its agreement with the relevant Supplier without being obligated to pay compensation.

15. Agreements with Suppliers

As long as it is practically possible, in any agreement to be executed between Suppliers and Modanisa, Modanisa endeavors to include audit rights over Suppliers, unilateral termination rights without Modanisa being obligated to pay compensation and right to request compensation by Modanisa in case of a unilateral termination in case of violation of this SCWC Policy and the Modern Slavery and Human Trafficking Laws to ensure their efficient application. During the renewal of existing agreements, such provisions will also be included in the existing agreements. In case of need, such provisions will be added into the agreements to be executed between other Business Partners and Modanisa.

16. Accessibility of this SCWC Policy

Modanisa ensures that a link to this SCWC Policy is accessible on the first page of Modanisa’s website to promote its compliance with all Modern Slavery and Human Trafficking Laws. A statement in compliance with the UK Modern Slavery Act 2015 can also be found in Modanisa's website through this link [please insert the link].

17. Trainings

In order to promote the compliance with the SCWC Policy, Modanisa provides specific training to all Modanisa Employees. This training will be tailored in accordance with the relevant needs and circumstances as well as Modanisa Employees' seniority and position. This training will be related to the Modern Slavery and Human Trafficking Laws and the SCWC Policy. Modanisa Employees, regardless of their positions, are all required to participate in any such training. Any failure to attend any such training without a valid reason may result in disciplinary sanctions.

These compliance trainings are to be provided to all new employees as part of their orientation program.

Where appropriate, Modanisa may also provide compliance trainings related to this SCWC Policy to its Business Partners, especially to its Suppliers. The refusal to participate in any such training without any valid reason may result in the termination of the business relationship without paying any compensation.

Face-to-face compliance training will be provided to Modanisa Employees based at the headquarters of the Holding Company. For other Modanisa Employees based in foreign countries or other cities in Turkey, online training will be provided. Additionally, if required and so far as is practical, translation to different languages will also be provided.

The Compliance Officer is responsible for the preparation and provision of training regarding the SCWC Policy and the Modern Slavery and Human Trafficking Laws, and may request assistance from the human resources department.

18. Reporting Violations

All Modanisa Employees are responsible for Modanisa's compliance with the Modern Slavery and Human Trafficking Laws. If any Modanisa Employee notices a violation of the SCWC Policy, they are required to immediately report the aforementioned situation to the Compliance Officer and/or Hotline. Modanisa encourages all Modanisa Employees to raise concerns and report suspicious circumstances to the Compliance Officer and/or Hotline as early as possible. The failure to report any suspicion is considered as a violation of this SCWC Policy.

Upon receipt of any concern, Modanisa will look into and address the matter.

19. Investigation

Modanisa takes seriously any notice relating to possible violation of the Modern Slavery and Human Trafficking Laws or this SCWC Policy. The Compliance Officer will confidentially examine the situation and determine appropriate action and next steps. Any individual involved in an investigation related to this SCWC Policy is required to cooperate in good faith with such investigation. Any individual who is involved with any such investigation will, subject to any applicable law, be required to keep all discussions and information confidential.

All parties involved in investigations are expected to cooperate during an investigation and provide all requested information and documents in a timely manner. If required, the Suppliers and other Business Partners must ensure that all actions are taken to comply with the requirements provided in the Turkish Personal Data Protection Law No. 6698 relevant to their own employees.

20. Internal Audit

During the periodical internal audits to be carried out in Modanisa, Modanisa and Modanisa Employees' continued compliance with the SCWC Policy and the Modern Slavery and Human Trafficking Laws is also assessed. If any failure of these rules or any room for development is identified during these internal audits, they are reported to the Compliance Officer with the suggested actions. The Compliance Officer is responsible for the supervision and implementation of any suggested actions.

21. Hotline

All Modanisa Employees, Suppliers, Business Partners and other parties can raise concerns related to the Modern Slavery and Human Trafficking Laws with Modanisa and report suspicious circumstances in confidence and without risk of reprisal through the Hotline. All reports to the Hotline can be made anonymously.

The “Modanisa Compliance Hotline” can be accessed through the following channels:

• Phone Number: [please insert a number]
• E-mail Address: [please insert an email address]

All complaints submitted to the Hotline will be kept confidential. Subject to any applicable local law, whistleblower's name will not be disclosed. All Modanisa Employees are encouraged to report their suspicions of misconduct in good faith in a "fear-free" environment, which ensures that they will not be subject to any form of reprisals.

22. Questions

Related to this Policy All Modanisa Employees and Business Partners can address their questions or concerns regarding this SCWC Policy to the Compliance Officer. If any investigation should be initiated related to these concerns, the Compliance Officer will carry out the investigation confidentially.

 

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

We know that slavery, servitude, child labour, forced labour and human trafficking (“Modern Slavery”) are global and growing issues given the rapid increase in global migration, existing in every region in the world and in every type of economy, whether industrialised, developing or in transition. No sector or industry can be considered immune or untainted. Modanisa is very keen on having high standards for supply chain and working conditions. Modanisa has zero-tolerance approach to Modern Slavery including but not limited to human trafficking, slavery, servitude, child labour, forced labour within our operations and supply chain. We all have a responsibly to be alert to the risks in our own business and in the supply chains. Any evidence of violations of the applicable laws will be investigated and appropriate measures will be taken.

Our organisation and business

Founded in 2011, Modanisa enables modest women to look good and feel self-confident in today’s world. Our mission is to build a global ecosystem that combines fashion and technology to serve the life style needs of modest women. We bring fashion and technology together with iconic brand and smart operations to create great value for our customers. We invest in each and every customer’s experience. We strongly believe in putting people first – our customer, our team, our partner. We bring accessibility to latest fashion, embrace differences and honor diversity. We build mutual trust with our stakeholders and we are a brand good on our word.

Our policies on Modern Slavery

It is one of our guiding principles to build and maintain the highest standards amongst our suppliers and take practical steps to guard against exploitation of workers, forced labour, harassment, intimidation and human trafficking. Equally, Modanisa is focussed on providing a working environment in which our People can thrive. Our suite of people-related strategies and policies ensure that integrity is ingrained as a core value, and annual delivery of our specialist modern slavery training validates our shared understanding of our compliance culture. It is the responsibility of all our People to adhere to the strategies, policies and training provided, in addition to any specific local requirements. Our strategies and policies are extended to our prospective supply chain partners through our SCWC Policy and are made available through our corporate website.

Modanisa internal policies include our Supply Chain and Working Conditions Policy (“SCWC Policy”) where we confirm that we will not tolerate or condone abuse of human rights within any part of our business or supply chains and will take seriously any allegations that human rights are not properly respected. In addition, our other internal policies and procedures such as our Employment Procedure and Code of Ethics envision rules which embody our utmost attention and sensitivity for fight against Modern Slavery.

Our supply chains

Almost all of Modanisa’s product suppliers are based within Republic of Turkey but we are provided with the services from all over the world, especially technology suppliers based overseas.

We have zero tolerance to Modern Slavery. As part of the Modanisa’s commitment to these principles, in May 2019 Modanisa developped the Modanisa Supplier Situation Analysis System for its suppliers (“Supplier Analysis System”) as part of its supply chain management. Modanisa requests to be informed about suppliers’ situations and their commitment on ethical business principles in several areas where human rights can be affected. These include the prohibition of forced labour, child labour and inhumane treatment. In connection with the priority issues established in the different areas, enhancing management of the entire supply chain from the viewpoint of corporate social responsibility has been established as a priority area.

All Modanisa employees around the world are required to abide by SCWC Policy in order to ensure that Modanisa exhibit and promote ethical business activities. Modanisa do not use child or forced labour in any of our global operations or facilities. None of us should tolerate any form of unacceptable treatment of workers in our operations or facilities. This means, among other things, that we do not permit exploitation of children, physical punishment or abuse, or involuntary servitude. We fully respect all applicable laws establishing a minimum age for employment, in order to support the effective abolition of child labour worldwide. Workers under the age of 18 shall not perform hazardous work and all workers under the age of 18 are employed solely with legal intern status. Employees understand that they must know and follow our policies, as well as the policies and procedures that apply to their job. Employees are expected to report known or suspected violations. Finally, failure to follow the law or the policies will subject employees to disciplinary action, up to and including termination.

We promote action to ban slavery and human trafficking from our supply chain. For the products that we sell, suppliers of those products are requested to commit to the ethical business principles set out in SCWC Policy. Further, we reflect those standards in agreements with suppliers. For products that we source ourselves and for services, all our suppliers receive a statement within their terms of business of our expectation that they, and their own supply chain, are free of slavery, servitude, forced labour and human trafficking. The statement refers to confirmation that our suppliers are deemed to be giving if they continue to supply products and/or services to us.

We take all reasonable levels of assurance and undertake the following activities on an ongoing basis to assess and address these risks:
 

• Due diligence process with a supplier in order to determine whether that they comply with Modern Slavery,
• Informing the suppliers related with SCWC Policy and Modern Slavery regulations and obtainment of statement in which suppliers undertake to comply with them,
• Determining the parts of the supply chain where there is a risk of slavery and human trafficking and implementation of a special audit program for the suppliers possessing such risks,
• Providing Modern Slavery trainings to all employees, and
• Implementation of a process on reporting violations.

Training

In order to promote the compliance with the SCWC Policy, Modanisa provides specific training to all Modanisa Employees. This training will be tailored in accordance with the relevant needs and circumstances as well as Modanisa Employees' seniority and position. This training will be related to the Modern Slavery and Human Trafficking Laws and the SCWC Policy. Modanisa Employees, regardless of their positions, are all required to participate in any such training.

Declaration

This statement has been published in accordance with the Modern Slavery Act 2015 and it sets out the steps taken by Modanisa Elektronik Mağazacılık ve Ticaret A.Ş. and its group companies (“Modanisa”) during year 2019 to prevent modern slavery and human trafficking in its own business and its supply chains.

As always, Modanisa will approach the fight against Modern Slavery with sensitivity and further develop the measures it takes in this context every year.



 

 

POLICY FOR CONFIDENTIALITY AND PROTECTION OF PERSONAL DATA

 

1. POLICY OBJECTIVE AND SCOPE

The objective of this Policy for Confidentiality and Protection of Personal Data (“POLICY”) is to inform individuals in relation to the processing of personal data of job applicants, suppliers, online and physical visitors, members, customers, shareholders and partners of MODANISA’s (“Data Supervisor”).

2. APPLICANTS
   1. Personal Data Collected in Relation to Applicant Group of Individuals

In relation to the group of individuals applying for a job, MODANISA may process information such as;

• Personal background, work experience, educational background, foreign language certificate and other certificates,
• Name and surname, address, date of birth, e-mail address, telephone number and other contact details,
• Records of information obtained during face to face interviews or via teleconference, video call or telephone,
• References or information obtained via research conducted by MODANISA, 
• Results of recruitment assessment tools determining skills and personal attributes,
• Salary expectations, disabilities and liabilities, 

and method of payment. Documents such as a criminal record and health report may also be required.

2. Purposes for Collecting and Processing Personal Data of Applicants

MODANISA may process an applicant’s personal data  based on one or more purposes specified  in  the section of this POLICY, titled “VII. Personal Data Processing  Purposes,” in accordance with the nature of the application.

• Evaluating the suitability of the applicant’s qualifications, experience and interest in relation to  the vacant position,
• Checking the validity of the information submitted by the applicant or contacting third parties for reference check purposes when required,
• Contacting applicant concerning the recruitment process or, if suitable, contacting the applicant for any position subsequently opened in the country or abroad,
• Meeting the requirements of regulations or those of an authorized body or organization,
• Developing and improving the recruitment principles implemented by MODANISA,
• Implementing operations which are required within the context of occupational health and safety.

3. Methods of Collecting and Processing of Personal Data of Applicants

Personal data of applicants may be collected during the recruitment process by employing other methods and tools specified  in this POLICY, or with additional methods and tools specified  below:

• Application form in print or published in  an electronic environment,
•  CVs which  have been submitted to MODANISA by applicants via e-mail, cargo, references and similar methods.
•  Recruitment or consultancy firms and LinkedIn,
•  Research carried out by MODANISA with the aim of confirming the accuracy of information obtained from the applicant during interviews conducted
•  Via tools such as video conferencing and telephones,
•  Recruitment tests which determine skills and personal attributes, carried out and analyzed by experienced experts.

MODANISA processes collected personal data via computer systems and human resources personnel, automatically and manually.

4. Applicant Reference Checks

MODANISA may carry out reference checks in respect of  the applicant. The reference check process is usually carried out by means of confirming the accuracy of the information provided by the applicant. Determining factors  that may have been withheld by the applicant and which may have the capacity to cause a threat to MODANISA will be part of the research conducted.

In the context of the reference check, necessary personal data such as the identification information of third parties and applicants, work and educational backgrounds may be shared. Personal data concerning the applicant may be obtained from third parties .

Applicants may, at all times, contact MODANISA regarding the reference check process.

5. Applicants’ Rights Related to their Personal Data

Applicants who wish to exercise their rights based on the Law on Protection of Personal Data no 6698 (“LPPD”) may apply to MODANISA in accordance with the rules and procedures declared in this POLICY.

6. The Personal Data Collected During the Application Process Which will Continue to be Processed in the Instance of Recruitment

All personal data concerning the applicant which has been collected and processed during the application procedure are transferred to their personal file upon the decision to recruit the candidate for the vacant position.

7. Security of Applicants’ Personal Data

With regards to  the personal data it processes,  MODANISA does not discriminate amongst data subject groups of individuals (such as applicants, group of individuals, interns). Detailed information regarding the security of personal data is found in the section of this document related to the security of personal data.

 

3. PRINCIPLES IN RELATION TO PROCESSING OF PERSONAL DATA
   1. Processing in Compliance with Law and Principle of Honesty

In the processing of personal data, the principles which are enshrined in  legal regulations, and those which are related to general confidence and  honesty are being complied with .

2. Ensuring that the Personal Data is Accurate and Up-To-Date when Necessary

Periodical verifications  and updates are made so  that the data processed are accurate and up-to-date, and the necessary measures are taken accordingly. In this context, systems for controlling the correctness of personal data and making necessary corrections are implemented in MODANİSA. These changes and updates can be made by members on the My Account page at www.modanisa.com.

3. Processing for Specific, Clear and Legitimate Purposes

Personal data are processed in accordance with  clear, specific and legitimate data processing purposes. The purpose for  which the data will be processed is described in detail below.

4. Being related to and Limited to the Purpose of Processing thereof, and Being Measured

In order for  the envisaged purpose/purposes to be realized, personal data are processed in a measured manner  and which is related to  and limited to the purpose, and we abstain from processing the personal data which are not related to achieving the purpose or which are not needed.

5. Preserving for the Period Stipulated in the Relevant Legislation or the  Period Required for the Purpose of Processing Thereof

MODANİSA preserves personal data only for the period prescribed  in the relevant legislation or the  period required for the purpose of processing thereof. In this context ,  first of all we identify whether a period is stipulated in the relevant legislation for the preservation of personal data, if a period is prescribed  , we act in accordance with it , and if no period is prescribed , we preserve the personal data for the  period required for the purpose of processing thereof. In case of expiry of such period or in case the reasons requiring them to be processed cease to exist , provided  there is no legal reason for allowing them to be processed for longer periods, personal data are deleted, destroyed or anonymized in accordance with MODANİSA’s Policy on Preservation and Destruction of Personal Data.

Preservation periods have been additionally indicated below.
 

4. TERMS AND CONDITIONS IN RELATION TO PROCESSING OF PERSONAL DATA

Express consent of the relevant person is only one of the conditions that needs to be satisfied according to the law and which makes processing of personal data legally possible. Apart from express consent, personal data may also be processed in case of the existence of one of the below-specified conditions stipulated by the law.

The basis on which  personal data processing  activity is carried out may be  one or more than one of the below-specified conditions specified by the law. In the case where the personal data processed constitute private personal data; conditions listed under the heading “Circumstances Where Private Personal Data May be Processed” will be applied.

Individuals are informed of which personal data are being processed under  this hereby POLICY, for which purposes and reasons the personal data are being processed, from which resources the personal data are collected, with whom these personal data will be shared, and how they will be used.

1. Being Explicitly Stipulated by Laws

 MODANİSA can process the personal data of individuals without obtaining his/her express consent in cases where processing of personal data is explicitly prescribed  by laws For example, pursuant of the Law on Electronic Trade Regulation, personal data to be processed in respect of  procedures such as membership to MODANISA, granting electronic permission for trade, purchase orders, deliveries, cancellation or return of products.

2. Inability to Obtain Express Consent of the Relevant Person Due to Actual Impossibility

Data may be processed without the explicit consent of an individual if it is compulsory to process personal data in order to protect the life or body integrity of the individual or any other person where  an individual cannot give his/her consent or whose consent is deemed invalid due to actual impossibility.

3. Direct Relationship with Conclusion or Performance of a Contract

Personal data belonging to the parties of a contract may be processed in case it is necessary,  provided that it is   directly related to the conclusion or performance of said contract. For example, the personal data provided by the Member in order to complete their MODANISA membership procedure.

4. Performance by MODANİSA of its Legal Obligation

Individuals’ data may be processed without obtaining explicit consent, where it is  compulsory to fulfill legal obligations as a data supervisor. For example, the delivery of an ordered product to a Member or the cost of a product being paid to the seller.

5. Making Public the Personal Data of Individuals

In case individuals’ personal data are made public by themselves, data may be processed without the need to obtain express consent. .For example, personal data shared with the public by a member on the internet via HIS social media account, may be processed provided that it is done in accordance with the will and proportionality .

6. Obligation to Process Data for Establishment or Protection of a Right

In the case where  data processing is mandatory in order to establish, exercise or protect a right, data may be processed without obtaining the express consent of the individual. For example, in relation to a complaint issued to the consumer arbitration committee by a Member, entering the transaction and information into this complaint folder.

7. Processing of Data Based on Legitimate Interest

In case the data processing for MODANİSA's legitimate interests is compulsory provided that the fundamental rights and freedoms of the individuals are not infringed, the data may be processed without obtaining the individual's explicit consent. For example, MODANISA conducting satisfaction surveys in order to ensure Customer satisfaction.

8. Processing of the Employee’s Personal Data Based on Express Consent

Employee personal data shall be  processed on the basis of express consent in cases where it can not be processed based on any of the conditions specified in Articles 3.1 to 3.7 above.

 

5. CIRCUMSTANCES WHERE PRIVATE PERSONAL DATA MAY BE PROCESSED

Part of the personal data are categorized  as “private personal data”, and they are subject to a special protection.

1. Processing of Private Personal Data Based on Express Consent

Private personal data may be processed in the event that the individual has given his/her express consent  in accordance with the principles specified in this hereby POLICY and by taking the necessary administrative and technical measures.

2. Circumstances Where Private Personal Data may be Processed Without Express Consent

In cases where the individual has not given his/her express consent, in the following cases, private personal data are processed provided  that sufficient measures to be determined by the Board of Protection of Personal Data (“Board”) are taken:

1. Private personal data other than  the individual’s health condition and sexual life, in cases where stipulated by laws,
2. Private personal data in respect of the health of the individuals and sexual life shall be  only available to persons who are bound by the duty of confidentiality or authorized bodies and institutions for the purpose of public health protection, preventive medicine, medical diagnosis, treatment and  care services, planning and management of health services and financing.

 

6. ENLIGHTENING AND INFORMING INDIVIDUALS

During the acquisition of personal data, individuals shall be informed by MODANİSA. In this context , they shall be  informed of the identity of the contact person of MODANİSA, the purpose for which personal data will be processed, to whom and for which purposes the data processed may be transferred, method of collecting personal data, and the rights that the employees are lawfully entitled to.

In case individuals request information in relation to their personal data, MODANİSA shall inform  them through ik@modanisa.com . Physical visitors shall be  informed about the video cameras present   on  MODANISA's premises . Additionally, there are signs placed at  visible points inside the building, which offer brief information.  With this hereby Policy, users visiting the MODANISA web site are informed; those who become Members are informed yet again not only by this hereby Policy, but also with the details presented on the Membership page.

 

MODANISA Contact Person: Lawyer Fatih Onur LENGERLİ

kisiselverilerim@modanisa.com

 

7. CATEGORIZATION OF PERSONAL DATA

Within the scope of this policy, MODANİSA processes the data of individuals in the below-specified categories:

• Credentials
• Contact Details
• Location Data
• Information on Family Members and Kith and Kin
• Physical Space Security Information
• Financial Information
• Personal Information
• Candidate Employee Information
• Individuals Processing Information
• Legal Transactions and Compliance Information
• Private Personal Data
• Information on Complaint Management

 

8. PURPOSE OF PROCESSING OF PERSONAL DATA
   1. Processing Conditions

Personal data are processed subject to  the following conditions. The conditions are;

• The relevant activity in relation to the processing of your personal data is explicitly stipulated by laws,
• The processing of your personal data by MODANİSA is directly related to and necessary for the conclusion or performance of a contract,
• The processing of personal data is mandatory  for the fulfillment  of MODANİSA’s legal obligation,
• Provided  that the personal data has been shared with  public by the individuals; to be processed by MODANISA in a proportional manner  for the purpose of publicity .
• Processing by MODANİSA of personal data is mandatory  for the establishment, exercise or protection of rights of MODANİSA or its individuals or third persons,
• Provided  that the fundamental rights and freedoms of individuals are not infringed ,  the processing personal data is obligatory in order to uphold  the legitimate interests of MODANİSA,
• The processing of personal data by MODANİSA is mandatory for the preservation  of the life and physical integrity of the data owner or another person, and in such a  case where  the owner of personal data is  in a position where he /she cannot give his/her consent due to an actual impossibility or legal invalidity.

In the case that the above conditions are satisfied; MODANİSA seeks to obtain the  express consent of the personal data owners in order to process personal data.

2. Processing Purposes

MODANISA shall process personal data for the following purposes:

Candidate Working Group:

• Ensuring completion and implementation of   human resources policies and processes ,
• Planning the selection and evaluation procedures of candidate worker’s applications,
• Implementing required operations within the framework of occupational health and safety regulations,
• The communication activities necessary for the placement of the working candidate,
• Internship recruitment, placing  and planning of operational processes.
• For intern lawyers; To fulfill the legal requirements within the scope of professional solidarity under the Legal Profession Act.

For the Customer Group:

• Fulfilling the legal requirements stipulated  in the law on electronic trade and the Turkish code of commerce.
• Planning activities focusing on customer satisfaction and/or experience.
• Legal, regulatory and company management legislations and ensuring compliance with correct application.
• Preparation of product to be delivered in accordance with the customer’s order and providing assurance that delivery shall be made e within guaranteed time frame.
• In cases  of cancellation and returns, relaying information to relevant department to ensure that the customer is reimbursed as soon as possible.
• .Establishing and implementing processes for ensuring the security of information.
• For the risk to be reduced  to an acceptable level.
• Risk Management.
• Forming Access Authorization and Control Matrix.
• Identifying Data Transfer techniques.
• Creating data preservation processes and procedures
• Identification and implementation of remote access procedures an processes
• Use of results derived from the sharing of anonymous data within the framework of customer CRM applications  in decision support systems.
• Correct targets within  the scope of campaign planning, feasibility studies and CRM.
• Invoicing and regular pursuance.
• Fulfilling company obligations.
• Data collection to form a customer portfolio.
• Data collection to bring a product which  is not in stock for customers.
• Data collection to be able to provide tailoring services to customers.

For the Supplier Group (Supplier, Supplier Executive, Supplier Employee):

• Management of the business process with suppliers.
• Implementation of legal processes and requirements such as contracts for the service required .
• Establishing  communication with the relevant supplier for production on behalf of the company.
• Drawing up contracts with selected suppliers.
• Carrying out purchasing procedures.
• Monitoring and supervision of manufacturing process.
• Managing communication with the depot during the cancellation procedures when deficient or faulty products are received.
• Supervision of payments and granting approvals.
• In accordance with the Occupational Health law and agreement.
• Payment and supervision of premiums to be paid to employees and the government, pursuant of the SGK (Social Security Institution) regulation.
• Checking whether employees hold a certificate of competency (a certificate, document of authority, etc. depending on their occupation)
• Inspection of documents regarding  hygiene and working at heights.
• Evaluation of supplier employees’ suitability according to OHS laws.
• Checking whether Social Security Institution premium debts have been paid.
• Gathering of required information and documents in order to establish  a legal relationship with the supplier.
• Managing relationships with suppliers.
• Ensuring company resources are used economically and focusing on  improvement of company operations based on customer oriented approach.
• Determining the needs of the depot and resolving it in a speedy and cost-effective manner.
• Carrying out purchasing transactions required by the company.
• Preparation of required visuals for product promotion and marketing.
• Recruitment of manpower required for the preparation of visuals necessary for product promotion and marketing.
• Obtaining documentation from real person or legal entity supplier processing personal data indicating adherence  to liabilities in terms of Modanisa’s data security, pursuant to the LPPD.
• Supervision of whether obligations are fulfilled  and planning auditing.
• Foreseeing the liability for suppliers to preserve confidentiality indefinitely.
• Drafting  a clause indicating that in the the case where  personal data relayed to suppliers is not obtained via legal channels, the supplier is obliged to inform Modanisa of the situation as soon as possible.

Claimant 3. For a Group of Individuals:

• Legal, regulatory and company management legislations and ensuring compliance with correct application.

Public Official conducting the investigation or proceeding, for the administrative organ employee:

• Obtaining information and documents required for the management of legal and administrative procedures.
• Fulfilling legal obligations .

        For Online Visitors:

• Requirement of adherence to legislative regulations.
• Logging of online visitors and user’s system actions.

        For Shareholders/Partners:

• Obtaining information and documents required for the management of legal and administrative procedures.

 

9. TRANSFER OF PERSONAL DATA TO THIRD PERSONS NATIONALLY AND ABROAD

Personal data and private personal data belonging to individuals may be transferred to third persons (third party companies, group companies, real third persons) in accordance with their  processing purposes , by taking the necessary security measures.

1. Transfer of Personal Data

Personal data may be transferred  to third parties in the the case where the  conditions  in LPPD’s Clause 8 and 9 are foreseen.

E-mail and/or telephone number may be shared with third parties abroad for singularization and match-up purposes. Information of anonymous quality about  online visitors which are non-member and their website use habits are collected with cookies and can be shared.

2. Third Persons to Whom the Personal Data are Transferred, and Their Purpose of Processing

Your personal data may be transferred to the below-listed individuals :

1. Business partners of MODANİSA,
2. Suppliers of MODANİSA,
3. Affiliates of MODANİSA,
4. Shareholders of MODANİSA
5. Legally competent public institutions and organizations,
6. Legally competent private jurists.

Scope of the above-specified persons to whom transfer is made, and the purpose of data transfer are specified below.

 

10. PRESERVATION PERIOD OF PERSONAL DATA

The preservation periods of personal data processed by MODANISA are indicated in the table below.

 

DEPARTMENT NAME	PERSONAL DATA GROUP	PERSONAL DATA CATEGORY	PRESERVATION PERIOD
LAW	Employee Data	Credentials Contact Details Financial Information Information on Legal Transactions Personal Information Educational Information Professional Experience and Knowledge Information on Side Benefits Personnel Group Information Organization Information Information on the Employee’s Performance and Career Development Private Personal Data	10 years pursuant of Turkish Code of Obligations
	Supplier Data (Real Person, Supplier Executive, Supplier Employee)	Credentials Contact Details Financial Information Information on Legal Transactions Risk Management Private Personal Data	10 years following conclusion of legal relationship
	Consultant/Trainer	Credentials Contact Details Financial Information Information on Legal Transactions Private Personal Data	10 years following conclusion of legal relationship
	Intern Lawyer	Credentials Private Personal Data	1 year following conclusion of internship
	Customer	Credentials Contact Details Financial Information Information on Legal Transactions Private Personal Data	10 years following conclusion of legal relationship
	Claimant 3. Individuals	Credentials Contact Details Financial Information Information on Legal Transactions Information on Customer Transactions Transaction Security Information Risk Management Information Private Personal Data	10 years as of final judgment
	Public official representative of the office running the investigation and proceedings	Credentials Information on Legal Transactions Private Personal Data	10 years as of final judgment
	Shareholder/Partner	Credentials Contact Details Financial Information Information on Legal Transactions Educational Information Private Personal Data	Unlimited Time
HUMAN RESOURCES	Employee Data	Credentials Contact Details Personal Information Professional Experience and Knowledge Financial Information Information on Legal Transactions Educational Information Side Benefits Private Personal Data	50 years
		Copy of Marriage Certificate Copy of Children’s IDs Personnel Group Contact Details	10 years
	Employee Candidate	Credentials Contact Details Personal Information	3 years
	Intern (Normal)	Credentials Contact Details Personal Information Financial Information Educational Information Information on Transactions of Employee Private Personal Data	10 years
	Intern (Mandatory)	Credentials Contact Details Private Personal Data Educational Information	10 years
PRODUCT	Employee Data	Credentials Contact Details Corporate Identity Information Information on Transactions of Employee	5 years following the end  of legal relationship
	Customer Data	Contact Details	Upon the end of the legal relationship; 1 year as of the date of retrieval of the commercial electronic message permit, 3 years for all records related to electronic  trade, 2 years of traffic information pursuant of the law no. 5651, 10 years pursuant to TPL, TCO, TCC, Consumer Protection Law.
	Supplier Data (Supplier Employee, Supplier Executive)	Credentials Contact Details Financial Information Corporate Identity Information Private Personal Data	Upon the end  of the legal relationship, 10 years in accordance with TCC and TPL.
PRIVATE LABEL	Supplier Data (Supplier Employee, Supplier Executive, Accounting Executive.	Credentials Personal Information Contact Details Private Personal Data Corporate Identity Information Financial Information	10 years following the end  of legal relationship
	Employee Data	Private Personal Data	10 years following the end of legal relationship
ADMINISTRATIVE AFFAIRS	Supplier Data (Supplier Employee, Supplier Executive)	Personal Information Credentials Private Personal Data Financial Information Contact Details Information on Legal Transactions	10 years following the end  of legal relationship
IT ( INFORMATION TECHNOLOGIES)	Employee Data	Credentials Personal Information Contact Details Risk Management Information Transaction Security Information	10 years
		Risk Management Information (Mac Adress, Internet Logs)	2 years
	Online Visitor Data	Transaction Security Information Risk Management Information	2 years
	Customer Data	Credentials Contact Details Financial Information Information on Customer Transactions Transaction Security Information Risk Management Information Information on Legal Transactions	10 years
	Supplier Data	Credentials Transaction Security Information Corporate Identity Information Contact Details Financial Information	10 years
STORE	Employee Candidate Information	Credentials Contact Details Personal Information Private Personal Data	2 years
	Supplier Data	Credentials Financial Information Contact Details Private Personal Data	10 years
BUSINESS DEVELOPMENT	Customer Data	Credentials Financial Information Contact Details Purchase Order Information	Until the end of the project period.
	Supplier Data	Contact Details Corporate Identity Information Financial Information	Until the end of the project period.
	On-line Visitor Data	Credentials Contact Details Location Information Information on Pages Visited	Until the end of the project period.
ACCOUNTING	Employee Data	Credentials Contact Details Corporate Identity Information Financial Information Personal Information Private Personal Data	5 years in accordance with TPL, 10 years in accordance with TCC
	Supplier Data	Credentials Contact Details Financial Information Private Personal Data	5 years in accordance with TPL, 10 years in accordance with TCC
	Customer Data	Credentials Financial Information Contact Details	5 years in accordance with TPL, 10 years in accordance with TCC
Purchase Department	Employee Data	Credentials Corporate Identity Information Contact Details	5 years following conclusion of legal relationship
	Supplier Data	Credentials Contact Details Financial Information Corporate Identity Information Private Personal Data Risk Management Information	10 years following the end of legal relationship
STUDIO	Employee Data	Credentials Corporate Identity Information Contact Details	5 years following the end of legal relationship
	Supplier Data	Credentials Contact Details	10 years following conclusion of legal relationship
		Private Personal Data (Photograph, video recordings)	70 years following the end  of legal relationship
		Transaction Information	Arranged to be updated on an annual basis

 

11. SAFETY OF PERSONAL DATA

To ensure the  safety of personal data, reasonable measures are taken which will prevent risks of unauthorized access , accidents and data losses, deliberate deletion of data or damages to data.

To prevent  access to personal data by persons other than those who have been granted authorisation to  access , all necessary technical and physical measures are taken. .In this context, particularly  the authorization system shall be  designed in such a way to make it impossible for anyone to access personal data to an extent which is more than required While ensuring safety of private personal data such as health data, measures which are more strict compared to  measures related to other personal data are taken.

Authorized persons are subjected to  necessary safety checks . In addition, the aforementioned persons are trained in relation to  their duties and responsibilities.

Records of access to personal data are kept to the extent permitted by technical opportunities, and these records are reviewed at regular intervals. When an unauthorized access is suspected , an investigation is immediately initiated .

MODANISA shall comply with the obligations specified below  for the purpose of ensuring safety of the data being processed:

• Acting lawfully and honestly regarding  the matters related to the protection of personal data,
• Processing the personal data accurately and in full,
• Carrying out the necessary practices for the purpose of updating the personal data which are outdated.
• When he/she notices any contradiction with  the law in relation to  processing of personal data, it shall inform   the relevant manager,
• Making necessary referrals for the exercise of legal rights related to personal data,

 

12. LEGAL RIGHTS OF INDIVIDUALS AND METHODS FOR EXERCISING THESE RIGHTS
    1. Rights Related to Personal Data in the Context of LPPD

Rights which can be exercised  by individuals in relation to personal data as stated in LPPD Clause 11, are specified  below:

1. Learn whether or not personal data have been processed,
2. Request information on the procedure, if personal data have been processed,
3. Obtain information on the purpose of processing personal data and find out whether personal data were used as fit for the purpose,
4. Obtain information  about the third persons to whom personal data were communicated domestically or abroad,
5. Request  the correction of personal data that may have been incompletely or inaccurately processed,
6. Request the deletion or destruction of personal data within the provisions set forth in applicable legislation,
7. Request that the third parties to whom personal data are transferred are informed about  the transaction carried out pursuant to sub-paragraphs (d) and (e),
8. Object to an outcome which is detrimental to the concerned as a result of the analysis of the processed data exclusively through automatic systems,
9. Request compensation for  damages in the case that damages are sustained  as a result of the illegal processing of personal data..

2. Principles in Relation to Exercising Rights in Relation to Personal Data

To exercise  their rights relating to personal data, Modanisa members may submit their application via e-mail with the e-mail address they have registered into the system during their membership process, to kisiselverilerim@modanisa.com. Individuals who are not members can submit their application by using the Use of Personal Data Application Form via www.modanisa.com. Applications filed  in this manner will receive a response within 30 days.

 

13 EFFECTIVENESS AND UPDATABILITY

This hereby POLICY has entered into force on date of publication. The Policy may be updated for the purpose of adaptation to changing conditions and compliance with the legislation. Information regarding the relevant  update will be provided via www.modanisa.com

 

 

ANNEX-1

DEFINITIONS STATED IN THE POLICY

 

Express Consent: Consent in relation to a specific matter, which is based on informing and which is expressed  with free will.

Anonymization : Anonymization of personal data is to render it impossible for personal data to be associated  in any manner with the identity of a real person who is   is identified or identifiable, even if they are matched with other data.

Personal Data Owner: Real persons whose personal data is being processed. For example, Members, Customers...

Personal Data: means any kind of information about an identified or identifiable real person.

Private Personal Data: Data in relation to race, ethnic origin, political opinion, philosophic belief, religion, sect or other beliefs, appearance, membership to associations, foundations or unions, health, sexual life, imprisonment and security measures and biometric and genetic data are private personal data.

Personal Data

Protection : Any transaction carried out  with  the data, such as obtaining, recording, storage, preservation, alteration, reorganization, disclosure, transfer, takeover, making available , classifying the personal data or blocking its   usage by full or partly automatic means, or by non-automatic means provided that they are part of a data entry system.

Data Processor: Real and legal persons who process personal data on behalf of the data supervisor depending on  the authorization granted  by the data supervisor.

Data Responsible: Real and legal persons who determine the aims and tools with which personal data will be  processed , real and legal persons responsible for  responsible for the establishment and management of the data record system .

KVKK: means the Law on the Protection of Personal Data No. 6698

Click for the Data Protection Law application form.

Click for the Data Protection Law violation notice form.

 

1. PARTIES
This hereby Membership Agreement (“Agreement”); between the owner of www.modanisa.com and mobile phone applications, MODANİSA ELEKTRONİK MAĞAZACILIK VE TİC. A.Ş., and its affiliates (“MODANISA”); and; the website user or member users of mobile applications becoming a member of www.modanisa.com and the mobile application (“Platform”) by accepting the conditions below (“Member”) and the payment collection agent located at Strawinskylaan 9371 077 XX AMSTERDAM, The Netherlands, MDN Europe B.V. and/or located at 85 Tottenham Court Road London W1T4TQ, Greater London, United Kingdom Modanisa London Limited and/or MODANISA’s affiliates (“Payment Collection Agent”); has been drawn up to determine the conditions which need to be met for a Member to benefit from the Services offered by MODANISA.
The BUYER and the SELLER shall be hereinafter referred to as "Party" individually and "Parties" collectively.
2. DEFINITIONS
Seller: Refers to the legal person launching or selling a product or service which is subject to electronic trade via a Platform. Seller means Modanisa Elektronik Mağazacılık A.Ş. , MDN Europe B.V., Modanisa London Limited and/or their affiliates.
Buyer: Refers to the legal person who buys or acts with the intention to buy products or services subject to electronic trade via a platform.
Payment Collection Agent: Refers to the legal person collecting payments on behalf of the MODANISA. The Payment Collection Agent is a fully owned company of the MODANISA. Payment Collection Agent means MDN Europe B.V. and/or Modanisa London Limited and/or their affiliates.
Service provider: Refers to real or legal persons operating in electronic trade.
Outsourced Service provider: Refers to real or legal persons who provide the electronic trade environment to allow other persons to carry out economic and commercial trade activities
Policy for Privacy and Protection of Personal Data: Refers to the text which can be accessed via the wwww.modanisa.com platform and which constitutes the general privacy policy related to MODANISA’s personal data and use of cookies, including in the forms in which and purposes for which MODANISA will use these personal data submitted by Members via the Platform.
My Account Page: Refers to the page specific to the Member which only the Member can access with the username and password created by them, where, for a Member to benefit from various applications and Services on the Platform, they can carry out all necessary transactions, where they can enter the personal data and information required for the application.
Services: Refers to the applications implemented by MODANISA to ensure Members perform the functions and transactions defined in the hereby Membership Agreement.
DPA: Data Protection Act 2018
GDPR: shall mean Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
Member: Refers to the real persons who have accepted the conditions and privacy statements of the membership agreement found on www.modanisa.com and have gained the title of “Member.”
User/Visitor: Refers to people who visit www.modanisa.com without becoming a member of the website.
Guest User: Refers to people who shop from www.modanisa.com without becoming a member of the website.
3. RIGHTS AND OBLIGATIONS OF PARTIES
3.1. In order to gain membership status, the user who wishes to become a Member must approve the Membership Agreement found hereby on the Platform, fill out the required areas with correct and up-to-date information, and have their Membership application evaluated and approved by MODANISA.
Users who wish to become a member must be over 18 (eighteen) years of age. Upon completion of the approval process and notification to the Member, the Membership status takes effect and thus, the Member shall have the rights and liabilities indicated in the hereby Membership Agreement and relevant areas of the Platform. Members who do not submit correct and up-to-date information when filling out the Membership Agreement in question, is personally liable for all harm that may occur. The Member always has the right to cancel their membership status by clicking on the “Cancel Membership” button on their My Account Page. Canceling membership does not imply non approval of commercial electronic messages being sent. The Member is required to separately and specifically revoke their approval for electronic message sending.
3.2. In the case of dispute concerning the person to which the rights and liabilities of membership belong and the persons in question submitting a request with MODANISA in this respect, the person who last made a payment to MODANISA for any given Service via the relevant Membership account will be accepted as the owner of the Membership account and action will be taken accordingly.
3.3. In the case where a Member wishes to initiate a legal transaction or a purchasing process in relation to the campaigns and/or advertisements displayed on the Platform, they accept and express that they are obliged to fulfill all legal obligations and complete all legal procedures required, including those stated on the Platform, and that MODANISA shall not be responsible to be aware of or to undertake the obligations and procedures in question.
3.4. The Member, in the Distant Sales Contract to be drawn up with the purchases from MODANISA via the Platform, accepts and expresses that MODANISA is the Seller party and they are the Receiving/Buyer/Purchaser party; they accept and express that MODANISA, in terms of the abovementioned Distant Sales Contract relationship, is only liable towards them in respect of the  consumer law and legislation which are applicable to Seller, and that they themselves assume full responsibility in respect of all other legislations.
3.5. Payment Collection Agents, will have the authority to collect for the products which a Member will purchase from the Seller and the Member, with the payment they will make to Payment Collection Agents, will be relieved from the obligation of paying the Seller.
3.6. The Member, with regards to the transactions and correspondence they carry out via the Platform, accept, and express they will adhere to the provisions in this hereby Membership Agreement, to the applicable legislations and to the code of ethics. The legal and criminal liabilities related to the Member’s actions and transactions within the Platform rest with the Member.
3.7. Pursuant to the applicable legislations, in the event a request submitted by competent authorities, MODANISA will be able to share the information it has, related to the Member, with the authorities in question.
3.8. In cases of forgery, fraud, misuse of the Platform, and offences which may constitute a crime in legislation, personal data obtained from Members during the process of membership via the Platform and/or shopping, may be provided to other Members who may be parties to an offense, limited to the issue in request for parties to exercise their legal rights and limited to this context.
3.9. The username and password information required by the Member to access the My Account Page and carry out transactions via the Platform is created by the Member; the responsibility regarding the privacy and security of this information shall rest with the Member. The Member accepts and declares in advance that the username and password creation operations were carried out by them, that the responsibility arising from these transactions shall rest with them, and that they will not raise any plea and/or objection alleging that they did not personally carry out these transactions and/or that they will not abstain from fulfilling their obligations in relation to this plea or objection.
3.10. The Member shall not use the Platform in a manner that is contrary to law and morality, especially in the following cases.
3.10.1. Using the Platform as a database on behalf of any person, to create a recording or directory, to check, update or modify;
3.10.2. Using the Platform to disrupt it completely or partially, to alter it or use it for reverse engineering purposes;
3.10.3. Carrying out transactions with false information or by using another person's information, false or misrepresented residential address, electronic mail address, contact, payment or account details included, incorrect or misrepresented personal data usage for creating fake Membership accounts and the misuse of these accounts in relation to the Membership Agreement or applicable legislations, using another Member’s account without permission, acting as another person or acting as a party or participator with an false name;
3.10.4. The use of comment and rating systems for purposes which are irrelevant to the Platform such as publishing the comments on the Platform in places other than the Platform, or in ways that are irrelevant to its purpose such as using it to manipulate systems;
3.10.5. For a virus or other harmful software to spread throughout the Platform, the Platform's database, any content on the Platform;
3.10.6. For actions which will cause an overload on the technical systems and communications or harm the technical process to take place, for “screen scraping” software or systems to be used on the Platform without MODANISA’s written consent, such as automatic programs, robots, web crawlers, spiders, data mining and data crawling, and for any content on the Platform, completely or partially, to be copied, published or used.
3.11. The Member is responsible for carrying out transactions on the Platform without causing to MODANISA material harm and to the Platform technical harm under any circumstances. The Member accepts and guarantees that they have taken all necessary precautions to protect the Platform from all kinds of harmful programs, viruses, softwares, unlicensed products, trojans, etc., including using security software and licensed products. The Member, in addition, accepts that they will not enter the My Account Page via robot or automatic access methods.
3.12. Usage of the Platform or its contents contrary to the conditions of use indicated in the hereby Membership Agreement or applicable legislation provisions will be deemed contrary to the law; MODANISA reserves the right to file lawsuits suits, bring claims and pursuance.
4. CONFIDENTIALITY AND PROTECTION OF PERSONAL DATA

“MODANISA is subject to both the DPA (Data Protection Act 2018) and the EU General Data Protection Regulation 2016/679 (“GDPR”), in relation to processing personal data obtained from Members. MODANISA collects, uses, transmits and processes personal data provided by Members, pursuant to the DPA, GDPR Privacy Policy and this Agreement found on the platform www.modanisa.com. DPA and GDPR Privacy Policy are both part ofthisMembershipAgreement.
Your payments shall be processing over our sister companies; Payment Collection Agents through your order number without accessing your personal data.
For more information regarding our use of personal data and your rights in relation to these matters;
To learn how we protect and process your personal data under DPA and GDPR; You will find our GDPR Privacy Policy here [GDPR Privacy Policy] and you may exercise your rights by sending an e-mail to our Data Protection Officer at dpo@modanisa.com. The e-mail address you use to contact us must be the e-mail address you submitted during your Modanisa membership process. Requests received from other e-mail addresses will not be responded to unless you are able to prove to our reasonable satisfaction that you are in fact a Member.
5. INTELLECTUAL PROPERTY RIGHTS
The intellectual property rights of the “Modanisa” brand and logo, “Modanisa” mobile application and Platform design, software, domain name and all kinds of trademarks, designs, logos, trade dress, slogans and other content produced by MODANISA in relation to these, belong to Modanisa. Members cannot use, share, distribute, exhibit, copy or reproduce work derived from the property of MODANISA or its subsidiaries which are subject to intellectual property rights, without written consent. Members cannot use the mobile application or the Platform, in full or partially, in another environment without the written consent of MODANISA. In the case where a Member or third parties act in breach of the intellectual property rights of MODANISA, the Member is obliged to compensate for the direct and indirect harm and costs of MODANISA and/or the third party in question.
6. AMENDMENTS TO THE AGREEMENT
MODANISA can unilaterally amend all kinds of policy, provision and condition as they see fit, including the Policy for Privacy and Protection of Personal Data by means of announcing via the Platform, provided that they comply with the applicable legislation provisions. Changing provisions in the hereby Membership Agreement will become valid as of the date they are announced on the Platform, remaining provisions will remain valid to generate verdicts and results.
7. FORCE MAJEURE
In the event that insurgency, embargo, government intervention, rebellion, invasion, mobilization, strike, lockout, work actions or strikes, cyber attacks, communication problems, infrastructure and internet breakdowns, system improvement and renewal work and breakdowns that may occur due to these, electricity cuts, fire, explosions, storms, floods, migration, epidemics or other natural disasters or other events which are beyond the control of, which cannot be attributed to MODANISA and cannot be foreseen (“Force Majeure”) prevent or delay MODANISA from fulfilling the obligations of the hereby Membership Agreement, MODANISA cannot be held liable for the prevented or delayed obligations due to Force Majeure and this situation cannot be deemed as a breach of the hereby Membership Agreement.
8. GENERAL PROVISIONS
8.1. Members accept that in the case of a dispute which may arise from the hereby Membership Agreement, MODANISA’s official books and commercial records and the e-archive records kept in MODANISA’s database and servers, electronic information and computer records will be considered binding, crucial and exclusive evidence and that this clause will be considered as an evidential contract.
8.2. The hereby Membership Agreement will be exclusively governed by the Laws of the Netherlands. Amsterdam Courts shall have jurisdiction over the settlement of all kinds of dispute arising from the hereby Membership Agreement or related to this hereby Membership Agreement.
8.3. MODANISA will contact the Member via the e-mail address, via telephone or by sending an SMS, details of which were provided by the Member during the membership process. The Member is responsible for keeping their e-mail address and telephone number up to date.
8.4. This hereby Membership Agreement constitutes the entire agreement between the Parties relating to the matter. Should any provision in this Membership Agreement is declared invalid in part or in full, inapplicable or unreasonable by an authorized court, arbitration commission or administrative authority, this Membership Agreement shall be deemed as severable to the extent of the invalidity, inapplicability or inadvisability in question, and remaining provisions shall continue to be in effect.
8.5. Members cannot completely or partially assign their rights or obligations specified in the hereby Membership Agreement without a prior written consent from MODANISA.
8.6. Failure to exercise or perform any right granted to it under this Contract by either Party shall not be construed as a waiver of such right or shall not prevent future exercise or performance of such right.
As of the 8th clause onwards, this hereby Membership Agreement, will enter into force as from the moment the Member has read and acknowledged each provision in full and approved it in the electronic environment.
 

“My Modanisa” LOYALTY PROGRAM TERMS OF USE – USER AGREEMENT

This “My Modanisa” LOYALTY PROGRAM TERMS OF USE-USER AGREEMENT (“Terms of Use or User Agreement”) explains the terms to benefit from My Modanisa services that will be offered to the members of the loyalty program (“My Modanisa”) managed by Modanisa Elektronik Mağ. ve Tic. A.Ş. (Modanisa), which will provide tangible and/or intangible benefits.

The natural person (Member) who becomes a member by accepting these Terms of Use accepts, declares and undertakes that s/he has read, understood and approved all of the Terms of Use, all kinds of statements made regarding My Modanisa membership and services and that he will act in accordance with these statements. The Member accepts, declares and undertakes that s/he will act in accordance with all applicable legislation and that he/she understands and approves all specified terms and rules while performing any transaction within the scope of this program. The legal and criminal responsibility of the Member in every transaction and action within Modanisa.com and My Modanisa belongs exclusively to him/her.


 

1. PROGRAM MEMBERSHIP

My Modanisa membership registration is currently carried out without any charge from the Member. Participation in My Modanisa is a unique advantage to registered member users and customers of modanisa.com.

After enrolling in the My Modanisa program, you must log in to your modanisa.com account to access the My Modanisa control panel. After logging in to your Modanisa.com account, the control panel can be accessed from the “My Modanisa” tab on the “My Account” page.

The Member accepts and declares that the information s/he provided while becoming a member of My Modanisa is correct and that s/he will update it in case of any change in this data and the Member also accepts that Modanisa is not responsible for any damages that may arise as a result of not updating these data or providing incorrect data and/or the termination of the rights acquired by the Member until that date.

Members may in no way convert, sell or transfer any intangible or tangible benefit to be provided to them. In case of detection of such a situation, the benefit provided by Modanisa will be immediately canceled and My Modanisa membership may be suspended or terminated.

After membership, situations such as closure, loss, stealing, or seizure of modanisa.com and/or My Modanisa account by the Member may cause the termination of various rights (including expiration of unused points) and/or opportunities acquired by the Member until that day. In addition, without limitation, in the event that the modanisa.com and/or My Modanisa membership is terminated, the reward points earned during the membership and the rights granted to the Member will be deleted, withdrawn and automatically terminated by Modanisa.

Modanisa can change the terms of My Modanisa, stop My Modanisa, update it, change its name, change it to a model that offers different advantages. In these changes, memberships will be automatically converted to the new model at Modanisa's discretion or Modanisa will inform about the terms of the new model.

The Member accepts, declares and undertakes that s/he is of legal age and is old enough to purchase the services offered.

The Member can terminate the membership at any time and without giving any reason, by notifying the Modanisa call center. In this case, the Member will be able to benefit from the rights s/he has earned until the expiration date of the membership, within the current conditions, and the points s/he has earned and not yet used as of the date of termination will be deleted. (Modanisa Call Center Telephone: 0850 333 64 72)

Modanisa shall not demand any compensation or fee from the Members in cases where these Terms of Use and/or membership are terminated except for manipulation, misuse of the system, and deliberate damage. Likewise, Members accept, declare and undertake that they will not demand any compensation, etc. from Modanisa in case the Terms of Use expire in any way.
 

2. POINTS EARNING AND USAGE

After accepting these Terms of Use and registering to the My Modanisa program, points can be earned for shopping and activities on Modanisa.com. There will be no retroactive point gains prior to My Modanisa membership.

In order to learn how many points will be earned from your Modanisa purchases, the “My Modanisa” control panel can be viewed on the “My Account” page.

The number of points awarded depends on the numerical value of the invoice currency, if the invoice currency is changed due to a change in the product shipping country, the number of points earned may change.

Points will appear on the control panel as "points pending approval" after ordering. Pending points will be activated and made available 21 days after the order, unless refunds are made. If the product is returned after 21 days, the points will be refunded even if it is approved.

You can also earn points by completing the activities offered by My Modanisa. To find out how many points will be earned from which activities, you can review the "My Modanisa" control panel on the "My Account" page.

Members can earn various points by following, liking, sharing products and seasonal competitions on their Facebook and Instagram accounts. The points earned for each activity will be announced to the Members on the point earning screen beforehand.

Modanisa may at any time give its customers the opportunity to earn extra points in addition to the points earned through eligible purchases and activities at certain times. Additional points are valid if terms and conditions are met and can be earned through special offers announced on the My Modanisa control panel.

The My Modanisa program is currently structured in 3-month periods. 1. Term “September-October-November”, 2. Term “December-January-February” 3. Term “March, April, May” 4. Term consists of “June-July-August”. Points approved in any 3-month period are only valid during that period. At the end of the period, unused points cannot be transferred to the next period, they are deleted within the same period. If there are points waiting for approval at the end of the semester, these points are not deleted, they can be used in the next semester if approved. Only the approved points 15 days before the end of the period are transferred to the next period. These points only cover the points earned from the purchases made on Modanisa.com, they cannot be transferred to other platforms or used.

Once enough points have been earned, the points can be used for various rewards based on level and amount of points earned. Period gifts consist of various privileges announced such as shopping vouchers and free shipping coupons that you can use on modanisa.com and/or other brands. Each period's gift may be different and limited in number. Modanisa is free to determine the My Modanisa score to which the gifts correspond, as it wishes.

My Modanisa points are not redeemable, they are only used to get period rewards in exchange for certain points. If a gift certificate or coupon is received in return for the points, this gift certificate or coupon can be used on Modanisa.com shopping subject to the specified conditions. Terms of use for gift certificates purchased with Points are an integral part of this program and are subject to the terms set forth in the Terms of Use.

Points not used during the period are not transferred to the next period, they are cancelled. Term rewards cannot be changed or canceled after they have been selected and determined.
 

3. MEMBERSHIP LEVELS

My Modanisa has Silver, Gold and Platinum levels. As you earn points by shopping and completing various activities, higher levels are achieved. Each level may have different terms and may be subject to additional terms and conditions.

Every Member registered to My Modanisa enters the program at the Silver level. When the points earned from your shopping and activities in the last 12 months exceed 100 points, the Gold level is reached, and when it exceeds 200 points, the Platinum level is reached. The advantages at the current level can be used for 1 year.
 
As the level changes, the points in the period are not deleted.

 

Levels	Point Ranges
Silver	0-99
Gold	100-199
Platinium	200+

 

4. PRIVACY AND PROTECTION OF PERSONAL DATA

When the Member uses the methods determined within the scope of My Modanisa, benefits from the services and benefits from the program, personal data required for membership, shopping information, navigation information obtained during the use of the website and mobile application, surveys, location data; and it is processed by Modanisa as a system requirement in order to design and convey MEMBER-specific content, campaigns, and tangible and intangible benefits, and are transferred to the necessary business partners for the realization of the transactions. The Member accepts this situation.

Modanisa processes the personal data it processes within the scope of the My Modanisa program in accordance with these Terms of Use and the program User Agreement. For more information about the personal data processed within the scope of this contractual relationship and your rights on this data, you can review the "Confidentiality Policy" and "Cookie Policy" and use your rights specified in Article 11 of the KVKK by sending an e-mail to kisiselverilerim@modanisa.com.
 

5. OTHER PROVISIONS

Modanisa owns all intellectual property rights of the data to be generated by the use of My Modanisa. It may prepare a report or use such information or reports itself without disclosing the membership information of the Member, and may share these reports and/or statistics with business partners and third parties. These transactions do not violate the provisions of Confidentiality and Commercial Communications Permission.

The Member accepts that the responsibility for the personal ideas, thoughts, expressions, comments and files s/he adds to Modanisa.com and My Modanisa media, and the personal information s/he sends while benefiting from Modanisa, belongs to him/her in accordance with the Law No. 5651 and other legislation and in addition, s/he accepts, declares and undertakes that Modanisa cannot be held responsible for this information in any way, and Modanisa is free to publish or delete these transactions, opinions and thoughts.

The Member accepts, declares and undertakes that all the financial rights enumerated in the Law on Intellectual and Artistic Works numbered 5846 and dated 5.12.1951 have been transferred to Modanisa, including the correspondence, subject headings and pseudonyms to be added to the Program comply with the general moral rules and etiquette and all broadcasting, processing and reproduction, dissemination, representation, sign, sound and/or image transmission related to the said correspondence.

The Member accepts, declares and undertakes that s/he will be responsible for the unauthorized use of third-party images, thoughts, copyrighted content and the like that s/he will add to My Modanisa, Modanisa has no responsibility for this, and Modanisa may take necessary measures and initiate legal proceedings.


Modanisa may, at any time, temporarily suspend or stop the operation of the system for technical reasons, security, update, maintenance and similar reasons.

Modanisa can change these Terms of Use, suspend the program, cancel the membership, and collect membership fees. These changes take effect immediately upon the publication of the new modified terms of use on www.modanisa.com. It is the Member's responsibility to be aware of the changes in these Terms of Use.

Modanisa, if it is determined that due to member transactions that raise security doubts and/or that the Members gain unfairly through member transactions and/or the transactions carried out are suspected of fraud, fraud or fraud, Modanisa may temporarily suspend or completely suspend the memberships of the relevant Members, in which case the points and earnings will be canceled and refunded. In such a case, Modanisa will have the right to take all legal and criminal remedies against the relevant Members and the relevant Members will be responsible for any damages that may arise.
 

6. EVIDENTIAL CONTRACT, THE BURDEN OF PROOF

Modanisa data and Member records and logs will constitute binding and conclusive evidence in any dispute arising from the performance of these Terms of Use.
 

7. APPLICABLE LAW, AUTHORIZED COURT AND ENFORCEMENT OFFICES

These Modanisa Terms of Use are subject to the laws of the Republic of Turkey. Istanbul Anatolian Courts and Enforcement Offices are authorized to settle any dispute that may arise from the performance of Modanisa Terms of Use.
 

8. ENFORCEMENT

These Terms of Use are valid and come into effect indefinitely after the Member becomes a member of My Modanisa.