PRIVACY POLICY

Introduction

At Werksan Barbell, we are committed to protecting the privacy of our users and ensuring that they can benefit from our services in a secure and complete manner. Accordingly, this Privacy Policy ("Policy") has been prepared to explain how we process and protect personal data in full compliance with the Turkish Personal Data Protection Law No. 6698 ("KVKK") and to inform our users about these practices.

The purpose of this Policy is to determine the terms and conditions regarding the collection, processing, storage, and use of personal data shared by members, visitors, and users (collectively referred to as the "Data Subject") through the website operated by Werksan Barbell at www.werksanbarbell.com and related mobile applications (collectively referred to as the "Platform").

What Personal Data Do We Process and Why?

In order to provide better services to our users, manage and complete order processes, communicate effectively with customers, provide information regarding products, services, campaigns, promotions, understand shopping preferences, perform trend and statistical analyses, improve website security, and fulfill our legal obligations arising from applicable laws and regulations, including but not limited to:

• Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through Such Publications

• Law No. 6563 on the Regulation of Electronic Commerce

• Turkish Penal Code No. 5237

• Personal Data Protection Law No. 6698 (KVKK)

we may process the following personal data:

• First name and surname

• E-mail address

• Telephone number

• Gender

• Date of birth

• Turkish Identification Number

• Tax Identification Number

• Personal interests and preferences

• Billing and delivery addresses

• Information shared through social media accounts upon your authorization

• Other information that may directly or indirectly identify you

In addition to the above, we may collect and process aggregated statistical information that does not directly identify individuals, such as:

• Website visit frequency and duration

• Order dates and times

• IP address used during order placement

• Product page visit statistics

• Purchased product statistics

These data are used to analyze visitor behavior and improve our services.

Data Processing and Storage

Your personal data are processed and stored based on your explicit consent and solely for the purposes specified in this Privacy Policy. Appropriate technical and administrative security measures are implemented to protect your information against unauthorized access, loss, misuse, or disclosure.

Certain data stored in our databases may be used periodically for:

• Marketing campaigns

• Customer segmentation

• Personalized promotional activities

• Prevention of unwanted communications

• Service improvement and customer experience enhancement

Such activities are always conducted in compliance with applicable laws and regulations.

Payment Security

When you choose to pay by credit card, you acknowledge that your payment information, including credit card number, expiration date, CVV/CVC security code, and related payment details, may be shared with authorized financial institutions and payment processors for transaction authorization purposes.

However, Werksan Barbell does not store credit card or debit card information within its systems under any circumstances.

Retention and Anonymization of Data

Werksan Barbell reserves the right to retain records associated with terminated user accounts provided that such records are anonymized.

Once anonymized, the information can no longer be linked to an identifiable individual and therefore ceases to be considered personal data under applicable legislation.

Users shall not have any rights or claims regarding anonymized records.

Sharing of Personal Data

Your personal data may be shared with third parties strictly for the purposes of providing our services, including but not limited to:

• Shipping and logistics providers

• Call center service providers

• Database and hosting providers

• Payment service providers

• Business partners supporting our operations

Additionally, personal data and traffic information may be disclosed to authorized public authorities, governmental institutions, courts, or regulatory agencies when legally required.

Except as required by law or for the purposes described in this Policy, your personal data will not be sold, rented, or shared with third parties for commercial purposes.

Personal data may also be transferred, where legally permitted, to:

• Domestic or international shareholders

• Affiliates and subsidiaries

• Contracted service providers

• Business partners located within or outside Türkiye

provided that appropriate safeguards are implemented.

Rights of Data Subjects

Pursuant to Article 11 of the Personal Data Protection Law No. 6698, data subjects have the right to:

• Learn whether personal data relating to them are being processed.

• Request information regarding processed personal data.

• Learn the purpose of processing and whether personal data are used in accordance with such purpose.

• Learn the third parties to whom personal data are transferred domestically or internationally.

• Request correction of incomplete or inaccurate personal data.

• Request deletion or destruction of personal data when the reasons requiring processing cease to exist.

• Request notification of correction, deletion, or destruction to third parties to whom personal data have been transferred.

• Object to outcomes arising exclusively from automated processing systems that may adversely affect the individual.

• Request compensation for damages arising from unlawful processing of personal data.

Requests regarding these rights may be submitted using the procedures specified on our website.

Werksan Barbell shall respond to such requests within thirty (30) days as required by law.

Werksan Barbell reserves the right to charge a fee in accordance with the tariff determined by the Personal Data Protection Board where applicable.

Data Retention Periods

Pursuant to Law No. 6563 on the Regulation of Electronic Commerce:

• Records relating to the withdrawal of commercial communication consent shall be retained for one (1) year from the date of withdrawal.

• Commercial electronic communication content and related transmission records shall be retained for three (3) years and may be presented to competent authorities upon request.

Upon expiration of the applicable retention periods, personal data shall be deleted, destroyed, or anonymized by Werksan Barbell in accordance with applicable legislation and internal data retention policies.

Policy Updates

Werksan Barbell reserves the right to amend this Privacy Policy at any time in order to comply with legal requirements, technological developments, or changes in business operations.

Updated versions of the Privacy Policy will become effective upon publication on the Platform.