GDPR

Welcome to TOMMYLIFE. This Privacy Policy applies to the services provided by EXPRESS SANAL MAĞAZACILIK ANONİM ŞİRKETİ (hereinafter referred to as "TOMMYLIFE") accessed through any platform or device that links to this Privacy Policy, including applications, websites, software, and related services ("Platform"). The Platform, located at Altınşehir Merkez Mah. Yan Yol Cad. No:32 Başakşehir / Istanbul, is provided and controlled by EXPRESS SANAL MAĞAZACILIK ANONİM ŞİRKETİ ("TOMMYLIFE," www.tommylife.com.tr, "AİRJONES, MODALOG, VERYPERİ," "we," or "us").

We are committed to protecting your privacy and respecting your confidentiality. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users and other individuals connected to our Platform. If you do not agree with this policy, you should not use the Platform.

What information do we collect

We may collect the following information from you through www.tommylife.com.tr:

Information You Provide

Your profile information. When you register on the Platform, you provide us with information such as your username, password, date of birth (if available), email address, and/or phone number, as well as information and photos you provide in your user profile. It is your responsibility to ensure that the information you provide is accurate and complete. Providing incorrect, misleading, or incomplete information may affect the validity of the requested service, impact our responsibilities to you and/or third parties, and may prevent us from fulfilling our obligations. In such cases, TOMMYLIFE accepts no responsibility. If TOMMYLIFE incurs damages due to your provision of incorrect, misleading, or incomplete information, you are responsible for compensating for such damages. User-generated content. We process the content you create on the Platform, including photos, sounds, videos, comments, tags, feedback, reviews, and associated metadata such as when, where, and by whom the content was created ("User Content"). Messages. When you create, send, or receive messages through the Platform's messaging features, we collect information you provide. This includes messages sent or received through our chat function when communicating with us and your use of virtual assistants when purchasing products on the Platform. This information includes the content of the message, when the message was sent, received, or read, and information about the message, such as the participants. Please note that messages you choose to send to other users on the Platform may be accessible to those users, and we are not responsible for how those users use or share your messages. Purchase information. When you make a purchase from TOMMYLIFE or through our shopping features on the Platform, including product purchases, we collect information such as payment card details, billing, delivery, and contact information, and details about the products you purchased. Information in correspondence you send to us, including situations where you contact us for support or feedback. Automatically Collected InformationUsage Information: We collect information about how you interact with the content we show you, including your interactions with advertisements, viewed videos, encountered issues, browsing and search history, liked content, content saved to the 'Favorites' section, and other information related to your use of the Platform.

Inferred Information: Additionally, we infer certain qualities about you, such as your interests, gender, and age range, in order to personalize the content.

Technical Information Collected About You: We collect specific information about the device you use to access the Platform, including your IP address, user agent, mobile carrier, time zone settings, advertising identifiers, device model, device system, network type, device identifiers, screen resolution, operating system, application and file names and types, keystroke patterns or rhythms, battery status, sound settings, and connected audio devices. If you log in from multiple devices, we may use your profile information to identify the activity across devices. Additionally, we may associate information collected from devices other than the ones you use to log in with your presence on the Platform.

Location Information: We collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS). If you choose to add location information to your User Content (e.g., tourist attractions, stores, or other points of interest), we collect that information.

Cookies: We and our service providers and partners use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) ("Cookies") to automatically collect information, such as which pages you most frequently view, how you interact with content, and to measure and analyze how you use the Platform to enhance your user experience, improve the Platform, deliver personalized advertising, and measure the effectiveness of ads and other content. We and our partners may also use Cookies to promote the Platform on other platforms and websites. Cookies enable specific features and functionalities of the Platform. Web beacons are very small images or images embedded in small data pieces, also known as "pixel tags" or "clear GIFs," that identify the time and date a page was viewed, the description of the page where the pixel tag was placed, and similar information that identifies your computer or device. Please refer to the "Your Rights and Options" section below to learn how to disable certain Cookies.

Other Information Obtained From Other Sources:

We may obtain information described in this Privacy Policy from other sources, including:

Social Media Platforms: If you choose to register on the Platform using third-party social media account information (e.g., Facebook, Twitter, Instagram, Google), or if you choose to use the Platform through these accounts, you will provide or allow us access to your username, publicly available profile, and other possible information related to this account. Similarly, we may share certain information, such as your application ID, access token, and referring URL, with your social media account. If you link your TOMMYLIFE account to another service, we may obtain information about your usage from that service. Advertisers and Other Partners: Advertisers, measurement partners, and other partners may share information with us about your actions both on and off the Platform, such as activities on other websites, apps, or in-store purchases, including information about products or services you have purchased. Some of our advertisers and other partners allow us to collect similar information directly from their websites or apps by integrating our tools for TOMMYLIFE, AİRJONES, MODALOG, VERYPERİ Advertisers. Affiliated Entities: We may obtain information about you from certain affiliated entities within our corporate group (TOMMYLIFE, AİRJONES, MODALOG, VERYPERİ), including activities on their platforms. Information Obtained from Your Interaction: We may obtain information about you from others when you are included in User Content, direct messages, complaints, objections, requests, or feedback sent to us or when your mention is included in these or when your contact information is provided to us. We may also collect information about you from other public sources. How We Use Your Information:

As explained below, we use your information to improve, support, and manage the Platform, enable its features, and comply with and enforce our Terms of Service and other terms and policies. We may also use your information, among other things, to personalize the content you see on the Platform, promote the Platform, and customize your advertising experience. We generally use the information we collect in the following ways:

For internal operations, including troubleshooting, data analysis, testing, research, statistics, and survey purposes, as well as to fulfill product, service, and Platform functionality, support, and information requests and solicit your feedback. To process your orders, including sharing your information with vendors, payment processors, and other service providers, to facilitate shopping features and make it easier to purchase and deliver products, goods, and services. To personalize the content you see while using the Platform. For example, we may provide services based on your chosen country settings or show you content similar to what you have liked or interacted with. To send you promotional materials, including instant messaging or emails, on behalf of ourselves or trusted third parties. To improve and develop our Platform and conduct product development. To measure and understand the effectiveness of advertisements and other content and to provide you with targeted advertisements and other personalized content on the Platform. To enable your participation in virtual elements programs. To facilitate your participation in interactive features of the Platform, such as allowing your content to be used in other users' videos, promoting events, and introducing popular topics, tags, and campaigns in our advertising and marketing campaigns. To monitor and detect misuse, harmful activity, fraud, spam, and illegal activities on the Platform and to combat them. To deliver content to you and your device in the most effective manner. To scan, analyze, and review User Content, messages, and associated metadata for the security and safety of the Platform, including the detection and prevention of violations of our Terms of Service, Community Guidelines, or other terms and policies. To facilitate independent researchers in conducting research that meets certain criteria. To verify your identity or age. To communicate with you, including informing you about changes to our services. To announce the winners of our contests or promotions, if permitted by the promotion rules, and to send relevant rewards to you. To enforce our Terms of Service, Community Guidelines, and other terms and policies. Consistent with your permissions, to provide you with location-based services, such as personalized advertising and other personalized content like advertisements. To train and improve our technology, such as machine learning models and algorithms. To facilitate the sale, promotion, and purchase of products and services and provide user support. How We Share Your Information:

We share your information with the following parties:

Business Partners:

If you choose to register on the Platform using your social media account information (e.g., Facebook, Twitter, Instagram, Google), and you choose to sign up to use the Platform through these accounts, you will provide or allow us access to your phone number, email address, username, and publicly available profile, or allow your social media account to provide this information to us. Similarly, we will share certain information, such as your application ID, access token, and referring URL, with the relevant social media platform. If you choose to allow a third-party service access to your account, we will share certain information about you with that third party. Depending on the permissions granted, the third party may access your account information and other information you choose to provide

We may share your information with law enforcement, public authorities, or other organizations if it is legally required or reasonably necessary for the following purposes:

• To comply with legal obligations, processes, or requests.
• To enforce our Service Terms, investigate potential violations, and apply other agreements, policies, and standards, including the prevention, detection, or addressing of security issues, fraud, or technical problems.
• To protect our rights, property, or safety, as well as the rights, property, or safety of our users, third parties, or the public, as required or permitted by law.

Sales, Mergers, or Other Business Transactions:

When you make a purchase through our shopping features, we share transaction-related information with sellers, payment and transaction processing providers, and other service providers. For example, we share order items, contact information, and delivery details to process your order. These organizations may use the shared information in accordance with their privacy policies.

Where We Store Your Information:

Your information may be stored on servers in Turkey. We have large servers in Turkey to provide our services to you globally and continuously.

Your Rights and Choices:

You have rights and choices regarding your information. Under applicable laws, you may have rights such as access to your data, deletion, updating or correction of your data, information about the processing of your data, and the right to file complaints with authorities. To exercise your rights under applicable laws, you can send a request to https://www.tommylife.com.tr/iletisim or musteri.hizmetleri@tommylife.com.tr. You can access and edit most of your profile information by logging into TOMMYLIFE. If you choose to delete the User Content you uploaded, you can also delete your entire account from Settings.

You can reject or disable cookies by adjusting your device browser settings. Please note that different browsers have different instructions, and disabling or rejecting certain types of cookies may impact the functionality of the Platform.

You can cancel your membership by logging in to tommylife.com.tr, navigating to My Account > Personal Information > Membership Cancellation section.

Security of Your Information:

We take steps to ensure the security and proper handling of your information. The information entered on "www.tommylife.com.tr" is equipped with the 'SSL' system for security. However, this protection is not effective for information sent via email.

Information obtained about members, prospective customers, and customers is kept confidential to the extent we protect our own trade secrets. This information can be accessed by our company's staff only to the extent necessary to provide the requested service.

To provide an appropriate level of security in line with the changing possibilities and severity of risks for your and other users' rights and freedoms, we have technical and organizational measures. We continue to implement and occasionally modify these measures to improve the overall security of our systems.

Privacy Policy Updates:

We may update this Privacy Policy from time to time. When we update it, we will inform you by updating the "Last Update" date at the top of this policy and by publishing the new Privacy Policy or providing other required notifications under applicable law. Continuing to access or use the Platform after the updated policy means you accept the updated policy.

Contact:

If you have questions, comments, complaints, or requests regarding this Privacy Policy, please contact us at https://www.tommylife.com.tr/iletisim and musteri.hizmetleri@tommylife.com.tr. We will attempt to address your request as soon as possible, and it does not affect your right to file a complaint with the relevant data protection authority in appropriate cases.

Your Rights under Law No. 6698 on Protection of Personal Data:

You have rights under Article 11 of the Law No. 6698 on Protection of Personal Data regarding your personal data. You can exercise these rights by contacting us through https://www.tommylife.com.tr/iletisim.

• Learn whether your personal data is processed.
• Request information if your personal data has been processed.
• Learn the purpose of processing personal data and whether it is used for its purpose.
• Know the third parties to whom personal data is transferred, domestically or abroad.
• Request correction of personal data if it is incomplete or incorrect.
• Request the deletion or destruction of personal data within the framework of the conditions specified in Article 7.
• Request notification of correction, deletion, or destruction of personal data to third parties to whom personal data has been transferred.
• Object to the occurrence of a result against the person by automatic means.
• Request compensation if personal data is processed unlawfully and causes damage.

You can find detailed information about the cookies we use on our website in our Cookie Policy at https://www.tommylife.com.tr/kisisel-verilerin-korunmasi.

GDPR COMPLIANCE NOTICE

This notice aims to inform you about the processing of personal data under the General Data Protection Regulation ("GDPR"). [TOMMYLIFE] provides information on the purposes of processing your personal data, your rights, and how to exercise them.

1. Data Controller:

Company Name: EXPRESS SANAL MAĞAZACILIK ANONİM ŞİRKETİ (TOMMYLIFE)

Address: Altınşehir Merkez Mah. Yan Yol Cad. No:32 Başakşehir / İstanbul

Phone: 0850 346 77 77

Email: musteri.hizmetleri@tommylife.com.tr

2. Processed Personal Data:

Our company may process the following categories of personal data:

First and last name

Contact information (phone number, email address)

User account information

Work history and education information

Geographical location data

3. Purposes of Processing:

Your personal data may be processed for the following purposes:

Providing services

Communication

Fulfilling your requests

Marketing and promotional purposes

4. Legal Basis:

The processing of personal data may rely on the legal bases under Article 6 of the GDPR, including:

Performance of a contract

Compliance with legal obligations

Consent of the data subject

Legitimate interests

5. Data Subject Rights:

Under the GDPR, as an individual whose personal data is processed, you have the following rights:

Right to information access

Right to rectification

Right to erasure

Right to restriction of processing

Right to data portability

Right to object

To exercise these rights, please contact [TOMMYLIFE - Contact].

6. Data Security:

Our company takes appropriate security measures to securely store and process your personal data.

7. Contact:

If you have any questions or concerns regarding GDPR or personal data, please feel free to contact TOMMYLIFE.

In the event of any changes to this notice, an updated version will be provided to you.