Privacy and Personal Data Protection Information Notice for Website Visitors
AVA Life Yapı Limited Şirketi (“AVA Life” or the “Company”) attaches great importance to the protection of privacy and the fundamental rights and freedoms of individuals, primarily pursuant to Article 20 of the Constitution and the relevant legislation. Accordingly, the Company adopts the lawful processing and secure protection of personal data as a fundamental principle and conducts all its activities and planning within this framework.

AVA Life considers the protection of personal data not only as a legal obligation but also as a natural consequence of the value it places on human dignity and privacy. With this awareness, necessary administrative and technical measures are taken to ensure the secure storage of personal data and to prevent unauthorized or unlawful use. This information notice has been prepared in accordance with the Personal Data Protection Law No. 6698 (“KVKK”) to explain the principles regarding the processing and transfer of personal data obtained during the use of the www.avacesme.com website.
1. Definitions
Website: Refers to the website with the domain name www.avacesme.com.
Law: Personal Data Protection Law No. 6698.
Personal Data: Any information relating to an identified or identifiable natural person.
Cookie: Small text files sent to the device of an online visitor via browsers by website servers. Cookies may store visitors’ site usage and browsing information for certain periods in order to improve user experience, enhance site performance, improve content, and provide marketing-related suggestions.
Online Visitor / Data Subject: All natural persons who access the website.
Board: The Personal Data Protection Board.
Company: AVA Life Yapı Limited Şirketi.
Hosting Provider: Natural or legal persons who provide hosting services for content and services on the internet.

2. Processed Personal Data
Within the scope of accessing and using the website, the following personal data may be processed:
For users visiting the website:
• Transaction security information (IP address, traffic data, etc.)
For visitors who fill out forms on the website:
• Identity information (name, surname)
• Contact information (phone number and e-mail address)
In addition, other data that may be necessary for the secure operation, development, and protection of the website may also be processed in accordance with the KVKK.

3. Method and Legal Grounds for Collecting Personal Data
Personal data are collected through the use of the website and the completion of contact forms, by fully or partially automated means, and for the period required for the relevant processing purpose.
While data are primarily processed based on the explicit consent of the data subject, they may also be processed without seeking explicit consent in the presence of legal grounds set forth in Article 5/2 of the KVKK, such as “explicitly stipulated by law,” “fulfillment of the data controller’s legal obligation,” “establishment, exercise or protection of a right,” and “legitimate interest.”

4. Purposes of Processing Personal Data
Personal data are processed in connection with the transactions carried out on the website and within the framework of the conditions stipulated by the relevant legislation for the following purposes:
• In case contact forms are completed, identity and contact information are processed for:
– Carrying out and supervising company activities,
– Managing customer relations,
– Evaluating requests, complaints, suggestions, and appreciation submissions,
– Contacting the visitor when necessary,
• Traffic data are processed for:
– Conducting information security processes and ensuring transaction security.
In addition, hosting providers are obliged to retain traffic data pursuant to Law No. 5651 and related legislation.

5. Information on Cookies
No third-party cookies are used on the website. Only cookies that are mandatory for the operation and security of the site are used. Visitors may manage their cookie preferences through browser settings and may refuse cookies or choose to receive warnings. However, disabling cookies may cause some functions of the website to not operate properly.

5.1 Purposes of Using Cookies
Cookies are used to ensure the basic functioning of the website, measure and improve performance, and provide ease of use.

5.2 Types of Cookies Used
Only mandatory cookies are used on the website. These cookies are required for session continuity and secure access.

5.3 Managing Cookie Preferences
Visitors may customize cookie preferences through their browser settings. Cookie settings may vary depending on the device and browser used. General information on this subject can be accessed via the support pages of relevant browser providers.

6. Transfer of Personal Data
Provided that the conditions set forth in Article 5/2 of the KVKK are met, personal data may be transferred, limited to the purposes stated in Article 4, to AVA Life’s group companies, business partners, affiliates, and authorized public institutions and organizations, by taking the necessary security measures. In the absence of such conditions, transfer is subject to the explicit consent of the data subject.

7. Measures Regarding Data Security
AVA Life takes all necessary administrative and technical measures to protect personal data against unauthorized access, unlawful processing, and loss. In the event that the website redirects users to other platforms, AVA Life is not responsible for the data protection practices of the redirected websites.

7.1 Administrative Measures
Regular KVKK trainings are provided to employees, compliance processes are monitored, and data protection awareness is evaluated among performance criteria. Confidentiality commitments are also obtained from third parties with whom data are shared.

7.2 Technical Measures
Encryption, access authorization, network and application security, firewalls, backup systems, and up-to-date malware prevention solutions are used in systems where personal data are processed. System security is continuously monitored through regular risk analyses, vulnerability scans, and penetration tests.

8. Rights of the Data Subject under the KVKK
Pursuant to Article 11 of the KVKK, data subjects have the right to learn whether their personal data are processed, request correction or deletion, learn the third parties to whom data are transferred, object to adverse results arising from automated systems, and request compensation for damages.
Applications may be submitted by filling out the Data Subject Application Form and sending it in writing or via a notary to the address 9 Eylül Neighborhood, Akçay Street No:203 Gaziemir / İzmir. If an e-mail address is registered in the Company’s systems, applications may also be sent to info@avacesme.com.
Applications must clearly state identity and contact information as well as the subject of the request. Applications are finalized within a maximum of thirty days. In necessary cases, a fee determined by the Board may be requested.
By using the website, the online visitor acknowledges that they have read this information notice and have been informed about the processing of their personal data.