HOMEND MOBILE PRIVACY POLICY

EFFECTIVE DATE: 2021-01-20

UPDATED: 2021-01-18

As Homend Elektronik Dayanıklı Tüketim Cihazları Sanayi ve Ticaret A.Ş. we are committed to protecting your privacy. Please take a moment to view our privacy policy and let us know if you have any questions.

Homend Elektronik Dayanıklı Tüketim Cihazları Sanayi ve Ticaret A.Ş. and subsidiaries (“we”, “us”, “our”, “Homend”) are committed to protecting your privacy. Our company applies the Privacy Policy and Application-Terms of Use for the privacy of user information, protection and processing of personal data, commercial electronic communications and other issues in the Homend mobile application. The privacy policy stated here is valid for Homend's mobile applications published in the Google Play Store and IOS App Store. This Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):

HOMEND SMART ROBOT Mobile Application

In this Privacy Policy, “Personal Data” means information that can be used to identify an individual, either from that information alone, or from that information and other information we have access to about that individual. “Smart Devices” refers to those nonstandard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc. “Apps” refers to those mobile applications developed Homend that provide end users remote control to Smart Devices and with the ability to connect to the supplier IoT Platform.

For other branded mobile applications powered by Fill in the abbreviation of the company name, our Clients control all the Personal Data collected through our Products. We collect the information under the direction of our Clients and the processing of such information shall be limited to the purpose of providing the service for which our Clients has engaged us.

As Homend, we may make changes to this Privacy Policy, and when we make a material change, we will notify you through our service, or in other words, allow you to review the changes before they become effective. If you object to any change, you can close your account.

What Personal Data Do We Collect?

In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services.

(I) When you need to authorize us to collect and use your personal information

Personal Information is collected to ensure that we provide products and / or services to you, as well as our own legal compliance with applicable laws, regulations and other regulatory documents. You have the right to choose whether to provide this information or not. However, in most cases, if you do not provide such information, we may not be able to provide you with related services or respond to the problem you are facing.

1. Information You Voluntarily Provide Us

• Account or Profile: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account. We will save this data in order to improve the application and meet the language setting requirements.

• Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

2. Information We Collect Automatically

These data are provided by App users and are required for the control of the device. Data and device logs are kept to analyze problems arising from the app processing process and for producing solutions.

• Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.

• Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.

• Log Information: When you use our app, the system and exception log may be uploaded.

• Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our specific Products or Services, such as robot cleaner and weather service. The collection of your location information will be carried out with your consent, and you can control it over the device you use and remove your consent.

3. Smart Devices Related Information

• Basic Information of Smart Devices: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information

• Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our Products or Services, we may collect different information reported by your Smart Devices. For example, smart weights or fitness trackers may report your height, weight, body fat mass (BFM), BMI and skeletal muscle mass (SMM); smart cameras are used for direction finding and mapping.

(II) Where you can authorize us to collect and use your personal information

To enable you to better control and manage smart devices offered by Homend, we may collect and use your personal information in the following additional features. If you do not provide this personal information, you can still use Homend core services, but you may not be able to use valuable additional features. These additional features include:

(1) User feedback:

We may collect feedback on issues you report to us, a feedback log, and the phone number or e-mail addresses you provide to us. This information will be used to help us better understand the problems you encounter, as well as to allow us to contact you.

(III) When we obtain your personal information from third parties

Under certain conditions permitted by law, we may obtain your personal information from third parties.

(IV) Non-personal information

We may also collect other information that is not directly or indirectly linked to an individual and that cannot be identified as personal information under applicable local laws. Such information may include statistical data generated when you use a particular service, such as clicks, page redirects, and browsing time. This type of information is collected to improve the services we provide to you.

Purposes and legal basis for processing Personal Data

The purpose for which we may process information about you are as follows:

• Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.,

• Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Marketing Communication: We may process your Personal Data to provide marketing and promotional materials to you on our Products and Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. The legal basis for this processing is your consent. Additionally, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Data to manage such activities.

• Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of our Products. The legal basis for this processing is your consent.

• Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Who Do We Share Personal Data With?

We do not sell any personal information to third parties. We may share your personal information with our third party service providers and business partners when necessary to help us provide you with the products and services described in this Privacy Policy. We only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:

• To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.

• To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Sites and Services.

• To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data.

• As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

• To subsidiaries or affiliates within our corporate family, to carry out regular business activities.

Except for the third parties described above, to third parties only with your consent.

If we share your personal information with these third parties, we will use encryption technology or similar technology to keep your information safe. We conduct strict controls on the data security practices of companies and organizations with whom we share personal information, and also sign strict data processing agreements with them. We also ask third parties to take adequate measures to protect your information and strictly comply with applicable laws, regulations and regulatory requirements.

International Transfer of Information Collected

To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence.

Your Rights Relating to Your Personal Data

We respect your rights and control over your Personal Data. You may exercise any of the following rights with the application methods listed below:

You do not have to pay a fee and we will aim to respond you within 30 days. If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

You may:

• Request access to the Personal Data that we process about you;

• Request that we correct inaccurate or incomplete Personal Data about you;

• Request deletion of Personal Data about you;

• Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;

• Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and

• Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.

Settings Control

We are aware that privacy concerns differ from person to person. Therefore, we provide examples of ways Homend makes available to you to restrict the collection, use, disclosure or processing of your personal information and to control your privacy settings: Enable or disable location access, camera, microphone, and read / write access permissions from your phone;

• Change personal information such as your nickname or profile picture. To do this, open the Homend app and go to "My&rt; Settings&rt; Personal data";

• Enable or disable smart device connections;

• Sign in or log out of your account.

Withdrawal of Consent

You can withdraw your consent to the collection, use and / or disclosure of your personal information under our ownership or control by submitting a request. Depending on the specific service you use, you can do this by contacting us at kvkk@homend.com.tr. Once the request is received, we will process your request within a reasonable time from the date of the request, and then, as per your request, we will not collect, use and / or disclose any of your personal information.

Please note that withdrawing your consent may have certain legal consequences. You may not be able to use Homend products or services depending on the scope of the powers you have given us to process your personal information. However, any decision you take to withdraw your consent or at the point of authorization will not affect personal information previously processed with your consent.

Security

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Homend provides various security strategies to effectively ensure data security of user and device. As for device Access Homend proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing kvkk@homend.com.tr.

Data Retention

We will retain personal information for as long as necessary to fulfill the purpose for which it was collected, as described in this Privacy Policy, or retain personal information to comply with applicable legal requirements. We will cease to store and delete or anonymize your personal information once the purpose of the collection has been fulfilled, or after we have received your request for deletion or cancellation or after stopping the relevant product or service. We will continue to retain relevant information in accordance with applicable laws, even if the requirement for further information processing is not relevant to the original collection purpose, provided it is for the public interest or for scientific or historical research or statistical purposes.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions about our practices or this Privacy Policy, please contact us as follows:

HOMEND ELEKTRONİK DAYANIKLI TÜKETİM CİHAZLARI SAN. VE TİC. A.Ş.

Mailing Address: Cumhuriyet Mahallesi Yeni Yol 1 Sk. Now Bomontı Apt. No: 2/12 Şişli/İstanbul

E-Mail: kvkk@homend.com.tr