Personal Data Protection
Disclosure Statement

1. Data Controller

Your personal data is processed by Pemt Teknoloji Yazılım Limited Şirketi ("Chucca") acting as the Data Controller.

2. Personal Data Processed

Within the scope of Chucca membership and loyalty program services, the following personal data may be processed:

• Phone number
• Membership records
• Loyalty program usage information
• Point earning and redemption records
• Campaign participation and usage records
• Transaction records
• Consent and authorization records
• Communication preferences
• Customer support requests
• System usage and technical log records

3. Purposes of Processing Personal Data

Your personal data may be processed for the following purposes:

• Creating and managing loyalty program memberships
• Operating point earning and redemption processes
• Managing campaigns, rewards, and benefit programs
• Providing customer support services
• Improving service quality
• Ensuring system security
• Managing membership-related operations
• Complying with legal obligations

4. Methods and Legal Basis for Collecting Personal Data

Your personal data may be collected electronically through:

• QR code interactions
• Membership and loyalty transactions conducted via WhatsApp
• Customer support processes
• Electronic communication channels
• Digital systems and platforms

Your personal data is processed based on the following legal grounds:

• Necessity for the establishment or performance of a contract
• Compliance with legal obligations
• Legitimate interests pursued by the Data Controller
• Explicit consent where required by applicable law

5. Transfer of Personal Data

Your personal data may be shared, where permitted by applicable legislation, with:

• Service providers
• Technology infrastructure providers
• Cloud service providers
• Messaging and communication service providers
• Customer support service providers
• Technical support providers
• Authorized public authorities and governmental bodies

Merchants and Merchant Group administrators using the Chucca platform do not have direct access to Members' personal data. Merchants and Merchant Group administrators may only access aggregated, anonymized, or statistical information required for the operation of loyalty programs. Where shared point redemption is enabled within a Merchant Group, limited information necessary for processing loyalty transactions may be processed by the system.

6. International Transfer of Personal Data

Some technology, communication, and infrastructure service providers used by Chucca may be located outside Türkiye. Accordingly, your personal data may be transferred internationally in compliance with applicable data protection legislation and subject to appropriate security measures. Further information regarding international data transfers is provided in the Explicit Consent Statement.

7. Data Retention Periods

Your personal data will be retained for the period required by applicable legislation or for as long as necessary to fulfill the purposes for which it was collected. Upon expiration of the applicable retention period, personal data will be securely deleted, destroyed, or anonymized in accordance with applicable legal requirements.

8. Your Rights Under KVKK

Pursuant to Article 11 of the Turkish Personal Data Protection Law (KVKK), you have the right to:

• Learn whether your personal data is being processed
• Request information regarding the processing of your personal data
• Learn the purpose of processing and whether data is used in accordance with that purpose
• Learn the third parties to whom personal data has been transferred
• Request correction of incomplete or inaccurate data
• Request deletion or destruction of personal data where applicable
• Object to decisions based solely on automated processing
• Request compensation for damages arising from unlawful processing of personal data

9. Contact Information

You may submit your requests regarding your rights under KVKK through the following communication channel: