LIVBEN – KVKK & PRIVACY CLARIFICATION TEXT

This text has been prepared for the "KVKK & Privacy" page on the livben.com.

1. Identity of the Data Controller

Pursuant to the Personal Data Protection Law No. 6698 ("KVKK"), the data controller:

Title: Livben Cosmetics Industry Trade Limited Company ("Livben")
Address: Adnan Kahveci Mah., City34 Sitesi, Kurtuluş Cd. No:26 A2 Blok Dükkan 2, 34528 Beylikdüzü / Istanbul / Turkey
Phone: +90 (212) 830 65 65
Support / Mobile: +90 (535) 210 69 03
E-mail: info@livben.com
Website: www.livben.com

Livben; multilingual and operating on a global scale, especially industrial products, machinery, equipment and It is a platform where advertisements are published for products for professional use. Real estate for Turkey on the platform and automotive categories. Sales transactions are direct transactions between the buyer and the seller. and Livben is only an intermediary service provider.

2. Scope of Lighting

This Clarification Text; It is related to the processing of personal data obtained by Livben through the following channels:

www.livben.com website and subdomains,
Mobile applications,
API and integrations,
Call center, email, support system, and other online/offline communication channels.

This text covers the personal data obtained through these channels in accordance with the KVKK and relevant legislation. explains the principles regarding processing, storage, transfer and protection.

3. Categories of Personal Data Processed

Livben is a member of the Platform, becoming a member, posting ads, sending offers/messages to postings or support. If you use its channels, it may process the following categories of personal data:

Identity Data
- Name, surname
- Username / nickname
- (When necessary) If it is a legal entity, company name, tax number, authorized person information
Contact Data
- Email address
- Mobile phone / landline phone
- Country, city, postal code, street address
- Preferred interface language (e.g., TR, EN, DE, etc.)
- Store/business communication channels (e.g., Telegram, WhatsApp, etc.), to the extent that you share
Account and Usage Data
- Membership date, account status, last login/check-out dates and times
- Advertisements, advertisement contents, titles, descriptions, images, price information, if any
- Industrial product category, subcategory, technical specifications, etc.
- In-platform messaging and offer history (security, dispute, and fraud to the extent necessary in their examinations)
- Comments, Q&A records and store reviews
Transaction Security and Technical Data
- IP address, browser type, operating system, device model
- Data collected through cookie records and similar technologies
- Server log records, error records, session information, security logs
- Verification and login information used for account security
Financial VPrivates
- Payment and collection records (e.g., listing credit, translation services, advertising/boost fees, etc.)
- Billing information (billing address, tax ID, title)
- Reference and receipt information regarding the payment transaction (PayTR, Iyzico or similar payment institutions limited to transactions carried out through it).
Your credit card information is not stored by Livben; Your card data is only stored by the relevant payment service provider (e.g. PayTR, Iyzico, etc.) in their own secure infrastructure.
Customer Relationship and Support Data
- Messages and complaints you send through the contact form
- E-mail and call center correspondence
- Notes on your support requests, feedback, and resolution process
Marketing Data (only with your explicit consent)
- Industrial product categories and filters you are interested
- Newsletter, campaign and announcement preferences
- Usage habits and visitor statistics obtained through cookies

4. Purposes of Processing Personal Data

Your personal data may be processed for the following purposes within the framework of the legal reasons specified in Articles 5 and 6 of the KVKK. is processed:

Operation of the Platform and Service Delivery
- Creating your membership registration, managing your account
- Advertising, searching, filtering, listing and viewing of industrial products Providing functions
- Bringing buyers and sellers together, providing messaging and offer infrastructure
- Ability of manufacturers, wholesalers, producers, factories and workshop owners to exhibit their products on a global scale
Establishment and Performance of the Contract
- Terms of use / membership agreement and execution of related service agreements
- Managing paid service (ad package, translation credit, showcase, feature, etc.) processes
- Fulfillment of payment, collection, return and invoice transactions
Fulfillment of Legal Obligations
- Keeping commercial, financial and accounting records
- Meeting the information requests of authorized institutions and organizations
- Fulfillment of obligations within the scope of the relevant legislation, especially KVKK
Security, Fraud and Abuse Prevention
- Detection, investigation and prevention of suspicious transactions
- Detection of fake accounts, fake advertisements, spam and fraud attempts
- Ensuring platform security, detecting and eliminating system errors
Customer Relations and Communication
- Evaluation and conclusion of your requests and complaints
- Informing about important changes, updates and system announcements regarding the services
Marketing, Analysis and Development Activities (with your explicit consent)
- Increasing service quality by analyzing usage habits
- Recommending ads and content that match your profile
- Newsletter, campaign and commercial Sending electronic messages

5. Method of Collection of Personal Data and Legal Reasons

Your personal data;

Membership/registration forms, profile pages, store opening forms,
Steps to create and edit ads,
Contact, support and complaint forms,
Cookies, SDKs, and similar tracking technologies,
Call center, email and other communication channels

electronically, by automatic or partially automatic means; when necessary, in a physical environment is collected.

The main legal grounds for processing your data are as follows:

Explicitly stipulated in laws (KVKK art.5/2-a)
Being directly related to the establishment or performance of a contract (art.5/2-c)
It is mandatory for the data controller to fulfill its legal obligation (art.5/2-ç)
Being mandatory for the establishment, exercise or protection of a right (art.5/2-e)
It is mandatory for our legitimate interests, provided that it does not harm the fundamental rights and freedoms of the person concerned (art.5/2-f)
Your explicit consent (including special categories of data within the scope of Article 5/1 and Article 6)

6. Parties to Whom Personal Data is Transferred and Foreign Transfers

Your personal data; In accordance with the KVKK and relevant legislation, in connection with and limited to the purpose, the following can be transferred to recipient groups:

Partners and Service Providers
- Server, hosting and cloud service providers (domestic or international)
- Payment institutions, banks, electronic money institutions (e.g. PayTR, Iyzico, etc.)
- Companies that provide technical maintenance, security, logging and storage services
- E-mail, SMS, notification and similar communication service providers
- Companies that provide advertising, analysis and measurement services (only with explicit consent)
Authorized Institutions and Organizations
- Courts, prosecutors' offices, law enforcement units, regulatory and supervisory institutions
- Tax offices and other official authorities
Group Companies / Subsidiaries (if applicable, to the extent relevant)

Due to our global and multilingual structure; located abroad for hosting, backup and similar services service providers can be used. In this case, your personal data will be processed in accordance with Article 9 of the KVKK:

Countries with adequate protection as determined by the Personal Data Protection Board, or
Data controllers in Turkey and the relevant foreign country to countries where there is no adequate protection undertakes adequate protection in writing and the permission of the Board is obtained.

can be transferred.

7. Your Rights Under KVKK

Pursuant to Article 11 of the KVKK, you have the following rights by applying to Livben:

To learn whether your personal data is processed or not,
Requesting information about it, if it has been processed,
To learn the purpose of processing and whether they are used in accordance with their purpose,
To know the third parties to whom it is transferred in the country or abroad,
Requesting correction if it is incomplete or incorrectly processed,
Although it has been processed in accordance with the KVKK and relevant legislation, the reasons requiring its processing to request the deletion or destruction of personal data in case of disappearance,
To request notification of these transactions to third parties to whom the data is transferred,
By analyzing the processed data exclusively through automated systems, a objecting to the emergence of the result,
Against the lawRequesting compensation for the damage in case you suffer damage due to the processing of the damage.

8. Application Methods

You can submit your requests within the scope of KVKK to Livben through the following channels:

By mail:
Livben Kozmetik San. Tic. Ltd. Şti.
Adnan Kahveci Mah., City34 Sitesi, Kurtuluş Cd. No:26 A2 Blok Dükkan 2,
34528 Beylikdüzü / Istanbul / Turkey
E-mail: To info@livben.com using your e-mail address registered
KEP: (If any) via our Registered E-Mail address
In-platform: Through the KVKK application form or support request screens that may be submitted in the future

Your applications will be finalized as soon as possible and within 30 days at the latest, depending on the nature of the request; Conclusion, will be notified to you in writing or electronically.

9. Updates

This KVKK & Privacy Clarification Text; legislative changes and any may be revised from time to time due to updates. Up-to-date text is always < a "KVKK & Privacy" on href="https://www.livben.com" target="_blank" rel="noopener">www.livben.com page and becomes valid from the date of publication.

LIVBEN – RETURN, WITHDRAWAL AND DISPUTE POLICY

This text has been prepared for livben.com, a global and industrial product-oriented advertisement platform.

1. The Role of the Platform and the Nature of the Service

1.1. Intermediary Service Provider Location

Livben; buyer for professional products such as industrial products, machinery, equipment, spare parts and so on and sellers.
Platform, manufacturer, wholesaler, producer, factory and workshop owners can pay their products for physical fair expenses. It allows it to be visible around the world without folding.
Advertisements in the real estate (real estate) and automotive (vehicle buying and selling) categories for Turkey on the platform is not published.
Livben is not a party to the sales contract established between the buyer and the seller; defect of the products subject to sale, The responsibility for its suitability, delivery and legal/physical condition belongs to the seller who made the announcement.

1.2. Parties to the Legal Relationship

The actual seller of the products; The real person or legal entity that creates the advertisement is the seller.
The legal relationship between the buyer and the seller is within the framework of the mandatory consumer and commercial legislation of the relevant country. It is established directly between the parties.
Livben's responsibility; To ensure the technical operation of the platform, publishing and displaying advertisements infrastructure and intermediary services clearly specified in their own contracts.

1.3. Global and Multilingual Structure

The platform is designed to be used in numerous countries and languages; consumer law of each country, trade law and mandatory local regulations are reserved.
Consumer's right of withdrawal, defective goods provisions and mandatory regulations; Which country is the legal transaction It may vary depending on the legislation.

2. Right of Withdrawal and Return Processes

2.1. General Principles for Consumer Transactions

If the buyer is considered a "consumer" by the legislation of the relevant country and the transaction falls within the scope of distance sales, withdrawal may be subject to provisions regarding the right.
Duration, beginning, method of exercise and exceptions of the right of withdrawal; the buyer and seller who are parties to the transaction It is determined according to the mandatory legislation of the country where it is located.
In their ad descriptions, sellers must specify their own return/withdrawal/warranty conditions and country-based special conditions, if any. should state it clearly and transparently.

2.2. Sample Turkey Application (For Informational Purposes)

In Turkey, the Law No. 6502 on the Protection of Consumers and Distance Contracts for consumer buyers As a rule, there is a 14-day right of withdrawal.
The period starts from the day the goods are delivered to the consumer or the third party designated by the consumer. However, this regulation is only valid for buyers who are considered consumers and their relevant scope.
For purchases made for industrial, professional and commercial purposes, different provisions may apply.

2.3. Examples of Situations Where the Right of Withdrawal May Not Be Exercised

Mandatory exceptions in the legislation of each country are reserved.

Industrial products produced in line with the special requests and demands of the buyer, specially designed for the person/business
Disposable or hygienic products that are not suitable for return (unpacked, used, etc.)
The defects and deficiencies clearly stated in the advertisement description are known to the buyer and the purchased as such second-hand products
Assembled, integrated into the facility, causing serious loss of value or technical risk if dismantled. Industrial Machines/Lines

3. Return Conditions

3.1. Condition of the Product at the Time of Return

Product; as close to the way it was received as possible, with all accessories, parts and documents (user manual, certificate, warranty certificate, etc.) must be returned together.
In industrial products; heavy use exceeding reasonable use for testing purposes, improper installation, incorrect voltage, etc. damage and loss of value may limit the right to refund or be a reason for deduction from the price. can create.

3.2. Deadlines and Notification

Withdrawal and return requests must first be forwarded to the seller who owns the advertisement; simultaneously (optional) Information can also be provided through Livben support channels.
Refund requests to be made after the expiration of the withdrawal period, without prejudice to the mandatory provisions of the relevant country. subject to the initiative of the seller.

3.3. Return Shipping / Shipping Fees

Who will bear the return cargo or logistics cost;
- Consumer legislation of the relevant country,
- Seller's ad descriptions and contract conditions
determined accordingly.
Special for dismantling and transportation of large volume and heavy industrial products (machinery, production line, heavy equipment) logistics may be required; In this case, the parties must agree on the cost sharing separately.

4. Defective Product, Dispute and Resolution Mechanisms

4.1. Defective Product

Product; significant defects that are hidden or not disclosed if they do not meet the basic characteristics stated in the advertisement or if it is illegal/actually unusable, it is considered a "defective product" according to the legislation of the relevant country. can be counted.
In this case, the consumer; such as refund, discount on defect rate, free repair or replacement with equivalent product rights may come to the fore according to the mandatory provisions of the relevant country.

4.2. First Remedy – Communication with the Seller

In case of dispute, the buyer; first of all, the in-platform messaging system, the specified phone/WhatsApp/Telegram or through other communication channels should contact the seller.
If a solution cannot be provided; the buyer can forward information and documents regarding the dispute to Livben support. Livben; facilitates communication between the parties within the framework of platform rules, but direct sales does not act as a party to the contract.

4.3. Official Dispute Authorities

If a consensus cannot be reached between the parties:
- Consumer Arbitration Committees, Consumer Courts or courts with general jurisdiction in terms of transactions in Turkey,
- In other countries, the competent consumer authorities and courts of the relevant country
may be authorized.

5. Fee and Commission Refunds

5.1. Refund of the Sales Price

In case of exercising the right of withdrawal or refund based on the agreement of the parties; under what conditions and The time it takes to return depends on the relevant country's legislation and the seller's policies/conditions.
Payment; As a rule, it is returned to the means of payment used in the sale (credit card, debit card, etc.). Bank and Payment institutions' processing times may vary.

5.2. Livben Commission and Service Fees

The commission that Livben collects from the seller or buyer is the same as the number of advertisements, advertisements, promotions, translation credits, advertisements, etc. Principles regarding the refund of service fees;
- Membership Agreement,
- Terms of Use,
- Mandatory legal rules of the relevant country
It is determined by taking into account.
In some cases; Commission for performing the service at the time (e.g. advertisement published, showcase period started, etc.) and service fees may not be refundable. These situations are clearly stated in the relevant contracts and information. is specified.

6. Abuse of Platform Rules and Refund Processes

6.1. Examples of Abuse

Making unrealistic or malicious refund/withdrawal requests,
Trying to return products that have been damaged as a result of intentional wrong or misuse,
Causing damage to buyers by deliberately arranging the contents of the advertisements in a misleading way,
Attempted fraud through fake accounts or fake documents.

6.2. Precautions That Can Be Taken

Sending warnings, temporary account restriction,
To the extent permitted by local law, limitation of return and withdrawal processes for the user concerned or additional verification stages,
Permanent closure of the account, partial or complete,
If deemed necessary, notification to the relevant official authorities.

7. Policy Changes

This Return, Withdrawal and Dispute Policy;
- Legislative changes,
- Updates to the Livben service model,
- Deployment of new features and services
can be updated unilaterally for reasons.
Up-to-date text is always < a href="https://www.livben.com" target="_blank" rel="noopener">www.livben.com pages and enters into force from the date of publication.

8. Contact

For your return, withdrawal, dispute and general support requests, you can contact Livben through the following channels:

Company: Livben Kozmetik San. Tic.
Address: Adnan Kahveci Mah., City34 Sitesi, Kurtuluş Cd. No:26 A2 Blok Dükkan 2, 34528 Beylikdüzü / Istanbul / Turkey
Phone: +90 (212) 830 65 65
Support / Mobile: +90 (535) 210 69 03
E-mail: info@livben.com