DRAFT — This text must be reviewed by DEJA's lawyer before publication.

Personal Data Protection Notice (KVKK)

This notice is provided under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") to inform you about the personal data processed through the DEJA mobile and web app (the "App").

1. Data controller

HNF Kimya Sanayi ve Ticaret Ltd. Şti. ("DEJA Paints"), Beylikdüzü OSB Mahallesi 3. Cadde No: 19/1, Beylikdüzü / İstanbul, Türkiye.

2. Personal data we process

• Identity and contact: name, mobile phone number, e-mail (optional), company and profession (optional), a delivery address for sample shipments.
• Request and project details: the product, style and colour you chose; approximate area, city/district, interior/exterior, current surface, timeline and your notes.
• Images: photos of your walls/rooms that you upload and the renders created from them. Location (GPS) and other EXIF data are removed on upload.
• Security: IP address, device and app information, session records, the push notification device token.
• Marketing: your contact details for news and offers, only if you give separate consent.

3. Purposes and legal grounds

• Receiving and handling your quote and sample requests and replying to you — KVKK Art. 5/2(c) (performance of a contract).
• Verifying your phone number by SMS code and keeping your account and the App secure — Art. 5/2(f) (legitimate interest).
• Notifying you when the status of a request changes — Art. 5/2(c).
• Complying with legal obligations — Art. 5/2(ç).
• Processing your photo with an AI service to show an indicative render of the chosen finish on your wall — with your explicit consent under Art. 5/1 and Art. 9.
• Marketing communication — only with your explicit consent.

4. Transfers

• Our SMS provider in Türkiye, Netgsm (your phone number), to send verification codes.
• Our hosting provider OVH SAS (OVHcloud; data centre in Frankfurt, Germany — abroad). All application data is stored on these servers; OVHcloud acts as a processor on our instructions only. The transfer relies on appropriate safeguards (a standard contract) under Article 9 KVKK.
• If you use "See it on my wall": your photo and the product image are sent to OpenAI's AI service (OpenAI API) (abroad). This happens only with your separate explicit consent; without it you can still use every other feature. See the AI image processing notice.
• Authorised public authorities, when legally required.

5. How we collect data

Electronically, through the App's forms, photo uploads and SMS verification.

6. Retention

• Wall photos and renders not attached to a project: 90 days.
• Photos and renders attached to a project: 2 years after the project's last update.
• When you delete your account in the App, your projects, requests and all photos are deleted immediately.

Dealer portal

For people who use the DEJA dealer portal (bayi.dejapaints.com) on behalf of a dealer company, we process their name, email address, phone number (optional), session and activity records (IP address, sign-in times, and who recorded stock movements or orders), request messages and attached files. The purpose is running the dealer relationship (orders, stock, support requests and notifications) and keeping the portal secure — KVKK art. 5/2(c) and 5/2(f). The data is stored with the hosting provider named above (OVHcloud, Frankfurt) and passed to our email provider to send notifications. When a user account is deleted, its account details are deleted; the company's order and stock records are kept as business records, no longer linked to the person.

7. Your rights

Under Article 11 KVKK you may ask whether your data is processed, request information, learn the purpose, know the recipients, request correction, deletion or destruction, object, and claim compensation for damage.

Send requests to deja@hnfkimya.com or the postal address above. You can delete your account at any time in the App under Account → Delete my account.

HNF Kimya Sanayi ve Ticaret Ltd. Şti. · Beylikdüzü OSB Mah. 3. Cadde No: 19/1, Beylikdüzü / İstanbul · deja@hnfkimya.com · +90 212 803 02 58