Skin Analysis Privacy Notice and Explicit Consent
SKIN ANALYSIS PRIVACY NOTICE
In this Privacy Notice, the principles regarding the processing of your personal data are set out below, in accordance with Law No. 6698 on the Protection of Personal Data (the "Law") and the relevant legislation, by the data controller Evly Pharma Kozmetik San. ve Tic. A.Ş. ("Evly" or the "Company"), located at Şerifali Mah. Söyleşi Sk. No:41A Ümraniye/Istanbul.
1. Personal Data Processed and Purpose of Processing
Within the scope of this Privacy Notice, your first and last name, contact details, marketing information, transaction security information, social media account information and photographs are processed.
In addition, your skin type and skin analysis information, which are special categories of personal data, are also processed within the scope of this Privacy Notice.
Our skin analysis service aims to analyze the photograph you provide or take with your device's camera and to offer Evly product recommendations suited to your skin type and needs. Within this scope, your personal data is used to provide the service, personalize product recommendations and improve the user experience; it is destroyed after you have completed the skin analysis experience and is not stored by our Company.
Accordingly, your special category data is not stored; it is used solely to be able to respond to your requests and to determine the products suited to your skin type, and is then destroyed immediately.
2. Method of Collection and Legal Basis of Personal Data
Your collected personal data is gathered in electronic form, through cameras or by uploading photographs, by partially or fully automated means, in order to fulfil the purposes set out in this Privacy Notice. Your personal data is processed on the legal grounds that "processing of the personal data of the parties to a contract is necessary, provided that it is directly related to the conclusion or performance of that contract" and, for your special category data, that your explicit consent has been obtained.
3. Recipients of Processed Personal Data and Purpose of Transfer
Your personal data may be transferred to our business partner ARHub Bilişim Anonim Şirketi (PulpoAR), which provides the skin analysis application service, and to other third parties and institutions that are our suppliers/business partners, within the scope of our Company's legitimate interests or for the fulfilment of obligations arising from legislation, and to authorized public bodies and, upon request, to judicial authorities or relevant law enforcement agencies. The purposes of transfer of your personal data are in line with the purposes of processing.
4. How to Contact the Data Controller and Your Rights
Pursuant to Article 11 of the Law, by applying to our Company, you have the right to: a) learn whether your personal data is being processed, b) request information if it has been processed, c) learn the purpose of processing and whether it is used in accordance with that purpose, d) learn the third parties to whom it is transferred domestically or abroad, e) request correction if it has been processed incompletely or inaccurately, f) request deletion or destruction within the framework of the conditions set out in Article 7 of the Law, g) request that the actions taken under items (e) and (f) above be notified to the third parties to whom it has been transferred, h) object to the emergence of a result against you through the exclusive analysis of your data by automated systems, i) request compensation for damages if you suffer harm due to unlawful processing.
As data subjects, in order to state your requests regarding your rights and to exercise your rights over your personal data, you can carry out the necessary changes, updates and/or deletion and related requests by completing the "Data Subject Application Form" accessible on our website and sending it via the Company's e-mail address hello@thepurestsolutions.live from your personal e-mail address registered with our Company, or via evlypharmakozmetik@hs01.kep.tr with a secure electronic signature, or by applying in writing in person or through a notary to the Company's address at Şerifali Mah. Söyleşi Sok. No :41/A Ümraniye / Istanbul. Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and within thirty days at the latest; however, if the process requires an additional cost, a fee may be charged to you according to the tariff determined by the Personal Data Protection Board.
EXPLICIT CONSENT STATEMENT
I give my consent for my special category personal data, counted in the health data category, namely my "skin type" and "skin analysis information":
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to be used for my skin to be analyzed online through the digital skin analysis tools on the websites of the Company or of the Company's supplier ARHub Bilişim Anonim Şirketi (PulpoAR) and for product recommendations to be made to me accordingly, and
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to be used for carrying out product marketing and advertising processes, including planning personalized marketing activities, conducting customer segmentation and targeting work, performing marketing analyses and other customer relationship management (CRM) analyses,
to be processed by the Company and transferred to its business partners.

