Privacy Policy – SAGAI GLOBAL LTD

PRIVACY AND PERSONAL DATA PROCESSING CLARIFICATION

1 – Introduction

Data Controller: Sagai Global LTD (“Sagai Global”)

Sagai Global LTD (“Sagai Global”) processes your personal data in accordance with the relevant laws and regulations on the Protection and Processing of Personal Data. In this context, this Personal Data Processing Clarification Text (“Clarification Text”) has been prepared to inform data subjects regarding the processing, storage, and transfer of their personal data.

Additionally, detailed information regarding the cookies used when you visit our Platform (our website) is provided in the Cookie Policy. Personal data processed through these cookies is explained in this Clarification Text.

2 – Which personal data do we process?

If you subscribe to Sagai Global, the following personal data will be processed:

User Account Information: Your first name, last name, subscriber number, subscription email address, address, and phone number.
Subscription Transaction Information: Your order and invoice details, transaction history related to your purchases, request and complaint information, Platform usage information.
Delivery Information: Phone number and delivery address you provide for the product you order, delivery transaction details.
Payment Information: Information regarding payments made by you and the payment methods, registered card details.
Transaction Security Information: Device information, IP address, cookie information, platform access logs.
Personal data processed under additional services: Data processed when you benefit from additional services such as discount coupons and campaigns offered on the Platform.

3 – Legal grounds, purposes, and methods of processing your personal data

Your personal data is processed by Sagai Global in accordance with the principles of “necessity” and “usefulness,” ensuring data minimization and taking necessary technical and administrative security measures, either automatically or non-automatically as part of a data recording system. Your personal data is collected through electronic means on the websites related to the subscription services provided by Sagai Global, by contacting you via live chat, call center, or email channels, or when physically communicated via printed forms, notifications, postal mail, or legal authorities.

When using the Platform Services as a Visitor, detailed information on the processed personal data can be found in the Cookie Policy and this Clarification Text.

Sagai Global shares your personal data with the recipient groups detailed below based on legal reasons. The purposes and legal grounds for processing your personal data are explained in detail below.

3.1 Subscription and Account Creation Process

Personal data processed in this category: User account information, subscription transaction information, transaction security information.

Managing the processes of establishing and performing the subscription agreement,
Managing the processes of creating and closing the subscriber profile/account on the Platform,
Verifying contact information,
Conducting transactions related to purchases on the Platform,
Conducting and auditing the business activities of Sagai Global,
Ensuring the security of Platform operations,
Ensuring the activities on the Platform are conducted in accordance with the law,
Fulfillment of obligations for data sharing and storage arising from legal requirements,
Ensuring that you benefit from Platform Services within the framework of our contractual relationship and subscription agreement,
Managing the operations of the Platform, obtaining information technology, software, and technological services.

Legal Grounds: Explicitly stipulated by law, necessary for the fulfillment of Sagai Global’s legal obligations, necessary for the performance of our Subscription agreement with you and ensuring compliance with the contract.

3.2 Order, Delivery, and Cancellation/Return Processes

Personal data processed in this category: User account information, delivery information, subscription transaction information, payment information, transaction security information.

Placing and processing orders,
Managing delivery and logistics activities,
Managing cancellation/return processes,
Managing payment and invoicing processes,
Managing the purchase processes of products/services on the Platform.

Your personal data is shared and processed with business partners and service providers for the following purposes:

Ensuring your use of Platform Services and managing purchasing and invoicing processes, in accordance with the obligations arising from applicable regulations that apply to Sagai Global and the vendor from whom you purchase products or services,
Managing and tracking delivery, logistics, and return processes with product vendors, cargo companies, private couriers, logistics, and customs consultancy firms,
Managing payment processes with our partner banks and payment institutions,
Providing information on delivery and related issues via bulk SMS/email services from our business partners.

3.3 Improvement of Subscriber Experience

Personal data processed in this category: User account information, subscription transaction information, delivery information, transaction security information.

Ensuring quick and easy access to products tailored to your preferences and interests,
Enhancing the user experience across services of Sagai Global’s Platform,
Improving our user experience and service quality,
Conducting analysis and reporting activities,
Conducting communication activities,
Evaluating requests, complaints, and suggestions regarding our products and services,
Managing sales and after-sales support services,
Ensuring subscriber satisfaction and addressing their requests and complaints,
Managing activities to develop and improve the products and services offered by Sagai Global.

Personal data is shared and processed with business partners providing call center services, service providers offering subscriber support, service providers for Platform operations, affiliates providing information technology, software, and technology services, group companies, and consultants for the purposes outlined above.

Legal Grounds: Necessary for the performance of our Subscription agreement with you, essential for Sagai Global to fulfill its obligations, and ensuring compliance with the contract.

3.4 Information Security, Risk, Audit, and Control Processes of Sagai Global
The personal data processed in this category includes: Your user account information, subscriber transaction information, delivery information, payment information, transaction security information.

Managing and auditing financial and accounting processes,
Managing billing processes,
Managing information security processes and investigating suspicious transactions,
Ensuring the security of operations related to the Platform,
Controlling, developing, and improving the quality of products and services provided by Sagai Global,
Conducting risk detection and analysis, and managing complaints,
Preventing fraud through cooperation with our business partners, consultants, and service providers, banks, e-invoice partners, cargo and courier companies, private integrators, independent auditors, customs, and accounting/tax services,
Ensuring the security of Sagai Global’s products, services, and operations, controlling and improving the quality of products and services, and conducting risk detection and analysis in collaboration with independent auditors, customs, tax consultants, our subsidiaries, group companies, private integrators, technology companies, business partners, and service suppliers.

Legal Basis: It is necessary for the performance of our Subscription Agreement with you, for the fulfillment of Sagai Global’s obligations, and for ensuring the provision of contractual guarantees.

3.5 Legal Process Execution
The personal data processed in this category includes: Your user account information, subscriber transaction information, delivery information, payment information, transaction security information.

Managing and following up on legal and litigation matters, responding to legal requests, reviewing and responding to applications as the relevant person in accordance with applicable procedures,
Ensuring that activities are conducted in compliance with laws and fulfilling the obligations arising from the legislation applicable to Sagai Global,
Managing legal consulting processes,
Sharing information with authorized persons, institutions, and organizations upon request,
Exercising and protecting a right in case of legal disputes,
Ensuring that Platform activities are conducted in compliance with laws, sharing information with authorized persons, institutions, and organizations for the purposes of compliance, including with regulatory and supervisory authorities, courts, enforcement offices, and mediators,
Conducting Sagai Global’s audit activities, legal consulting processes, ensuring the security of Sagai Global’s operations, and investigating suspicious transactions in cooperation with lawyers, auditors, tax consultants, forensic experts, cybersecurity consultants, tax consultants, group companies, subsidiaries, third-party consultants, and business partners.

Legal Basis: It is necessary for the establishment, exercise, or protection of a legal right, for the fulfillment of Sagai Global’s legal obligations, and for ensuring the provision of contractual guarantees. As explicitly provided by the law.

3.6 Processes Based on Consent
The personal data processed in this category includes: Your user account information, subscriber transaction information, delivery information, payment information.

Managing marketing, advertising, and promotion activities,
Conducting financial offer processes,
Providing special offers to you, improving your satisfaction by better understanding you, and sending commercial electronic messages for the purpose of these activities in collaboration with our affiliates, group companies, service providers, and business partners.

Legal Basis: Your consent. It is important to note that if you wish to withdraw your consent for receiving commercial communication, you can communicate your request to Sagai Global using the methods outlined under the heading “6-Communication for Your Rights and Requests.”

3.7 Additional Service Processes Provided on the Platform
In the context of additional services provided on the Platform, if you wish to benefit from these services, your personal data is processed within the framework of the clarification texts provided in the relevant service area and shared in accordance with applicable laws.

Here is the translation of your provided text into corporate and contractual English language:

4 – How Does Sagai Global Protect Your Personal Data?
Personal data shared with Sagai Global is under its supervision and control. Sagai Global, as the data controller, is responsible for establishing the necessary organization, taking and adapting technical measures to ensure the confidentiality and integrity of information in accordance with the applicable legislation. Aware of our obligations in this regard:

Periodic penetration tests are conducted in compliance with international and national technical standards related to data privacy.
The personal data you provide to Sagai Global is protected using SSL (Secure Sockets Layer) technology.
Regular risk analyses are performed regarding personal data processing activities, and actions are taken to mitigate identified risks.
Access and authorization controls are implemented to prevent unauthorized access to personal data.
Data processing policies are regularly updated.

5 – Your Rights Regarding the Protection and Processing of Personal Data
By contacting Sagai Global through the methods outlined in the “Communication for Your Rights and Requests” section of this Privacy Notice, you have the right to:

Learn whether your personal data is being processed,
Request information if your personal data has been processed,
Learn the purpose of processing your personal data and whether it is being used in accordance with that purpose,
Be informed about third parties to whom your personal data is transferred, either domestically or abroad,
Request correction if your personal data is incomplete or incorrect,
Request the deletion or destruction of your personal data,
Request notification to third parties to whom your personal data has been transferred regarding the correction, deletion, or destruction of your personal data,
Object to any decision resulting in an adverse outcome for you that is solely based on automated processing of your personal data,
If you suffer damage due to the unlawful processing of your personal data under applicable laws, request compensation for your losses.

6 – Communication for Your Rights and Requests
You may send your questions and requests related to your personal data in a properly formatted petition or “Sagai Global LTD Application Form,” clearly stating your request and providing necessary documents and information. You can access the application form here.

Application Method	Address for Application
In-Person Written Application	71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Notary	71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
E-mail	From your previously notified and registered email address in the system: [email protected]

*Please write “Personal Data Protection Law Data Subject Request” in the subject line of the application form or email.
**Individuals applying via the “In-Person Written Application” method are required to present identity documents to verify their identity.

As personal data owners, if you submit your requests related to your rights to Sagai Global, Sagai Global will process your request free of charge and conclude it within 30 (thirty) days at the latest. However, if a response to your application requires a fee under the applicable legislation, Sagai Global may charge for the costs incurred.

7 – About the Privacy Notice
This Privacy Notice will be effective as of the date it is published by Sagai Global. Sagai Global reserves the right to update this Personal Data Protection Privacy Notice at any time within the framework of applicable legislation. Updates will become immediately effective upon publication on the Platform.
Update Date: 13.02.2025