NORAVIS COSMETICS INDUSTRY AND TRADE JOINT STOCK COMPANY

**1. PRIVACY AND COOKIE POLICY

WEBSITE PRIVACY AND COOKIE POLICY**

Protecting the privacy of visitors (“Data Subjects”) to the website operated by Novaris Kozmetik Sanayi Ticaret Anonim Şirketi (“Company”) at https://essay.com.tr/ is one of our primary principles. Through this Website Privacy Policy (“Policy”), explanations are provided regarding (1) the processing of Data Subjects’ personal data, (2) the Cookie Policy, and (3) the enforcement of the Website Privacy Policy.

1.1 Processing of Data Subjects’ Personal Data

Personal data obtained during your visit to our website may be processed by the Company, as the data controller, within the scope described below in accordance with the Personal Data Protection Law No. 6698 (“Law”).
You may access detailed information regarding the processing of your personal data at https://essay.com.tr/.

1.2 Purpose of Processing Your Personal Data

Your personal data obtained due to your visit to our Website may be processed by the Company in accordance with Articles 5 and 6 of the Law for the following purposes:

• Carrying out the necessary work by our relevant business units to conduct the commercial activities performed by the Company and managing the related business processes,
• Carrying out necessary work by our business units and managing the related processes to enable relevant persons to benefit from the products and services offered by the Company,
• Planning and executing activities necessary for customizing and promoting the Company’s products and services according to the relevant persons’ preferences, usage habits, and needs.

1.3 Parties to Whom Your Personal Data Is Transferred and Purpose of Transfer

Your personal data obtained during your visit to our website may be transferred to our business partners, suppliers, legally authorized public institutions, and private persons within the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, in line with the purposes of processing your personal data.

1.4 Method and Legal Ground of Collecting Your Personal Data

Any information identifying or making you identifiable is considered “personal data.”
Within the scope of your visit to our Website, personal data is collected through cookies, which are technical communication files, in accordance with the data processing conditions set forth in the Law.

Mandatory cookies are processed based on the legal ground of “being necessary for the establishment or performance of a contract” under Article 5/2(c) of the Law.

Analytical, marketing, personalization, and preference cookies are used based on explicit consent pursuant to Article 5/1 of the Law. Explicit consent is obtained through the cookie preference panel, and data subjects may withdraw their consent at any time.

1.5 Rights of Data Subjects

As a personal data owner, you have the following rights under Article 11 of the Law:

• To learn whether your personal data is processed,
• If processed, to request information regarding such processing,
• To learn the purpose of processing and whether your personal data is used in accordance with that purpose,
• To know the third parties to whom your personal data is transferred, domestically or abroad,
• To request correction of your personal data if it is incomplete or incorrectly processed, and to request that such correction be notified to third parties to whom your data has been transferred,
• To request deletion or destruction of your personal data under the conditions stipulated in the Law, and to request that such process be notified to third parties to whom your data has been transferred,
• To object to any result arising to your detriment from the analysis of your personal data exclusively through automated systems,
• To request compensation if you suffer damage due to unlawful processing of your personal data.

You may submit your applications regarding these rights by completing the Data Subject Application Form of Novaris Kozmetik Sanayi Ticaret Anonim Şirketi available at https://essay.com.tr/.
Your request will be finalized free of charge as soon as possible and within a maximum of thirty days, depending on its nature. However, if processing the request requires additional cost, a fee may be charged according to the tariff determined by the Personal Data Protection Board.

1.6 About the Cookie Policy

This Cookie Policy explains what cookies are and how we use them. You should read this policy to understand what cookies are, how we use them, what types of cookies we use, what information we collect using cookies, how this information is used, and how you can control your cookie preferences.
You may change or withdraw your consent at any time through the Cookie Notice on our website.

Cookies are stored on devices during the session or for a predetermined period depending on their usage purposes and are automatically deleted once their retention period expires. Data subjects may delete cookies at any time through their browser settings.

You may find more information about who we are, how to contact us, and how we process personal data in our Privacy Policy.

What Are Cookies?

Cookies are small text files used to store small pieces of information. When a website loads on your browser, cookies are stored on your device. Cookies enable the proper functioning of the website, enhance website security, improve user experience, and help us analyze website performance to identify what works and what needs improvement.

To provide you with the most efficient use of our website and to improve your user experience, we use cookies. If you prefer not to use cookies, you may delete or block cookies through your browser settings. However, this may affect your ability to use our website. Unless you change your cookie settings, we will assume that you accept the use of cookies.

1.7 How We Use Cookies

Third-party cookies used on our websites are primarily for understanding how the website performs, how you interact with the website, maintaining the security of our services, providing relevant advertisements, and ultimately offering you a better service. They help enhance your user experience and accelerate your future interactions with the website.

The primary purposes of using cookies on our Website include:

• Improving the services offered to you by enhancing the functionality and performance of the website,
• Improving the Website, offering new features, and personalizing existing features according to your preferences,
• Ensuring the legal and commercial security of both you and our Company.

1.8 Types of Cookies We Use

Like most online services, our website uses first-party and third-party cookies for a variety of purposes. First-party cookies are mostly essential for the proper functioning of the website and do not collect personally identifiable information.

Essential Cookies:
Necessary for experiencing all functionality of our site. They help maintain user sessions and prevent security threats and do not store personal information.

Statistics Cookies:
Store information such as the number of visitors, unique visitors, pages visited, and traffic sources. These help us analyze website performance.

Marketing Cookies:
Used to personalize advertisements shown to you and monitor the effectiveness of advertising campaigns. Information stored may be used by third-party ad providers to show relevant ads on other websites.

Functional Cookies:
Support non-essential features such as embedding videos or enabling content sharing on social media.

Preference Cookies:
Store settings such as language preferences for a more personalized browsing experience during future visits.

1.9 How to Control Cookie Preferences

Consent is obtained from data subjects for cookies other than mandatory cookies. Visitors are provided a cookie information and preference panel where they can manage their cookie settings. Through this panel, users may accept, reject, or change cookie preferences at any time.

Additionally, different browsers offer various methods to block or delete cookies. For more information on managing and deleting cookies, you may visit:
wikipedia.org or www.allaboutcookies.org.

1.10 Types of Cookies Used on Our Website

Session Cookies:
Temporary cookies used during the visit and deleted once the browser is closed.

Persistent Cookies:
Used to enhance website functionality and provide faster and better service by remembering user preferences.

1.11 Cookies Used on Our Website

• Technical Cookies
• Authentication Cookies
• Flash Cookies
• Customization Cookies
• Analytical Cookies

(Descriptions preserved as in original text.)

1.12 Can Data Subjects Prevent Cookie Usage?

Yes. You may personalize your cookie preferences by changing your browser settings.
(Links preserved as provided.)

1.13 Enforcement of the Website Privacy Policy

If this Policy is updated in whole or in part, its effective date will be revised.

The Policy is published on the Company’s website and provided to personal data owners upon request.

For detailed information on the processing of your personal data, please refer to our PERSONAL DATA PROTECTION AND PROCESSING POLICY.