PRIVACY NOTICE (KVKK)

This notice is provided under Article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”). It explains how we process the personal data of people who visit the LAUNCHONTOFI website, buy our products, subscribe to our newsletter, apply to become a wholesale partner or contact us.

This English text is an adaptation for international customers. In case of any discrepancy, the Turkish version (KVKK Aydınlatma Metni) prevails.

Data controller

Name / trade name	Remzi Muslu (sole proprietorship)
Address	Kocaoba Cumhuriyet Caddesi 2A, 35980 Dikili / İzmir, Türkiye
Email	contact@launchontofi.com
Phone	+90 212 671 04 12

What data we process and why

Website visitors

• Data: IP address, browser and device information, pages visited, cookie preferences.
• Purposes: Running the website securely and correctly, information security and providing features such as the cart, favourites and your cookie preferences. We currently do not use any analytics or marketing measurement tools; if we add them in the future, they will be activated only if you consent in the cookie banner. See our Cookie Policy for details.

Customers (orders)

• Data: Name, delivery and billing address, phone, email, Turkish ID number or tax number (where required for invoicing), order and return history, order-related email correspondence and notes of phone calls, payment details (bank transfer/EFT receipt, sender name and bank details; your IBAN where a refund is needed).
• Purposes: Taking your order, collecting payment, delivering the product, invoicing, handling withdrawals, returns, exchanges and defective goods claims, customer service and statutory record-keeping.
• Orders are placed with the message generated from the cart on our website, via WhatsApp, by email to contact@launchontofi.com or by phone. Payment is made by bank transfer / EFT after the order has been confirmed. We do not collect card details.

Newsletter subscribers

• Data: Email address, name and phone if provided, date and channel of consent.
• Purpose: Sending news about drops, products, campaigns and events. Commercial electronic messages are sent only with your consent under Turkish E-Commerce Law No. 6563, through our own email infrastructure (contact@launchontofi.com), and your consent is registered in the Message Management System (İYS). You can withdraw consent free of charge at any time via the one-click unsubscribe link in each message or through İYS.

Wholesale (dealer) applicants

• Data: Name, company name, tax details, address, phone, email, shop details and any other information you share in the application form.
• Purpose: Evaluating your application, contacting you and, where agreed, entering into a dealer agreement.

Contact form

• Data: Name, email, phone (optional), message content.
• Purpose: Answering your questions, suggestions and complaints.

Orders by email and phone

• Data: Email address, phone number, content of messages and calls, order and delivery details.
• Purpose: Handling orders and questions sent by email or phone, sending you the Pre-Information Form and the Distance Sales Agreement and recording your confirmation.
• WhatsApp: If you message us on WhatsApp to order or for support, your name, phone number, message content and cart details are processed to set up and perform your order and to communicate with you (KVKK Art. 5/2-c and 5/2-f). WhatsApp is provided by WhatsApp Ireland Limited / Meta Platforms and data may be processed on servers abroad; by choosing this channel you start the conversation yourself. Transfers abroad are assessed under KVKK Art. 9; you can always order by email or phone instead.

Legal grounds (KVKK Article 5)

We rely on the following legal grounds listed in Article 5 KVKK:

• Establishing or performing a contract (Art. 5/2-c): Orders, delivery, returns and customer service; evaluating wholesale applications.
• Compliance with a legal obligation (Art. 5/2-ç): Tax, invoicing, consumer protection and e-commerce obligations.
• Expressly provided by law (Art. 5/2-a): Keeping commercial records and invoices.
• Establishing, exercising or defending a right (Art. 5/2-e): Use as evidence in potential disputes.
• Legitimate interest (Art. 5/2-f): Website security, strictly necessary cookies, answering your enquiries.
• Explicit consent (Art. 5/1): Analytics and marketing cookies, if used in the future, and any other processing based on consent. Separate consent is obtained for commercial electronic messages under Law No. 6563.

How we collect data

We collect data electronically and partly automatically through website forms, the cart and order pages, cookies and similar technologies, email and phone.

Who we share data with

Limited to the purposes above and in line with Articles 8 and 9 KVKK, we may share data with:

• Our contracted courier companies, for delivery and returns,
• Banks, to receive payments and make refunds,
• Our website hosting provider (Spaceship),
• The Message Management System (İYS), to register consent for commercial electronic messages,
• Accountants, financial advisers and legal counsel
• Authorised public bodies and courts, upon request

We currently do not use any analytics provider, and newsletters are sent through our own email infrastructure rather than a third-party newsletter service.

Transfers abroad

Our website is hosted on Spaceship infrastructure, whose servers may be located outside Turkey. Technical data generated when you visit the site (for example, your IP address and browser information) and information you submit through the site may therefore be processed on servers abroad.

Such transfers are made in accordance with Article 9 KVKK, primarily on the basis of appropriate safeguards such as the standard contracts published by the Personal Data Protection Board. Where standard contracts are used, the Personal Data Protection Authority is notified within 5 business days of signing. Where appropriate safeguards cannot be provided, the transfer is made only in one of the occasional-transfer cases listed in Article 9(6), in particular on the basis of your explicit consent after you have been informed of the possible risks.

How long we keep data

We keep data for as long as the purpose requires and for the periods required by law; afterwards it is deleted, destroyed or anonymised.

• Orders, invoices and other commercial and accounting records (including order correspondence): 10 years under the Turkish Commercial Code No. 6102 and Tax Procedure Law No. 213,
• Newsletter consent records: 3 years after your consent ends,
• Wholesale applications, contact form submissions and other messages: 2 years (if a dealer agreement is concluded, its records are kept like other commercial records),
• Cookies: for the periods stated in our Cookie Policy.

Children

Although we sell scooter models designed for kids, we expect orders to be placed by a parent or legal guardian. We do not knowingly collect personal data from people under 18.

Your rights (KVKK Article 11)

You may ask us to:

• Tell you whether we process your personal data,
• Provide information about that processing,
• Explain the purpose of processing and whether data is used accordingly,
• Name the third parties in Turkey or abroad to whom data is transferred,
• Correct incomplete or inaccurate data,
• Delete or destroy data under the conditions of Article 7 KVKK,
• Notify third parties to whom data was transferred of such correction, deletion or destruction,
• Object to a result against you arising solely from automated analysis,
• Compensate damage caused by unlawful processing.

How to apply

In line with the Communiqué on the Procedures and Principles of Application to the Data Controller, you can apply:

• In writing with a wet signature and proof of identity, to Kocaoba Cumhuriyet Caddesi 2A, 35980 Dikili / İzmir, Türkiye,
• Signed with a secure electronic or mobile signature, to contact@launchontofi.com,
• From the email address registered with us, to contact@launchontofi.com.

Please include your name, Turkish ID number (or nationality and passport/ID number for non-citizens), postal address, email and phone if available, and what you are requesting. We respond free of charge as soon as possible and at the latest within 30 days; if the request involves an additional cost, a fee under the Board’s tariff may be charged. If your application is rejected, you find the answer insufficient or we do not respond in time, you may file a complaint with the Personal Data Protection Board (KVKK Kurulu).