**DATA CONTROLLER** Atlas Media ("Company", "we", "our") processes your personal data as a data controller within the scope of the Turkish Personal Data Protection Law No. 6698 ("KVKK"). **PERSONAL DATA PROCESSED** We may process the following personal data during your use of our services: • **Identity Information:** Name, surname, username • **Contact Information:** Email address, phone number • **Digital Identity Data:** IP address (hashed), browser information, device identifiers • **Usage Data:** On-site behavior, reading preferences, click data • **Legal Transaction Data:** Terms of use consent records, consent declarations **PURPOSES OF DATA PROCESSING** Your personal data is processed for the following purposes: 1. **Service Provision:** Delivery of news content, personalized experience 2. **Membership Operations:** Account creation, authentication, account management 3. **Communication:** Newsletter delivery, informational and marketing communications 4. **Analysis and Improvement:** Measuring site performance, improving user experience 5. **Legal Obligations:** Fulfilling legal requirements, responding to regulatory requests 6. **Security:** Fraud prevention, ensuring information security **LEGAL GROUNDS** Your personal data is processed based on the following legal grounds under Article 5 of KVKK: • Your explicit consent • Necessary for the establishment or performance of a contract • Necessary for the data controller to fulfill its legal obligations • Necessary for our legitimate interests **DATA TRANSFER** Your personal data may be transferred, limited to the purposes stated above: • To authorized public institutions within the scope of legal obligations • To business partners from whom we receive services (hosting, analytics, email services) • To servers located abroad (with appropriate security measures) **DATA RETENTION PERIOD** Your personal data is retained for the duration required by the processing purposes and considering the statute of limitations prescribed by relevant legislation: • Account data: Duration of active account + 3 years • Transaction records: 10 years (legal requirement) • Analytics data: 2 years • Marketing data: Until consent is withdrawn **YOUR RIGHTS UNDER KVKK** Pursuant to Article 11 of KVKK, you have the following rights: • To learn whether your personal data is processed • To request information if your personal data has been processed • To learn the purpose of processing your personal data and whether they are used in accordance with their 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 • To request deletion or destruction of your personal data within the scope of Article 7 of KVKK • To request notification of correction, deletion or destruction operations to third parties to whom data has been transferred • To object to the occurrence of a result against you through the analysis of processed data exclusively through automated systems • To claim compensation for damages if you suffer damage due to unlawful processing of your personal data **APPLICATION METHOD** To exercise your rights: • Email: kvkk@atlas.news • Web form: atlas.news/data-rights Your applications will be answered free of charge within 30 days at the latest. **DATA SECURITY** The following technical and administrative measures are taken for the security of your personal data: • SSL/TLS encryption • Firewall protection • Access control and authorization • Regular security audits • Staff training • Incident response procedures **COOKIE PRACTICES** For detailed information about cookie usage on our website, please review our Cookie Policy. **CONTACT** Atlas Media Washington DC, USA Email: legal@atlas.news KVKK Contact: kvkk@atlas.news Last updated: January 2025 Version: 2.0

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