Samsung Free Privacy Notice

Effective Date: June 30, 2021

At Samsung Electronics Co., Ltd. (“Samsung”), we know how important privacy is to our customers. Samsung is the data controller for Samsung Free. The Data Controller Representative of Samsung in Turkiye is “Samsung Electronics Istanbul Pazarlama ve Ticaret Ltd. Şti.”.We created this Privacy Notice (“KVKK Notification Text”) to make sure you understand how we collect and use your personal information.

Samsung aims to process personal data of Samsung Free users in accordance with the international data protection provisions and the provisions of the Law No. 6698 on Protection of Personal Data (the “KVKK- also known as LPPD in English abbreviation”) and other legislation.

We hereby inform you that your personal data that you have provided/will provide to Samsung and/or are obtained externally by any means by Samsung due to your being a Samsung Free user shall be processed by Samsung acting as of “Data Controller”:

• within the framework of the purpose for which they are required to be processed and as relevant, limited, and proportionate to such purpose,
• by preserving the accuracy and the most up-to-date state of such personal data as they have been provided to Samsung by you or otherwise,
• and by complying with the conditions stipulated in the KVKK.

With this KVKK Notification Text (Obligation to Inform Text), it has been aimed to continue and develop the activities carried out by Samsung in accordance with the principles contained in the KVKK.

Our Privacy Policy at https://account.samsung.com/membership/terms/privacypolicy also applies to your use of Samsung Free. Our Privacy Policy contains more information about how we use your data. It also includes information about your rights and how to contact us. Please read our Privacy Policy in addition to this KVKK Notification Text. However, this KVKK Notification Text shall always prevail over the Privacy Policy in relation to how we use your information for Samsung Free.

WHAT INFORMATION DO WE COLLECT?

Samsung shall process your personal data for the purposes and legal grounds specified in this KVKK Notification Text. If there is any change in the purpose for which your personal data are processed or in the legal grounds thereof, this KVKK Notification Text shall be updated and re-published by Samsung.

Through Samsung Free, Samsung obtains and maintains information about you in various ways. Your personal data are collected through electronic media, via all kinds of information, documents and certificates you have submitted to Samsung and collected through the application, both before and after the establishment of the contractual relationship and during such contractual relationship.

Information About Your Use of Samsung Free

We will collect information about your use of our Samsung Free through software on your devices and information you submit directly. We will collect:

• Samsung account information: your Samsung account ID and date of birth, when you sign in to Samsung account to use Samsung Free or signed in to Samsung account on your device;
• Device information: We obtain information through automated means about your Samsung Free-enabled devices, such as hardware information, including manufacturer, device type and model, country, country specific code, telecommunication provider information, language setting, software information, including operating system version, mobile country code/mobile network code, IP address, device identifiers (such as IMEI and Universal Unique ID), and other unique identifiers, and app version you use to access Samsung Free;
• Service usage: Service version, settings (such as language), usage information (time, duration, and patterns, including what you click), and country information relating to your use of Samsung Free.
• Content information: We collect information related to the content you view or play when you use the various tabs offered through Samsung Free. For example:

Play tab: we obtain information about how you use the Play tab, such as what you click or what games we recommend for you.

Read tab: information related to what news articles and categories of news articles you viewed or are interested in according to your preferences you can choose to receive personalized news and ads.

We also collect other information about you, your devices and apps, and your use of Samsung Free in ways that we describe to you at the time of collection.

HOW DO WE USE YOUR INFORMATION?

We use the information collected for the following purposes:

• to identify and authenticate you so you may use Samsung Free;
• to provide you with the features offered by Samsung Free;
• to improve and customize your experience with Samsung Free such as delivering content and responses tailored to you and the way you interact with Samsung Free;
• to respond to your requests, inquiries, and instructions made through Samsung Free to improve your customer service experience;
• to allow you to interact with and use participating Samsung and third-party apps and services;
• to operate, evaluate and improve Samsung Free and our business (including developing new products and services, enhancing and improving our products and services, managing our communications, analyzing our products, services, and customer base, conducting market research, performing data analytics, and performing accounting, auditing, and other internal functions);
• for advertising and providing sponsored content;
• to send you useful information for usage of Samsung Free (such as new content in the tabs or new features of Samsung Free) via push notifications;
• to protect against, identify, and prevent fraud and other criminal activity, claims and other liabilities; and
• to comply with and enforce applicable legal requirements, relevant industry standards and our policies, including this KVKK Notification Text and the Privacy Policy found here: https://account.samsung.com/membership/terms/privacypolicy.

We use and combine the information we collect about you from Samsung Free with data from other services, features or devices you use, such as when you use the Game Launcher/Galaxy Store standalone application, you can get customized services based on the data that combines game usage records from Samsung Free, Game Launcher and Galaxy Store.

Samsung Free may provide the ability to connect to or show other websites, apps, services, and other features, such as showing content you like or use from Samsung or third-party services. For example, when you use each tab, content providers may provide you with content to view or play. Third-party websites, apps, services, and features may operate independently from us and may have their own privacy notices or policies. Review them to ensure that you understand how they process your information. To the extent that any other linked or shown website, app, service, or other feature is not owned or controlled by us, we are not responsible for its content, use, or privacy practices.

Samsung processes personal information for the purposes described above. Samsung's legal basis to process personal information is outlined below:

Your personal data are processed being limited to the use of the related service/platform; in compliance with the legislation in force and the Law on Protection of Personal Data; by automated or non-automated methods;

• based on Article 5, paragraph 2 of the KVKK, sub-paragraph c), which stipulates 'if it is necessary to process personal data of contractual parties, provided that such processing is directly related to the establishment or performance of the contract', and sub-paragraph f) thereof, which stipulates 'if it is mandatory to process personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not violated':

and may be updated in line with our obligations arising from the legislation and the company policies.

Your personal data shall be kept for a reasonable period of time until the purpose for which they are processed ceases to exist or until the end of the legal time period specified in the relevant legislation, and in any case until the expiry of the statute of limitations.

WHO DO WE SHARE YOUR INFORMATION WITH?

The procedures and principles to be applicable to personal data transfers are set forth in Articles 8 and 9 of the KVKK, and the personal data of the data subject may be transferred to third parties in Turkiye and/or abroad.

We will disclose your information internally within our business and to the following entities, but only for the purposes described above.

• Business partners: partners or service providers who we work together with to provide you with Samsung Free, such as third parties who provide content within Samsung Free;
• Service providers: carefully selected companies that provide services for or on behalf of us, such as cloud platform providers who maintain data on our behalf. These providers are also committed to protecting your information;
• Other parties when required by law or as necessary to protect Samsung Free: for example, it may be necessary by law, legal process, or court order from governmental authorities to disclose your information. They may also seek your information from us for the purposes of law enforcement, national security, anti-terrorism, or other issues that are related to public security;
• Other parties in connection with corporate transactions: we may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of bankruptcy; and
• Other parties with your consent or at your direction: in addition to the disclosures described in this Privacy Notice, we may share information about you with third parties when you separately consent to or request such sharing.

HOW LONG DO WE RETAIN YOUR INFORMATION AND WHERE DOES IT GO?

How long your data will be retained depends on the legal basis relied upon to process your data. For example, data we process to perform our contract with you requires us to keep the data throughout the time you use Samsung Free. As long as you are an active user of Samsung Free, we will retain and process this data. Data such as your account information and device information and identifiers fall into this category.

Data we process to promote our business interests, such as your usage of Samsung Free, is only kept for as long as needed for the purposes for which it was collected. For example, this data may be collected to perform analytics so we can develop improvements to Samsung Free, or we may process data to keep a record of inquiries you made through or about Samsung Free to improve your customer service experience.

In addition, we may also process your data based on your consent. If you withdraw your consent, we will stop processing your data that relies on your consent, but it will not impact the processing of data collected prior to your withdrawal until the purposes for which such data was collected have been achieved.

Please note, although we aim to retain your data for the time period described above, your data may be processed longer pursuant to applicable law. For example, if a specific statute mandates we require a certain piece of data, we comply and retain that data until the required retention period expires.

As long as your data is retained by us your data will always be subject to appropriate safeguards.

Your use of Samsung Free will involve the transfer, storage, and processing of your personal information to other countries; such countries include, without limitation, countries in the European Economic Area, the Ireland, the Republic of Korea and the United States. All international data transfers are subject to legal requirements to ensure that your personal information is processed safely and as you would expect.

YOUR RIGHTS UNDER KVKK

Data Subject's Rights under KVKK
In accordance with Article 11 of the KVKK, you may apply to Samsung and make requests on the following issues about your personal data:

a. Learning whether or not your personal data have been processed,
b. Obtaining information on the procedure, if your personal data have been processed,
c. Learning the purpose for which your personal data have been processed and whether or not they are used in line with such purpose,
d. Obtaining information about third parties to whom your personal data are transferred within Turkiye or abroad,
e. Requesting correction of your personal data if they have been processed incompletely or inaccurately and requesting the notification of third parties to whom your personal data are transferred of the correction made in this respect,
f. Requesting deletion, destruction, or anonymization of your personal data if the reasons for which they are processed no longer exist and requesting the notification of third parties to whom your personal data are transferred of such deletion, destruction, or anonymization procedure,
g. Objecting to the occurrence of a result which is detrimental to you as a result of analyzing of your processed personal data exclusively through automatic systems,
h. Requesting indemnification for your damages which are caused by unlawful processing of your personal data.

Samsung or our Data Controller Representative shall receive and evaluate the data subject requests through the "Samsung Electronics Co., Ltd. Data Subject Application Form" available on https://www.samsung.com/tr/info/kvkk/. Samsung or our Data Controller Representative shall conclude your application free of charge in accordance with Article 13 of the KVKK according to the nature of the request, and within 30 (thirty) days at the latest. If the request is rejected, the reason(s) for rejection shall be notified to you in writing or electronically together with the relevant grounds.

Your Other Rights
In addition to the Related Person Rights requests that are specified in 5.1 and which you can submit to Samsung or Data Controller Representative, rights below also have been offered and automated by Samsung for your use.

• Examining your data that we collect (specific to the relevant application)
• Deleting your data on Samsung apps and services (specific to the relevant application)
• Updating your Samsung Account information
• Opting out of the marketing communications

You can access the relevant rights on https://privacy.samsung.com/#/. Samsung reserves the right to change the scope of these rights.

UPDATES TO THIS KVKK Notification Text

This KVKK Notification Text may be updated to let you know about changes in how we collect and process your information in Samsung Free or changes in related laws. The date when the document was last updated is shown at the top of this KVKK Notification Text. You may access the most up-to-date version of this KVKK Notification Text on https://api.mop.apps.samsung.com/config-svc/v1/legals/latest/pn?cc=TR&lo=en-TR.