CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA (KVKK)

1. Data Controller Pursuant to the Law on the Protection of Personal Data No. 6698 (“KVKK”), your personal data may be processed by Axesome Biotechnology Cosmetics and Medical Consultancy Import Export Trade Limited Company (“Company” or “Genoscope”) as the data controller within the scope explained below.

2. Purpose of Processing Personal Data Your personal data (Identity, Contact, Transaction Information) and Special Categories of Personal Data (Health data, skin swab samples, genetic/genomic analysis results, RNA/DNA data) are processed for the following purposes:

  • Providing the “Personalized Genomic Skincare” service,

  • Analyzing your skin biology at the transcriptomic level to create formulas specific to you (Your Genomic Color),

  • Sharing analysis results with your Genoscope Doctor’s Club member physician to manage the treatment/care process,

  • Delivering products and services to you,

  • Fulfilling legal obligations and notifying authorized institutions (Ministry of Health, etc.), in accordance with the conditions specified in Articles 5 and 6 of the KVKK.

3. To Whom and for What Purpose the Processed Personal Data May Be Transferred Your collected personal data and genetic analysis results may be transferred to;

  • Our contracted laboratory partners for the completion of the analysis process,

  • The authorized Genoscope Doctor’s Club member physician/clinic from whom you receive service and follow-up,

  • Shipping companies for the execution of logistics processes,

  • Legally authorized public institutions and organizations, within the framework of the data transfer conditions specified in Articles 8 and 9 of the KVKK.

4. Method and Legal Reason for Personal Data Collection Your personal data is collected via our website, mobile applications, forms filled out through contracted physicians, and physically collected skin swab samples. These data are processed based on the legal grounds of “Explicit Consent” and “Necessity for the establishment or performance of a contract.” Specifically, your genetic data is not processed without your wet-signed or digital Explicit Consent Declaration.

5. Rights of the Data Subject (Article 11) Pursuant to Article 11 of the KVKK, data subjects have the right to:

  • Learn whether personal data is processed,

  • Request information if their personal data has been processed,

  • Learn the purpose of processing personal data and whether they are used appropriately,

  • Know the third parties to whom personal data are transferred domestically or abroad,

  • Request correction of personal data in case of incomplete or incorrect processing,

  • Request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK.

To exercise these rights, you may submit your request in writing to axesome@gmail.com or to Atatürk Mah. Ataşehir Bul. 2 Blok Sitesi 55. Ada Manolya 1 No:17B Suite:9 Ataşehir, Istanbul, Türkiye.