Explicit Consent and Commercial Electronic Message (İYS) Notice

1. Scope of Explicit Consent

This document governs the limited processing activities carried out on the basis of your explicit consent under Law No. 6698 on the Protection of Personal Data (the "KVKK"), together with the commercial electronic message approval under Law No. 6563 on the Regulation of Electronic Commerce, by Loopcode Bilişim Yazılım Mühendislik Eğitim ve Danışmanlık A.Ş. ("Loopcode" or the "Company"; registered address: Yavuz Sultan Selim Mah. Dr. Sadık Ahmet Cad. No:24 İç Kapı No:1, Fatih/İstanbul, Türkiye), which operates the Gathin platform (gathin.com) and acts as merchant of record for paid tickets.

A significant portion of your personal data is processed without requiring explicit consent, on the legal grounds set out in Article 5/2 of the KVKK, such as the establishment and performance of a contract, compliance with a legal obligation, the establishment and exercise of a right, and the legitimate interests of the Company. Detailed information on such processing is provided in the KVKK Privacy Notice and the Privacy Policy. The activities listed below, however, rely solely on your explicit consent, and withholding that consent does not prevent you from using Gathin services.

(a) Profiling for marketing purposes: Analysing your user behaviour, event attendance history, saved events, community memberships and interests in order to offer you tailored event, community and campaign recommendations, to personalise promotional content and to place you into interest-based segments is subject to your explicit consent.

(b) Transfer abroad where necessary: Service providers located outside Türkiye may be used in the provision of services such as hosting, e-mail and SMS delivery, analytics (Google Analytics), maps (Google Maps) and authentication (Google OAuth). Pursuant to Article 9 of the KVKK, where an adequacy decision or the appropriate safeguards prescribed in that article cannot be secured, the transfer of your personal data abroad is subject to your explicit consent.

Your explicit consent is given of your own free will, in relation to a specific matter, and after the necessary information has been provided. You are under no obligation to give this consent, and giving it is not a precondition for any service.

The KVKK explicit consent set out in this document and the commercial electronic message approval described below are separate and optional. You may give only one of them, both, or neither; your choice for each is independent.

2. Commercial Electronic Message Approval

Pursuant to Law No. 6563 and the Regulation on Commercial Communication and Commercial Electronic Messages, your prior approval must be obtained for commercial electronic messages sent for the purpose of promoting or marketing goods and services, increasing the recognition of a business, or reinforcing such recognition through content such as celebrations and good wishes. By giving this approval, you agree to receive commercial electronic messages sent by the Company and by organisers within the Gathin ecosystem.

The scope of the approval covers the following messages:

• E-mails sent by organisers to members exclusively for promotional and marketing purposes,
• Messages about communities you are not a member of or have not attended, new events, campaigns and offers,
• Promotional, campaign and informational messages from the Company regarding Gathin services.

Once commercial electronic messaging is activated, your approval will be recorded in the Message Management System (İYS). Loopcode is not currently registered with İYS and does not send marketing messages of this nature.

Transactional messages are not subject to this approval. Notifications sent within the scope of performance of the contract and in line with your request — such as ticket or RSVP confirmations, reminders sent 24 hours before an event, and reminders relating to an event you have saved — do not qualify as commercial electronic messages and are sent independently of this approval.

Informational messages within a community are likewise not subject to this approval. Messages serving a service or informational purpose relating to the events of a community you are a member of — such as notices, invitations, updates (for example, the postponement of an event) and post-event forms — are sent on the basis of the membership relationship, performance of the contract and legitimate interest, and each message offers an easy and free opt-out. Because these messages have no promotional or marketing purpose, they do not qualify as commercial electronic messages. By contrast, messages sent exclusively for promotional or marketing purposes are deemed commercial electronic messages and are sent to you only if you give this approval.

3. Channels and Scope of the Approval

Commercial electronic messages are sent primarily via the e-mail channel; marketing messages are not currently sent by SMS or telephone call, and there are no plans to do so. Should the SMS or telephone channel be used in the future, your approval for that will be obtained separately. Messages may be delivered via the Mailgun infrastructure (e-mail only; no SMS is sent).

Every commercial electronic message includes the identity and contact details of the sender, together with a straightforward opt-out method allowing you to refuse further messages.

4. Right to Refuse and to Withdraw Approval

You may exercise your right to refuse commercial electronic messages and to withdraw the approval you have given at any time, without giving any reason and free of charge. You may exercise this right by any of the following means:

• Through İYS (iys.org.tr),
• From the notification settings section within the application,
• Via the unsubscribe link contained in e-mails,
• By following the opt-out instruction stated in SMS messages (for example, by replying RET),
• By contacting info@loopcode.co.

Your refusal will be processed within the period prescribed by legislation, after which no commercial electronic messages will be sent to you. Likewise, you may withdraw the explicit consent given under the KVKK through this document at any time via info@loopcode.co. No fee is charged for withdrawing your approval or for refusing messages.

5. Consequences of Withdrawing Explicit Consent

Withdrawal of your explicit consent or of your commercial electronic message approval takes effect prospectively. Withdrawal does not affect the lawfulness of processing carried out on the basis of that consent up to the date it takes effect.

• When you withdraw your commercial electronic message approval, the sending of promotional and marketing messages stops. Transactional messages and mandatory notifications within the scope of performance of the contract continue to be sent.
• When you withdraw your explicit consent for marketing profiling, personalised recommendations and marketing activities are stopped; your access to core platform services is not affected.
• When you withdraw your explicit consent for transfers abroad, certain functions or features may be limited where the relevant processing depends on a service provider located outside Türkiye. The Company will endeavour, so far as possible, to maintain continuity of service through alternative solutions.

In any event, withholding or subsequently withdrawing the explicit consent or the commercial electronic message approval set out in this document does not prevent your access to the core services of the Gathin platform. As the explicit consent and the commercial electronic message approval are separate and optional, withdrawing one does not affect the validity of the other. Detailed information on your rights as a data subject under Article 11 of the KVKK is provided in the KVKK Privacy Notice.