1. Data Controller

This Privacy Policy applies to the processing of personal data by ALC MOBILE DIS TICARET LIMITED SIRKETI, a company incorporated under the laws of the Republic of Türkiye (the “Company”), on the website www.bytr.com (the “Website”) .

The Company acts as the data controller in accordance with applicable data protection laws.

2. Scope

This Privacy Policy governs the collection, use, storage, and protection of personal data of users who access the Website or place orders through www.bytr.com .

The Website does not target residents of any specific foreign jurisdiction and is operated as a cross-border e-commerce platform.

3. Purpose of Processing

The Company processes the following personal data of users of the Website for the following purposes:

The Company does not store full payment card details.

4. Legal basis

The Company processes personal data only when there are appropriate legal bases.

Personal data are processed based on:

• Performance of a contract, to which the data subject is a party, guarantor, or beneficiary • Legitimate interests of the Company • Compliance with statutory requirements applicable to the Company • User consent, where required

5. Actions with personal data

When processing personal data, the Company performs the following actions (operations) with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, and destruction of personal data.[ALRUD4.1]

Personal data may be transferred by the Company exclusively to the following persons, subject to the existence of appropriate legal basis, to the extent and in the manner required by applicable law:

• Payment service providers • Logistics and delivery partners • IT and hosting service providers • Authorized public authorities when legally required

Data are not sold or disclosed to unauthorized third parties.

6. Cross-Border Data Transfers

Due to the cross-border nature of the services, personal data may be processed and stored in foreign jurisdictions where the Company’s service providers are located.

Data transfers are conducted on a limited, purpose-based basis and are protected through appropriate technical and organizational safeguards consistent with international data protection standards.

When conducting cross-border transfers, the Company complies with the requirements of applicable law.

7. Data Retention

Personal data are processed and retained only for the period necessary to fulfill the purposes outlined in this Policy or as required by applicable laws.

Following the fulfillment of the processing purpose or otherwise the expiration of the period for processing and retaining personal data, the personal data is subject to destruction.

8. Data Security

The Company implements reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration.

However, absolute security cannot be guaranteed for internet-based transmissions.

9. User Rights

Users have a right to:

• Request information about their personal data • Request correction or deletion • Object to certain processing activities • Exercise other rights provided for by applicable law

Requests may be submitted via email: info@bytr.com

10. Cookies and Similar Technologies

The Website uses cookies [ALRUD5.1]and similar technologies solely to ensure core functionality, security, and performance of the Website.

Cookies are not used to identify users directly and are not employed for profiling, behavioral tracking, or targeted advertising.

Users may manage or disable cookies through their browser settings. Disabling cookies may affect certain Website functions but will not prevent access to general content.

11. Policy Amendments

The Company reserves the right to update this Privacy Policy at any time. Updates become effective upon publication on the Website.

12. Language Priority

This Privacy Policy is drafted in English. Russian translations are provided for informational purposes only.

In case of discrepancy, the English version shall prevail.

13. Contact

For privacy-related inquiries, please contact:

Email: info@bytr.com