Personal Data Protection Policy

In accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK"), your personal data will be processed by our Company, as the Data Controller, within the framework explained below, for the purposes of use, recording, storage, updating, transfer, and/or classification, depending on the business purposes. In this context, our Company, in accordance with the laws and regulations regulating the protection of personal data to protect the fundamental rights and freedoms of individuals, especially the privacy of private life, takes all technical and administrative measures to ensure an appropriate level of security to prevent the unlawful processing, unauthorized access, and preservation of your personal data.

This text is intended for all real persons whose personal data is processed by our Company, excluding our Company employees or employee candidates who have applied to our Company.

The personal data processed as the data controller is not limited to those listed here but includes, among others: Name, surname, ID number, address, phone number, email address, signature, physical location/security camera recordings, call center/service quality voice recordings, bank account number, cookie records.

Purposes and legal reasons for the processing of personal data; The personal data you share are processed for the following purposes:

• To benefit you and/or the institutions and organizations you represent from the products and services offered by our Company, to determine and implement the commercial and business strategies of our Company, to conduct necessary studies, including but not limited to marketing activities, business development, and planning activities,
• To carry out administrative operations related to communication conducted by our Company,
• Ensuring the physical security and control of the locations used by our Company,
• Establishing business partner/customer/supplier (authorized or employees) relationships,
• Fulfillment of contract requirements and financial reconciliation regarding products and services offered together with our business partners, suppliers, or other third parties,
• Implementation of our Company's human resources policies,
• Calling our Company's call center or using the website.

and/or

Processed for the purpose of participating in the training, seminars, or events organized by our Company.

Method of collection and storage of personal data; Your personal data shared with our Company can be collected by automatic or non-automatic methods, verbally, in writing, or electronically, through offices, branches, call centers, websites, social media platforms, mobile applications, and similar means. Your personal data will be stored in electronic and/or physical environments. All necessary information security measures are implemented, and technical security infrastructure developments are made to prevent your personal data obtained and stored by our Company from being exposed to unauthorized access, manipulation, loss, and damage. Your personal data will be processed and stored in accordance with the necessary information security measures, and during the legal retention period or, if such a period is not foreseen, for the duration required by the processing purpose. After this period, your personal data will be removed from the data flows of our Company by deletion, destruction, or anonymization methods.

Transfer of Personal Data;

In accordance with the Laws and other legislation, and for the purposes stated:

• To Sirius Interactive Informatics Advertising Technology Industry and Trade Ltd. Sti. and Sirius group companies,
• To companies acting on behalf of our Company, whom we have authorized, and our representatives,
• To regulatory and supervisory authorities, public institutions, or organizations that are explicitly authorized to request personal data in their laws,
• Limited to joint ventures, supplier and contractor companies, banks, credit risk, and financial institutions, and other real or legal persons for products and services offered together with business partners, regardless of these, at home and abroad, within the framework of the specified purposes,
• To consultants, including tax and other consultants, legal entities and institutions, and auditors, without being limited to them, and to third parties we consult with, including inspectors, are authorized to be transferred.

Your rights according to Article 11 of the KVKK; By applying to our Company, you have the right to:

• Learn whether your personal data is processed,
• Request information if your personal data has been processed,
• Learn the purpose of processing personal data and whether they are used in accordance with their purpose,
• Know the third parties in the country or abroad to whom personal data is transferred,
• Request correction of personal data if it is incomplete or incorrectly processed,
• Request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK,
• Request notification of the transactions made pursuant to subparagraphs (e) and (f) of Article 11 of the KVKK to third parties to whom personal data are transferred,
• Object to the emergence of a result against you by analyzing personal data exclusively through automated systems,
• Demand compensation if you incur damage due to unlawful processing.

In accordance with Article 13 of the KVKK, you can submit your request to use the above-mentioned rights in writing or through other methods specified by the Personal Data Protection Board to our Company.

To use your rights mentioned above, you can personally deliver your request petition with the necessary information to identify you, send it via a notary public, or send it to [email protected]."

Note: This translation is provided for informational purposes only, and in case of any discrepancies or legal questions, it is recommended to consult with a legal professional familiar with the relevant jurisdiction.