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KAYITES MÜHENDİSLİK LTD.ŞTİ.

UNDER THE LAW OF PROTECTION OF PERSONAL DATA LIGHTING ABOUT PERSONAL DATA PROCESSING AND INFORMATION TEXT

Kayıtes Engineering takes the highest possible security measures within the framework of the relevant legislation in order to ensure that your personal data is collected, stored and shared in accordance with the law and to protect your privacy. With the awareness of this responsibility, we process your personal data as explained below and within the framework of the legislation, as a data controller under the Law No. 6698.

1) Identity of Data Officer and Representative

In accordance with Article 10 of the Personal Data Protection Law (“KVKK”) No. 6698 of your personal data, Kayı-Tes Mühendislik Taah. Forward. Elect. And Daya. Cons. Goods. Singing. Tic. Ltd. Sti. The extent to which it can be processed by is described below.

2) Purpose of Processing Personal Data

Your collected personal data can be processed by Kayis Engineering in accordance with the basic principles stipulated by the legislation for the following purposes:

• To carry out the necessary activities by the business units of our company and to carry out the activities in this direction in order to carry out the commercial activities carried out by Kayıtes Engineering in accordance with the legislation and Company policies;

• Determining the human resources policy of Kayıtes Mühendislik, carrying out its activities and execution;

• Determining, planning and implementing commercial policies of Kayesh Engineering in the short, medium and long term;

• Providing the commercial, technical and legal security of the related persons who have a business relationship with Kayıtes Mühendislik and providing liaison with these real / legal persons;

• Protecting the commercial reputation and trust it is established by Kayıtes Mühendislik;

• To comply with the information retention, reporting and information obligations envisaged by the official institutions within the scope of the relevant legislation, and to fulfill the legal obligations we are subject to in order to benefit from these services;

• In order to determine and implement our company's commercial and business strategies; financial operations, communication, market research and social responsibility activities, purchasing operations (demand, proposal, evaluation, order, budgeting), internal system and application management operations, management of legal operations;

• Examining, evaluating, responding to requests from public authorities or interested persons;

• Ensuring the security and control of the physical spaces of the company with camera recording systems;

• Fulfillment of the burden of proof as evidence in future legal disputes;

• Processing of personal data specified in KVKK Articles 5 and 6 is processed within the scope and conditions.

• Within the scope of our activities, your data is classified into automatic decision making in order to process the necessary work and information. This situation is obligatory for the reports to be created and documents to be submitted to the relevant institutions.

The processing of your personal data is a legal and contractual obligation, and if your data is not provided, it is impossible to carry out the commercial activities of real / legal persons who have a business relationship with the company, to fulfill the notifications and obligations required under the legislation, to ensure the execution of human resources activities, to provide legal-technical-commercial safety. will become.

3) To whom and for what purpose the data can be transferred

Personal data are transmitted to the following persons by Kayıtes Mühendislik within the scope of Article 8 and Article 9 of the KVKK, provided that they are limited to the purposes listed above:

• Business partners and affiliates of Kayıtes Mühendislik,

• Persons and institutions permitted by the Turkish Commercial Code, Turkish Code of Obligations, Labor Law and other relevant laws and regulations,

• With the institutions, organizations, persons and companies ordered by administrative and legal authorities and special regulations to the legally authorized institutions and organizations;

• If it is transferred, it will be transferred to the natural and legal persons that we receive products and services from which we cooperate, by asking if the domestic institution and / or enterprise to be transferred also has KVKK compatibility and data security.

4) People's Gathering Management and Legal Reason

In order to carry out our activities, your personal data is collected by our company based on different channels (verbal, written, electronic environment) to comply with the legislation and company policies, execute contracts, clearly foresee the law, and legitimate interests of the company. Your personal data may be processed and transferred for the purposes specified in this Disclosure Text within the scope of the personal data processing conditions and purposes specified in articles 5 and 6 of KVKK, in accordance with the basic principles stipulated by KVKK.

5) Time to Keep Personal Data

Your personal data is maintained for the period required by the relevant legislation or for the purpose for which they are processed. The following criteria are taken into account when determining the maximum duration:

• Related data categories of processing purposes within the scope of the data responsible operates the industry adopted the necessary general practice time, relevant data category, which requires the processing of personal data is located and the time will continue the legal relationship which is established with the contact,

• The period during which the legitimate interest to be obtained by the data controller will be valid in accordance with the law and the rules of honesty, depending on the purpose of the relevant data category.

• The period during which the risks, costs and responsibilities to be maintained due to the storage of the relevant data category depending on the purpose of processing will continue legally

• Whether the maximum period to be determined is suitable for keeping the relevant data category accurate and up-to-date, if necessary,

• The period in which the data controller has to store personal data in the relevant data category due to his legal obligation,

• The timeout period set by the data controller to assert a right based on personal data in the relevant data category.

6) Rights of the Personal Data Owner in Article 11 of Law No. 6698

As personal data holders, Kayi-Tes Mühendislik Taah. Forward. Elect. And Daya. Cons. Goods. Singing. Tic. Ltd. Sti. Our company will finalize the request in the shortest time and at the latest within thirty days, depending on the nature of the request, if you forward it to the Registers Engineering through the methods set out in the Protection and Processing of Personal Data Policy. In this context, personal data owners;

• Learning whether personal data is processed,

• Requesting information regarding personal data if it has been processed,

• Learning the purpose of processing personal data and whether it is used in accordance with its purpose,

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

• Requesting correction of personal data in case of missing or incorrect processing and requesting notification of the transaction made within this scope to third parties to whom personal data is transferred,

• Requesting the deletion or destruction of personal data in case the reasons requiring its processing disappear even if it has been processed in accordance with the provisions of KVKK and other relevant laws, and requesting the notification of the transaction made within this scope to third parties to whom the personal data has been transferred,

• To object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems,

• In the event that the personal data is damaged due to the illegal processing of the data, they have the right to demand the removal of the damage.

In case the application is rejected, the answer is insufficient or the application is not answered in due time; the person concerned may complain to the Personal Data Protection Board within thirty days, and anyway within sixty days from the date of application. Pursuant to Article 13 of the Law, the applicant cannot apply for a complaint before the application is exhausted. Within the scope of international legislation, apart from the above-mentioned rights of the person concerned; There is also the right to request restrictions on the processing of personal data and to withdraw consent to the processing or transmission of personal data.

As Kayıtes Engineering, we attach importance to the security of your Personal Data. As Belgees Engineering, we are sensitive about protecting and processing all kinds of personal data belonging to people who benefit from our products and services and all persons related to Kayesh Engineering in accordance with the Law No. 6698 on Protection of Personal Data (KVK Law). We process your Personal Data within the limits set out in the policy text below and within the limits stipulated in the legislation.

1. OBJECTIVE, SCOPE AND DEFINITIONS

1.1.AMAÇ

This Personal Data Processing and Protection Policy, Kayı-Tes Mühendislik Taah. Forward. Elect. And Daya. Cons. Goods. Singing. Tic. Ltd. Sti. It is the main policy text that regulates the principles to be followed while fulfilling its obligations brought by the Law No. 6698 on Protection of Personal Data (KVKK) and other relevant legislation.

I 1.2.KAPSA

The policy includes Personal Data, which is collected, processed or shared with Kayis Engineering during its activities, including Kayis Engineering employees, customers, website visitors; Kayıtes Engineering is binding before its departments and employees.

1.3.TANIM on

Personal Data means any and all information directly or indirectly which enables the company to identify the identity of a Contact Person, individually or by combining it with other information in the hands of or control by Kayes Engineering.

Personal Qualified Personal Data includes information about people's race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, disguise and outfit, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and means data on genetic information.

Personal Health Data means any health information related to a specific or identifiable natural person.

Data Processing means any transaction performed on Personal Data, including collecting, saving, storing, maintaining, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing its use.

Contact Person Personal Data means all natural persons processed by Kayıtes Mühendislik or on behalf of.

Open Consent means approval by a free will, after being informed of a particular subject.

Destruction means deletion or destruction of Personal Data.

Anonymized Data means that the Personal Data cannot be associated with any identifiable or identifiable natural person under any circumstances, even after the data controller or any other person who will make the Person identifiable use all reasonable and ordinary methods.

Data Processor means the natural or legal person who processes Personal Data on his behalf, based on the authority granted by the data controller. In each concrete case, who is the Data Processor should be evaluated separately.

Data Responsible means the natural or legal person who determines the purposes and means of processing Personal Data and is responsible for the establishment and management of the data recording system. The data controller may be Kayis Engineering, or from time to time , may be a third person on behalf of Kayis Engineering or authorized by Kayes Engineering. In each concrete case, who is the data controller should be evaluated separately.

Board means the Personal Data Protection Board.

2. PERSONAL DATA PROCESSING

they 2.1.İLK

Kayıtes Mühendislik acts in accordance with the following principles in every activity it performs regarding personal data collection and processing:

2.1.1 Compliance with Laws and Integrity Rules

Personal Data will be collected and processed in accordance with law and integrity rules.

2.1.2. Accuracy and Actuality When Necessary

It is required for the purpose of collecting and processing Personal Data:

• Take reasonable measures to keep Personal Data complete, accurate and up-to-date,

• If the Persons provide information about changes related to Personal Data, they will update Personal Data and take reasonable measures to update, correct or delete missing or incorrect data.

2.1.3. Having Clarity, Clarity, and Legitimate Purposes

Kayes Engineering is committed to collecting and processing Personal Data to the extent necessary and linked to the business purpose in its collection. Except where legally permitted or required, Personal Data will not be collected and / or processed in advance for purposes expected to emerge in the future. Except when the processing of Personal Data is legally required or possible, it will only be processed for legitimate purposes, which are clearly stated prior to the collection of the data, and in accordance with the Open Consent, where it is to be received or required.

Prior to any data collection activity by Kayis Engineering, in cases where the express consent of the relevant person is required in accordance with the data collection method and this Policy, online environments where consent is obtained or consent will be used.

Where Personal Data is processed by third parties who process Data on behalf of Kayıtes Mühendislik, third parties are required to commit in writing or contract in advance, in compliance with the obligations contained in this Policy.

2.1.4.Protection with the Period Required by the Purpose of the Predicted or Processed in Related Legislation

Personal Data are stored for maximum storage, in accordance with their processing purposes; this period may be held for a longer period in order to comply with the obligations determined in the legislation or to protect legitimate business interests. After the legal, administrative or commercial required periods have expired, the Personal Data not needed will be deleted, anonymized or destroyed in accordance with the legislation and the Registration and Disposal Policy of the Registered Engineering Personal Data.

With regard to Personal Data contained in the physical and electronic data recording systems, Kayıtes Engineering is responsible for the destruction of all data in accordance with the legislation, if the purpose of collecting this data is eliminated and the legal retention periods expire.

All transactions regarding the deletion, destruction and anonymization of Personal Data will be recorded and these records will be kept for at least three (3) years, excluding other legal obligations.

3. DATA COLLECTION AND PROCESSING

Kayıtes Engineering will collect and process Personal Data in accordance with the legal conditions below.

3.1 Approval

The Relevant Person will be processed after collecting and / or processing his Personal Data in accordance with the legislation and Policy and after giving Open Consent in writing or electronically. In the case of Personal Health Data processing, Open Consent is definitely taken in writing. Open Consent declarations received will be documented and stored in physical or electronic environment. Personal Data can be processed without the consent of the Relevant Person in the presence of the following cases listed in KVKK:

• Clearly prescribed by law.

• A person who is unable to explain his consent due to actual impossibility or whose consent is not legally valid, is compulsory to protect himself or someone else's life or bodily integrity.

• The processing of Personal Data belonging to the parties to the contract is necessary, provided that it is directly related to the establishment or performance of a contract.

• It is mandatory for the Data Controller to fulfill its legal obligation.

• The person concerned has been made public by himself.

• Data Processing is mandatory for the establishment, exercise, or protection of a right.

• Data processing for the legitimate interests of the Data Officer is mandatory, without prejudice to the fundamental rights and freedoms of the Person concerned.

3.2 Special Qualified Personal Data

Special Qualified Personal Data may only be processed in cases where it is explicitly prescribed by law, with the exception of the Persons' express Consent or the data relating to health and sexual life. Personal Data related to health and sexual life can only be processed by people under the obligation to keep secrets for the purpose of protecting public health, preventive medicine, conducting medical diagnosis, treatment and care services, planning and managing health services and financing without seeking the express consent of the concerned. The processing of Special Qualified Personal Data complies with the decisions of the Personal Data Protection Board.

4. TRANSFER OF PERSONAL DATA

Personal Data only in the presence of the instances does not seek the consent of the Open or Open Person's consent to the transfer of data can be transferred to third parties in Turkey.

In transferring Personal Data to third parties abroad;

The foreign country to which Personal Data is transferred provides adequate protection; or In the absence of adequate protection in the relevant foreign country, Kayıtes Engineering and the data responsible in the relevant foreign country must have written commitments in writing that sufficient protection has been provided and the Board must have permission and conditions.

5. RIGHTS AND OBLIGATIONS

5.1 Rights of the Person

Real persons whose Personal Data are collected or processed by Kayıtes Mühendislik have the right to apply to the Data Supervisor in accordance with KVKK. By using the right of application, the Person concerned may refer to the below-mentioned requests in writing or by e-mail, according to the contact information provided in the last part of this Policy, to Kayıtes Engineering or its representatives:

• Learning whether Personal Data is processed,

• If Personal Data is processed, obtaining information about it,

• Learning the purpose of processing Personal Data and whether it is used in accordance with its purpose,

• To know the third parties to whom Personal Data are transferred in Turkey or abroad,

• In case personal data are incomplete or incorrectly processed, correction of these,

• Deletion or destruction of Personal Data under the law,

• To object to the emergence of a result against the individual by analyzing the processed Personal Data exclusively through automated systems,

• Loss of damage if Personal Data is damaged due to unlawful processing.

5.2 Responsibilities of the Data Controller

5.2.1 Lighting Obligation

Kayes Engineering will inform the Persons with an informative, clear and understandable notification about the process of processing Personal Data and the purposes of Data Processing during the acquisition of Personal Data; ensure that they are informed about their rights to their Personal Data and that they have reasonable access to their Personal Data processed by Kayıtes Mühendislik.

Notification to the relevant Persons includes, at a minimum, the following elements:

• The identity of the Data Controller or its representative, if any,

• Purpose, method and legal reason of Data Processing,

• To whom and for what purpose the Personal Data can be transferred,

• Legal rights of the Persons mentioned under article 5.1 above.

5.2.2 Data Security Obligations

Kayıtes Engineering within the scope determined in the relevant legislation,

• Personal Data not being processed illegally

• Personal Data not being illegally accessed

• Takes necessary technical and administrative measures to ensure the appropriate level of security to ensure that Personal Data is protected against misuse, disclosure, alteration and destruction.

1. Kayıtes Engineering performs or makes necessary inspections to ensure Personal Data security.

2. The Personal Data that it collects and / or processes within the framework of Kayıtes Engineering activities (i) keeps it confidential in accordance with KVKK provisions and Policy, (ii) does not use it for purposes other than processing, (iii) any Data Processing activities of its employees who are not involved in the processing of Personal Data due to their duties prohibitions, and (iv) allow employees to have access to Personal Data to the extent that they are within the limits of their duties. This obligation continues after leaving office.

3. In the event that the Processed Personal Data is obtained by others in an illegal way, Kayıtes Mühendislik shall notify this situation to the concerned and the Board as soon as possible.

5.2.3 Registration at the Data Controllers Registry

According to the By-Law on Registration of the Registrar of Engineering Data Officers, the Personal Data Protection Authority will fulfill the relevant obligation to be fulfilled in accordance with the Regulation by registering in the Data Controllers Registry. In this context, the following information will be presented to the public:

• The name and address of the Data Controller, the representative of the Data Controller and the contact person, if any, and the REM address, if any,

• For what purposes Personal Data can be processed,

• Personal Data subject groups and groups and data categories belonging to these people,

• Recipient and recipient groups to which Personal Data can be transferred,

• Personal Data foreseen to be transferred to foreign countries,

• The registration date and the date when registration ends,

• Measures taken regarding Personal Data security,

• The maximum time required for the purpose for which the Personal Data is processed.

6. CHANGES TO BE MADE IN POLICY

Provisions in this Policy may be changed, if necessary, by publishing on their websites in accordance with the provisions of the legislation. If any of these provisions change, the related changes take effect on the date of the change.

Kayı-Tes Mühendislik Ltd.Şti.

e-mail: info@kayites.com