Protection of Personal Data

PROTECTION OF PERSONAL DATA

KIRAÇA HOLDİNG ANONİM ŞİRKETİ INFORMATIVE TEXT ON PROTECTION OF PERSONAL DATA

We, Kıraça Holding A.Ş. (“Company), show ultimate sensitivity about the security of your personal data. In this context, we attribute great importance to processing and preserving any personal data belonging to all persons affiliated with the Company, including our customers benefiting from our products and services, in accordance with the Law on the Protection of Personal Data (Law on PPD) numbered 6698. With full comprehension of this responsibility, as a “Data Controller”, we process your personal data within the limits imposed by the legislation as explained below:

1. Collection and Processing of Personal Data and Purposes for Processing

Depending on the products, services or business operations provided by our Company, your personal data can be collected verbally, in written or electronically via automatic or non-automatic tools through offices, branch offices, dealers, call centers, websites, social media channels, mobile applications and etc. Your personal data will be collected, processed and updated, as long as you keep benefiting our Company’s products and services.

In addition, your personal data can be processed when you use our call center or website with the intention of benefiting from the Company services; or visit our Company or website; or participate in trainings, seminars, or events organized by our Company.

Your collected personal data will be processed in accordance with the Articles 5 and 6 of the Law on PPD regulating data processing conditions and purposes with a view to: ensuring that our business units carry out the necessary works for you to benefit from our products and services; providing customized products and services according to your discretion, usage habits and needs; assuring legal and commercial security of our Company as well as of the persons in business relationship with our Company (administrative operations relating to communications within the Company, ensuring physical security and supervision at the Company premises, assessment processes for business partners/customers /suppliers – authorized officials or employees- as well as legal compliance process and financial affairs, etc.); determining and implementing commercial and business strategies of our Company; and finally, executing the Human Resources policies of our Company.

2. How and for Which Purposes the Processed Personal Data can be Transferred

Your collected personal data may be transferred to our business partners, suppliers, shareholders, public institutions and private persons authorized by law in accordance with the Articles 8 and 9 of the Law on PPD regulating data processing conditions and purposes with a view to: ensuring that our business units carry out the necessary works for you to benefit from our products and services; providing customized products and services according to your discretion, usage habits and needs; assuring legal and commercial security of our Company as well as of the persons in business relationship with our Company (administrative operations relating to communications within the Company, ensuring physical security and supervision at the Company premises, assessment processes for business partners/customers /suppliers – authorized officials or employees- as well as legal compliance process and financial affairs, etc.); determining and implementing commercial and business strategies of our Company; and finally, executing the Human Resources policies of our Company.

3. Methods and Legal Reason for Collecting Personal Data

Your personal data is collected verbally, in written or electronically so that our Company can provide its products and services within the legal framework for the above stated purposes while completely and properly fulfilling its responsibilities incurring from the relevant contract and law. Your personal data that is collected for this legal reason can be processed and transferred with purposes stated in the Articles (1) and (2) of this text within the scope of the personal data processing conditions and purposes determined in the Articles 5 and 6 of the Law on PPD.

4. Personal Data Holder’s Rights Stated in the Article 11 of the Law on PPD

Provided that the personal data holders submit to our Company their claims relating to their rights by the below-stated means in this Informative Text, our Company will finalize the claim within thirty days at the latest free of charge, depending on the quality of the claim. Yet, in case the Personal Data Protection Board imposes a price, a payment will be collected as per the tariff determined by our Company. Within this scope, personal data holders are entitled:

• To learn whether their personal data is processed,
To demand information in case their data is processed,
• To learn the purpose for processing the data and whether it is used for that purpose,
• To know about the third persons receiving the relevant personal data at home or in foreign countries,
• To claim correction of the personal data, in case it is incompletely or incorrectly processed, and within this scope, to request notification to the third persons to whom the personal data is transferred,
• To demand deletion or disposal of personal data and notify the third persons that have received the data of such an act, in case the reasons for processing the personal data disappear, despite the relevant data has been processed in compliance with the provisions of the Law on PPD and other relevant regulations,
• To object to the results of processed data analyses made exclusively by electronic systems, if they are to the detriment of the personal data holders,
• To claim compensation for the damages, in case any damage occurs due to processing of personal data in defiance of the law.

As per the 1st paragraph of the Article 13 of the Law on PPD, you may submit your claims to our Company in written or by other means determined by the Personal Data Protection Board in order to use your rights stated above. As the Board has not determined any means of communication yet, you need to submit your application to our Company in written as required by the Law on PPD. Within this framework, the channels and methods to deliver your applications in written as defined by the Article 11 of the Law on PPD are explicated below:

In order to use your above-mentioned rights, please send your application including your required credentials as well as explanations for the right you claim to use from among those stated in the Article 11 of the Law on PPD by filling the form in the www.kiraca.com.tr address and by sending signed copy of the document to our address: Acıbadem Cad. Doğancı Sok. No:3 Üsküdar/Acıbadem, together with your credentials by personal delivery or through a notary or via other methods determined in the Law on PPD.

KIRAÇA HOLDİNG A.Ş. POLICY ON PROTECTION OF PERSONAL DATA
APPLICATION FORM