In accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), your personal data will be processed by our Company, in its capacity as Data Controller, for business-related purposes within the scope outlined below, including being used, recorded, stored, updated, transferred, and/or classified. In this regard, our Company, in compliance with the laws and regulations issued to protect personal data and the fundamental rights and freedoms of individuals, particularly the privacy of private life, takes all necessary technical and administrative measures to prevent unlawful processing and access to your personal data and to ensure its secure storage.

The target audience of this text includes all individuals whose personal data are processed by our Company, except for employees of our Company or job applicants who have applied to our Company.

The personal data processed by us as the data controller include, but are not limited to, the following:

Name, surname, Turkish ID number, address, phone number, email address, signature, physical space/security camera footage, call center/service quality voice recordings, bank account number, cookie records

Purposes and legal reasons for processing personal data: The personal data you share with us may be processed by our Company for the purposes of:

• Conducting necessary activities to ensure that you and/or the institutions and organizations you represent benefit from the products and services provided by our Company, including but not limited to determining and implementing our Company’s commercial and business strategies, conducting marketing activities, and carrying out business development and planning activities,
• Managing the administrative operations related to communication conducted by our Company,
• Ensuring the physical security and control of our Company’s premises,
• Establishing business partner/customer/supplier (authorized representatives or employees) relationships,
• Ensuring compliance with contractual obligations and financial settlements related to products and services provided together with our business partners, suppliers, or other third parties,
• Managing the human resources policies of our Company,
• Contacting our call center or using our website

and/or

• Facilitating participation in training sessions, seminars, or events organized by our Company.

Collection and storage methods of personal data: The personal data you share with our Company may be collected verbally, in writing, or electronically through offices, branches, call centers, websites, social media platforms, mobile applications, and similar channels, either automatically or non-automatically. Your personal data will be stored in electronic and/or physical environments. To prevent unauthorized access, manipulation, loss, or damage to the personal data collected and stored by our Company, necessary business processes and technical security infrastructure developments are implemented.

Your personal data will be processed and stored with all necessary information security measures taken and will be retained for the legally prescribed retention period or, if such a period is not specified, for the duration required for the purpose of processing. Once this period expires, your personal data will be removed from our data flows using deletion, destruction, or anonymization methods.

Transfer of personal data:

Your personal data may be transferred in accordance with the laws and other relevant regulations and for the purposes described:

• To Türk Telekomünikasyon A.Ş. and its group companies,
• To companies and representatives authorized by us to act on our behalf,
• To regulatory and supervisory bodies, public institutions, or organizations that have the legal authority to request your personal data under applicable laws,
• To business partners, suppliers, contractors, banks, credit risk and financial institutions, and other individuals or legal entities,
• To tax and similar advisors, individuals involved in legal proceedings, institutions, organizations, and auditors, as well as third parties from whom we receive consultancy services,

and to authorized individuals and institutions, including third parties, both domestically and internationally, for the purposes specified above.

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

• Learn whether your personal data is being processed,
• Request information if your personal data has been processed,
• Learn the purpose of processing and whether it is being used in accordance with its purpose,
• Know the third parties to whom your personal data is transferred domestically or internationally,
• Request correction of incomplete or inaccurate data,
• Request deletion or destruction of personal data under the conditions stipulated in Article 7 of the KVKK,
• Request notification to third parties to whom your personal data has been transferred of the actions taken under (e) and (f),
• Object to the processing of your data if solely analyzed by automated systems leading to an unfavorable result,
• Claim compensation if you suffer damage due to the unlawful processing of your personal data.

In accordance with Article 13(1) of the KVKK, you may submit your request to exercise your above-mentioned rights to our Company in writing or via other methods specified by the Personal Data Protection Board.

To exercise your rights mentioned above, you can submit your request along with necessary identification details in person, through a notary, or via other methods specified by the Personal Data Protection Board, or by sending an email with a secure electronic signature to topsystemdrive.com.tr.