DISCLOSURE TEXT

DISCLOSURE TEXT ON PROCESSING OF THE PERSONAL DATA OF THE VISITORS (the “Disclosure Text”)

A) Personal Data Protection and Data Controller

Your personal data may be processed in accordance with the relevant provisions of the Personal Data Protection Law No. 6698 (“the PDP Law”), the regulations of the Personal Data Protection Committee, and other legislations; and pursuant to the relevant legislation, our Company takes all technical and administrative measures to ensure proper security level in order for prevention of illegal processing of your personal data, prevention of illegal access to your personal data, and for protection of your personal data.

Pursuant to the PDP Law and the relevant legislation, NET BORU SANAYI VE DIŞ TICARET KOLLEKTIF ŞIRKETI BORA ŞAMAN VE ORTAĞI (“NET BORU SANAYI” or “the Company”), as the Data Controller, may process your personal data in accordance with the legislation and for the informative and other purposes set forth hereunder. This information and Disclosure Text has been drawn up in accordance with the PDP Law No. 6698.

Security of your personal data is ensured by NET BORU SANAYİ (NET BORU SANAYI VE DIŞ TICARET KOLLEKTIF ŞIRKETI BORA ŞAMAN VE ORTAĞI. All your personal data associated with our Company are processed and protected in accordance with the PDP Law (Personal Data Protection Law No. 6698). The procedures and principles regarding processing of personal data, collected when you visit our www.netboru.com internet address and/or collected by means of our Company’s closed circuit recording systems when you visit our Headquarters, are implemented in accordance with the PDP Law. For detailed information relating to any issue included in this Disclosure Text, please visit ‘Our Policy on Protection and Processing of Personal Data’ page available on our web site at www.netboru.com address.

B) Purpose of Processing Personal Data

Your personal data, provided during registration, providing entrance card, monitoring with security cameras, and monitoring of entrances and exits of the visitors’ vehicles for ensuring the security of our Company, and provided by you to access the internet service provided by our Company to its visitors upon request, may be transferred for management of the access records and fulfilment of our regulatory obligations, provided to be limited to the personal data processing requirements and purposes set forth in Articles 5 and 6 of the PDP Law No. 6698. Pursuant to the requirements and purposes set forth in Articles 5 and 6 of the PDP Law, the personal data collected provide information relating to monitoring of the visitors’ entrance and exit through activities such as monitoring with security cameras, registration, providing entrance card, and identity register. In this regard, the visitors may be required to submit documents such as identity card, driving license, passport, or chamber card, etc. We have the visitors watch a teaser trailer relating to occupational safety, in order to provide awareness on occupational safety related rules applicable in the facility; and subsequently their names, surnames, and signatures are taken in respect of their notification about these occupational safety related rules. Also, at the visitor welcoming point, the visitors are provided with a brochure by which they are notified about the occupational safety and environmental rules; and this brochure involving (the visitor’s personal data such as their Surnames, Company Names, Vehicle Registration Numbers, entrance/exit times, and signature) is kept as a record. Furthermore, if the Visitor would like to access the internet service by using the internet network of NET BORU SANAYI, data is collected for monitoring and ensuring traceability and reliability of such service.

These data are processed in order to ensure the legal, technical and commercial work security of the relevant parties having business relation with NET BORU SANAYI and to ensure the security of the facilities owned by the Company.

C) To Whom And For What Purposes May The Processed Personal Data Be Transferred

Your personal data collected may be transferred to our business partners, shareholders, subsidiaries/ affiliates, or public/private institutions and organizations authorized by law in accordance with the personal data processing requirements and purposes set forth in Articles 8 and 9 of the PDP Law No. 6698, exclusively for achievement of the aforementioned purposes.

D) Methods and Legal Reasons of Collecting Personal Data

Your personal data is collected by our Company based upon the legal grounds set forth in the above articles (B) and (C), through your identity card, license plate, verbal statement, internet access via our Company’s internet network, or through the closed circuit cameras installed in our buildings when you visit our Company or our www.netboru.com internet address. Your personal data so collected may be processed and transferred in accordance with the personal data processing requirements and purposes set forth in Articles 5 and 6 of the PDP Law No. 6698, also for the purposes set forth in the above articles (B) and (C) of this Disclose Text.

E) Your Rights Relating To Processing Of Personal Data

Pursuant to Article 11 of the PDP Law, you have right to apply our Company

a) To learn whether any personal data have been/are being processed or not;
b) To request information if your personal data have been/are being processed;
c) To learn the purpose of personal data processing and whether this data is used for intended purposes;
d) To know the third parties to whom the personal data is transferred at home or abroad;
e) To request the rectification of the incomplete or inaccurate data processing, if any;
f) To request that the third parties to whom personal data have been transferred be notified of the actions performed in case of rectification of such incomplete or inaccurate data processing;
g) To request the deletion or destruction of personal data, if the reasons necessitating personal data processing no longer exist (even if these personal data were processed in accordance with the provisions of the PDP Law and other relevant legislations); and to request that the third parties to whom personal data have been transferred be notified of the actions performed within this scope;
h) To object to the result, if the processed personal data have been analysed exclusively by automatic systems and the result of this analysis is not in data subject’s favour;
i) To request compensation for the damage arising from the unlawful processing of personal data;

The internet use is recorded pursuant to the PDP Law and ISO 27001,
The indoor and outdoor areas of the factory are being monitored and recorded with cameras.

In order for you to exercise your abovementioned rights, you should fill in the form available at www.netboru.com internet address and deliver a signed copy of this form, including information required for verification of your identity and explanations relating to the rights you would like to exercise pursuant to Article 11 of the PDP Law, to the following address by hand (together with your personal identifying documents), through a notary public, or by any other method set forth in the PDP Law: Aydınlı Serbest Bölge Mahallesi Kurşun Cad. No: 9/102 Tuzla/Istanbul, or you may send the electronically signed form to the following email address: kvk@netboru.com. Upon delivery of your PDP Law-related requests through any of the foregoing methods, our Company shall consider and conclude your them within 30 (thirty) days. Although our Company principally does not charge any fee for such requests, we reserve our right to demand fee over the tariff determined by the Personal Data Protection Committee.

BORA ŞAMAN
CEO

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