GENERAL DISCLOSURE TEXT

NET BORU SANAYI VE DIŞ TICARET KOLLEKTIF ŞIRKETI BORA ŞAMAN VE ORTAĞI GENERAL DISCLOSURE TEXT ON PERSONAL DATA PROTECTION (the” General Disclosure Text”)

We, NET BORU SANAYI VE DIŞ TICARET KOLLEKTIF ŞIRKETI BORA ŞAMAN VE ORTAĞI, pay strict attention to the security of your personal data. Having this consciousness, we attach great importance in processing and protecting of all kinds of personal data belonging to persons related to our Company (including any third party who utilizes our Company’s services) in accordance with the Personal Data Protection Law No. 6698 (“the PDP Law”). With full comprehension of our responsibility and acting in the capacity of “Data Controller” as defined in the PDP Law, we processes your personal data as set forth here below and within the framework of the limitations permitted by the legislation.

Definitions

The following terms referred herein this General Disclosure Text have the following meanings:
Personal Data: means all kinds of information belonging to identified or identifiable natural persons;
Personal Data Protection Law (“the PDP Law”): means the Personal Data Protection Law No. 6698 entered into force by its publication in the Official Gazette dated 7 April 2016.
Our Company: NET BORU SANAYI VE DIŞ TICARET KOLLEKTIF ŞIRKETI BORA ŞAMAN VE ORTAĞI;
Data Processor: means any natural person or legal entity who processes Personal Data by the authority vested in it by the Data Controller; and
Data Controller: means any natural person or legal entity who determines the purposes and means of Personal Data processing, and who is responsible for the setup and management of the data recording system.

1) Data Controller and Its Representative

In accordance with the PDP Law, your personal data may be processed by our Company, as the Data Controller, within the framework specified here below:

2) Collection and Processing of Personal Data, and Processing Purposes

Your personal data shall be processed in accordance with the personal data processing requirements and purposes set forth in Articles 5 and 6 of the PDP Law in order to enable our business units to carry out the required operational activities and to carry out the participant and customer transactions for the purpose of accomplishment of our Company’s activities in accordance with the relevant legislation and the procedures of our Company, and in order for planning and execution of our Company’s human resources policies and processes in accordance with the relevant legislation and the procedures of our Company.

The data referred herein are kept/protected for 5 years, unless otherwise stipulated in the relevant law.

3) To Whom and for Which Purposes May the Processed Personal Data be Transferred

Your personal data collected may be transferred—in accordance with the personal data processing requirements and purposes set forth in Articles 8 and 9 of the PDP Law— to the officials, domestic business partners, and suppliers of our Company and/or to the public/private institutions and organizations authorized by law in order to enable our business units to carry out the required operational activities and to carry out Participant’s registration and other transactions, and in order for rendering of consultancy services for the purpose of accomplishment of our Company’s activities in accordance with the relevant legislation and the procedures of our Company, and in order for planning and performance of our Company’s human resources policies and processes in accordance with the relevant legislation and the procedures of our Company.

4) Methods and Legal Reasons of Collecting Personal Data

Depending on your relation with our Company, your personal data may be collected orally, in written, or electronically, by either automatic or non-automatic methods, by means of our Company’s units, offices, web site, social media channels, mobile applications, or similar means. 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 for the purposes specified in the above articles (2) and (3) of this General Disclosure Text. Furthermore, your personal data may be processed when you use our web site to utilize the services rendered by our Company, when you visit our Company or our web site, and/or when you attend the trainings, seminars, or organisations held by our Company.

5) Rights of the Data Subject as Listed in Article 11 of the PDP Law

In the event that you, as Data Subjects, submit to our Company your requests relating to your rights by any method set out herein below, our Company shall conclude your requests free of charge and within thirty days at the latest, considering the nature of your requests. However, in the case that the transaction necessitates an extra cost, the fee in the tariff designated by the Personal Data Protection Committee shall be collected by our Company. In this context, the Data Subjects have right:

• To learn whether any personal data have been/are being processed or not;
• To request information if their personal data have been/are being processed;
• To learn the purpose of personal data processing and whether this data is used for intended purposes;
• To know the third parties to whom the personal data is transferred at home or abroad;
• To request the rectification of the incomplete or inaccurate data processing, if any; and to request that the third parties to whom personal data have been transferred be notified of the actions performed within this scope;
• 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;
• 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; and
• To request compensation for the damage arising from the unlawful processing of personal data.

Pursuant to Article 13(1) of the PDP law, you can deliver to our Company your requests relating to exercise of your abovementioned rights in writing or by other means as set forth by the PDP Law. At this stage, as the Personal Data Protection Committee did not define a certain method, you are required to submit your application to our Company in writing pursuant to the PDP Law. Within this framework, the channels and methods through which you may submit your written applications under Article 11 of the PDP Law are explained hereunder.

In order for you to exercise your abovementioned rights, you may deliver your requests, 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 them to the following email address with secure electronic signature: kvk@netboru.com.

BORA ŞAMAN
CEO


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