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PERSONAL DATA PROTECTION AND PROCESSING POLICY

INTRODUCTION

The protection of personal data is among the core values and policies that Turkbox Technology and Software Systems Ltd. Co. (briefly “Turkbox”) attaches importance to at the corporate level.

This Personal Data Protection and Processing Policy (briefly the “Policy”) sets out the principles to be adopted and taken into consideration in practice regarding the processing and protection of personal data in accordance with the Turkish Personal Data Protection Law No. 6698 (“PDPL”) and other relevant legislation.

With this Policy, TURKBOX undertakes to act in accordance with this Policy and the procedures to be implemented accordingly in order to ensure that all kinds of personal data belonging to all related persons are processed and stored in compliance with the Personal Data Protection Law No. 6698.

PURPOSE OF THE POLICY

The purpose of this Policy is to determine the principles regarding the methods and processes for the protection of personal data in order to comply with the PDPL.

Within this scope, TURKBOX shall make the necessary arrangements to ensure compliance with the Policy within its organization, ensure the continuity of compliance with the Policy by operating internal audit mechanisms periodically, and take all necessary administrative and technical measures regarding the processing and protection of personal data.

SCOPE OF THE POLICY

This Policy covers personal data collected, processed, or shared with TURKBOX during its activities, including employees, customers, website visitors, and mobile application users of TURKBOX. This Policy applies to such activities and may be amended with the approval of the board of directors if required by PDPL regulations or deemed necessary by TURKBOX’s data controller representative or Committee.

DEFINITIONS

Personal Data means any information that enables TURKBOX to identify the identity of a Data Subject, directly or indirectly, either alone or by combining it with other information held or controlled by TURKBOX.

Special Categories of Personal Data mean data relating to individuals’ race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.

Personal Health Data means any information relating to the health of an identified or identifiable natural person.

Data Processing means any operation performed on personal data, including collection, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, acquisition, making available, classification, or preventing its use.

Data Subject means all natural persons whose personal data are processed by or on behalf of TURKBOX.

Explicit Consent means consent given freely, on a specific subject, after being informed.

Disposal means the deletion or destruction of personal data.

Anonymized Data means data rendered impossible to associate with an identified or identifiable natural person, even when all reasonable and customary methods are used by the data controller or any third party.

Data Processor means the natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller.

Data Controller means the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

Board means the Personal Data Protection Board.

AMENDMENTS TO THE POLICY AND EFFECTIVE DATE

The provisions of this Policy may be amended by TURKBOX, when deemed necessary, by publishing them on its website in accordance with the legislation.

This Policy entered into force upon its publication in January 2020.