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AS 2023 TECHNOLOGY AND FOREIGN TRADE LTD. CO.

PERSONAL DATA PROTECTION INFORMATION NOTICE**

As AS 2023 Technology and Foreign Trade Ltd. Co., we have prepared this Information Notice to inform you regarding the processing, storage, and transfer of your personal data within the scope of the Personal Data Protection Law No. 6698 (KVKK) and the relevant legislation.

Which Personal Data Are Processed?

Your personal data categories listed below may be processed depending on your relationship with our company and the nature of the transaction:

Identity Information

Data Subject Groups:
Employee Candidate, Employee, Shareholder/Partner, Intern, Parent/Guardian/Representative

Purposes of Processing:

Execution of emergency management processes
Execution of information security processes
Execution of employee candidate / intern / student selection and placement processes
Execution of application processes of employee candidates
Execution of employee satisfaction and engagement processes
Fulfillment of contractual and legal obligations for employees
Execution of side benefits and vested rights processes
Execution of audit/ethical activities
Execution of training activities
Execution of access authorization processes
Ensuring compliance with legislation
Execution of finance and accounting processes
Execution of loyalty processes to company/products/services
Ensuring physical space security
Execution of assignment processes
Execution and follow-up of legal affairs
Execution of internal audit/investigation/intelligence activities
Execution of communication activities
Planning of human resources processes
Execution and supervision of business activities
Execution of occupational health and safety processes
Evaluation of improvement suggestions
Ensuring business continuity
Execution of logistics processes
Execution of customer relationship management
Execution of customer satisfaction processes
Organization and event management
Execution of performance evaluation processes
Execution of wage policy
Work/residence permit procedures for foreign employees
Execution of talent/career development processes
Providing information to authorized individuals, institutions, and organizations
Execution of management activities
Creation and tracking of visitor records

Contact Information

Data Subject Groups:
Employee Candidate, Employee, Shareholder/Partner, Supplier Employee, Supplier Representative, Customer, Parent/Guardian/Representative, Visitor

Purposes of Processing:
(Identical to the relevant list above including communication, marketing, event management, customer relations, etc.)

Location Data

Data Subject Groups:
Employee, Shareholder/Partner

Purposes of Processing:

Execution and supervision of business activities
Execution of occupational health and safety processes
Execution of management activities

Personnel Data

Data Subject Groups:
Employee Candidate, Employee, Shareholder/Partner, Intern

Purposes of Processing:
(As listed above: HR planning, performance evaluation, employment obligations, audits, OHS, finance, etc.)

Legal Transaction Data

Data Subject Groups:
Employee, Shareholder/Partner

Purposes of Processing:

Fulfillment of legal and contractual obligations
Execution of ethical and audit activities
Execution of assignment processes
Execution and follow-up of legal affairs
Internal audit/investigation/intelligence processes
Ensuring operational security
Execution of management processes

Physical Space Security Data

Data Subject Groups:
Employee Candidate, Employee, Shareholder/Partner, Potential Customer, Supplier Employee, Supplier Representative, Customer, Visitor

Purposes of Processing:

Ensuring physical space security
Execution and supervision of business processes
Execution of occupational health and safety processes
Creation and tracking of visitor records

Financial Data

Data Subject Groups:
Employee, Shareholder/Partner

Purposes of Processing:
(Including purchasing, sales, after-sales support, finance, accounting, marketing, budgeting, wage policy, agreements, strategic planning.)

Professional Experience Data

Data Subject Groups:
Employee Candidate, Employee, Intern

Purposes of Processing:
(Recruitment, evaluations, HR processes, training, OHS, audits, performance, talent management, etc.)

Health Information

Data Subject Groups:
Employee Candidate, Employee, Shareholder/Partner, Intern

Purposes of Processing:

Emergency management
Recruitment and placement processes
Application evaluations
Employee satisfaction processes
Fulfillment of legal obligations
Execution of side benefits and vested rights
Finance and accounting
Assignment processes
HR planning
OHS processes
Evaluation of improvement suggestions
Ensuring business continuity

Criminal Conviction and Security Measures Data

Data Subject Groups:
Employee Candidate, Employee, Shareholder/Partner, Intern

Purposes of Processing:

Recruitment processes
Application evaluations
Employee satisfaction processes
Fulfillment of contractual and legal obligations
Ensuring compliance with legislation
Internal audit/investigation/intelligence activities
HR planning
Execution and supervision of business activities

To Whom and For What Purpose Your Personal Data May Be Transferred

Your personal data may be transferred to:

Authorized Public Institutions and Organizations

To fulfill legal obligations
To comply with regulatory processes
For legal proceedings
For employee-related legal requirements

Real Persons and Private Legal Entities

For business operations
For communication processes
For occupational health and safety processes
For logistics processes
For handling requests and complaints
For event and organization management
For purchasing and sales transactions

Affiliates and Subsidiaries

For information security
For business operations and audits
For HR planning
For archiving and storage processes
For finance and accounting
For contract management

Retention Period of Personal Data

Your personal data is stored:

For the duration required by law or related regulations, if such a period exists,
If no period is specified, for a reasonable time in connection with the purpose of processing and in a limited and proportionate manner.

Your Rights Regarding Your Personal Data

As a data subject, you have the right to:

Learn whether your personal data is processed,
Request information regarding processing,
Learn the purpose of processing and whether it is used appropriately,
Learn the third parties to whom data is transferred domestically or internationally,
Request correction of incomplete or inaccurate data,
Request deletion or destruction of personal data within the framework of the law,
Request notification of correction or deletion to third parties,
Object to processing through automated systems that may produce unfavorable results,
Request compensation for damages arising from unlawful processing.

How Can You Exercise Your Rights?

You may submit your requests regarding your personal data:

By personally applying to AS 2023 Technology and Foreign Trade Ltd. Co. with a valid ID,
By sending your petition signed with your electronic or mobile signature to as2023teknoloji@hs06.kep.tr via your registered e-mail address (KEP).

Application Requirements

Applications must include:

Name, surname, signature (if written),
TR ID number (or passport/ID number for foreigners),
Residential or workplace address for notification,
E-mail address, phone number, and fax number (if provided),
Clear and understandable information regarding the request.

If acting on behalf of someone else, a notarized power of attorney must be provided.

Response Time

Your requests will be processed and responded to within 30 days from the date they are received by our company.