PRIVACY DISCLOSURE STATEMENT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

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In accordance with the provisions of the Personal Data Protection Law No. 6698 (“KVKK”), any information that makes your identity specific or identifiable, including your special categories of personal data, is processed as "Personal Data" by ÇÖZÜM ÜNLÜER BAĞIMSIZ DENETİM VE YEMİNLİ MALİ MÜŞAVİRLİK A.Ş. in its capacity as the Data Controller, within the scope detailed below.

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The term “processing of your personal data” is a legal concept, and pursuant to Law No. 6698, it refers to any operation performed upon personal data, such as collection, recording, storage, preservation, alteration, reorganization, disclosure, transfer, takeover, making available, classification, or prevention of use.

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Your personal data shared with our Company in your capacity as a subscriber, customer, supplier, consumer, physical or online visitor, business partner, or employee (including apprentices and interns) may be processed in accordance with the KVKK, proportionally and in connection with our operational and service purposes. It may be transferred to third parties domestically or abroad, stored, used for profiling or other commercial purposes related to our business, and classified.

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As ÇÖZÜM ÜNLÜER BAĞIMSIZ DENETİM VE YEMİNLİ MALİ MÜŞAVİRLİK A.Ş., we attach the utmost importance to the security of your personal data. In all the products and services we offer you, we take the highest possible level of security measures to protect your privacy during the lawful collection, storage, processing, and, when necessary, sharing of your personal data.

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Our purpose in publishing this information/disclosure text is to inform you in the clearest possible manner, in line with your satisfaction, about the methods of collecting your personal data, the purposes of processing, the legal grounds for processing, and your legal rights.

Information and concepts that are of vital importance regarding the protection and processing of personal data are provided below, aiming to ensure your complete enlightenment with these concepts.

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a) Who is the Data Controller?

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Pursuant to the Personal Data Protection Law No. 6698 (Law No. 6698), the data controller is our Company, ÇÖZÜM ÜNLÜER BAĞIMSIZ DENETİM VE YEMİNLİ MALİ MÜŞAVİRLİK A.Ş. Your personal data may be collected and processed by ÇÖZÜM ÜNLÜER BAĞIMSIZ DENETİM VE YEMİNLİ MALİ MÜŞAVİRLİK A.Ş., the data controller, within the scope explained below.

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b) Purposes for Which Your Personal Data Is/Will Be Processed

• Your personal data will be processed within the framework of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698 for the purposes of fulfilling the requirements of your contracts, carrying out necessary evaluations for the services provided, ensuring compliance with national and international legislation—primarily tax legislation and Social Security Institution legislation—complying with risk monitoring and information disclosure obligations, fulfilling information sharing, reporting, and disclosure obligations prescribed by authorities, complying with information and document retention obligations arising from legislation, preventing fraud, ensuring security, executing planning and statistical activities required by our company, determining and implementing our company's commercial and business strategies, managing our finance, communication, market research, and purchasing operations, sustaining internal system and application management operations, managing our legal processes, executing social responsibility projects, and providing you with uninterrupted, better, and more reliable service.

• In addition to the above-mentioned points, your personal data may be processed to communicate with you regarding the products and services you receive/will receive in order to develop and present customized products and services, and, provided that you have given your consent, to use them in promotional, product/service offer, marketing, and campaign activities, to develop suitable services and products, to conduct customer satisfaction studies, and to carry out current or new product studies, market research, and target customer group determination for our company.

• Within the scope of contracts concluded or activities carried out jointly with third-party real or legal persons who are in a business relationship with our Company, your personal data may be processed to fulfill our company's legal and commercial obligations arising from contracts, establish and protect rights, execute commercial and legal evaluation processes, conduct legal and commercial risk analyses, and manage financial affairs.

c) To Whom and for What Purpose the Processed Personal Data May Be Transferred

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Your personal data may be transferred, within the limits of the relevant legislation and restricted to the fulfillment of the purposes mentioned above and the obligations brought by the legislation, to authorities such as the T.R. Ministry of Finance Revenue Administration and the Social Security Institution, legally authorized public institutions such as ministries and judicial authorities, support service organizations and other contracted entities from which our Company receives services that are complementary to or an extension of our operations, consultants, organizations, financial institutions, audit or independent audit companies, and banks with which the Company cooperates in cases permitted by law, within the framework of the personal data processing conditions and purposes specified in Article 8 of Law No. 6698 regarding the transfer of personal data and Article 9 regarding the transfer of personal data abroad.

ç) Method and Legal Basis for Personal Data Collection

Your personal data is collected through channels through which our company, or institutions, organizations, and individuals authorized to represent our company, communicate or may communicate with you in the future, such as our Company's website, mobile or digital applications, social media, customer interviews, SMS text messages, written/digital applications made to our company and other websites, direct sales teams, and support service organizations. These data are collected within the scope and limits permitted by the relevant legislation and concluded contracts, by obtaining your consent where legally required, and occasionally by accessing the databases of various institutions and organizations.

Your personal data collected through these methods can be processed and transferred for the purposes specified in this Disclosure Statement within the scope of the personal data processing conditions and purposes set forth in Articles 5 and 6 of Law No. 6698.

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d) Your Rights Enumerated in Article 11 of Law No. 6698 as a Personal Data Subject

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According to the regulation in Article 11 of Law No. 6698, your rights enumerated in Article 11 are as follows:

• To learn whether your personal data has been processed,

• To request information if your personal data has been processed,

• To learn the purpose of the processing of your personal data and whether they are used in accordance with their purpose,

• To know the third parties to whom your personal data has been transferred domestically or abroad,

• To request rectification of your personal data if it has been processed incompletely or inaccurately, and to request that the operation performed within this scope be notified to the third parties to whom your personal data has been transferred,

• To request the erasure or destruction of your personal data in the event that the reasons requiring its processing cease to exist, despite having been processed in accordance with Law No. 6698 and other relevant legal provisions, and to request that the operation performed within this scope be notified to the third parties to whom your personal data has been transferred,

• To object to the occurrence of a result against you by means of analyzing your processed data exclusively through automated systems,

• To request compensation for damages in case you incur damages due to the unlawful processing of your personal data.

If you submit your requests regarding your rights to our company using the methods specified below, our company will conclude the request free of charge as soon as possible and within thirty days at the latest, depending on its nature.

 

However, if the transaction incurs an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be charged by our company. In this context, pursuant to Paragraph 1 of Article 13 of Law No. 6698, you may submit your request regarding the exercise of your above-mentioned rights to our company in writing and through other methods to be determined by the Personal Data Protection Board. Within this framework, the channels and procedures through which you will submit your application in writing to our company for applications to be made within the scope of Article 11 of Law No. 6698 are explained below. In order to exercise your above-mentioned rights, such requests regarding Personal Data must be submitted in writing using the following communication channels, along with information that will enable the identification of the relevant data subjects.

 

• Email (KEP) Address: cozumdenetim@hs01.kep.tr

• Postal Address: 1476 Sok. No:2 K:7 D:9 Aksoy Residence Alsancak-İzmir

Submitted for your information.