Personal Data Protection Law

As Etex Tekstil ve Kayış San. Tic. Ltd. Şti, we place great importance on the privacy and security of your personal data.

In this context, processing and storing all kinds of personal data belonging to all individuals associated with Etex Tekstil ve Kayış San. Tic. Ltd. Şti, including our customers and business connections benefiting from our products and services, in accordance with the Personal Data Protection Law No. 6698 (“KVKK”), are among our priorities. In light of the "Data Controller" role we bear under KVKK and in awareness of this responsibility, we would like to inform you about the purposes of processing your personal data, the methods and reasons for collecting your data, your rights regarding the processing of your personal data, and the application procedures and principles for exercising these rights as follows.

a. What is Personal Data? Which of your Personal Data do we collect?

Personal data (“Personal Data”) refers to any information that can be associated with you, primarily personal information related to your identity (such as name, surname, Turkish Identification Number, etc.), as well as address and phone information, vehicle and license plate information, family status information, IP address, bank account information, and any other information that can be linked to you. Special Categories of Personal Data (“Special Category Personal Data”) is a specific type of personal data that includes sensitive personal data such as race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and attire, membership of associations, foundations or unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data. The explanations we provide on this page regarding your Personal Data also encompass your Special Category Personal Data.

In this context, as Etex Tekstil ve Kayış San. Tic. Ltd. Şti, we collect Personal Data of our customers, business connections, employees, job applicants, platform (our internet/mobile sites and applications) users, visitors, and authorized personnel and employees of institutions with whom we have subcontractor or similar business relationships, in compliance with KVKK when necessary. We can detail the Personal Data we collect as follows:

• Identity Data: Data related to an individual's identity such as name, surname, Turkish Identification Number, identity photocopy, etc., collected from our customers, business connections, employees, job applicants, platform (internet/mobile sites and applications) users, visitors, and authorized personnel and employees of institutions with whom we have subcontractor or similar business relationships.
• Contact Data: Data that facilitates communication with the individual, such as phone number, address, email address, IP address, collected from our customers, business connections, employees, job applicants, platform (internet/mobile sites and applications) users, visitors, and authorized personnel and employees of institutions with whom we have subcontractor or similar business relationships.
• Family Member Data: Data about the individual's family members and relatives collected from our employees, job applicants, and authorized personnel and employees of institutions with whom we have subcontractor or similar business relationships, in order to comply with relevant legislation and/or to protect the legal and other interests of our Company or the relevant person.
• Financial Data: Data such as salary, wage information, bank account information collected from our employees, job applicants, customers, business connections, and authorized personnel and employees of institutions with whom we have subcontractor or similar business relationships, depending on the legal relationship established with the data subject by our Company.
• Personnel Data: All kinds of personal data that form the basis for the establishment of personnel rights of natural persons in a working relationship with our Company, collected from our employees, job applicants, and employees of institutions with whom we have subcontractor or similar business relationships.
• Physical Site Security Data: Personal data such as security and camera recordings taken at the entry to the physical site and during the stay within the site, collected from our customers, business connections, employees, job applicants, visitors, and authorized personnel and employees of institutions with whom we have subcontractor or similar business relationships.
• Communication and Complaint Management Data: Personal data obtained from our customers, business connections, platform (internet/mobile sites and applications) users, visitors, and authorized personnel and employees of institutions with whom we have subcontractor or similar business relationships during the processes of receiving and evaluating any kind of request or complaint directed towards our Company.
• Special Category Personal Data: Data such as health data, biometric data (voice and video recordings), religion and information about associations and unions to which one belongs, collected from our customers, business connections, employees, job applicants, visitors, and authorized personnel and employees of institutions with whom we have subcontractor or similar business relationships, as specified in Article 6 of KVKK.
• Other Data: Data processed for technical transaction security, purchase information, cookies, and other means, as well as data collected automatically, collected from our customers, business connections, employees, job applicants, platform (internet/mobile sites and applications) users, and authorized personnel and employees of institutions with whom we have subcontractor or similar business relationships.

b. How do we Collect / Process your Personal Data and for What Legal Reasons?

We collect your Personal Data through the following main purposes and methods, and through other channels that may be added in the future, in automatic or non-automatic ways, whether vocal, oral, written, or electronic.

We collect your Personal Data through various channels such as our internet and mobile platforms (our internet/mobile sites and applications), our social media accounts operated on behalf of Etex Tekstil ve Kayış San. Tic. Ltd. Şti across various social media platforms, our call center managed by Etex Tekstil ve Kayış San. Tic. Ltd. Şti, email, short messages (“SMS”) or multimedia messages (“MMS”), and other communication methods. Additionally, within the scope of sales and marketing activities of Etex Tekstil ve Kayış San. Tic. Ltd. Şti, we collect data through agreements signed with you or your authorized company, presented commercial offers, printed and electronic forms, business cards and other documents provided by you during customer visits. We also collect data through third parties such as Etex Tekstil ve Kayış San. Tic. Ltd. Şti’s group companies, business connections, dealers and sales channels, manufacturing companies or firms supplying services/products, and sources such as the Trade Registry, using various methods that may be entirely or partially automatic or non-automatic as part of any data recording system, whether verbally, in writing, or electronically.

We process the Personal Data we collect through the above methods based on one or more of the legal reasons specified below:

• Your explicit consent,
• The provisions of laws and regulations in force in the Republic of Turkey allowing processing,
• When it is necessary to protect your life or physical integrity or that of another person in cases where it is not possible to obtain your consent due to actual impossibility,
• Necessary for the fulfillment of the contract we have concluded with you or your company,
• Necessary for the fulfillment of our legal obligations to process your Personal Data,
• Your Personal Data being made public by you,
• Necessary for the use or protection of our legal or contractual rights as Etex Tekstil ve Kayış San. Tic. Ltd. Şti .,
• Necessary for our legitimate interests in processing your Personal Data, provided that it does not harm your fundamental rights and freedoms.

As Etex Tekstil ve Kayış San. Tic. Ltd. Şti, we preserve all Personal Data we process in accordance with the durations mandated by KVKK and other regulations, and in any case, as long as the above legitimate purposes remain, we maintain all necessary administrative and technical measures to protect the data.

c. For What Purposes Do We Process Your Personal Data?

We process the Personal Data we collect according to their nature for the following general purposes:

1. Fulfillment of the obligations arising from contracts concluded by Etex Tekstil ve Kayış San. Tic. Ltd. Şti, provision, production, sale, delivery, and installation of offered products and services, development of products and services, conducting necessary work and evaluations to benefit you from them, and performing post-sales maintenance and repair operations.
2. Monitoring and fulfilling obligations arising from consumer legislation and responding to consumer applications.
3. Monitoring, evaluating, and providing support services for requests and complaints of relevant individuals such as customers and consumers, managing consumer satisfaction, and conducting planning, statistics, and satisfaction surveys within this scope.
4. Conducting quality assessment and improvement studies to provide better and more reliable products and services and ensure sustainability, and supervising suppliers, subcontractors, and similar business partners.
5. Conducting advertising and marketing activities for the products and services offered by Etex Tekstil ve Kayış San. Tic. Ltd. Şti, promoting, promoting, campaigning, offering, organizing events, providing information about new products and services, and conducting corporate communication activities.
6. Conducting marketing and CRM (Customer Relationship Management) activities.
7. Organizing corporate communication and other events and invitations within this scope, providing information about them, and conducting market research studies.
8. Improving the digital platforms we offer to our customers, consumers, and business connections, extracting statistics such as the number, type, visit frequency, behaviors, geographic locations, and similar data of users to provide efficient and personalized experiences to platform users, offering personalized content, campaigns, and advertisements according to the interests and needs of platform (internet and mobile site and applications) users, and using cookies for this purpose.
9. Ensuring the legal and commercial security of individuals within business relationships with Etex Tekstil ve Kayış San. Tic. Ltd. Şti (planning administrative operations related to communication conducted by our Company, ensuring and supervising the physical security of company locations, evaluation and supervision processes for business partners/customers/suppliers (authorized or employees), legal compliance processes, etc.).
10. Using legal rights, using information about processing history as evidence in case of disputes after the termination of the legal relationship.
11. Determining and implementing the commercial, legal, and business strategies of Etex Tekstil ve Kayış San. Tic. Ltd. Şti.
12. Executing human resources, accounting/finance policies of Etex Tekstil ve Kayış San. Tic. Ltd. Şti.
13. Planning, supervising, and executing information security processes.
14. Compliance with domestic and international legislation, providing information requested by public institutions and organizations, and fulfilling reporting obligations.

d. Transfer of Personal Data and Processing of Personal Data by Third Parties

The Company may transfer personal data to a third natural or legal person in compliance with KVKK regulations. In such cases, the Company ensures that the third parties to whom data is transferred also comply with this Policy. Necessary protective provisions are added to the contracts concluded with the third parties in this context.

• Transfer of personal data to third parties located in Turkey: Personal Data can be transferred by the Company to third parties located in Turkey without requiring explicit consent in exceptional cases defined in Article 5.2 and Article 6.3 of KVKK, or with the explicit consent of the Data Subject in other cases as per Article 5.1 and Article 6.2 of KVKK.
• Transfer of personal data to third parties located abroad: Personal Data can be transferred by the Company to third parties located abroad without requiring explicit consent in exceptional cases defined in Article 5.2 and Article 6.3 of KVKK, or with the explicit consent of the Data Subject in other cases as per Article 5.1 and Article 6.2 of KVKK. Additionally, one of the following conditions regarding the foreign country to which data is transferred must be met.
• The foreign country to which personal data is transferred is recognized by the Supervisory Board as a country with adequate protection.
• If the foreign country to which the transfer will take place is not listed on the Supervisory Board’s list of secure countries, the Company and the Data Controllers in the relevant country must obtain permission from the Supervisory Board by providing a written commitment that adequate protection will be ensured.

e. Your Rights and Application Procedure

e.1. Your Rights Regarding Your Personal Data

We would like to inform you that you have the following rights regarding your data processed within Etex Tekstil ve Kayış San. Tic. Ltd. Şti . and its affiliates:

1. To learn whether your Personal Data is being processed,
2. To obtain information regarding your Personal Data if it is being processed,
3. To understand the purpose of the processing of your Personal Data and whether your Personal Data is being used in accordance with that purpose,
4. To know who the third parties are to whom data is transferred domestically or abroad, and which data is transferred if any,
5. To request the correction of your Processed Personal Data if they are incomplete or incorrect,
6. To request that the correction, deletion, or destruction of your Personal Data be communicated to the third parties to whom your Personal Data is transferred if such processes occur,
7. To request the deletion or destruction of your processed Personal Data if the reasons requiring the processing of your Personal Data cease or if your Personal Data becomes outdated,
8. To object to the emergence of a result unfavorable to you through the analysis of your Processed Personal Data exclusively via automated systems,
9. You have the rights to claim compensation in case of damage resulting from the unlawful processing of your Personal Data.

e.2. Application

You can submit your requests regarding your Personal Data by filling out the application form linked below:

1. By submitting it to our consultation office at the company address listed in the Data Controller Identification Information section, or by serving it via a Notary to the same address,
2. It can also be done via registered electronic mail.

Etex Tekstil ve Kayış San. Tic. Ltd. Şti will process requests directed to it as soon as possible and no later than thirty (30) days, free of charge, depending on the nature of the request. In the event that fulfilling your requests incurs a cost, we may only charge you fees as per the tariff determined by the Personal Data Protection Board.

As a result of the requests directed to Etex Tekstil ve Kayış San. Tic. Ltd. Şti, we may accept the requests or reject them by explaining the reasons, and we can convey this response in writing or electronically to the person making the request. If the request is accepted, Etex Tekstil ve Kayış San. Tic. Ltd. Şti is obligated to promptly fulfill the requirements of the request.

e.3. Complaint

If the requests you have directed to Etex Tekstil ve Kayış San. Tic. Ltd. Şti are rejected by Etex Tekstil ve Kayış San. Tic. Ltd. Şti, you are not satisfied with the response provided by Etex Tekstil ve Kayış San. Tic. Ltd. Şti or if no response is given, you may file a complaint with the Personal Data Protection Board within thirty (30) days from the date the response was notified to you, or within thirty (30) days from the end of the thirty (30) day period if no response is provided.

f. Data Controller Identification Information

The term Etex Tekstil ve Kayış San. Tic. Ltd. Şti used in this document is organized for a subsidiary established in Turkey and is addressed to individuals whose data is controlled by the company specified below:

Etex Tekstil ve Kayış San. Tic. Ltd. Şti

Address: Maltepe Neighborhood, Çiftehavuzlar Street, Prestij Business Center, Floor:5 No:518-709 34035 Bayrampaşa/Istanbul/Turkey

Phone: +90 212 565 78 47

Phone: +90 212 674 97 74

Phone: +90 532 341 57 16

Fax: +90 212 674 97 48

Email: info@etexflock.com

KVKK Application Form

Under the Personal Data Protection Law No. 6698 (“KVK Law”), personal data subjects defined as relevant individuals (“hereinafter referred to as “Applicant”) have the right to make certain requests regarding the processing of their personal data under Article 11 of the KVK Law. In accordance with the first paragraph of Article 13 of the KVK Law, applications regarding these rights to our Company, as the Data Controller, must be submitted personally, in written Turkish, and through the methods specified below by the Personal Data Protection Board (“Board”).

Below are the details on how written applications should be submitted to us.

In accordance with the Communiqué on the Procedure and Principles for Applications to the Data Controller (dated 10/03/2018 and numbered 30356 R.G.), the following information must be included in applications:

Information to be Filled Out During Application:

• Name, surname, and signature if the application is written,
• For Turkish Republic citizens, the Turkish Identification Number, for foreigners, nationality, passport number or, if available, identification number,
• Residential address or workplace address for notification purposes,
• Electronic mail address, phone, and fax number for notification purposes, if available,
• Subject of the request

Additionally, information and documents related to the subject are attached to the application.

If you wish to submit an application regarding your personal data, the application form below must be filled out completely. This application form has been prepared to identify your relationship with our Company, determine your personal data processed by our Company if any, and to enable us to respond to your relevant application accurately and within the legal timeframe. To mitigate legal risks that may arise from unlawful and unjust data sharing and especially to ensure the security of your personal data, our Company reserves the right to request additional documents and information (such as copies of ID cards or driver's licenses) for identity and authority verification. If the information related to the requests you submit through the form is inaccurate or an unauthorized application is made, our Company does not accept liability for requests arising from such incorrect information or unauthorized applications.

Your submitted applications will be responded to in writing, free of charge, within thirty days at the latest from the date your request reaches us, according to the nature of the request, as per the second paragraph of Article 13 of the KVK Law.