Law on Protection of Personel Data

Personal data within Ortadoğu Holding A.S. Companies listed in the attachment (hereinafter referred to as “Ortadoğu Holding”) are under the assurance of ORtadoğu Holding, we take the necessary technical and administrative measures to ensure that personal data are safely stored and processed in accordance with the law, in accordance with Law No. 6698 on Protection of Personal Data (”the Law”).

In this direction, in order to inform you in within the context of the processing, preservation and transfer of your personal data in accordance with the Law, this Disclosure Text has been arranged within the scope of the Law on Protection of Personal Data.

1. For what purposes personal data can be processed

   Your personal data, in accordance with the Law, may vary, depending on the services provided by the Ortadoğu Holding and the business activities of the Ortadoğu Holding and they may be collected either verbally, in writing, or electronically, by automated or non-automated means, via Ortadoğu Holding units and offices, websites, social media, mobile applications etc. When you use our call centres or internet pages, visit Ortadoğu Holding or our website, social media pages, your personal data will be generated and updated.

   In accordance with the conditions laid down in Articles 5 and 6 of the Law and all applicable legislation, your personal data may be processed by Ortadoğu Holding for the purposes below:

   • To ensure that our legal obligations are fulfilled as required or mandated by legal arrangements,
   • To provide software services and other outsourcing services for the fulfilment of operational activities,
   • To ensure that the necessary works to be carried out by the related units in order to conduct commercial activities indicated in the Ortadoğu Holding main contracts in accordance with the legislation and related company and Ortadoğu Holding policies and to carry out activities in this regard,
   • To identify, plan and implement short, medium and long-term commercial policies of the Ortadoğu Holding
   • To provide information about products, services and projects provided by Ortadoğu Holding upon customizing in accordance to the related persons’ liking, usage habits and needs,
   • To provide an efficient customer service,
   • To supply services and proposals,
   • To provide info on all kinds of promotions, campaigns, lotteries,
   • To carry our all kinds of marketing and advertising activities,
   • To determine the visitor profiles,
   • To provide the commercial reliability of Ortadoğu Holding,
   • To ensure that all requests, demands and complaints to be resolved,
   • To provide support service to Customers and Visitors under the contract and within the framework of service standards,
   • To make market researches and statistical studies,
   • To contact persons within business relationship with Ortadoğu Holding,
   • Marketing, compliance management, vendor/supplier management,
   • Planning, supervision and execution of information security processes,
   • Establishment and management of information technology infrastructure,
   • Planning and execution of employees’ access authorizations to Data Owner information,
   • To track the finance and/or accounting transactions including invoicing,
   • To track the legal affairs,
   • Planning and executing corporate communication activities,
   • To ensure that the data is accurate and up-to-date.


2. I Transfer of Personal Data and Transfer Purposes

   Your Personal Data may be transferred in accordance with the essential principles assumed by Law and in accordance with the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law within the direction of the legitimate and legal personal data processing purposes of Ortadoğu Holding listed below;

   • To protect the commercial reputation and confidence,
   • To determine, plan and implement commercial and business strategies in short, medium and long-term,
   • To make you benefit from the products, services and projects offered by our business units,
   • To offer you products, services and projects customized to your liking, usage habits and needs,
   • the legal and commercial security of the persons involved in the business relationship (administrative operations directed to the communication carried out by the Ortadoğu Holding, to ensure the physical security and control of the locations belonging to the Ortadoğu Holding, evaluation process of partner/customer/supplier (authorized or employees), reputation research processes, legal compliance process, auditing, financial affairs, etc.)
   • for the purpose of conducting human resources policies, to Ortadoğu Holding authorized, suppliers, shareholders and legally authorized institutions and organizations.

   Detailed information on the transfer of your personal data by Ortadoğu Holding can be found at www.ortadoguholding.com.tr under “Ortadoğu Holding Protection and Processing of Personal Data Policy”.

3. 3 I Transfer Abroad

   In accordance with the Article 9 of the Law and within the direction of Ortadoğu Holding’s legitimate and legal personal data processing purposes, in order for our business units to undertake the necessary work to make you benefit from the products and services offered by the Ortadoğu Holding, to recommend the products and services provided by Ortadoğu Holding and sub-brands upon customizing in accordance to your liking, usage habits and needs, for the legal and commercial security of the persons involved in business relationship with Ortadoğu Holding (administrative operations directed to the communication carried out by the Ortadoğu Holding, to ensure the physical security and control of the locations belonging to the Ortadoğu Holding, evaluation process of partner/customer/supplier (authorized or employees), reputation research processes, legal compliance process, auditing, financial affairs, etc.), to determine and implement Ortadoğu Holding’s commercial and business strategies and to carry out the human resources policies of Ortadoğu Holding, your personal data may be transferred to foreign countries if you give consent, and even if you have given a consent, your personal data may be transferred to foreign countries only with sufficient protection or with data responsibility committed to adequate protection within the framework of the provisions in the Law.

4. I Method of Collecting Personal Data and Legal Reason

   Your personal data is kept in compliance with the legislative requirements, as long as it is permissible under the relevant legislation. Your personal data may be collected, processed, transferred and stored within the scope of personal data processing conditions and purposes specified in Article 5 and 6 of the Law and for the purposes specified in the Articles 1 and 2 of this text.

   Your personal data may be obtained by Ortadoğu Holding with other methods (Ortadoğu Holding centre, agencies and other physical environments which you may communicate with affiliates, agents, sales offices or other subcontractors or business partners, call centres, websites, mobile applications and similar electronic processing platforms, social media or other public media, upon participating to the training, seminar or other events, upon inquiry or through Holding Companies or other persons and entities who are authorized in verbal, written, audio or video recording form or other physical or electronic media etc.).

   In order for the activities of the companies under Ortadoğu Holding to be carried out in accordance with Ortadoğu Holding principles, targets and strategies and in order to protect Ortadoğu Holding’s rights and interest, the personal data collected and processed by one of the companies in Ortadoğu Holding may also be transferred and processed by other companies under the Ortadoğu Holding.

5. I Your Right under the Article 11 of the Law as Data Subject

   If you submit your requests for your rights as Data Subject to Ortadoğu Holding in the manner set out below, Ortadoğu Holding will conclude your request free of charge within 30 (thirty) days as soon as possible. However, if a fee is foreseen by the Personal Data Protection Board, the fee will be charged at the rate determined.

   In this context, data subjects can apply to Ortadoğu Holding and use the following rights:

   • To learn whether Ortadoğu Holding has processed the data of the data subject,
   • If personal data are processed under Ortadoğu Holding, to request information on this data processing activity,
   • If personal data are being processed under Ortadoğu Holding, to learn about the purpose of the personal data processing activity and whether it is being used appropriately for the purpose of processing,
   • If personal data is transferred to third parties within country or abroad, requesting information on these third parties,
   • If your personal data is incompletely or incorrectly processed, to ask them to be corrected,
   • If the personal data are incompletely or incorrectly processed under Ortadoğu Holding, to request to be notified of the third parties to whom the personal data is transferred,
   • To request that personal data to be deleted, destroyed or anonymized, where the reasons that require the processing of personal data disappear although it has been processed in accordance with the provisions of the Law and other related provisions,
   • To request that third parties to which personal data are transferred to be notified if the reasons for the processing of personal data have disappeared,
   • To request the personal data processed by the Ortadoğu Holding to be analysed exclusively through automated systems and in the event of the conclusion of the analysis that the person concerned thinks that a conclusion that is against the related person, to object this conclusion.
   • To demand the damage be compensated in the event of a damage due to the processing of personal data unlawfully.

   Pursuant to Article 13 (f.l) of the Law, you may submit your request to exercise your rights listed above to the Ortadoğu Holding in writing or by other means established by the Personal Data Protection Board. In this context, the channels and procedures you will submit your applications to be made under Article 11 of the Law to the Middle East Group are outlined below.

   You may submit request including your explanations on the right you wish to exercise among the rights set forth in Article 11 of the Law, together with your identification documents by filling the Personal Data Subject Application Form within the Scope of Law No. 6698 on the Protection of Personal Data under www.ortadoguholding.com.tr website

   • by delivering a signed copy to “Kaptanpaşa Mah. Piyalepaşa Blv. Ortadoğu Plaza No: 73 Kat: 19 Okmeydanı - Şişli/istanbul” address by hand,
   • by sending to our address above via notary public or registered mail,
   • by e-mail to info@ortadoguholding.com.tr address by signing with Secure E-Signature or
   • via Registered E-mail Address (KEP), to the KEP address of the company you want to apply as secure electronic signed.
6. I Changes

   Ortadoğu Holding reserves the right to make changes to this disclosure text for the purposes of the changes in the Protection of Personal Data Law and the methods to be determined by the Personal Data Protection Board.

LAW NO. 6698 ON PROTECTION OF PERSONAL DATA PERSONAL DATA SUBJECT APPLICATION

In accordance with the Law on Personal Data Protection No. 6698 (”KVK Law”), personal data subjects who are defined as related persons (“Applicant”) have been granted the right to have certain requests regarding the processing of personal data in Article 11 of the KVK Law. According to the KVK Law; the applications to be made to our Company as data controller in relation with these rights must be delivered to us in writing or with other methods determined by Protection of Personal Data Board (”Board”).

The applications communicated in writing through the following channels will be concluded free of charge, within 30 days from the date of your request to our Company, in accordance with Article 13 of the KVK Law. However, if the transaction also requires a cost, a fee may be charged at the time specified in the Board.

APPLICATION CHANNELS:

The applications to be made in writing to our company can be made by filling and signing the form below completely and sending it with any of the following methods.

APPLICATION METHOD	APPLICATION ADDRESS	DESCRIPTION
In Person	Kaptanpaşa Mah., Piyalepaşa Buvarı Ortadoğu Plaza No:73, 34384 Okmeydanı Şişli/Şişli/istanbul	It is possible for the Applicant to come to the following application address in person and to apply with his/her proof of identity
Via notary public,		On the notification envelope, “Information Request Within the Context of the Law on Personal Data Protection” must be written.
Via registered letter		Identification documents must be included and “Information Request Within the Context of the Law on Personal Data Protection” must be written on the notification envelope.
Via E-mail with Secure Electronic signature or Mobile signature	info@ortadoguholding.com.tr	It must be signed by the Applicant via Secure Electronic signature or Mobile signature and the expression “Information Request Within the Context of the Law on Personal Data Protection” must be written to the subject field.
Via Registered E-Mail (KEP)	ortadoguinsaat@hs03.kep.tr (Diğer şirketlerimizin KEP adresleri için tıklayınız.)	On the subject field of the KEP application, “Information Request Within the Context of the Law on Personal Data Protection” must be written.