1.Introduction

This clarification and consent text has been prepared in accordance with the Turkish Personal Data Protection Law No. 6698 ("Law") to obtain the explicit consent of data subjects and to inform them about the rights specified in Article 10 and 11 of the Law regarding the processing of personal data and sensitive personal data by Cevher Metalurji Demir Çelik Sanayi ve Ticaret A.Ş. ("Our Company") and other group companies, in their capacity as data controllers.

2.Definitions

The concepts of personal data, sensitive personal data, and data processing used in this clarification and consent text are based on the definitions provided in the Law.

In the Law, the term:

"Personal data" refers to any information relating to an identified or identifiable natural person,

"Processing of personal data" refers to any operation performed on personal data, such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, acquiring, making available, classifying, or preventing its use, whether by fully or partially automated means, or by non-automated means as part of a data recording system.

3. Principles of Personal Data Processing

Pursuant to Article 4 of the Law, personal data belonging to the data subject shall be processed by our Company in accordance with the principles of lawfulness and fairness; accurate and, where necessary, up-to-date; for specific, explicit, and legitimate purposes; in a manner that is relevant, limited, and proportionate to the purposes for which they are processed; and in compliance with the rules for retention as stipulated in the relevant legislation or as required for the purpose for which they are processed.

4.Purposes of Processing Personal Data

The personal data collected will be processed by our Company and group companies for the purposes of carrying out the necessary work by our business units to enable you to benefit from the products and services offered by our Company and group companies; customizing the products and services offered by our Company and group companies according to your preferences, usage habits, and needs and recommending them to you; ensuring the legal and commercial security of our Company, our group companies, and individuals who have business relations with our Company; conducting administrative operations related to communication carried out by our Company; ensuring the physical security and supervision of locations belonging to our Company; carrying out evaluations, reputation research, legal compliance processes, and financial affairs related to business partners, customers, suppliers, and/or their authorized representatives or employees; determining and implementing the commercial business strategies of our Company; and ensuring the execution of our Company's human resources policies, in accordance with the personal data processing conditions and purposes stated in Articles 5 and 6 of the Law.

5.Transfer of Personal Data

Your collected personal data may be transferred to our group companies and individuals or legal entities with whom our Company has business relations for the purposes of carrying out the necessary work by our business units to enable you to benefit from the products and services offered by our Company and group companies; customizing the products and services offered by our Company and group companies according to your preferences, usage habits, and needs, and recommending them to you; ensuring the legal and commercial security of our Company, our group companies, and individuals who have business relations with our Company; conducting administrative operations related to communication carried out by our Company; ensuring the physical security and supervision of locations belonging to our Company; conducting evaluations, reputation research, legal compliance processes, and financial affairs related to business partners, customers, suppliers, and/or their authorized representatives or employees; determining and implementing the commercial business strategies of our Company; and ensuring the execution of our Company's human resources policies.The transfer of personal data will be carried out in compliance with the conditions stipulated in Articles 8 and 9 of the Law.

6.Collection Method and Legal Basis for Personal Data/Special Categories of Personal Data

Your personal data may vary depending on the services provided by our company and the commercial activities of our company and may be collected in written or electronic form through automatic or non-automatic methods via our company units and offices, group companies, website, social media platforms, mobile applications, and similar means. As long as you benefit from the products and services offered by our company and group companies, your personal data will be processed in accordance with the durations stipulated by law.

7.Rights of the Data Subject as Specified in Article 11

Data subjects have the right to apply to our company, acting as the data controller, to inquire whether their personal data has been processed, and if so, to request information about it. They have the right to learn the purpose of processing their personal data and whether it is used in accordance with that purpose; to be informed about third parties to whom their personal data has been transferred, both domestically and internationally; to request the correction of their personal data if it is incomplete or inaccurate; to request the deletion or destruction of their personal data in accordance with the conditions stipulated in Article 7 of Law No. 6698; to request that third parties to whom their personal data has been transferred be notified of the corrections or deletions made, in accordance with the provisions of Article 11 (d) and (e) of the Law; to object to a result that is produced exclusively by automated processing of their data and which may have a negative impact on them; and to request compensation for any damage caused by the unlawful processing of their personal data.

The Personal Data Processing Clarification Text for CEVHER METALURJİ STEEL INDUSTRY AND TRADE INC. and other Group Companies.