KVKK INFORMATION TEXT

KVKK Policy

Protection of Personal Data

OEC ELEKTRONİK HABERLEŞME SİSTEMLERİ LTD. ŞTİ.

PERSONAL DATA PROTECTION AND PROCESSING POLICY

ENTRANCE

This Personal Data Protection and Processing Policy (Policy in short), OEC ELEKTRONİK ILETISIM SİSTEMLERİ LTD. Sti. (OEC Communication Systems in short) sets forth the principles to be adopted and taken into account at the point of application in the processing and protection of personal data in accordance with the provisions of the relevant legislation, especially the Law on the Protection of Personal Data No. 6698.

With this Policy, OEC Communication Systems undertakes to act in accordance with this Policy and the procedures to be applied accordingly in terms of the personal data within its own structure.

PURPOSE OF THE POLICY

The main purpose of this Policy is to determine the principles regarding the methods and processes for the protection of personal data in order to comply with the KVK Law. In this context, OEC Communication Systems will make the necessary arrangements for compliance with the Policy within its own structure and will ensure the continuity of compliance with the Policy by periodically operating internal audit mechanisms on compliance and take all necessary administrative and technical measures in terms of processing and protection of personal data.

SCOPE OF THE POLICY

This Policy covers all activities related to the personal data processed by OEC Communication Systems, applies to such activities and may be amended from time to time with the approval of the board of directors if required by the KVK Regulations or when deemed necessary by the data controller representative and other officials of OEC Communication Systems.

PRINCIPLES TO BE APPLIED IN THE PROCESSING OF PERSONAL DATA

Personal data will be processed by OEC Communication Systems in verbal, written or electronic media by automatic or non-automatic methods and the processing of personal data will be acted in accordance with the Constitution and KVK Law. In addition, a number of principles will be adhered to in the processing of personal data. In this context;

Personal data will be processed by OEC Communication Systems in accordance with the law and good faith, in accordance with the principles of proportionality and proportionality, as much as necessary in accordance with the purpose of personal data. The processing of personal data that is not relevant or not needed for the realization of the purpose will be avoided.

Personal data will be processed by OEC Communication Systems for specific, clear, legitimate and lawful reasons. Before the processing of personal data, OEC Communication Systems will determine the purpose for which personal data will be processed and in this context, personal data will be presented to the information of the data owners before processing, and their explicit consent will be obtained when necessary.

OEC Communication Systems retain personal data only for the periods stipulated by law or for as long as necessary in accordance with the purpose for which they are processed. In this context, if a period is determined for the storage of personal data in the relevant legislation, this period will be acted in accordance with, and if a period is not determined, the personal data will be kept for the period necessary for the purpose for which they are processed. Insofar as these periods are at the end of these periods, personal data may be stored longer in order to constitute evidence in a possible legal dispute or to cause a dispute to which a party may occur. In determining the retention period herein, the statute of limitations specified in the relevant laws for the assertion of the said right shall be taken into account. In such a case, the stored personal data will only be accessed when it is necessary to use it in the relevant legal dispute and will not be accessible for any other purpose. If all these periods expire or the reasons that require processing disappear, the personal data will be deleted, destroyed or anonymized. Personal data will not be stored with the possibility of future use.

OEC Communication Systems will take all necessary measures to ensure that the personal data it processes are complete, accurate and up-to-date, and will update the relevant personal data if the data owner requests changes to the personal data.

In the KVK Law, it is regulated that special measures can be introduced for the processing of personal data of special nature. In this context, personal data processing activities will be carried out by taking into account the special provisions stipulated in the KVK Law on the processing of personal data of a special nature and their transfer to third parties and abroad, and in addition to the above-mentioned issues, personal data processing activities will be carried out by fulfilling the special requirements required by the law in these cases.

Regarding the transfer of personal data to third parties at home or abroad, the necessary organizational systems will be established to act in accordance with the regulations stipulated in Articles 8 and 9 of the KVK Law.

PROCESSING OF PERSONAL DATA

Personal data will be processed after the information to be made to the data owner and if the data owner gives explicit consent. The data owner will be informed of their rights before obtaining explicit consent within the framework of the Disclosure Obligation and explicit consent will be obtained by methods in accordance with the KVK Regulations.

In cases where the processing of personal data without explicit

consent is foreseen within the scope of KVK regulations (Article 5.2 and Article 6.3 of the KVK Law), OEC Communication Systems may process personal data without obtaining the explicit consent of the data owner. In this context:

In the event that the life or bodily integrity of the data owner and/or a person other than the data owner who is unable to disclose his/her consent due to actual impossibility or whose consent is not legally valid is protected,

If it is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment, implementation, performance or termination of a contract,

If the processing of personal data is mandatory for OEC Communication Systems to fulfill its legal obligation,

In the event that the personal data has been made public by the data owner,

If the processing of personal data without explicit consent is mandatory for the establishment, exercise or protection of a right,

Provided that it does not harm the fundamental rights and freedoms of the data owner, if the data processing is mandatory for the legitimate interests of OEC Communication Systems,

If expressly provided for in the laws,

Personal data may be processed by OEC Communication Systems without explicit consent.

OBLIGATION TO DISCLOSE THE PERSONAL DATA OWNER

OEC Communication Systems, KVK Law 10. In accordance with the article, it will enlighten the persons whose data will be processed during the acquisition of personal data about how their data will be processed. In the KVK Law, the minimum issues that should be included in the information are enumerated:

The identity of the Company as the data controller and its representative, if any,

The purpose for which personal data will be processed,

To whom and for what purpose the processed personal data may be transferred,

Method of collecting personal data and legal grounds,

The rights of the personal data owner;

To learn whether personal data is processed or not,

In case of processing personal data, to request information about it,

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

To know the third parties to whom personal data are transferred at home or abroad,

In the event that the personal data

is processed incompletely or incorrectly by OEC Communication Systems, to request their correction and to request that the transaction carried out within this scope be notified to the third parties to whom the personal data are transferred, Requesting the deletion, destruction or anonymization of personal data in the event that the reasons requiring the processing of personal data to be evaluated within the principles of purpose, duration and legitimacy disappear despite being processed in accordance with the provisions of the KVK Law and other relevant laws, and requesting that the transaction carried out within this scope be notified to the third parties to whom the personal data is transferred,

To object to the occurrence of a result against the person himself in the event that the processed personal data is analyzed exclusively by means of automatic systems,

Requesting the compensation of the damage in case of unlawful processing of personal data and damage suffered for this reason.

In cases where the data owners want to exercise their rights and/or think that OEC Communication Systems does not act within the scope of this Policy while processing personal data, they may submit their requests by hand to the e-mail address specified below and which may change from time to time with a secure electronic signature or to the postal address below which may change from time to time with a wet signed petition with identifying documents or through a notary.

Data Controller : OEC ELEKTRONİK HABERLEŞME SİSTEMLERİ LTD. ŞTİ.

Phone : 0 216 325 8872

Fax : 0 216 325 8872

Web : www.oec.com.tr

E-Mail : info@oec.com.tr

Postal Address : Uzunçayır Cad. Konak İş Merkezi A Blok No:30 K:3 D:53 Hasanpaşa – Kadıköy / İSTANBUL

OEC Communication Systems will conclude the relevant request free of charge as soon as possible and within thirty days at the latest according to the nature of the request. As a result of the evaluation, OEC Communication Systems may accept the applications and take the necessary actions or reject the applications by electronic mail or mail with reasons. The personal data owner may file a complaint with the KVK Board within 30 days in case of rejection of the application, finding the response insufficient or not responding to the application in time.