Personal Data Processing Clarification Text

This Clarification Text has been prepared by Efeniks İnşaat Anonim Şirketi (“Company”) to inform the Company's customers regarding the processing of their personal data by the Company within the scope of the Law on Protection of Personal Data No. 6698 (“Law No. 6698”). Detailed information about the processing of your personal data within the scope of this Clarification Text can be accessed from the Efeniks İnşaat Anonim Şirketi Personal Data Protection and Processing Policy available at www.efeniks.com.tr.

a) Methods and Legal Reasons for Obtaining Personal Data

Your personal data is collected in electronic or physical environments. Your personal data collected for the legal reasons stated in this Clarification Text can be processed and shared within the framework of the personal data processing conditions specified in Articles 5 and 6 of the Law.

b) Purposes of Processing Personal Data

Your personal data is processed for the purposes of planning and executing the necessary activities to recommend and promote the products and services offered by Efeniks İnşaat Anonim Şirketi to the relevant persons by customizing them according to the likes, usage habits, and needs of the relevant persons, performing the necessary work by the relevant business units for the persons to benefit from the products and services offered by Efeniks İnşaat Anonim Şirketi and conducting the related business processes, carrying out the necessary work by the relevant business units to perform the commercial activities carried out by Efeniks İnşaat Anonim Şirketi and executing the related business processes, planning and executing the commercial and/or business strategies of Efeniks İnşaat Anonim Şirketi, and ensuring the legal, technical, and commercial-business security of Efeniks İnşaat Anonim Şirketi and the related persons who have a business relationship with Efeniks İnşaat Anonim Şirketi within the framework of the personal data processing conditions specified in Articles 5 and 6 of the Law.

c) Parties to Which Personal Data Can Be Transferred and Purposes of Transfer

Your personal data can be shared with the business partners and suppliers of Efeniks İnşaat Anonim Şirketi, legally authorized public institutions and organizations, and legally authorized private law persons within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law for the purposes of planning and executing the necessary activities to recommend and promote the products and services offered by Efeniks İnşaat Anonim Şirketi to the relevant persons by customizing them according to the likes, usage habits, and needs of the relevant persons, performing the necessary work by the relevant business units for the persons to benefit from the products and services offered by Efeniks İnşaat Anonim Şirketi and conducting the related business processes, carrying out the necessary work by the relevant business units to perform the commercial activities carried out by Efeniks İnşaat Anonim Şirketi and executing the related business processes, planning and executing the commercial and/or business strategies of Efeniks İnşaat Anonim Şirketi, and ensuring the legal, technical, and commercial-business security of Efeniks İnşaat Anonim Şirketi and the related persons who have a business relationship with Efeniks İnşaat Anonim Şirketi.

d) Rights of Data Subjects and Use of These Rights

If you submit your requests regarding your rights as personal data subjects to the Company by following the methods specified under the title Use of Rights by Data Subjects, your requests will be evaluated and concluded by our Company as soon as possible and within 30 (thirty) days at the latest. Pursuant to Article 11 of the Law, as a personal data subject, you have the following rights:

• To learn whether your personal data is processed or not,
• If your personal data has been processed, to request information regarding this,
• To learn the purpose of processing your personal data and whether it is used in accordance with its purpose,
• To know the third parties to whom your personal data is transferred domestically or abroad,
• If your personal data is incomplete or inaccurately processed, to request their correction and to request notification of the third parties to whom the personal data has been transferred,
• To request the deletion or destruction of your personal data in the event that the reasons requiring its processing are eliminated, although it has been processed in accordance with the provisions of the Law and other relevant laws, and to request the notification of the third parties to whom the personal data has been transferred,
• To object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,
• To demand the compensation of the damage in case of loss due to the unlawful processing of personal data.

Article 28 of the Law lists the cases where data subjects do not have the right to request, and in this context;

• If the processing of personal data is necessary for the prevention of crime or for a criminal investigation,
• If the processing of personal data made public by the data subject himself/herself,
• If the processing of personal data is necessary for the execution of audit or regulation duties by the authorized and competent public institutions and organizations, and professional organizations that have the status of a public institution, based on the authority granted by the law,
• If the processing of personal data is necessary for the protection of the economic and financial interests of the State in relation to budgetary, tax, and financial matters,

In such cases, the above-mentioned rights cannot be exercised regarding the data.

Pursuant to paragraph 1 of Article 28 of the Law, in the following cases, since the data is outside the scope of the Law, the requests of data subjects regarding these data will not be processed:

• If personal data is processed by real persons within the scope of activities related to themselves or their family members living in the same residence, provided that they are not given to third parties and the obligations regarding data security are complied with,
• If personal data is processed for purposes such as research, planning, and statistics by making them anonymous with official statistics,
• If personal data is processed for artistic, historical, literary, or scientific purposes, or within the scope of freedom of expression, provided that it does not violate the privacy of private life or personal rights, or constitute a crime,
• If personal data is processed within the scope of preventive, protective, and intelligence activities carried out by the authorized and competent public institutions and organizations that are assigned and authorized by the law to ensure national defense, national security, public security, public order, or economic security,
• If personal data is processed by judicial authorities or execution authorities regarding investigation, prosecution, trial, or execution proceedings.

Use of Rights by Data Subjects

Data subjects can use the “Form for Applications to be Made to the Data Controller by the Personal Data Owner” available at www.efeniks.com.tr to exercise the above-mentioned rights.

Applications will be made with documents identifying the relevant data subject, by following the method below:

• By delivering a wet-signed copy of the form in person, through a notary, or by registered mail with return receipt;
• To the address of Göcek Mah. Gençlik Sk. No:2/4 Fethiye Muğla Turkey,
• By following a method stipulated by the Personal Data Protection Board.

Efeniks İnşaat Anonim Şirketi responds to the requests of data subjects who want to exercise their rights within the limits set forth by the Law and in accordance with the Law within a maximum of thirty (30) days. Third parties cannot make requests on behalf of personal data owners without a special power of attorney issued through a notary by the data subject.

Applications made by personal data owners are processed free of charge as a rule, but a fee may be charged based on the fee schedule stipulated by the Personal Data Protection Board.

Efeniks İnşaat Anonim Şirketi may request information from the relevant person to determine whether the applicant is the personal data owner, and may ask questions to the personal data owner to clarify the issues stated in the application.