Our Privacy Policy, KVKK Clarification Text on

CORPORATE GENERAL PRIVACY NOTICE ON PROTECTION OF PERSONAL DATA

As İ.Mak Redüktör Varyatör San. Tic. A.Ş. (“İ.Mak Redüktör”) we have prepared this privacy notice in order to inform our online visitors, customers, potential customers, supplier employees and supplier executives regarding the processing, storage and transfer of your personal data within the framework of the Law on Protection of Personal Data No. 6698 (“LPP”), General Data Protection Regulation (“GDPR”) and relevant legislation and legal regulations.

1) What are the Personal Data Categories We Process and For What Purposes Do We Process Them?

Personal information of our business partners may be processed by İ.Mak Redüktör according to article 4.2 of LPP in accordance with the principles of

(i) to be compatible with law and rules of good faith
(ii) to be accurate and, where necessary, up-to-date,
(iii) to process for specific, explicit, and legitimate purposes,
(iv) to be relevant, limited and proportionate to the purpose for which data are processed,
(v) to store for such duration specified by the relevant legislation or is necessary for the purpose for which data are collected

within the scope of our ongoing business relations with our business partners, it can be processed for the purposes mentioned below (it is possible for one person to fall under multiple categories).

A. Visitors

Identity information (e.g. name, surname), Physical security information (e.g. security camera records) will be processed for the following purposes.

a) Creating and tracking visitor records, b) to ensure physical security,

B. Our Online Visitors

Transaction security information (e.g. your IP address information), marketing information (e.g. cookie records) of our online visitors using our website and (if you provide us with them*) identification information, contact information (e.g. your e-mail address) will be processed for the following purposes.

a) to ensure our operations comply with the legislation,
b) to conduct information security processes,
c) to follow up on requests/complaints,
d) to conduct communication operations,
e) to give information to authorized persons, institutions, and organizations,
f) to access to website via the Internet

C. Customers

Identity information, contact information, customer transaction information (e.g. order information), physical security information, financial information (e.g. balance sheet information), legal transaction information, marketing information (e.g. shopping history information) of the executives and/or employees of our legal person customers and/or natural person customers will be processed for the following purposes.

a) to ensure our operations comply with the legislation,
b) to conduct financial and accounting operations,
c) to conduct/audit business operations,
d) to conduct logistics operations,
e) to carry out after sales support services,
f) to carry out sales processes of goods/services,
g) to carry out marketing analysis studies,
h) to carry out contract management processes,
i) to give information to authorized persons, institutions, and organizations,
j) to ensure physical security,
k) to conduct legal dispute resolution,
l) to carry out storage and archiving operations,
m) to conducting risk management operations,
n) to carry out advertisement / campaign / promotion processes,
o) to carry out loyalty management programmes for company/products/services
p) to conduct communication operations.

D. Our Potential Customers

Identity information, contact information, customer transaction information, physical security information, marketing information of the employees of our legal person customers and/or natural person customers will be processed for the following purposes.

a) to carry out sales processes of goods/services,
b) to carry out contract management processes,
c) to ensure physical security,
d) to carry out advertisement / campaign / promotion processes, e) to carry out marketing analysis studies.

E. OurSupplierEmployee

Identification information, contact information, physical security information of our supplier employees will be processed for the following purposes.

a) To conduct communication operations, b) to conduct/audit business operations, c) to ensure physical security,

d) to carry out supply chain management processes,
e) to conduct logistics operations,
f) to ensure our operations comply with the legislation,
g) to carry out occupational health/safety operations.

F.Our Supplier Representative

Identity information, contact information, physical security, customer transaction information, financial information, marketing information, legal transaction information of our natural person suppliers or legal person supplier’s representatives will be processed for the following purposes.

a) to conduct/audit business operations,
b) to carry out procurement processes of goods/services,
c) to conduct financial and accounting operations,
d) to carry out contract management processes,
e) to carry out investment processes,
f) to ensure physical security,
g) to handle and follow-up on legal affairs.

2) What are the Collection Methods of Your Personal Data?

Your personal data mentioned above in categories are gathered fully or partially through physical means e.g. order forms, contracts, visitor forms, or information systems and electronic devices (e.g. telecommunications infrastructure, computers and phones), third parties (e.g. KKB and

Findeks Report), our website and other documents declared by the person concerned. 3) How Long Do We Keep Your Personal Data?

Your personal data specified in categories above, if a period is stipulated in the relevant legislation, for the specified period; If the period is not stipulated, our legitimate interests are kept by taking the following criteria into account as long as it continues.

İ.Mak Redüktör’s usages
Applied commercial practices
Prescription periods stipulated in the relevant legislation

Personal data stored at the end of these periods are deleted, destroyed, or anonymized.

4) What Is the Legal Reason for Collecting Your Personal Data?

Your personal data is processed by İ.Mak Redüktör in order to achieve the objectives described above, it is processed based on the following legal reasons stated in Article 5 of LLP;

(i) Clearly stated by law
(ii) Processing of personal data belonging to the parties of a contract, is necessary

provided that it is directly related to the conclusion or fulfilment of that contract.

(iii) Data processing is mandatory for the data controller to fulfil their legal obligation. (iv) Data processing is mandatory for the establishment, exercise or protection of any right (v) Data processing is mandatory for the legitimate interests of the data controller,

provided this processing does not harm the fundamental rights and freedoms of the data subject.

5) Do We Transfer Your Personal Data to a Third Party?

a) Personal data belonging to our visitors can be shared with law enforcement and judicial authorities for the purpose of resolving legal disputes or in order to comply with their legal requests as per the relevant legislation.

b) Personal data of our online visitors can be shared with judicial authorities for the purpose of resolving legal disputes or in order to comply with their legal requests as per the relevant legislation.

c) Personal data belonging to our customers, can be shared with the authorized public institutions and organizations in order to ensure that our operations comply with the legislation, handle and follow-up on legal affairs, to inform the authorized persons, institutions and organizations within the scope of the legal regulations; they are transferred to our group companies, suppliers, cargo companies, IT companies, insurance companies, banks and financial advisors to the extent necessary for the purpose of conducting business operations/auditing, risk management processes and performing our services properly. In addition, the personal data in question may be transferred to the law firm we work with and the judicial authorities, in order to be used as evidence in possible legal disputes in the future.

d) The personal data of our potential customers can be transferred to the law firm we work with and judicial authorities in order to be used as evidence in possible legal disputes in the future.

e) The personal data belonging to our supplier employee, can be shared with the authorized public institutions and organizations in order to ensure that our operations comply with the legislation, handle and follow-up on legal affairs, to inform the authorized persons, institutions and organizations within the scope of the legal regulations, to carry out/supervise business operations; it is transferred to group companies, suppliers, cargo companies, IT companies, banks and our financial advisor to the extent necessary to perform our services properly. In addition, the personal data in question may be transferred to the law firm we work with and the judicial authorities, in order to be used as evidence in possible legal disputes in the future.

f) The personal data belonging to our supplier authority, can be transferred within the scope of the legal regulation to the authorized public institutions and organizations in order to ensure our activities comply with the legislation, to handle and follow up on the legal affairs, to inform the authorized persons, institutions and organizations, to carry out/supervise business operations; it is transferred to group companies, suppliers, cargo companies, IT companies, banks and our financial advisor to the extent necessary to perform our services properly. In addition, the personal data in question may be transferred to the law firm we work with and the judicial authorities, in order to be used as evidence in possible legal disputes in the future.

6) Do We Transfer Your Personal Data Abroad?

As İ.Mak Redüktör, we do not transfer your personal data abroad Turkey.

7) How Can You Exercise Your Rights Regarding Your Personal Data?

Your requests within the scope of Article 11 of the Law on Protection of Personal Data No 6698, which regulates the rights of the data subject, can be conveyed to İ.Mak Redüktör through the “Application Form to Data Controller” prepared for your convenience in accordance with the “Notification Regarding the Application Procedures and Principles of Application to Data Controller” at the address www.imakreduktor.com

Right of Access: You have the right to request a copy of your personal data from our company. A small amount of payment may be requested from you for this activity.

Right to Controvert: If you have any personal data that you think is wrong, you have the right to request our company to correct it. At the same time, if you have any personal data that you think is incomplete, you have the right to request our company to complete it.

The Right to be Forgetten: In some cases, you have the right to request our company to delete your personal data.

Right to Restrict Processing: In some cases, you have the right to request our company to limit the processing of your personal data.

Right to Objection to the Processing Process: In some cases, you have the right to object to the processing of your personal data from our company.

Right to Data Portability: In certain cases, you have the right to request our company to transfer your personal data we obtain to another organization or directly to you.

Data Controller: İ.Mak Redüktör Varyatör San. Tic. A.Ş.

Address: Şeyhli Mah. Sanayi Cad. No:1 Pendik-İstanbul

Mail: [email protected]