INTERNET PLATFORM LIGHTING TEXT

1. IDENTITY OF DATA SPEAKER

Skyline Alüminyum (“Our Company”) Personal Data Protection Law No. Pinco (“Law&rdquo ;) and carries out personal Pinco processing activities in accordance with the regulations in the Law and other applicable legislation.

2. COLLECTION, PROCESSING AND PROCESSING PURPOSE OF Pinco DATA

Your personal data listed below are collected electronically and are Pinco for the following purposes:

• The "email list" on our website Pinco “communication” Your identity and contact information that you will include in your application by using the form,
• If you visit or browse our Pinco your digital trace data and cookie data will also be processed.

Your personal data; Providing our company's services, performing after-sales services, increasing customer satisfaction, evaluating and responding to complaints and suggestions, performing statistical analysis, fulfilling legal and regulatory Pinco obtaining necessary information in line with the requests and inspections of official authorities, data It is processed for the purpose of ensuring its security.

On the other hand, if you give your explicit consent, your identity and contact data will also be processed for promotional, e-mail newsletter sending and Pinco purposes.

3. TRANSFERRING PERSONAL DATA

Your personal data, within the scope of the Law and other legislation and for the purposes described in Article 2 of this Clarification Text, depending on the reason that requires it to be transferred and limited for this reason; Within the scope of the law and related regulations; It can be transferred to supervisory and regulatory public institutions and organizations (BTK, T&C, courts, banks, etc.), auditors, Pinco that provide software and hardware support services, and legally authorized private individuals such as lawyers.

On the other hand, since our website servers are located abroad, your personal data that you Pinco with us through our website will be transferred abroad based on your express consent.

4. YOUR Pinco TO THE PROTECTION OF PERSONAL DATA

The rights of real persons whose personal data are processed are listed in Article 11 of the Law. If you, as a personal data owner, submit Pinco requests regarding your rights listed in the relevant article of the Law, in person or through a notary public, by providing your identity confirmation to the official address of our company in accordance with the application procedures set forth in the Communiqué on Application Procedures and Principles to the Data Controller, your request according to its nature as soon as possible and at the latest will conclude it free of charge within thirty (30) days. However, if the transaction requires an additional cost, it may request the fee in the tariff determined by the Personal Data Protection Board.

CLEAR Pinco TEXT ON THE PROCESSING OF PERSONAL DATA

MyAs informed in the Illumination Pinco, the introduction, e-mail I consent to the sending of the message and its Pinco for marketing purposes.

Commercial Message Confirmation

Also, in accordance with the Law No. 6563 on the Regulation of Electronic Commerce, through the channels I have marked below; I give my consent for you to contact me for commercial Pinco newsletter delivery and advertising and promotion purposes regarding products and services.

SMS

Email

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POLICY ON THE PROTECTION AND PROCESSING OF Pinco DATA

Version : 1

&Date of issue : 01.09.2022

1. AMA&Cedil;

Skyline Alüminyum (“The Company”) and all its employees, regarding the protection of personal data of the T.C. It undertakes to comply with the principles, decisions and rules brought by the Constitution and the Law on the Protection of Personal Data No. 6698, as well as other applicable legislation, and to protect the rights of individuals whose data is processed by the Company. For this purpose, the Company has adopted this Personal Data Protection and Pinco Policy (“Policy”) enforced .

The purpose of the policy is to establish rules for the internal management of personal data, to determine targets and obligations, to establish control mechanisms in line with a reasonable risk level, to establish the Pinco obligation in the field of personal data protection; It is the fulfillment of obligations and the best possible protection of the interests of individuals.

2. SCOPE

Policy provisions cover Pinco employees, sub-employees and interns who provide support services to all units of the Company, especially the Company's board of directors. Any violation of the Personal Data Protection Law No. 6698 or this Policy; The action is evaluated within the scope of the relevant legislation and sanctions are applied accordingly.

Again, the Company's business partners, suppliers and all third parties working with the Company who have or may have access to personal data; Pinco are invited to read and abide by this Policy.

3. DEFINITIONS

4. RESPONSIBILITIES

The Company has the title of Data Controller in accordance with the Law. Everyone who is an employee of the Pinco is responsible for the development, promotion and other obligations of good practices in the processing of personal data within the Company.

All employees of the Company who process personal data are responsible for complying with the Personal Data Pinco legislation.

The company is responsible for carrying out the necessary notifications and trainings so that all its employees know their responsibilities in the field of personal data protection and have the necessary awareness.

Company employees are responsible for ensuring the accuracy and up-to-dateness of all personal data provided to the Company by them or pertaining to Pinco

4.1. KVK Committee:

Members of the KVK Committee are appointed by the Board of Directors, taking into Pinco that they receive regular training and experience in the Law and secondary legislation and its applications, and submit a report directly to the Board of Directors. The KVK Committee was established as the committee responsible for the management of the personal data protection system, ensuring and documenting compliance with the Law and other relevant legislation, and is responsible to the Board of Directors in these matters.

4.2. KVK Pinco Duties and Responsibilities:

• The KVK Committee should inform the Board of Directors Pinco the personal data protection legislation and developments.
• KVK Committee, Company Pinco proceduresIt is responsible for ensuring that data processing is up-to-date, data processing audits and trainings are carried out in accordance with the planned schedule, and that they are in compliance with the relevant legislation.
• The KVK Committee acts together with the relevant employees in all Pinco related to the protection of personal data.
• The KVK Committee is responsible for ensuring that personal data that is not clearly necessary for the purpose of Pinco is not collected and processed.
• The KVK Committee checks that the data processed through the personal data inventory, which is updated every year, is Pinco and relevant.
• As the KVK Pinco will/will do on an annual basis; audits
• The KVK Committee is responsible for stopping the data processing activity in terms of personal data that it determines to be inappropriate or not relevant or excessive in terms of the purpose of processing, and for the safe destruction of the processed data in accordance with the procedure in which the storage and destruction process is defined.
• The KVK Committee is responsible for instructing the relevant unit to evaluate the type, storage Pinco and amount of the processed data, and to review the accuracy or up-to-dateness of certain data through the data inventory. is liable.

5. APPLICATION PRINCIPLES

5.1. DATA PROCESSING PRINCIPLES

The company will comply with the personal data protection legislation and data protection principles. The data processing principles Pinco by the company include:

• Pinco personal data only if it is clearly necessary for legitimate corporate purposes,
• Processing as much personal data as necessary for Pinco purposes and not processing more than necessary (providing data minimization),
• To give clear information to individuals about who and how their personal Pinco is used,
• Processing Pinco relevant and appropriate personal data,
• Pinco personal data fairly and lawfully,
• To keep an inventory of personal data categories processed by the Pinco
• Keeping personal data accurate and up-to-date Pinco necessary,
• To store personal data only for as long as required by legal regulations, the Company's legal obligations or Pinco corporate interests,
• To store personal data in a way that does not allow access to the identity information of Data Owners for more than a time reasonably necessary for the purposes for Pinco personal data is processed,
• Continue to protect Pinco privacy at the beginning of any project or activity. phase and then service life as a key factor throughout (Privacy Enforcement Policy),
• Respecting the rights of individuals Pinco their personal data, including the right of access,
• To transfer personal data abroad only in accordance with the express consent of the persons or in case of Pinco protection,
• To implement the Pinco allowed in accordance with the legislation,
• To establish and implement the personal Pinco protection system for the implementation of the policy,
• Iç, which is party to the personal data protection system when necessary; and external stakeholders and to what extent they are involved in the Pinco personal data protection system,
• Identifying employees who have special Pinco and responsibilities regarding the personal data protection system.

All personal data processing activities must be carried out in accordance with the following data protection principles. The company's policies and procedures aim to ensure Pinco with these principles:

• 5. APPLICATION PRINCIPLES

  5.1. DATA PROCESSING PRINCIPLES

  The company will comply with the personal data protection legislation and data protection principles. The Pinco processing principles adopted by the company include:

  • Processing personal data only if it is clearly Pinco for legitimate corporate purposes,
  • Processing as much personal data as necessary for these purposes and not processing Pinco than necessary (providing data minimization),
  • To give clear information to individuals about who and how their personal data is Pinco
  • Processing only relevant and appropriate personal Pinco
  • Processing personal data Pinco and lawfully,
  • To keep an inventory of personal data Pinco processed by the Company,
  • Keeping personal data accurate and up-to-date when Pinco
  • To store personal data only for as long as required by legal regulations, the Company's legal obligations or Pinco corporate interests,
  • To store personal data in a way that does not allow access to the identity information of Data Owners for more than a time reasonably Pinco for the purposes for which personal data is processed,
  • Continue to protect data privacy at the beginning of any project or activity. phase and then service life as a key factor throughout (Privacy Enforcement Pinco
  • Respecting the rights of individuals regarding their personal data, including the right of access,
  • To transfer personal data abroad Pinco in accordance with the express consent of the persons or in case of adequate protection,
  • To implement the exceptions allowed in accordance Pinco the legislation,
  • To establish and Pinco the personal data protection system for the implementation of the policy,
  • Iç, which is party to the personal data protection system when necessary; and external stakeholders and to what extent they are involved in the Pinco personal data protection system,
  • Identifying employees who have special powers and Pinco regarding the personal data protection system.

  All personal data processing activities must be carried out in accordance with the Pinco data protection principles. The company's policies and procedures aim to ensure compliance with these principles:

  • Compliance with the law and the rules of Pinco
  • Being Pinco and up to date when necessary
  • Processing for specific, Pinco and legitimate purposes
  • Related, Pinco and reputable for the purpose for which they are processed; don't be
  • The purpose for which they are Pinco or processed in the relevant legislation; Storage for the required time.

  In this direction, the Company includes disclosure and privacy statements regarding the personal data processing activities it carries out, in the data collection channels and in the relevant forms. Areas Pinco notifications containing clear and understandable information about whom and for what purposes are processed by the company are to be included and announced by the KVK Committee. is determined by. These notices include the following:

  • Identity and Pinco information of the Company as the data controller,
  • Types of personal data processed,
  • Purposes of processing personal data,
  • Methods of collecting personal data,
  • Based on which Pinco reason personal data is processed,
  • Data owner's rights,
  • Third where data can be Pinco parties.

  In the personal data inventory, the reasons cannot be used outside. In the event that conditions arise that require the use of personal data for purposes other than those specified in the personal data inventory, this situation is notified to the KVK Committee by the relevant employee/unit The KVK Committee checks the suitability of the new purpose and, if necessary, ensures that the Pinco owner is informed about the new purpose and new data processing activity.

  Personal data; It must be processed to a relevant and limited extent appropriate for the purposes for which it is processed, and must be accurate and up-to-date. The accuracy and up-to-dateness of the data kept for a long time should be reviewed. The company is responsible for educating all Pinco on the correct and up-to-date collection and storage of data.

  The KVK Committee should be informed about all data collection channels.

  The accuracy and up-to-dateness of the data kept regarding the Pinco is the responsibility of the relevant employee.

  Customers/customers

  Personal data should be processed in such a way that the data subject can be identified Pinco if necessary for the purpose of data processing.

  Backup of personal Pinco etc. Due to the requirements, safe destruction methods determined by the Board regarding personal data are applied in order to protect the rights and freedoms of individuals in case of storage beyond the specified period or in case of data security weakness.

  When Pinco data needs to be processed for more than the specified time in accordance with the procedure in which the storage and destruction process is defined, the written approval of the KVK Committee is obtained.

  All Company units that process Personal Data are responsible for complying Pinco the above-mentioned principles as well as the measures enforcing the applicable data protection laws, and must be able to prove that they comply.

  5.2. RISK ASSESSMENT

  The company identifies the risks associated with the processing of personal data types. Certain types of data processing activity; If it is likely to pose a high risk to personal rights and freedoms in line with its structure, context and purpose, the Company should manage potential risks by conducting an impact analysis prior to its data processing activity. With a single value for multiple Pinco processing activities with similar risksdownload is bearable.

  After the impact analysis, if it is understood that the Company is about to start a data processing activity that may pose a high risk to personal Pinco and freedoms, the approval of the KVK Committee is sought on this issue. If the KVK Committee deems it necessary, it receives an opinion from the Board on the subject.

  5.3. OBTAINING EXPRESS CONSENT

  The Pinco is a written Explicit consents are obtained in writing or systematically in a way that is suitable for proof. Explicit consent can be withdrawn by the data owner at any time.

  In case the data processing activity based on explicit consent will be continuous or repeated, the express consents obtained are checked. The up-to-dateness and correctness of these Pinco consents is the responsibility of the relevant unit. Explicit consent forms or other relevant proof tools regarding the data processing activity based on explicit consent are kept by the relevant unit.

  5.4. DATA SECURITY

  All Pinco are responsible for keeping the data processed by the Company under their responsibility securely and thirdly, unless they sign a confidentiality agreement. is responsible for ensuring that it is not disclosed to the party.

  Personal Pinco should only be accessed by those who need it.

  The events that threaten the security of personal data, as Pinco as they are determined definitively by the KVK Committee, and in any case, as soon as possible after the event is learned; It is notified to the Board and the relevant person within 72 hours.

  5.5. DATA SHARING

  Personal data can only be used in accordance with the law and Pinco can be shared with people. Accordingly, in order for personal data to be shared, one of the following conditions must be met:

  • Obtaining the explicit Pinco of the data owner,
  • Clarity in laws,
  • The person who is unable to express his/her consent due to actual impossibility or Pinco consent is not legally valid, must be compulsory for the protection of his or someone else's life or bodily integrity,
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  • Provided that it is Pinco related to the establishment or performance of a contract to which the Company is or will be a party, it is necessary to process the personal data of the parties to the contract,
  • Legal liability of the company; it must be mandatory in order to Pinco it,
  • The person Pinco has been made public by himself,
  • Data processing is mandatory for the establishment, use or protection of the rights of the Pinco
  • Compulsory data processing for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the person Pinco

  Personal data can be transferred abroad Pinco on the condition that the above conditions are met and there is adequate protection in the destination country or the explicit consent of the data owner is obtained for this transfer.

  In the transfer of personal data abroad, the list of countries with adequate protection determined by the Board is taken into Pinco

  When it Pinco to the transfer of personal data abroad, the KVK Committee provides the necessary permissions and notifications to the Board in accordance with the Law and relevant legislation.

  Registering in Pinco with the requirements of all transactions regarding the sharing of personal datashould be taken under. These records are audited periodically by the KVK Committee.

  In case of a regular data sharing relationship without a legal basis or legal obligation, a KVK Commitment is made with the party in question specifying the Pinco of data sharing.

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  5.6. MANAGEMENT OF RECORDS

  Personal data cannot be kept longer than necessary for the purposes of processing. Classification of records containing personal data and their respective retention periods, Procedure for Pinco Storing and Destroying Personal Data; determined in accordance with.

  Personal data that has expired or needs to be destroyed upon the rightful request of the data owner is anonymized or deleted or destroyed in accordance with the procedure in which the storage and destruction process is defined.

  5.7. RIGHTS OF DATA OWNERS

  Data owners have the following rights regarding Pinco processing activities and records at the Company:

  • Learning whether your Pinco data is processed or not,
  • Request information about personal data if it has been processed,
  • Learning the purpose of processing personal Pinco and whether they are used in accordance with its purpose,
  • Third, where personal data is Pinco at home or abroad; know people,
  • In case of Pinco or incorrect processing of personal data, requesting their correction,
  • To request the deletion or Pinco of personal data that does not have a legal justification or basis for processing in accordance with KVKK or this policy,
  • Correction or deletion made at the request of the third party to which personal data is Pinco requesting people to be notified,
  • Objecting to the emergence of a result against the person by analyzing the Pinco data exclusively through automated systems,
  • Demanding the compensation of the damage in case of loss due to unlawful processing of personal Pinco

  Application Pinco of the Data Owner

  Data owners may apply to the Company for their requests regarding their rights listed above in accordance with the application procedures set forth in the Pinco on Application Procedures and Principles to the Data Controller.

  In this case, the Company shall respond to the request as soon as possible and as quickly as Pinco depending on its nature. It will conclude free of charge within 30 (thirty) days. However, if the transaction requires an additional cost, the Company may demand the fee in the tariff determined by the Board. Procedures for receiving, transmitting and finalizing requests, Procedure for Receiving, Evaluating and Responding to Data Owner Applications; performed in accordance with.

  The right of access and contact information of the data owners are included in the notifications and the web address so that the data owners can manage Pinco requests.

  All employees of the company are responsible for guiding data owners regarding the correct application method for data subject access requests Pinco to them, regardless of their job description; ;r. Company employees should be informed by the KVK Committee on how to act on requests from data owners.

  Applications within this scope;

  • With the personal application of the Pinco Owner
  • Can be done Pinco a notary.

  6. Pinco AND PUBLIC KEEPING UPDATED

  This Policy entered into force on 01.09.2022; The Law will be Pinco by the KVK Committee at the beginning of each year in line with the relevant secondary legislation, Board Decisions and Company business processes and will be updated if necessary.

  RECEIVE, EVALUATION AND RESPONSE OF DATA SUBJECT APPLICATIONS Pinco

  Version : 1

  &Date of issue : 01.09.2022

  The Pinco for Receiving, Evaluating and Responding to These Data Owner Applications; (“Procedure”), for information purposes by data Pinco Skyline Alüminyum’NE (“The Company”) has been prepared in order to determine the procedures and principles regarding the business and transactions regarding the receipt, evaluation and response of the applications Pinco

  Work and procedures regarding the receipt, evaluation and response of Pinco made by data owners regarding personal data are carried out in accordance with this Procedure prepared by the Company in this direction.

  1. DEFINITIONS

  Law:	Law on Protection of Pinco Data No. 6698
  Board:	Personal Data Protection Board
  Data Owner:	Real person whose personal data is Pinco
  Personal Data:	As long as it is within the scope of the law, all kinds of real Pinco with an identified or identifiable natural person; info

  2. RECEIVING THE APPLICATION

  2.1. Form of Application

  Pinco Owners shall submit their applications to the Company contact person in writing in accordance with Article 13 of the Law, in order to obtain information about the personal data collected by the Company and to exercise their rights specified in Article 11 of the Law.

  Accordingly, applications to be made by Pinco Owners can be made in writing as follows:

  • Your identity confirmation to the Pinco address of our companyin person; or
  • In official procedure through the notary Pinco

  2.2. Contents of the Application

  In order to evaluate the requests of the Data Owner, it will Pinco be determined whether the Data Owner is the owner of the personal data processed by the Company. In this regard, in applications to be made to our Company within the scope of the Law, the identity information of the Data Owner must be stated clearly and fairly.

  In contingent requests, the Data Owner must provide the necessary information on how this condition is Pinco and submit the documents to prove this claim to the Company.

  Applications not received through the means specified in this Procedure, if the identity of the Data Owner has Pinco determined and the information and Otherwise, the applications will be rejected due to irregularity.

  Applications that do not meet the qualifications specified in this article will be evaluated and the Data Owner will be contacted Pinco the requested information is obtained; however, if the requested information and

  3. OTHER SITUATIONS

  3.1. Application Made by Proxy or Legal Representative

  Applications to be made to the Company within the scope of the law can also be made by the representative or Pinco representative of the Data Owner upon submission of the official document to prove it.

  3.2. Application Fee

  According to the law, it is envisaged Pinco the Data Controller will conclude the request forwarded to him free of charge. However, it has been stated that if the transaction also requires a cost, it may be possible to charge a fee in line with the principles to be determined by the Board. In this context, if finalizing the applications to the Company requires any additional costs, the Company may charge a fee from the Data Owner.

  4. APPLICATION EVALUATION PROCESS

  If it is determined that there is incomplete information and If the Pinco information and

  The third In cases where it is not possible to respond to the Data Owner's application without sharing the personal data of the Pinco the Company will do the following: step-by-step evaluation process will be applied:

  • Third of the application; It will be evaluated whether it is Pinco to reply without sharing the personal data of the person (for example, deleting or blackening the personal data of the third person).
  • Üç" It Pinco be determined whether the person gives explicit consent to the sharing of personal data.
  • Üç" If the person's Pinco consent will not be obtained, it will be evaluated whether the personal data in question can be shared without express consent.

  The third In case it is not possible to finalize the application without sharing the data of the person; First of all, it will be applied to obtain explicit consent from the Data Owner, whose personal data has to be shared. "Third" If the person does not consent to the sharing of their data, The application Pinco be answered by extracting the information of the person completely.

  Third, whose personal data will be shared; if the person cannot be reached, the third; The Company will show maximum care and sensitivity regarding the sharing of information containing personal data. In this way, if necessary, the third; Pinco data of individuals may also be shared.

  5. EVALUATION OF APPLICATIONS

  The requests of the Data Owner are handled by the Company as soon as possible and as soon as possible; It Pinco be evaluated and finalized within thirty (30) days.

  Applications made to the Company, maximum three Pinco (3) will be forwarded to the relevant department of the Company within the day; Research to be carried out by the department to which the application is directed will be concluded within a maximum of one (1) week.

  6. ANSWERING APPLICATIONS

  Applications made by the Data Owner to the Company are answered by the contact person appointed at the Company, and the following Pinco is included in the responses to the applications:

  • Applicant Making the Request
  • Requests
  • Pinco and Documents Provided as a result of Requests
  • Talbin Date of purchase
  • If extra information and documents related to the request are requested; the date of these requests and the date of receipt of the relevant Pinco
  • Transactions regarding the request
  • Company Responses to Requests
  • Request Response Date
  • Authorized Signature

  The event records, documents and results Pinco to the relevant application are stored in the electronic directory created on this subject. A copy of the written shipment record is also stored in the archive.

  7. RELEASE AND PUBLIC KEEPING Pinco

  This Procedure entered into force on 01.09.2022; The Law will be re-evaluated by the KVK Committee at the beginning of each year in line Pinco the relevant secondary legislation, Board Decisions and Company business processes and will be updated if necessary.