GENERAL INFORMATION AND CLARIFICATION TEXT REGARDING THE LAW ON PROTECTION OF PERSONAL DATA (LPPD)

This information and clarification text has been prepared by Kompass Europe in accordance with the Law on Protection of Personal Data No. 6698, accepted on 24/3/2016, and other related legislation, in order to inform and clarify data subjects during the lawful collection, acquisition, storage, sharing, and protection of the confidentiality of personal data.

Within this scope, this information text is presented for your information and review in order to fulfill our obligation to inform you in accordance with Article 10 of the relevant law regarding the data that will be processed lawfully with the conditions and purposes explained below.

Definition of Data Controller:

As defined in Article 3 of Law No. 6698, the data controller is defined as "the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system."

Within this scope, Kompass Europe is responsible as the Data Controller regarding the processing of personal data, and the fulfillment of the obligation to inform and clarify is provided through this clarification text.

Legal Basis and Reasons for Processing Personal Data:

In the event of obtaining personal data explicitly defined in the Law on Protection of Personal Data No. 6698, this data is processed within the scope of Articles 5 and 6 of the relevant Law. In this context, your personal data will be processed based on the following legal reasons. In cases other than the specified legal reasons, your explicit consent will be requested for the processing of your personal data. According to the law, these legal purposes are:

• To be able to provide information when requested by authorized public institutions and organizations, especially when requested by the Courts and authorized public officials.

• To fulfill legal obligations and to exercise rights arising from the current legislation.

• To be necessary for the fulfillment of obligations arising from the establishment, performance, and conclusion of the contract.

• The processing of personal data by Kompass Europe is necessary for the establishment, exercise, or protection of the rights of our party, you, or third parties.

• Processing of data is mandatory for the legitimate interests of Kompass Europe, provided that the fundamental rights and freedoms of the person are protected (due to processes such as conducting satisfaction assessment activities of existing customers, organization and event management, performing financial and accounting transactions, conducting audit processes, carrying out occupational health and safety activities, fulfilling the obligation to notify authorized public institutions such as the Courts, etc.).

• It is necessary for the protection of the life or physical integrity of the person or another person who is unable to disclose his/her consent due to actual impossibility or whose consent is not legally valid.

• Personal data has already been made public by the data subject.

• Data processing is mandatory for the establishment, exercise, or protection of a right.
  
  

Personal Data other than the purposes listed above will be processed by obtaining the explicit consent of the data subject. Personal data acquired and to be processed within the framework of the Law may vary depending on the legal relationship to be established between Kompass Europe and the data subject. Personal data may be collected by Kompass Europe through different platforms (manual methods, verbal/written statements, electronic channels, forms on the Kompass Europe website, or through website visits and usage by entering information such as name, surname, business or private e-mail address, or by logging in with a username and password, activities and events held within Kompass Europe).

Personal Data acquired by Kompass Europe may be obtained, stored, updated, and processed as long as it meets the above conditions and/or explicit consent exists.

Purpose of Collection and Processing of Personal Data

Your Personal Data acquired by us through our website or other means mentioned above will be processed by us for the following purposes according to its nature:

• To carry out the necessary planning, evaluation, and work by our business units to enable our customers to benefit from the products and services we offer as Kompass Europe;

• To carry out advertising and marketing activities for the services we offer, to provide information on similar issues, and to carry out corporate communication activities;

• Carrying out marketing and Customer Relationship Management activities;

• Organizing other events, campaigns, and invitations within the scope of corporate communication and providing information about them, conducting market research studies;

• Improving and personalizing the digital platforms we offer to our customers, and using cookies for this purpose if necessary;

• Following up and evaluating requests, suggestions, and complaints from data subjects, customer management, and planning in this context, and conducting evaluation studies in all areas;

• To ensure the sustainability of all kinds of activities carried out within the scope of Kompass Europe, to make improvements, and to audit the persons and companies with whom we have a contractual relationship;

• Ensuring the legal and commercial security of persons with whom Kompass Europe has a business-service relationship;

• Planning and execution of occupational health and safety processes;

• Using the information in question to exercise legal rights, and using information about the transaction history as evidence in case of a dispute after the termination of the existing legal relationship with the relevant person/institution;

• Carrying out planning, reporting, visitor/customer statistics and similar studies within the scope of activities and/or ensuring compliance with relevant domestic legislation, providing information requested by public institutions and organizations, fulfilling reporting obligations.

• Confirming identity information of visitors, who do transaction on the website/mobile application, or the person on whose behalf the transaction is made, recording other required information like address for communication.

• Ensuring the security of the internet site and other electronic systems and physical environments established by Kompass Europe.
  
  

Rights of the Data Subject

The rights of natural/legal persons whose personal data are processed in accordance with Article 11 of the LPPD are as follows:

• To learn whether personal data is processed or not,

• To request information if personal data has been processed,

• 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 is transferred at home or abroad,

• To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data has been transferred,

• To request the deletion or destruction of personal data in the event that the reasons requiring processing disappear, although it has been processed in accordance with the provisions of the LPPD and other relevant laws, and to request notification of the transaction made within this scope to third parties to whom personal data has been transferred,

• To object to the emergence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,

• To demand compensation for the damage in case of damage due to unlawful processing of personal data.
  
  

In order to exercise the above-mentioned rights, the written request containing the distinctive identity/registration information, the right to be used and the explanations regarding this issue, will be processed if it is sent by registered mail with return receipt to Kompass Europe's Menderes/İZMİR address in accordance with Article 11 of the Law No. 6698.

Evaluation of Data Subject Requests

In accordance with Article 13, Paragraph 1 of the Law No. 6698, requests regarding the exercise of the above-mentioned rights will be concluded free of charge as soon as possible (However, if the transaction requires an additional cost, the fee in the tariff determined by the Board may be charged.) after they are submitted to Kompass Europe in writing or by other methods determined by the Personal Data Protection Board, and feedback will be provided via the contact information you have provided to us.

Links to Third-Party Websites

The Kompass Europe website may contain links to third-party websites. Kompass Europe does not accept any responsibility for the privacy policies of these sites and in no way guarantees that the data protection practices in force on these websites comply with all relevant laws and regulations.