PERSONAL DATA OWNER CLARIFICATION LETTER

INTRODUCTION

HİTAY HOLDİNG A.Ş (“Hitay” or “Company”) is dedicated to fully comply with Law 6698 on the Protection of Personal Data (“KVK Law”) published in Official Gazette 29677 on April 7, 2016, and with the ethical code of conduct of its business sector. It is extremely important for us to protect the privacy and Personal Data of those who participate in the research we conduct as a company and of all parties involved in the process. We show utmost sensitivity regarding the security of your Personal Data.

With this awareness, the processing and preservation of all types of personal data in accordance with the KVK Law is extremely important for us. With the full understanding of this responsibility, we collect, process and store your personal data within the limits specified by the legislation and as defined by the legislation, as described in the KVK Law, as described below. In this context, we will only process your Personal Data within the boundaries of this Clarification Letter to carry out our research.

1. SUBJECT

The subject of this Clarification Letter is to regulate the Company's rights and obligations regarding the processing of Personal Data within the scope of the relevant legislation related to the protection of Personal Data, especially the KVK Law regarding the Personal Data that the Data Owner participates in the general surveys included in the Personal Data Protection Policy.

2. COLLECTABLE DATA

Your collectible data relates to the processing of your Personal Data or Special Qualified Personal Data covered by explicit consent or other circumstances:

a. Your Personal Data; including your name, address, phone number, e-mail address, TR identity information, age, occupation, socio-economic status, information that specifically identifies you, and other similar information;

b. Your Private Personal Data including but not limited to your race, ethnicity, political views, religious or philosophical beliefs, union membership, health or sexual orientation.

3. DATA COLLECTION METHOD AND LEGAL CAUSE REASON

Purposes of Collecting, Processing and Processing Personal Data

Your personal data may vary depending on the service provided by Hitay and the commercial activities of our Company, and your personal data may be collected verbally, in writing or electronically, using automatic or non-automated methods, units and offices, website, social media channels, mobile applications and similar means of Hitay Group Companies.

As long as you benefit from the products and services offered by Hitay Group Companies, your Personal Data may be processed when you use our Company call centers or our website, visit our websites, attend training, seminars or organizations organized by the Company.

In addition, your Personal Data may be processed in order to provide the products and services offered by Hitay Group Companies in accordance with the purposes set out below, and to fulfill their contractual and legal obligations completely and accurately.

The purpose and basis of Personal Data processing of Hitay is the entirety of the objectives stated in the registrations of Hitay Group Companies. In this context, the Personal Data of research participants can be collected and processed for the purposes of Hitay, including but not limited to:

a. Conducting market research and social research; In this context, your participation in the survey research;

b. Verification and updating of our Personal Data records;

c. Responding to questions and requests you direct to us, including not providing the services you request;

d. To ensure that our customers understand the consumers' awareness, usage or satisfaction of various products and services; creating surveys and focus groups to measure public attitude and opinion, designing or testing new products or testing communication effectiveness;

e. Having our business units carry out the necessary work on the services provided by our company;

f. They can be processed within the personal data processing conditions and purposes specified in the 5th and 6th articles of the KVK Law.

Hitay Group Companies will not go beyond these purposes and basis in terms of processing Personal Data.

4. TO WHOM AND FOR WHICH PURPOSES PROCESSED PERSONAL DATA CAN BE TRANSFERRED

The Company may transfer Personal Data of research participants to third parties in the following ways:

a. Sharing with Hitay Group Companies and their affiliates (including those abroad);

b. The necessary works being carried out by our business units to benefit you from the products and services offered by the Company and the legal and natural persons who have business relationships with the Company;

c. Sharing with the suppliers and consultants of the company or in connection with the services provided, and processing by those specified. For example, data collection or processing services to host survey sites;

d. In order for the Company to share with its customers with the approval to be obtained in addition from you;

e. In accordance with applicable law or in response to a subpoena or an public institution's order;

f. Sharing them with the authorized representatives and/or suppliers of Hitay Group companies, which provide services, including but not limited to; data adding services, data verification services, database mapping services, coding services, data segmentation services and services related to rewards, incentives and raffles;

g. Determination and implementation of our company's commercial and business strategies;

h. Provided that the party receiving or obtaining identifying information agrees to use personally identifying information in accordance with this Clarification Letter and to protect and maintain its security, integrity and confidentiality in accordance with this Disclosure Text; in connection with a change of ownership or control, including but not limited to the merger or acquisition of any or all of the Company's commercial assets;

i. Within the framework of the personal data processing conditions and purposes specified in the 8th and 9th articles of KVK Law

The Company maintains the Personal Data it processes correctly and up-to-date, in line with the methods stipulated in the relevant legislation and Board decisions. The Company will delete or destroy Personal Data ex officio or upon the Participant's request, in case the reasons requiring its processing disappear.

5. RIGHTS OF THE DATA SUBJECT DEFINED IN ARTICLE 11 OF KVK LAW

As data subjects, if you submit your requests regarding your rights to our Company by the methods set out below in this Clarification Letter, our Company will conclude your request free of charge within thirty days at the latest. If the answer to the application is given in a recording medium such as CDs or flash memories, the fee that can be requested by the Personal Data Protection Authority will not exceed the cost of the recording medium. In this context, as Data subject, you are entitled to;

a. Learning whether your personal data is processed,

b. If your personal data is processed, requesting relevant information,

c. Learning the purpose of processing your personal data and whether they are used appropriately,

d. Learning the third parties in Turkey or abroad to whom your personal data is transferred,

e. Requesting the correction of your personal data in case of incomplete or incorrect processing of such data, and requesting that the transaction made within this scope be notified to third parties to whom personal data is transferred,

f. Requesting the deletion or destruction of personal data if the reasons for processing them is no longer valid, and requesting that the transaction made within this scope be notified to third parties to whom personal data is transferred, even though they were processed in line with KVK Law and other relevant laws,

g. To object to the emergence of a result against the data owner by analyzing the processed data exclusively through automated systems,

h. If your Personal Data are processed illegally, you are entitled to request that the loss be compensated if you suffer any damages.

6. PROCEDURE OF APPLICATION TO DATA CONTROLLER

To exercise your rights set out above in accordance with the 1st paragraph of Article 13 of the KVK Law and the Communiqué on the Procedures and Principles for Applications to Data Controller; you can fill in the Data Subject Application Form under the Law on the Protection of Personal Data link at www.hitay.com and deliver it by hand or through a notary public or by registered mail to Eski Büyükdere Cad. Özcan Sok. No: 2 34416, 4. Levent/Kağıthane/İstanbul on behalf of the Company concerned, or by scanning the relevant form, you can send it to info@hitay.com by using secure electronic signature, mobile signature or by using your e-mail address, which you previously notified to Hitay and registered in our systems.

Our company may accept the request or refuse it by explaining its reason; we shall notify the answer to the person concerned in writing or electronically. Our company fulfills its requirement in case the request in the application is accepted.

In cases where the application is rejected, the answer given is insufficient or the application is not answered within due time; the data subject, within 30 (thirty) days from the date of our Company's response, and in any case 60 (sixty) days from the date of application, can make a complaint to the Board.

7. SCOPE

This Clarification Letter covers the terms and conditions of the Personal Data Protection Policy published by Hitay on its website.

8. QUESTIONS AND COMPLAINTS

If you have any questions or concerns regarding participation in this Clarification Letter, application or participation in a research, you can contact us via the e-mail address info@hitay.com

You can reach the Personal Data Owner Application Form here .