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HARD SHIELD BRM PERSONAL DATA PROTECTION AND PROCESSING POLICY

1. PURPOSE AND SCOPE

In each of our businesses within the scope of HARD SHIELD BRM, maximum sensitivity is given to the security of personal data. With this awareness, we attach great importance to the processing, recording, transfer, sharing and storage of all kinds of personal data belonging to all persons related to our Companies, including those who benefit from our products and services, in accordance with the Law on the Protection of Personal Data No. 6698 (“KVK Law”). In line with the importance HARD SHIELD BRM attaches to the protection of personal data, the basic principles regarding the compliance of the HARD SHIELD BRM KVK Policy and the activities carried out by HARD SHIELD BRM with the regulations in the "KVK Law" are determined. With the implementation of the HARD SHIELD BRM KVK Policy regulations, the data security principles adopted by HARD SHIELD BRM will be made sustainable. HARD SHIELD BRM KVK Policy is for natural persons and HARD SHIELD BRM employees, whose personal data are processed by automatic and non-automatic means, provided that they are part of any data system.

2. TARGET

With the HARD SHIELD BRM KVK Policy, it is aimed to establish the necessary order to establish the necessary systems and to ensure compliance with the legislation in line with the goal of raising awareness about the legal processing and protection of personal data within the scope of HARD SHIELD BRM. In this context, HARD SHİELD BRM KVK Policy aims to guide the implementation of the regulations set forth by the KVK Law and the relevant legislation.

3. DEFINITIONS

The definitions used and important in the HARD SHİELD BRM KVK Policy are as follows:

Explicit Consent: Consent about a specific subject, based on information and expressed with free will. Anonymization: Making personal data incapable of being associated with an identified or identifiable natural person in any way, even by matching it with other data.

Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Lighting Obligation: Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Lighting Obligation, which was published in the Official Gazette dated 10 March 2018 and numbered 30356. Employee(s) HARD SHIELD BRM employee(s). Customer(s) benefiting from HARD SHIELD BRM services.

Regulation on the Processing of Personal Health Data: Regulation on the Processing of Personal Health Data and Ensuring Privacy, published in the Official Gazette dated 20 October 2016 and numbered 29863.

Personal Health Data: All kinds of information about the physical and mental health of an identified or identifiable natural person, and information about the health service provided to the person.

Personal Data: Any information relating to an identified or identifiable natural person.

Personal Data Owner: The natural person whose personal data is processed. E.g; customers and employees

Personal Data Protection Unit: The unit that will provide the necessary coordination within the Company within the scope of ensuring, maintaining and maintaining compliance with the personal data protection legislation by HARD SHİELD BRM.

Processing of Personal Data: Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available personal data by fully or partially automatic or non-automatic means provided that it is a part of any data recording system, All kinds of operations performed on data such as classification or prevention of use.

KVK Law: Law No. 6698, dated March 24, 2016, published in the Official Gazette dated 7 April 2016 and numbered 29677.

KVK Board: Personal Data Protection Board.

KVK Authority: Personal Data Protection Authority. KVK Compliance

Program: A program to ensure compliance with the legislation on the protection of personal data, put into effect by HARD SHIELD BRM.

Special Qualified Personal Data: Data related to race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data .

HARD SHIELD BRM : All companies included in HARD SHIELD BRM.

HARD SHIELD BRM Business Partners: Parties with which HARD SHIELD BRM has business partnerships for various purposes while carrying out its commercial activities.

HARD SHIELD BRM Personal Data Retention and Disposal Policy: In accordance with the Regulation on the Deletion, Destruction, Anonymization of Personal Data, for the process of determining the maximum time required for the purpose for which personal data is processed, and for deletion, destruction and anonymization. “HARD SHIELD BRM Personal Data Retention and Disposal Policy” on which it is based. HARD SHIELD BRM Suppliers Parties that provide services to HARD SHIELD BRM on a contractual basis.

HARD SHİELD BRM Data Owner Application Form: The application form that data owners will use when using their applications regarding their rights in Article 11 of the KVK Law.

Data Processor: The natural and legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller.

Data Controller: The person who determines the purposes and means of processing personal data and manages the place where the data is kept systematically.

Data Controllers Registry: The Data Controllers Registry, which is open to the public and kept under the supervision of the Personal Data Protection Authority, under the supervision of the KVK Board. Communiqué on Procedures and Principles of Application to Data Controller: Communiqué on Procedures and Principles for Application to Data Controller, which came into force after being published in the Official Gazette dated 10 March 2018 and numbered 30356.