Privacy Policy: Clarification Text on Personal Data Processing

At Alkataş İnşaat ve Taahhüt Anonim Şirketi (“Company”), we place the utmost importance on the security and privacy of your personal data. We strive to implement highest-level security measures to process and safeguard this information. In our capacity as the "data controller" and in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and relevant legislation, we process your personal data within the scope outlined below.

The Alkataş İnşaat ve Taahhüt Anonim Şirketi Clarification Text on the Processing of Personal Data (“Clarification Text”) has been prepared in the most transparent manner pursuant to Article 10 of the KVKK, titled “The Data Controller's Obligation to Inform”. It is designed to fully brief you on the identity of the data controller, the methods and legal grounds for collecting your personal data, the purposes of processing, the potential recipients and purposes of data transfers, the processing duration, and your rights listed under Article 11 of the KVKK. All references to "Your Personal Data" in this Clarification Text also encompass your "Special Categories of Personal Data".

1- Method and Legal Grounds for Collecting Your Personal Data:

Your personal data may vary depending on the nature of your relationship with our Company. It can be gathered through automated or non-automated channels, in verbal, written, or electronic formats, via our Company’s associated departments, website, social media channels, call center, mobile applications, and similar platforms. Your personal data will be processed, updated, and securely stored in both digital and physical environments throughout the duration of your relationship with our Company.

Your personal data may be processed and transferred in line with the purposes outlined in Section 2 below, and within the scope of the conditions and purposes of processing personal data specified in Articles 5 and 6 of Law No. 6698.

2- Purposes of Processing Your Personal Data:

Your collected personal data will be processed for the following purposes:

• Enabling our relevant business units to carry out the necessary operations so that real and/or legal third-party institutions and organizations associated with our Company can benefit from the premium products and services offered by our Company and/or its affiliates,

• Ensuring the safety of life and property, as well as legal, commercial, and occupational health and safety, for real and/or legal third-party institutions and organizations located at our Company’s headquarters, construction sites, centers, and units,

• Fulfilling legal and regulatory requirements and taking necessary precautions under all applicable laws and secondary regulations, including Labor Law No. 4857, Turkish Commercial Code No. 6102, Turkish Code of Obligations No. 6098, Law on Consumer Protection No. 6502, Occupational Training Law No. 3308, Occupational Health and Safety Law No. 6331, Law on Protection of Personal Data No. 6698, Law No. 5651 on Regulation of Publications on the Internet and Combating Crimes Committed Means of These Publications, Tax Procedure Law No. 213, Social Insurance and General Health Insurance Law No. 5510, Basic Health Services Law No. 3359, Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliates, Private Hospitals Regulation, Regulation on Processing and Protection of Privacy of Personal Health Data, etc.,

• Executing auditing and/or regulatory duties carried out by authorized public institutions, organizations, and professional organizations with the status of public institutions,

• Fulfilling information and document requests made by judicial organs and/or administrative authorities,

• Performing listing, reporting, and validation analysis regarding the usage of products and services offered across our Company and todos our centers and units; generating statistical and scientific insights, developing our products and services accordingly, boosting customer satisfaction, and tailoring user experiences,

• Conducting market research, promotion, and essential briefings regarding our products and services; evaluating complaints and suggestions, and contacting you directly via the communication channels shared with our Company,

• Sustaining all workflows such as academic training, scientific research, project applications, and brand operations including transfers, publications, and consultations under the FSEK and Industrial Property Law,

• Executing all Human Resources processes and corporate policies of our Company,

• Determining, developing, and implementing the administrative and academic steps, business strategies, and legal compliance workflows of our Company,

• Carrying out accreditation and performance evaluation studies for our Company and its associated centers and units,

• Planning, managing, and invoicing the financing of all services rendered,

• Enhancing the training and professional development of all employees,

• Fulfilling requests for participation in corporate events, seminars, and training programs,

• Carrying out risk management and quality improvement activities,

• Fulfilling rights and obligations including offers, promotions, and exemptions provided within the framework of agreements with contracted private insurance companies and/or other partner institutions,

• Taking all necessary technical and administrative measures for systems and applications under data security protocols,

within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

3- To Whom and For What Purpose Your Processed Personal Data May Be Transferred

In accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and relevant legislation, your personal data—processed strictly within the scope of the purposes specified in Section 2 of this "Clarification Text" and in compliance with the "General Principles" in Article 4, "Conditions for Processing Personal Data" in Article 5, and "Conditions for Processing Special Categories of Personal Data" in Article 6 of the KVKK—may be transferred to ALKATAŞ İNŞAAT VE TAAHHÜT ANONİM ŞİRKETİ and/or its affiliates, legally authorized public and/or private third-party institutions and organizations, business partners, subcontractors, franchisees, suppliers, and domestic and/or international third parties from whom service is contractually acquired or with whom collaboration is maintained to carry out our premium products and services, within the framework of the data processing conditions and purposes specified in Articles 8 and 9 of the KVKK.

4- Data Processing Duration:

Your personal data will be processed strictly for the purposes specified in Section 2 of this Clarification Text, adhering to the data processing and statutory limitation periods stipulated in all laws and other legal regulations to which our Company and its affiliates are subject. In the event of modifications to data processing durations within the laws, the newly defined periods shall be taken as the basis.

5- Rights of the Personal Data Owner Listed under Article 11 of the KVKK:

Without prejudice to the cases provided in Article 28 of the KVKK titled "Exceptions", you may apply to our Company under Article 11 of the Law to exercise your rights regarding your personal data to:

a) Learn whether your personal data is being processed,

b) Request information if your personal data has been processed,

c) Learn the purpose of processing and whether they are being used in line with that purpose,

d) Know the third parties to whom your personal data is transferred domestically or abroad,

e) Request correction if your personal data is processed incompletely or inaccurately,

f) Request deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the Law,

g) Request notification of the operations carried out pursuant to subparagraphs (e) and (f) to the third parties to whom your personal data has been transferred,

h) Object to any outcome against you resulting from the analysis of your processed data exclusively through automated systems,

i) Demand compensation for damages in the event that you suffer harm due to unlawful processing of your personal data.

Applications can be made in writing or electronically using the methods below, after filling out the 'Data Subject Application Form' available on our Company's website at 'alkatas.com.tr'.

For written applications:

You may submit a wet-signed copy of the Data Subject Application Form in person with a verifying ID document, or through a notary-certified power of attorney proving your authorization to apply for the rights listed under Article 11, or send it via a notary public to the address: 'Ertürk Sok. NO:1 K1 Plaza Beykoz - İstanbul'.

For electronic applications:

You can sign the Data Subject Application Form with an electronic or mobile signature possessing a "secure electronic signature" certificate as defined in the Electronic Signature Law No. 5070, and send it to our KEP (Registered Electronic Mail) address: ".........". Alternatively, you may send it via the email address you previously shared with and registered in our Company’s systems, or through software/applications specifically developed by our Company for application purposes.

Your requests submitted to our Company will be answered in writing or electronically as soon as possible and no later than thirty days depending on the nature of your request, subject to the processing fee determined under Article 7 of the Communiqué on the Procedures and Principles of Application to the Data Controller.