The Law of Protection of Personal Data

AKTAY LAW FIRM

LEGAL DISCLOSURE ON THE PROCESSING OF PERSONAL DATA

1. About This Legal Disclosure

This Legal Disclosure has been issued to fulfill our legal responsibilities and obligations arising from the Law on Protection of Personal Data No. 6698 (“KVKK”) and other legislation. In accordance with the provisions of the KVKK, Aktay Law Firm, we will act as the data controller. Pursuant to Article 10 of the KVKK, we would like to inform you about how we collect, process, store and share your personal data as a data controller and your rights in this regard.

2. Data Subjects and Your Personal Data

2.1.      Data Subjects

2.1.1.   Visitors of Websites

We process information about IP addresses of visitors in order to classify and evaluate the user data, to understand how the features and functions of the website are used for website analytics and improvements ,and to improve the user experience in a way not violate their fundamental rights and freedoms since such processing is necessary for protection of our legitimate interest in accordance with Article 5/2 (f) of the KVKK.

Our website also contains links to some of our social media accounts. By clicking on the icons of the relevant social media providers on our website, you may also have access to our social media accounts. The relevant social networks may also collect and process your personal data. We have no control over the collected data and their data processing activities. If you access your social media accounts, we recommend that you review the privacy statements and terms of use introduced by the relevant social media providers.

• Clients

Personal data of our clients or their representatives/officials/employees are processed within the framework of the consultancy service or litigation proceedings we carry out with our clients, for the purpose of providing services to our clients, representing our clients, establishing a proxy relationship with our clients, concluding service contracts and performing assignments given by our clients since such processing is directly related to establishment or performance of a contract (contractual necessity) in accordance with Article 5/2 (c) of the KVKK.

Personal data of our clients or their representatives/officials/employees are also processed to manage our business relations with our clients, to communicate with them, to inform them of legal developments and updates in a way not violate their fundamental rights and freedoms since such processing is necessary for protection of our legitimate interest in accordance with Article 5/2 (f) of the KVKK.

• Personal Data

2.2.1. Your Personal Data

1. Identification and contact data:Name, phone number, mail address, e-mail address and contact details.
2. Registration data:Event, conference registrations.

• Client service data: Personal data relating to clients or data received from clients third parties, invoicing details and payment history, and client feedback.

1. Compliance data:Government identifiers, passports or other identification documents, dates of birth.
2. Job applicant data:Data provided by job applicants others on our website or offline means in connection with employment opportunities that may be subject to a separate privacy notice.
3. Device data:Computer Internet Protocol (IP) address, unique device identifier (UDID), and other data linked to a device, and data about usage of our website.

• Your Special Categories of Data

Personal data relating to the race, ethnic origin, political opinion, philosophical belief, religion, religious sect or other belief, appearance, membership to associations, foundations or trade-unions, data concerning health, sexual life, criminal convictions and security measures, and the biometric and genetic data are deemed to be special categories of personal data.

Your special categories of personal data is collected and processed based on your explicit consent in accordance with Article 6/2 of the KVKK for the purposes stated below:

• Special categories of personal data other than health and sexual life, only in cases stipulated by law,
• Health data is only processed for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.

3. Collection of Your Personal Data

We collect the following personal data with automatic methods such as our servers and electronic devices and non-automatic methods such as our document archives, but which are part of a data recording system.

4. Purposes and Legal Reasons for Processing Your Personal Data

Your personal data that you have submitted to Aktay Law Firm is stored by Aktay Law Firm as the data controller in accordance with the basic principles stipulated in the KVKK. Your personal data will be processed by our Law Office in the capacity of data controller, within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK, limited to these purposes.

5. Transfer of Your Personal Data to Third Parties in the Country

Your personal data may be transferred to authorized public institutions and organizations, financial institutions, and service providers from which we receive services, within the scope of the above-mentioned purposes and legal reasons.

6. Transfer of Your Personal Data to Third Parties Abroad

Your personal data is not transferred abroad.

7. Retention Period of Your Personal Data

Your personal data is primarily stored for the periods determined in the legal legislation. If a storage period has not been determined in the legal legislation; We keep your personal data for as long as required by the purpose of processing. A period of 6 months to 1 year for the storage of your data, if any, depending on the purpose of processing, if any, for the storage of your data, taking into account the possibility that a request from a court or an administrative authority authorized by law regarding the relevant data reaches us late, or that a dispute that we may be a party to occurs. The storage period of the data is determined by adding it and at the end of the determined period, the said data is deleted.

1. Your Legal Rights as The Data Subject

Regarding the processing of your personal data; under the Article 11 of the KVVK, we inform you that you can use the following legal rights by applying to Aktay Law Firm as a data controller:

1. to learn whether his/her personal data are processed or not,
2. to demand for information as to if his/her personal data have been processed,
3. to learn the purpose of the processing of his/her personal data and whether these personal,
4. data are used in compliance with the purpose,
5. to know the third parties to whom his personal data are transferred in country or abroad,
6. to request the rectification of the incomplete or inaccurate data,
7. to request the erasure or destruction of his/her personal data under the conditions referred to in Article 7,
8. to request reporting of the operations carried out pursuant to sub-paragraphs (e) and (f) to third parties to whom his/her personal data have been transferred,
9. to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,
10. to claim compensation for the damage arising from the unlawful processing of his/her personal data.

1. Exercise of Your Rights Regarding Your Personal Data

In order for your application to be evaluated, it must meet the conditions in the Communiqué on Application Procedures and Principles to the Data Controller. You can reach the relevant Communiqué at www.resmigazete.gov.tr.

If your applications and requests regarding your personal data meet the conditions in the relevant Communiqué:

1. By sending it to our address info@aktay.av.tr with wet signature and information sufficient to verify your identity,
2. By sending it to the address of ile Yapı Kredi Plaza Kat 11 Beşiktaş, İstanbul with wet signature and information sufficient to verify your identity,
3. With a valid identity document, you can apply to Aktay Law Firm in person and send it to Aktay Law Firm.

1. Response Time of Your Requests Regarding Your Personal Data

Your requests regarding your personal data will be answered within 30 days at the latest from the date they reach us, with the method you applied for.

AKTAY HUKUK BÜROSU

EXPLICIT WRITTEN CONSENT

have fully read, reviewed, evaluated and understood Legal Disclosure (Aydınlatma Metni) prepared and duly submitted to my attention by Aktay Law Firm in accordance with the Law No: 6698 on the Protection of Personal Data and applicable legislation;

have fully understood that personal data shall mean an information relating to an identified or identifiable natural person; and processing of personal data shall mean an operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, disclosure, dissemination, transfer or otherwise making available, alignment, blocking and

have fully and freely agreed, declared and undertaken that I hereby grant my explicit consent for processing of identification and contact data, registration data, client service data, compliance data, job applicant data, device data and my special categories of personal data limited to the purposes defined in the Legal Disclosure.