INFORMATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

ICI TEKNOLOJİ SAN. TİC. A.Ş.
INFORMATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

At ICI Teknoloji San. Tic. A.Ş. ("ICI Teknoloji"), we highly value the protection of your personal data and expect the same sensitivity from you. It is crucial for us that you carefully read this document, which details what personal data we use and for what purposes, as well as understand the responsibilities of ICI Teknoloji, which is responsible for ensuring the administrative and technical security of this data as the “Data Controller.”

Your Personal Data Will Be:

• Processed within the scope of purposes requiring their processing, and in a manner that is relevant, limited, and proportionate to these purposes,
• Maintained for accuracy and kept up-to-date, as provided or reported by you,
• Recorded, stored, safeguarded, re-organized, and shared with institutions authorized to request such data under the law,
• Transferred, disclosed, classified, and processed in other forms as stipulated under the Personal Data Protection Law (KVKK) and applicable legal conditions, including to domestic and foreign third parties.

Why Am I Reading and Approving This Document?

Article 10 of the “Personal Data Protection Law” (KVKK) No. 6698, published in the Official Gazette dated April 7, 2016, and numbered 29677, requires that individuals whose personal data is processed (referred to as "Data Subjects" in KVKK) be informed by the “Data Controller” processing (using) such data.

As a Data Controller, ICI Teknoloji is obligated to demonstrate that these individuals have been duly informed.

Methods for Collecting Personal Data

Your personal data may be collected on behalf of ICI Teknoloji A.Ş. by natural or legal persons processing data using various methods, including but not limited to:

• Membership forms completed in electronic or physical formats,
• Contact forms filled out on our websites or third-party platforms for communication purposes,
• Various contracts signed with our company and emails, faxes, and letters sent to us,
• Social media channels and search engines,
• Membership agreements, applications, forms, and proposals.

Additionally, video recordings of our visitors are collected via a camera monitoring system at our buildings and facilities’ entrances and within the premises. The purposes of this monitoring include enhancing the quality of the services offered, ensuring reliability, and safeguarding the security of the company, visitors, and other individuals.

Camera surveillance records are stored in digital environments and are accessible to a limited number of authorized employees. ICI Teknoloji has taken the necessary technical and administrative measures under Article 12 of the KVKK to ensure the security of the personal data obtained through camera monitoring activities.

Personal Data Used

ICI Teknoloji processes the following categories of your personal data:

Parties with Whom Personal Data May Be Shared, Reasons for Usage, and Purposes of Sharing

By accepting this Information Text on the Processing and Protection of Personal Data, as the Data Subject, you consent to the processing of your data shared with us, with your explicit consent. This processing allows us to provide you with various benefits, deliver personalized events, career offers, announcements, surveys, and other forms of electronic communication or messages for purposes outlined in this document, in accordance with Article 8 of the Personal Data Protection Law (KVKK).

Personal data shared through written or verbal communication channels with ICI Teknoloji may be processed automatically in verbal, written, or electronic forms, provided it does not harm the fundamental rights and freedoms of the data subject. These processes are carried out based on legal grounds under Articles 5 and 6 of the KVKK for purposes including, but not limited to:

• Conducting operational activities,
• Collaborating with business units and partners,
• Managing human resources to protect, enforce, and fulfill the rights of individuals,
• Ensuring the legal security of our company and the individuals we establish business relationships with arising from these relationships,
• Taking necessary steps to ensure compliance and execution of agreements.

Your personal data will be processed and stored in line with the purposes stated in this document and not used outside the scope defined herein. Appropriate information security measures will be implemented to safeguard the data.

Through your explicit consent, your personal data may be processed for purposes connected to the objectives stated above, ensuring its lawful use and protection.

Purposes for Processing and Sharing Your Data

Your personal data is processed and shared for the following purposes:

• Ensuring the accuracy and currency of your data,
• Verifying students' university enrollment through the Application Form,
• Enhancing the satisfaction of students participating in the ICI Academy by organizing surveys in electronic and/or physical formats,
• Providing necessary information regarding ICI Academy, including event details and questions,
• Conducting our activities,
• Organizing and providing necessary information for surveys and competitions, including satisfaction surveys when necessary,
• Evaluating application forms received from you within the scope of career development, assessing job applications through human resources for suitable positions, and managing and monitoring these processes,
• Establishing communication with individuals in business relationships with the company,
• Preparing legal reports,
• Ensuring corporate communication,
• Offering personalized job postings and employment-related information,
• Providing support services under contract and service standards,
• Identifying the preferences and needs of candidates/visitors and shaping and updating our services accordingly,
• Recording addresses and other necessary information for communication purposes,
• Organizing all records and documents that serve as a basis for processing in electronic (internet/mobile, etc.) or paper formats,
• Offering recommendations and providing information about our services to candidates applying to ICI Teknoloji/ICI Academy via our partnered institutions, solution providers, or third-party digital platforms and websites,
• Contacting you regarding your requests and complaints, addressing the issues you communicated during your interactions,
• Fulfilling our legal obligations as required or mandated by regulations,
• Sending newsletters or notifications via email,
• Enhancing, maintaining, and expanding the quality of services provided by ICI Teknoloji by generating candidate statistics, identifying general trends, and conducting assessments based on statistical results to provide better services during the execution of ICI Teknoloji's offerings.

Your data is processed and shared in compliance with legal requirements and to fulfill these objectives effectively.

Processing of Personal Data for Human Resources and Employment Purposes

During the job application process, the personal data you share with us, such as resumes, diplomas, and other documents, are processed, stored, and transferred to evaluate your job application. The processing, transfer, and storage of the personal data you share as a job candidate are carried out within the scope of this Policy. Personal data belonging to employees are collected, processed, and stored in accordance with this Policy.

Your personal data may be shared with our business partners, shareholders, official institutions, auditors, attorneys, and financial advisors. However, such transfers are conducted within specific purposes and with your knowledge.

Processing of Personal Data Without Explicit Consent

As the Data Controller, ICI Teknoloji may process your personal data without requiring explicit consent under the following conditions:

• When explicitly stipulated by law;
• When necessary to protect the life or physical integrity of a person unable to express consent due to actual impossibility or whose consent is not legally valid;
• When necessary for the performance of a contract, provided the processing is directly related to the fulfillment of the contract;
• When necessary to fulfill our legal obligations as the Data Controller;
• When the data has been made public by the data subject;
• When processing is necessary for the establishment, exercise, or protection of a right;
• When processing is necessary for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Your personal data may be processed for the purposes outlined below under any of the conditions listed above.

Transfer of Personal Data

Your personal data may be transferred to collaborative organizations and program partners under the provisions of the Law regarding the transfer and international transfer of personal data, for the purposes and legal reasons specified in this Information Text.

Domestic Transfer of Personal Data

As a company, we act in compliance with the provisions of the KVKK and decisions and regulations issued by the Personal Data Protection Board (KVK Board) regarding the transfer of personal data. Except for exceptional circumstances outlined in the legislation, personal data and sensitive personal data are not transferred to other individuals or entities without the explicit consent of the data subject.

In exceptional cases outlined in the KVKK and other legislation, personal data may be transferred without explicit consent to authorized administrative or judicial institutions or organizations within the boundaries and methods specified by the relevant legislation.

Transfer of Personal Data Abroad for Online Events, Meetings, or Interviews

In cases of necessity, the company may provide remote event services or conduct online meetings or interviews via programs/applications such as Zoom, Google Meet, Google Classroom, Google Forms, Adobe Connect, etc. In such cases, personal data—including audio and/or video recordings classified as sensitive personal data—may be processed by the company and transferred abroad as these programs are sourced internationally.

During these processes, personal data shared through applications like Zoom, Google Meet, Google Classroom, Google Forms, and Adobe Connect are classified as "personal data." The use of such data is limited to the scope and duration of the online event, meeting, or interview.

To ensure compliance:

• Audio and video data exchanged during live sessions must not be recorded, shared, or made accessible to third parties without explicit permission.
• These personal data and the intellectual property rights of the company must be respected. Any violations may lead to serious legal consequences under KVKK and other relevant regulations.

Retention of Personal Data

Your personal data may be retained for as long as required for processing purposes. Once the purposes for processing are no longer valid, and in the absence of other legal or contractual obligations, personal data will be deleted, destroyed, or anonymized.

Rights Related to the Processing of Personal Data

As the data subject, you have the following rights under Article 11 of the KVKK:

• To learn whether your personal data is being processed,
• To request information about processed data,
• To understand the purpose of processing and whether it is being used appropriately,
• To know the third parties, domestic or international, to whom your personal data is transferred,
• To request corrections if your data is incomplete or incorrect,
• To request the deletion or destruction of your personal data under specified conditions,
• To request notification of corrections or deletions to third parties to whom your data was transferred,
• To object to adverse outcomes resulting from the analysis of your data exclusively through automated systems,
• To claim compensation for damages if your personal data is processed unlawfully.

Accuracy and Updates to Personal Data

You are responsible for ensuring that the personal data provided is accurate and up to date. You can request updates to your personal data by notifying ICI Teknoloji of any changes. The company is not liable for any issues arising from incorrect or outdated information provided by the data subject.

Revision of the Information Text

This Information Text may be revised by ICI Teknoloji as deemed necessary. Any updates will be communicated appropriately.

Sincerely…

Note: This Information Text was last updated on March 2, 2021.