Legal Notice

POLARKON METAL STRUCTURES INDUSTRIAL AND COMMERCIAL INC. GENERAL PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA

As Polarkon Metal Structures Industrial and Commercial Inc. (“POLARKON” or “the
Company”), we would like to inform and clarify our personal data processing activities in
accordance with Article 10 of the Personal Data Protection Law No. 6698 (“KVKK”).

1- Data Controller and Representative

In accordance with the KVKK, POLARKON, acting as the data controller, may process,
record, store, classify, and update your personal data for the purposes described below in a
manner consistent with the law and the principles of good faith. We may also disclose or
transfer your personal data to third parties in cases permitted by law and/or limited to the
purpose for which it was processed.

2- Purpose of Processing Your Personal Data

Your personal data is processed in accordance with the fundamental principles set forth in
the Personal Data Protection Law (KVKK) for purposes such as the conduct of our
Company’s operational activities, business relationships, and human resources processes;
fulfilling the requests of data subjects; providing products and services to you in the most
appropriate manner; continuing marketing and technical processes; ensuring the Company’s
commercial security; and carrying out our operations, and are securely stored in physical or
electronic media for a period appropriate to the purpose of processing. POLARKON acts in
compliance with all obligations set forth in the KVKK and all relevant legislation.

For detailed information regarding the purposes for which your personal data is processed by
our Company, please refer to the POLARKON Personal Data Protection and Privacy Policy
available at www.polarkon.com.tr.

3- Transfer of Your Personal Data

Your personal data processed for the purposes outlined above is transferred, in accordance
with the fundamental principles set forth in the KVKK and within the scope of the conditions
and purposes for processing personal data specified in Articles 8 and 9 of the KVKK,
POLARKON may transfer your personal data—limited to the purposes stated above—to our
business partners, shareholders, authorized public institutions and organizations, private
individuals, companies from which we receive support services to conduct our operations,
and independent audit firms, subject to legal obligations and statutory limitations.

4- Data Transfer Abroad

POLARKON may transfer your personal data, in accordance with the principles set forth in
Article 4(2) of the Personal Data Protection Law (KVKK), either by obtaining your explicit
consent or, in cases provided for in Articles 5(2) and 6(3), without obtaining your explicit
consent and in compliance with the rules set forth in Article 9 of the Law, After foreign
countries with adequate protection, as determined by the Personal Data Protection Board
(“the Board”), have been announced, your personal data may be transferred only to
individuals and entities established in those countries; for countries where adequate
protection has not been determined and announced, data may be transferred only to
individuals and entities established in those countries, provided that the data controllers in
Turkey and the relevant foreign country have committed in writing to providing adequate
protection and the Board’s authorization for the relevant transfer has been obtained.

5- Method and Legal Basis for Collecting Your Personal Data

Your personal data is collected by POLARKON through various channels and based on the
legal grounds specified above, for the purpose of conducting our operations; it is also
collected to improve the services we offer and to carry out our commercial activities. In this
context, your personal data may be processed and transferred either by obtaining your
explicit consent in accordance with the principles set forth in Article 4(2) of the KVKK, or
without obtaining your explicit consent if the conditions specified in Articles 5(2) and 6(3) are
met.

6- Your Rights as a Data Subject Under Article 11 of the KVKK

As data subjects, you may submit requests regarding your rights by filling out and signing the
form available at www.polarkon.com and sending it to the following address: Birlik Mahallesi,
450th Street, 490th Avenue, No. 3/1, 06610 Ankara.

POLARKON will process your request free of charge as soon as possible and no later than
thirty (30) days, depending on the nature of the request. However, if the process incurs
additional costs, we will charge the fee set by the Board.

Pursuant to Article 11 of the Personal Data Protection Law (KVKK), your rights are as
follows:

  • The right to learn whether your personal data is being processed,
  • To request information regarding the processing of your personal data,
  • To learn the purpose of the processing of personal data and whether it is being used
    in accordance with that purpose,
  • To know the third parties to whom personal data has been transferred, whether within
    the country or abroad,
  • To request the correction of personal data if it has been processed incompletely or
    incorrectly,
  • To request the erasure or destruction of personal data under the conditions set forth
    in Article 7,
  • To request that the actions taken pursuant to subparagraphs (d) and (e) be notified to
    third parties to whom the personal data has been transferred,
  • To object to a decision made solely through the automated processing of personal
    data that adversely affects the individual,
  • To request compensation for damages suffered as a result of the unlawful processing of
    personal data.
  • This Privacy Notice (“Notice”) was prepared on February 1, 2022. In the event of any
    changes to the text