PROTECTION OF PERSONAL DATA CLARIFICATION TEXT

DATA RESPONSIBLE AND REPRESENTATIVE

In accordance with the Law on Protection of Personal Data No. 6698 (“PDPL”), your personal data may be processed by Hydrotur Import Export Industry and Trade Limited Company as the data controller within the scope described below.

DEFINITION OF PERSONAL DATA

Personal data, as defined in Article 3 of the PDPL, means any information relating to an identified or identifiable natural person.

FOR WHAT PURPOSE PERSONAL DATA WILL BE PROCESSED

Your personal data is processed in accordance with the personal data processing principles specified in Article 4 of the PDPL, based on one or more of the personal data processing conditions specified in Article 5 of the PDPL. In all personal data processing activities carried out by the Data Controller, we act in accordance with the obligations sought in all relevant legislation, especially the PDPL.

Purposes of processing your personal data within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the PDPL; are carrying out the necessary work by our business units to benefit you from the services offered by the Data Controller, recommending the services offered to you by customizing them according to your tastes, usage habits and needs; ensuring the legal and commercial security of the people who have a business relationship with the Data Controller as well as the determination and implementation of commercial and business strategies.

Your personal data is processed by the Company for the following purposes:

• Updating and confirming the accuracy of the information transmitted to us,
• Planning and execution of business activities and operational processes,
• Ensuring that company activities are carried out in accordance with company procedures or relevant legislation,
• Ensuring that the obligations under the contractual relationship are duly fulfilled,
• Follow-up of contract processes or legal requests,
• Management and execution of customer relations,
• Planning and execution of corporate sustainability, corporate governance, strategic planning and information security processes,
• Sales, marketing and promotion processes of products and services and market research,
• Finance and accounting affairs,
• Recording camera footage at our Company’s location within the scope of our obligations arising from security and/or law.
• The purpose of improving the user experience on our website and creating content and advertising strategies from the information collected.

Your personal data shared with the organizations (Google, Yandex, etc.) used by our company’s extensions:

• By means of cookies, digital information about visitors’ age, gender, location, devices they use, etc.
• Via Google Analytics, Google Search Console, Google Tag Manager, Google Ads, Google Data Studio, information about visitors’ age, gender, location, devices they use, behavior patterns, etc.
• Via Yandex Javascript codes, information about visitors’ age, gender, location, devices they use, behavior patterns, etc.
• Via Bing Javascript codes, information about visitors’ age, gender, location, devices they use, behavior patterns, etc.
• Via Facebook Pixel, information about visitors’ age, gender, location, devices they use, behavior patterns, etc.
• Via Social Networks (LinkedIn, Instagram, Tiktok, etc.), personal information about visitors’ name, surname, phone number, etc.
• Via the contact forms, personal information about the visitors’ name, surname, phone number, etc.
• By sending e-mails directly to Hydrotur e-mail addresses, personal information about the visitors’ name, surname, phone number, etc.
• With instant correspondence software Live Support, WhatsApp, etc., personal information such as name, surname, phone number, etc.
• By using different software within the scope of digital marketing strategy, personal information about visitors’ name, surname, phone number, age, gender, location, devices they use, behavior patterns, etc.

TO WHOM AND FOR WHAT PURPOSES THE PROCESSED PERSONAL DATA MAY BE TRANSFERRED

Your collected personal data, for the purposes described in Article 3 of this Clarification Text, provided that necessary security measures are taken, can be transferred primarily to official authorities, judicial authorities and regulatory and supervisory institutions, to our subsidiaries and affiliates, business partners, investors, performance assistants and suppliers, to our shareholders, legally authorized public institutions and private individuals, limited to the policies on the protection and processing of personal data shared by the Data Controller on the internet address “https://www.hydrotur.com.tr” and the stated purposes written in this Clarification Text within the framework of the personal data processing conditions and purposes specified in Articles 5 and 6 of the PDPL. In addition, your personal data may also be transferred abroad, provided that the necessary security measures are taken and limited to the purposes written in this Clarification Text.

METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA

Your personal data, can be submitted verbally, in writing or electronically, including but not limited to, information transmitted to our Company’s e-mail address, information transmitted directly orally or in writing to the department, website, e-mail, mobile communication, mobile applications, application and membership forms, miscellaneous agreements; is collected for legal reasons for the realization of the purposes specified in Article 3 of this Clarification Text.

RIGHTS OF PERSONAL DATA OWNERS

Pursuant to Article 11 of the PDPL, persons whose personal data are processed can apply to Hydrotur Import Export Industry and Trade Limited Company and make requests regarding the following issues:

1. Learning whether their personal data is processed or not,
2. If their personal data has been processed, requesting information about it,
3. To learn the purpose of processing their personal data and whether they are used in accordance with the purpose,
4. Learning the third parties to whom their personal data are transferred at home or abroad,
5. Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made in this context to the third parties to whom their personal data has been transferred,
6. Requesting their deletion, destruction or anonymization in the event that the reasons requiring the processing of personal data disappear, and requesting the notification of the transaction made in this context to the third parties to whom their personal data has been transferred,
7. Objecting to the emergence of a result against the data owner by analyzing the processed data exclusively through automated systems,
8. To request the compensation of the damage in case of loss due to unlawful processing of their personal data.

Requests arising from the PDPL will be made through the “Personal Data Owner Application Form”. In accordance with Article 13 of the PDPL, application requests will be finalized free of charge, depending on the nature of the request and within 30 (thirty) days at the latest. In case of rejection of the request, the reason(s) for the rejection shall be justified in writing or electronically.

Filling out the Personal Data Owner Application Form at the address https://www.hydrotur.com.tr, your request, including the necessary information identifying your identity to exercise your above-mentioned rights, and your explanations regarding your right that you request to exercise from the rights specified in Article 11 of the PDPL; you can submit a signed copy of the form to Yeşilbağlar Mh. Selvili Sok. No:2/1 Beyaz Ofis A Blok Kat 2 No:10 Pendik/Istanbul by hand, via notary public or with secure electronic signature to the address muhasebe@hydrotur.com.tr or pursuant to Article 13 of the PDPL, you can send by other methods to be foreseen by the Personal Data Protection Board.

In applications, name, surname and signature if the application is written, TR identity number for citizens of the Republic of Turkey; nationality, passport number/identity number for foreigners, place of residence or workplace address for notification, if any, e-mail address, telephone or fax number for notification and request subject is mandatory.

In the application you will make containing your explanations regarding the right you have as the personal data owner and request to use the above-mentioned rights; the subject you request must be clear and understandable, the subject you request is related to yourself or if you are acting on behalf of someone else, you must be specifically authorized in this regard and your authority must be documented, the application must contain your identity and address information, and documents confirming your identity must be attached to the application.

USE OF COOKIES

Cookies can be used in the Application to improve your user experience by identifying your areas of interest and to personalize the services offered to you via the Application. Cookies are small files left on the hard drives of your devices. These files facilitate navigation and make the service much more comfortable to use.

DATA SECURITY

The Data Controller takes all necessary technical and administrative measures to ensure the appropriate level of security in order to prevent the unlawful processing of personal data, to prevent unlawful access to personal data and to ensure the preservation of personal data.

It implements technical and organizational security measures to protect your managed personal data from being manipulated, lost, damaged or used by unauthorized persons. Our security measures are in constant development along with technological advances. It takes all necessary technical and administrative measures to ensure the appropriate level of security in order to prevent the unlawful processing of personal data, to prevent unlawful access to personal data, and to ensure the preservation of personal data.