PDPL

Personal Data Protection and Processing Policy

In accordance with the Law No. 6698 on the Protection of Personal Data

1. Purpose

The purpose of this Policy is to determine the procedures and principles regarding the processing, protection, storage and disposal of personal data by Deta Industry in accordance with the relevant legislation, especially the Law No. 6698 on the Protection of Personal Data ("PDPL").

2. Scope

This policy covers all natural persons whose personal data are processed by Deta Industry, including:

Employees

Employee candidates

Customers

Suppliers

Business partners

Website visitors

all natural persons whose personal data is processed.

3. Definitions

Personal Data

Any information relating to an identified or identifiable natural person

Special Categories of Personal Data

Data requiring stricter protection such as race, health, biometric data

Data Subject (Relevant Person)

The natural person whose personal data is processed

Data Controller

The natural or legal person who determines the purposes and means of processing personal data (Deta Industry)

4. Principles Regarding the Processing of Personal Data

Deta Industry acts in accordance with the following principles when processing personal data:

Compliance with the law and rules of honesty
Being accurate and up-to-date when necessary
Processing for specific, explicit and legitimate purposes
Being relevant, limited and proportionate to the purpose for which they are processed
Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed

5. Purposes of Processing Personal Data

Personal data may be processed for the following purposes:

•Execution of human resources processes

•Execution of services and activities

•Management of communication processes

•Providing information security and access authorizations

•Fulfillment of legal obligations

•Ensuring customer and candidate satisfaction

6. Legal Grounds for Processing Personal Data

Personal data is processed based on one or more of the following legal grounds:

Clearly provided for in laws

Establishment or performance of a contract

Fulfillment of the data controller's legal obligation

Establishment, exercise or protection of a right

Legitimate interest of the data controller

Explicit consent of the data subject

is processed based on these legal grounds.

7. Transfer of Personal Data

Personal data may be transferred to:

Authorized public institutions and organizations

Persons and organizations from which legal, financial and technical services are received

in accordance with Articles 8 and 9 of the PDPL.

In cases requiring explicit consent, the approval of the data subject is obtained.

8. Retention Period of Personal Data

Personal data is stored:

•For the periods stipulated in the relevant legislation

•For as long as the processing purpose requires

Upon expiry of the period, data is deleted, destroyed or anonymized in accordance with the PDPL.

9. Data Security Measures

Deta Industry takes necessary administrative and technical security measures to:

Prevent unauthorized access

Prevent data loss and unlawful transactions

Ensure the security of personal data

10. Rights of the Data Subject

In accordance with Article 11 of the PDPL, data subjects have the right to:

Learn whether their personal data is processed

Request information if processed

Learn whether it is used in accordance with its purpose

Request correction if incomplete or incorrectly processed

Request deletion or destruction

Request compensation for damages due to unlawful processing

11. Application Method

Data subjects may submit their requests within the scope of the PDPL to Deta Industry in writing or by methods determined by the Personal Data Protection Board.

Applications are concluded free of charge within 30 days at the latest.

12. Entry into Force and Updating of the Policy

This policy enters into force on the date of publication.

It may be updated in line with legislative changes and corporate needs.

The current policy is always published on the Deta Industry website.