This Information and Clarification Form has been prepared in relation to the processing and transfer of the “Personal Data” of real persons, which is regulated by Law No.6698 on the Protection of Personal Data (“Law KVK”). Pursuant to Law No.6698, all kinds of up-to-date information that you may share with our company will be considered as “Personal Data”. Your collected personal data will be processed in accordance with the law and the principle of good faith, in an accurate manner and will be updated whenever necessary, for determined, clear and legitimate purposes and will be stored for the duration prescribed in the legislation and for no longer than is necessary for the purposes for which it has been processed.. The security of your personal data is very important for us, your personal data will be stored in secured data centers in Turkey and abroad, in accordance with to the conditions set out in the legislation, , and will be transferred to reliable business partners with whom our firm executed confidentiality agreements. If you wish to alter your data sharing preferences, you can direct your request to our data experts, via our e-mail address [email protected] or our call center on +902124850860 and cancel your membership.

a) Data Controller and Processor

Pursuant to Law No.6698 on the Protection of Personal Data (“Law KVK”), your personal data will be processed by arcoglobal (will be referred to as the COMPANY in short) in its capacity as the “Data Controller”, within the scope defined in the explanations below.

b) Purpose of processing your Personal Data

Your collected personal data will be processed within the scope of the conditions and purposes set out in articles 5 and 6 of Law No.6698 and for the purposes of fulfilling the obligations of the COMPANY and real and legal persons which have business relationships with our COMPANY, providing information regarding updates, for the execution and performance of the contracts that will be executed with you, for reminding you of and performing legal obligations, to carry out various advertisement and promotion activities, to the carry out and follow up on financial, accounting and legal transactions, tp follow up on your requests and claims – to follow up on agreement processes and/or legal claims, to receive your opinion through polls and the voting as part of the planning and carrying out of customer satisfaction activities, for the determination and development of adequate products, projects and services which are specific to you, the provision of efficient customer service, the communication of amendments in the legislation, the company’s internal policies which are relevant to you, or other notifications which concern you, birthday celebration, participation in lotteries or contests, the granting of gifts and other similar events for your benefit, the organization of promotion and campaigns, the communication of information to you via mail, SMS and fax, the notification of campaigns, printed bulletins, magazines, letters related to campaigns, the determination of our visitor profile, the assessment of requests, claims and complaints, and the execution of our company’s human resources policy, in order to reply to your questions and meet your demands.

c) Persons to whom the processed data can be transferred and the purpose of transfer

Your personal data will be processed in accordance with law and the principle of good faith, in an accurate manner and updated whenever required, for determined, clear and legitimate purposes, in relation and limited to the purpose of processing, and will be stored for the duration prescribed in the legislation and for no longer than is necessary for the purposes for which it has been processed.. Furthermore, subject to compliance with the conditions set out in articles 8 and 9 of the Law KVK, and taking of the required measures, and limited to the purposes indicated in item (b) of the present notification, they can be shared with our direct/indirect local/foreign subsidiaries or associated partners, local/foreign/international, public/private institutions, companies and other third parties or institutions, providing services/support/consultancy to OUR COMPANY or with which our COMPANY is cooperating, or project/program/financing partners, our company’s affiliates, consultants, shareholders or solution partners, other group companies, Central Registry Agency and other competent institutions, suppliers or sub-contractors, within the framework of personal data processing conditions and purposes set out in articles 8 and 9 of Law No: 6698. The COMPANY can process and store your personal data in Turkey provided that the required security measures are taken, or in a foreign country, provided that the country to which the personal data will be transferred provides adequate protection or, where there is not adequate protection , provided that the COMPANY and the data controllers in the relevant foreign country gives guarantee of adequate protection in writing and subject to the approval of the Board , or by means of servers abroad or in other electronic environment. Without any prejudice to fundamental rights and freedoms of the data subject, they are collected and processed on the basis of the COMPANY’s legitimate interest or your express consent legal reasons.

ç) Method of collection of personal data and legal reasons

Your personal data can be collected by our COMPANY, through different channels (COMPANY’s head-office, branch-offices, agencies or other sub-contractors or offices and other physical environments by which you can contact business partners, call centers, Internet sites, mobile applications and similar electronic processing platforms, social media or other public channels, participation in training, conference and similar environment or via other group companies or contractual persons and institutions, in writing, verbally, sound or image recording or other physical or electronic environment etc.).

Your personal data can be collected, processed, transferred and stored, within the scope of data processing conditions and purposes set out in articles 5 and 6 of Law KVK, for the purposes set out in items (b) and (c) of this text.

Your personal data shall be stored for the period prescribed by the relevant laws.

d) Your rights as owner of personal data

As owners of personal data, if you direct your requests concerning your rights to our Company, as indicated hereunder, our Company will accede to your request within the shortest possible time, depending on the nature of the request, and within a period of thirty days at the latest. However, if a fee is determined by the Board of Protection of Personal Data, the fee specified in our Company’s tariff will be applicable. Accordingly, owners of personal data can request the following:

• Learn if their personal data have been processed or not,
• Information with regards to the processed personal data,
• Inquire about the purpose for which the personal data are being processed and whether they have been used in accordance with the purpose,
• Inquire about third parties to whom the personal data have been transferred, in Turkey or abroad,
• Request that the personal data which are processed inaccurately or erroneously be corrected and request that the transaction carried out within this scope to the persons to whom they have been transferred be communicated,
• Request the destruction or deletion of personal data in the event that they are processed in compliance with the Law KVK and other relevant legal provisions but the reasons for their processing have lapsed, and inquiring about the transactions carried out with regards to the third persons to whom they have been transferred,
• Challenge the unfavorable result obtained from the analysis of the processed data exclusivelyby means of automatic systems,
• Request compensation for the loss incurred due to the processing of personal data in breach of the law.

Terms of Use and Privacy

This “Terms of Use and Privacy” text contains the principles governing User’s visits of the website of ARCO MAĞAZACILIK SİSTEMLERİ A.Ş. (COMPANY). Users hereby declare and warrant that neither the COMPANY nor any group company its affiliated with or any employee, manager, authorized person or institution will bear any civil or criminal liability arising from the use of information obtained by means of the use of the COMPANY’s logo or the pages of its Website on any other Website, as a result of any content uploaded by third parties or visitors on its Website, or any content that is used within the framework of general internet applications and thus does not generate responsibility. The COMPANY has the right to change and update all kinds of content, opinion and information provided on the Website and the terms and conditions of the present legal disclaimer, without the need for any prior notice.

• All contents, opinions and information contained on the COMPANY’s Website have been created using the information and data which have been obtained by the COMPANY from sources and third persons believed to be reliable.
• The contents, opinions and information contained on the COMPANY’s Website are only for information and indicative purposes and shall not be construed in any way whatsoever as an offer for sale or purchase. For this reason, prior to taking any action based on the information/opinion and contents obtained from this Website, users must check the accuracy of the information.
• The COMPANY does not guarantee that the information which has been obtained from third persons and reliable sources and which is available on its Website is accurate, complete and unchangeable, and users shall remain responsible for any decision taken by them based on this information, and the COMPANY shall not be held liable for the inaccuracies or incorrectness of the information.
• Furthermore, the COMPANY’s employees and consultants shall not be liable for any direct or indirect losses arising from the contents, opinions and information provided on the Website.

Use of Cookies

Data such as the pages visited and domains clicked by the Users during their visit to the Website are automatically collected by the COMPANY, in accordance with art.2/1-j of Law No.5651. The data which are collected using the “cookie” technology, qualify as statistical information. The purpose of this technology is to make the content of the pages visited by users easily accessible as of their first visit. Many browsers have been designed so as to accept these cookies which are initially a technical communication file; however users can change their browser settings, at any time, if they wish so, in order to ensure that the technical communication file does not appear or that a warning is given when the technical communication file appears. To enable behavioral advertisement and marketing, the COMPANY has the right to associate users’ behavior on the website with a cookie stored in the browser and define new marketing lists based on metrics such as the number of pages viewed, the duration of the visit and the number of target completion. Subsequently, users may receive targeted advertisement content based on either their field of interest on the Website or other websites in the network of video advertisements.

Points to consider by virtue of laws no.5651 and 5846

Users agree that there can be links on the website that provide access to another website or content, the control, accuracy and efficiency of which are not related to the COMPANY in any manner and that the COMPANY does not in any way support these sites and does not guarantee the accuracy of the information they contain, and shall not be held responsible for the content of these sites, and the loss arising from the use of these sites.

Users agree that the website can contain any text, information, comment, opinion, news, image, picture, form, chart and other material belonging to the COMPANY or a third person or institution, that the COMPANY has legal rights over these materials, as regulated by the Law on Intellectual and Artistic Works, that they cannot be copied, altered, reproduced, published, sold, used, or subjected to any intervention whatsoever, without the COMPANY’s authorization.