This Personal Data Disclosure Statement has been prepared in accordance with the Personal Data Protection Law No. 6698 (“PDPL”) to inform you about the collection, processing, transfer of your personal data, and your rights under the PDPL. Located at MERKEZ DISTRICT, ERSEVEN STREET, NO:8 34406, KAĞITHANE, ISTANBUL, TURKEY, Promaks Software Industry and Trade Joint Stock Company (“Company” or “PROMAKS”), as the data controller, processes your personal data in compliance with PDPL and relevant legislation as detailed below. For more detailed information, you can refer to the Promaks Personal Data Processing and Protection Policy.

Personal Data We Process To achieve the personal data processing purposes mentioned in this Disclosure Statement, we process the following personal data: Your name, surname, email, phone number, mobile phone, residence and address information; your location details; IP address information; your marketing data including cookie records.

Our Personal Data Processing Purposes We process your personal data limited to the following purposes: To offer and conduct sales processes of our products and/or services, To carry out purchasing processes of products and/or services, To update, customize, and improve our products and services according to your needs and requests, To solve problems in our products and services, detect errors, issues, and bugs, and resolve them, To inform you about our new products or services, changes in our current products or services, our campaigns, and promotions, To provide you with necessary training and information on our products and services and explain how our programs are used, To conduct customer relationship processes, To provide call center and remote support services, To carry out website membership processes, To ensure individuals benefit from Akademikro training, To create customer Portal registration, To manage cookies to enhance the experience of our website visitors, detect demands and issues, and expedite their searches. (For more details, you can check our Cookie Policy) To provide product demos, To receive e-invoice, e-archive, e-consignment note, e-agreement, e-producer, e-z (z report) applications, and provide e-ledger service, To receive e-signature and KEP applications, To update your contact details to continue our commercial activities and provide these updated details to our related institutions, group companies, contractors, and/or suppliers, To analyze your business processes to tailor our products and services to fit your processes and improve them according to your suggestions, requests, or our reports, to investigate and respond to any complaints you make, To conduct refund processes for those who made incorrect payments, To conduct activities oriented towards customer satisfaction, To plan and execute social media and communication processes, To conduct marketing activities and manage advertising/campaign/promotion processes, To enable our customers to open current cards, create a Mikro account, and update their existing record, To survey business partner satisfaction, To manage, conduct, and oversee our business activities, and to ensure business continuity, To conduct financial and accounting affairs, To ensure the physical space security of our buildings and facilities, create and track visitor records, To ensure the security of our software and systems and conduct information security processes, To provide fringe benefits and advantages for our employees’ relatives, To contact the relatives of our employees in emergencies, To evaluate job applications of candidate employees, conduct interviews and meetings, and contact individuals referenced in their resumes, To manage processes related to company acquisitions, To issue commercial credit cards by our company, To comply with legal regulations and fulfill our legal obligations.

Our Methods for Collecting Personal DataWe collect your personal data through the following automatic and non-automatic channels:

• Email, SMS, business cards,
• Phone, Fax,
• CCTV (Closed Circuit Camera Recordings),
• Physical forms,
• Our website,
• Remote access platforms,
• Mail, cargo or courier services,
• Face-to-face meetings,
• Other physical and electronic mediums.

Legal Reasons for ProcessingYour personal data is processed based on the legal reasons stated in Article 5 of the KVKK: explicitly foreseen in laws, necessary for the establishment and performance of the contract between the Company and you, necessary for the Company to fulfill its legal obligation, necessary to establish, exercise, and protect the rights of the Company, necessary to fulfill the legitimate interests of the Company, and based on your explicit consent. Your specially qualified personal data is processed based on the legal reasons stated in Article 6 of the KVKK: when there’s explicit consent from the person concerned, as foreseen in laws, for the planning and management of health services and financing, and when processed by persons or authorized institutions and organizations under the obligation of confidentiality.

Transfer of Your Personal DataBased on the legal reasons stated in Articles 8 and 9 of the KVKK, some of your personal data may be transferred to our domestic and foreign business partners, suppliers, authorized public institutions and organizations, group companies, company representatives or agents, legally authorized persons, and the public for the purposes mentioned above.

Your Rights Regarding Your Personal DataAccording to Article 11 of the KVKK, you have the following rights regarding your personal data:

• To learn whether your personal data is processed or not,
• To request information if your personal data is processed,
• To learn the purpose of processing your personal data and whether they are used appropriately,
• To know the third parties to whom your personal data has been transferred domestically or abroad,
• To request correction if your personal data is processed incompletely or inaccurately and to request the related correction to be notified to the third parties to whom your personal data has been transferred,
• Despite being processed in accordance with the Law No. 6698 on the Protection of Personal Data and other related laws, to request deletion or destruction of personal data if the reasons for its processing are no longer present, and to request the third parties to whom your personal data has been transferred to be informed about this process,
• To object to any result against you by analyzing the processed data exclusively through automated systems,
• To request compensation in case of damage due to the illegal processing of personal data. You can send your requests regarding these rights via the Application Form on our website. Your application will be processed free of charge. However, if the requested operation requires additional costs, fees determined by the Personal Data Protection Board will be charged to the applicant.