Policy for Confidentiality and Protection of Personal Data

FABRIQA İNOVASYON A.Ş.

1. POLICY OBJECTIVE AND SCOPE

The objective of this Policy for Confidentiality and Protection of Personal Data (“POLICY”) is to inform individuals in relation to the processing of personal data of job applicants, suppliers, online and physical visitors, members, customers, shareholders and partners of FABRIQA’s (“Data Supervisor”).

2. APPLICANTS

   1. Personal Data Collected in Relation to Applicant Group of Individuals

In relation to the group of individuals applying for a job, FABRIQA may process information such as;

• Personal background, work experience, educational background, foreign language certificate and other certificates,

• Name and surname, address, date of birth, e-mail address, telephone number and other contact details,

• Records of information obtained during face to face interviews or via teleconference, video call or telephone

• References or information obtained via research conducted by FABRIQA,

• Results of recruitment assessment tools determining skills and personal attributes,

• Salary expectations, disabilities and liabilities, and method of payment. Documents such as a criminal record and health report may also be required.

1. 2. Purposes for Collecting and Processing Personal Data of Applicants

FABRIQA may process an applicant’s personal data based on one or more purposes specified in the section of this POLICY, titled “VII. Personal Data Processing Purposes,” in accordance with the nature of the application.

• Evaluating the suitability of the applicant’s qualifications, experience and interest in relation to the vacant position,

• Checking the validity of the information submitted by the applicant or contacting third parties for reference check purposes when required,

• Contacting applicant concerning the recruitment process or, if suitable, contacting the applicant for any position subsequently opened in the country or abroad,

• Meeting the requirements of regulations or those of an authorized body or organization,

• Developing and improving the recruitment principles implemented by FABRIQA,

• Implementing operations which are required within the context of occupational health and safety.

1. 3. Methods of Collecting and Processing of Personal Data of Applicants

Personal data of applicants may be collected during the recruitment process by employing other methods and tools specified in this POLICY, or with additional methods and tools specified below:

• Application form in print or published in an electronic environment,

• CVs which have been submitted to FABRIQA by applicants via e-mail, cargo, references and similar methods.

• Recruitment or consultancy firms and LinkedIn,

• Research carried out by FABRIQA with the aim of confirming the accuracy of information obtained from the applicant during interviews conducted

• Via tools such as video conferencing and telephones,

• Recruitment tests which determine skills and personal attributes, carried out and analyzed by experienced experts.

FABRIQA processes collected personal data via computer systems and human resources personnel, automatically and manually.

1. 4. Applicant Reference Checks

FABRIQA may carry out reference checks in respect of the applicant. The reference check process is usually carried out by means of confirming the accuracy of the information provided by the applicant. Determining factors that may have been withheld by the applicant and which may have the capacity to cause a threat to FABRIQA will be part of the research conducted. In the context of the reference check, necessary personal data such as the identification information of third parties and applicants, work and educational backgrounds may be shared. Personal data concerning the applicant may be obtained from third parties. Applicants may, at all times, contact FABRIQA regarding the reference check process.

1. 5. Applicants’ Rights Related to their Personal Data

Applicants who wish to exercise their rights based on the Law on Protection of Personal Data no 6698 (“LPPD”) may apply to FABRIQA in accordance with the rules and procedures declared in this POLICY.

1. 6. The Personal Data Collected During the Application Process Which will Continue to be Processed in the Instance of Recruitment

All personal data concerning the applicant which has been collected and processed during the application procedure are transferred to their personal file upon the decision to recruit the candidate for the vacant position.

1. 7. Security of Applicants’ Personal Data

With regards to the personal data it processes, FABRIQA does not discriminate amongst data subject groups of individuals (such as applicants, group of individuals, interns). Detailed information regarding the security of personal data is found in the section of this document related to the security of personal data.

3. PRINCIPLES IN RELATION TO PROCESSING OF PERSONAL DATA

   1. Processing in Compliance with Law and Principle of Honesty

In the processing of personal data, the principles which are enshrined in legal regulations, and those which are related to general confidence and honesty are being complied with.

1. 2. Ensuring that the Personal Data is Accurate and Up-To-Date when Necessary

Periodical verifications and updates are made so that the data processed are accurate and up- to-date, and the necessary measures are taken accordingly. In this context, systems for controlling the correctness of personal data and making necessary corrections are implemented in FABRIQA. These changes and updates can be made by members on the My Account page at www.kartelam.com.

1. 3. Processing for Specific, Clear and Legitimate Purposes

Personal data are processed in accordance with clear, specific and legitimate data processing purposes. The purpose for which the data will be processed is described in detail below.

1. 4. Being related to and Limited to the Purpose of Processing thereof, and Being Measured

In order for the envisaged purpose/purposes to be realized, personal data are processed in a measured manner and which is related to and limited to the purpose, and we abstain from processing the personal data which are not related to achieving the purpose or which are not needed.

1. 5. Preserving for the Period Stipulated in the Relevant Legislation or the Period Required for the Purpose of Processing Thereof

FABRIQA preserves personal data only for the period prescribed in the relevant legislation or the period required for the purpose of processing thereof. In this context, first of all we identify whether a period is stipulated in the relevant legislation for the preservation of personal data, if a period is prescribed, we act in accordance with it, and if no period is prescribed, we preserve the personal data for the period required for the purpose of processing thereof. In case of expiry of such period or in case the reasons requiring them to be processed cease to exist, provided there is no legal reason for allowing them to be processed for longer periods, personal data are deleted, destroyed or anonymized in accordance with FABRIQA’s Policy on Preservation and Destruction of Personal Data. Preservation periods have been additionally indicated below.

4. TERMS AND CONDITIONS IN RELATION TO PROCESSING OF PERSONAL DATA

Express consent of the relevant person is only one of the conditions that needs to be satisfied according to the law and which makes processing of personal data legally possible. Apart from express consent, personal data may also be processed in case of the existence of one of the below-specified conditions stipulated by the law.

The basis on which personal data processing activity is carried out may be one or more than one of the below-specified conditions specified by the law. In the case where the personal data processed constitute private personal data; conditions listed under the heading “Circumstances Where Private Personal Data May be Processed” will be applied. Individuals are informed of which personal data are being processed under this hereby POLICY, for which purposes and reasons the personal data are being processed, from which resources the personal data are collected, with whom these personal data will be shared, and how they will be used.

1. 1. Being Explicitly Stipulated by Laws

FABRIQA can process the personal data of individuals without obtaining his/her express consent in cases where processing of personal data is explicitly prescribed by laws for example, pursuant of the Law on Electronic Trade Regulation, personal data to be processed in respect of procedures such as membership to FABRIQA, granting electronic permission for trade, purchase orders, deliveries, cancellation or return of products.

1. 2. Inability to Obtain Express Consent of the Relevant Person

Due to Actual Impossibility Data may be processed without the explicit consent of an individual if it is compulsory to process personal data in order to protect the life or body integrity of the individual or any other person where an individual cannot give his/her consent or whose consent is deemed invalid due to actual impossibility.

1. 3. Direct Relationship with Conclusion or Performance of a Contract

Personal data belonging to the parties of a contract may be processed in case it is necessary, provided that it is   directly related to the conclusion or performance of said contract. For example, the personal data provided by the Member in order to complete their FABRIQA membership procedure.

1. 4. Performance by FABRIQA of its Legal Obligation

Individuals’ data may be processed without obtaining explicit consent, where it is compulsory to fulfill legal obligations as a data supervisor. For example, the delivery of an ordered product to a Member or the cost of a product being paid to the seller.

1. 5. Making Public the Personal Data of Individuals

In case individuals’ personal data are made public by themselves, data may be processed without the need to obtain express consent. For example, personal data shared with the public by a member on the internet via HIS social media account, may be processed provided that it is done in accordance with the will and proportionality.

1. 6. Obligation to Process Data for Establishment or Protection of a Right

In the case where data processing is mandatory in order to establish, exercise or protect a right, data may be processed without obtaining the express consent of the individual. For example, in relation to a complaint issued to the consumer arbitration committee by a Member, entering the transaction and information into this complaint folder.

1. 7. Processing of Data Based on Legitimate Interest

In case the data processing for FABRIQA's legitimate interests is compulsory provided that the fundamental rights and freedoms of the individuals are not infringed, the data may be processed without obtaining the individual's explicit consent. For example, FABRIQA conducting satisfaction surveys in order to ensure Customer satisfaction.

1. 8. Processing of the Employee’s Personal Data Based on Express Consent

Employee personal data shall be processed on the basis of express consent in cases where it can not be processed based on any of the conditions specified in Articles 3.1 to 3.5 above.

5. CIRCUMSTANCES WHERE PRIVATE PERSONAL DATA MAY BE PROCESSED

Part of the personal data are categorized as “private personal data”, and they are subject to a special protection.

1. 1. Processing of Private Personal Data Based on Express Consent

Private personal data may be processed in the event that the individual has given his/her express consent in accordance with the principles specified in this hereby POLICY and by taking the necessary administrative and technical measures.

1. 2. Circumstances Where Private Personal Data may be Processed Without Express Consent

In cases where the individual has not given his/her express consent, in the following cases, private personal data are processed provided that sufficient measures to be determined by the Board of Protection of Personal Data (“Board”) are taken:

• Private personal data other than the individual’s health condition and sexual life, in cases where stipulated by laws,

• Private personal data in respect of the health of the individuals and sexual life shall be only available to persons who are bound by the duty of confidentiality or authorized bodies and institutions for the purpose of public health protection, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.

6. ENLIGHTENING AND INFORMING INDIVIDUALS

During the acquisition of personal data, individuals shall be informed by FABRIQA. In this context, they shall be informed of the identity of the contact person of FABRIQA, the purpose for which personal data will be processed, to whom and for which purposes the data processed may be transferred, method of collecting personal data, and the rights that the employees are lawfully entitled to.

In case individuals request information in relation to their personal data, FABRIQA shall inform them through email.

7. CATEGORIZATION OF PERSONAL DATA

Within the scope of this policy, FABRIQA processes the data of individuals in the below- specified categories:

• Credentials

• Contact Details

• Location Data

• Information on Family Members and Kith and Kin

• Physical Space Security Information

• Financial Information

• Personal Information

• Candidate Employee Information

• Individuals Processing Information

• Legal Transactions and Compliance Information

• Private Personal Data

• Information on Complaint Management

8. PURPOSE OF PROCESSING OF PERSONAL DATA

   1. Processing Conditions

Personal data are processed subject to the following conditions. The conditions are;

• The relevant activity in relation to the processing of your personal data is explicitly stipulated by laws,

• The processing of your personal data by FABRIQA is directly related to and necessary for the conclusion or performance of a contract,

• The processing of personal data is mandatory for the fulfillment of FABRIQA’s legal obligation,

• Provided that the personal data has been shared with public by the individuals; to be processed by FABRIQA in a proportional manner for the purpose of publicity.

• Processing by FABRIQA of personal data is mandatory for the establishment, exercise or protection of rights of FABRIQA or its individuals or third persons,

• Provided that the fundamental rights and freedoms of individuals are not infringed, the processing personal data is obligatory in order to uphold the legitimate interests of FABRIQA,

• The processing of personal data by FABRIQA is mandatory for the preservation of the life and physical integrity of the data owner or another person, and in such a case where the owner of personal data is in a position where he /she cannot give his/her consent due to an actual impossibility or legal invalidity.

In the case that the above conditions are satisfied; FABRIQA seeks to obtain the express consent of the personal data owners in order to process personal data.

1. 2. Processing Purposes

FABRIQA shall process personal data for the following purposes:

1. 1. 1. Candidate Working Group:

• Ensuring completion and implementation of   human resources policies and processes,

• Planning the selection and evaluation procedures of candidate worker’s applications,

• Implementing required operations within the framework of occupational health and safety regulations,

• The communication activities necessary for the placement of the working candidate,

• Internship recruitment, placing and planning of operational processes.

• For intern lawyers; To fulfill the legal requirements within the scope of professional solidarity under the Legal Profession Act.

8. 2. 2. For the Customer Group:

• Fulfilling the legal requirements stipulated in the law on electronic trade and the Turkish code of commerce.

• Planning activities focusing on customer satisfaction and/or experience.

• Legal, regulatory and company management legislations and ensuring compliance with correct application.

• Preparation of product to be delivered in accordance with the customer’s order and providing assurance that delivery shall be made e within guaranteed time frame.

• In cases of cancellation and returns, relaying information to relevant department to ensure that the customer is reimbursed as soon as possible.

• Establishing and implementing processes for ensuring the security of information.

• For the risk to be reduced to an acceptable level.

• Risk Management.

• Forming Access Authorization and Control Matrix.

• Identifying Data Transfer techniques.

• Creating data preservation processes and procedures

• Identification and implementation of remote access procedures an processes

• Use of results derived from the sharing of anonymous data within the framework of customer CRM applications in decision support systems.

• Correct targets within the scope of campaign planning, feasibility studies and CRM.

• Invoicing and regular pursuance.

• Fulfilling company obligations.

• Data collection to form a customer portfolio.

• Data collection to bring a product which is not in stock for customers.

• Data collection to be able to provide tailoring services to customers.

8. 2. 3. For the Supplier Group (Supplier, Supplier Executive, Supplier Employee):

• Management of the business process with suppliers.

• Implementation of legal processes and requirements such as contracts for the service required.

• Establishing communication with the relevant supplier for production on behalf of the company.

• Drawing up contracts with selected suppliers.

• Carrying out purchasing procedures.

• Monitoring and supervision of manufacturing process.

• Managing communication with the depot during the cancellation procedures when deficient or faulty products are received.

• Supervision of payments and granting approvals.

• In accordance with the Occupational Health law and agreement.

• Payment and supervision of premiums to be paid to employees and the government, pursuant of the SGK (Social Security Institution) regulation.

• Checking whether employees hold a certificate of competency (a certificate, document of authority, etc. depending on their occupation)

• Inspection of documents regarding hygiene and working at heights.

• Evaluation of supplier employees’ suitability according to OHS laws.

• Checking whether Social Security Institution premium debts have been paid.

• Gathering of required information and documents in order to establish a legal relationship with the supplier.

• Managing relationships with suppliers.

• Ensuring company resources are used economically and focusing on improvement of company operations based on customer oriented approach.

• Determining the needs of the depot and resolving it in a speedy and cost-effective manner.

• Carrying out purchasing transactions required by the company.

• Preparation of required visuals for product promotion and marketing.

• Recruitment of manpower required for the preparation of visuals necessary for product promotion and marketing.

• Obtaining documentation from real person or legal entity supplier processing personal data indicating adherence to liabilities in terms of FABRIQA’s data security, pursuant to the LPPD.

• Supervision of whether obligations are fulfilled and planning auditing.

• Foreseeing the liability for suppliers to preserve confidentiality indefinitely.

• Drafting a clause indicating that in the case where personal data relayed to suppliers is not obtained via legal channels, the supplier is obliged to inform FABRIQA of the situation as soon as possible.

8. 2. 4. Claimant 3. For a Group of Individuals:

• Legal, regulatory and company management legislations and ensuring compliance with correct application.

8. 2. 4. Public Official conducting the investigation or proceeding, for the administrative organ employee:

• Obtaining information and documents required for the management of legal and administrative procedures.

• Fulfilling legal obligations

8. 2. 6. For Online Visitors: Requirement of adherence to legislative regulations.

• Logging of online visitors and user’s system actions.

8. 2. 6. For Shareholders/Partners:

• Obtaining information and documents required for the management of legal and administrative procedures.

9. TRANSFER OF PERSONAL DATA TO THIRD PERSONS NATIONALLY AND ABROAD

Personal data and private personal data belonging to individuals may be transferred to third persons (third party companies, group companies, real third persons) in accordance with their processing purposes, by taking the necessary security measures.

9. 1. Transfer of Personal Data

Personal data may be transferred to third parties in the case where the conditions in LPPD’s Clause 8 and 9 are foreseen. E-mail and/or telephone number may be shared with third parties abroad for singularization and match-up purposes. Information of anonymous quality about online visitors which are non- member and their website use habits are collected with cookies and can be shared.

9. 2. Third Persons to Whom the Personal Data are Transferred, and Their Purpose of Processing

Your personal data may be transferred to the below-listed individuals:

• Business partners of FABRIQA,

• Suppliers of FABRIQA,

• Affiliates of FABRIQA,

• Shareholders of FABRIQA

• Legally competent public institutions and organizations,

• Legally competent private jurists.

Scope of the above-specified persons to whom transfer is made, and the purpose of data transfer are specified below.

9. PRESERVATION PERIOD OF PERSONAL DATA

The preservation periods of personal data processed by FABRIQA are indicated in the table below.

9. SAFETY OF PERSONAL DATA

To ensure the safety of personal data, reasonable measures are taken which will prevent risks of unauthorized access, accidents and data losses, deliberate deletion of data or damages to data.

To prevent access to personal data by persons other than those who have been granted authorisation to access, all necessary technical and physical measures are taken. In this context, particularly the authorization system shall be designed in such a way to make it impossible for anyone to access personal data to an extent which is more than required While ensuring safety of private personal data such as health data, measures which are more strict compared to measures related to other personal data are taken.

Authorized persons are subjected to necessary safety checks. In addition, the aforementioned persons are trained in relation to their duties and responsibilities.

Records of access to personal data are kept to the extent permitted by technical opportunities, and these records are reviewed at regular intervals. When an unauthorized access is suspected, an investigation is immediately initiated.

FABRIQA shall comply with the obligations specified below for the purpose of ensuring safety of the data being processed:

• Acting lawfully and honestly regarding the matters related to the protection of personal data,

• Processing the personal data accurately and in full,

• Carrying out the necessary practices for the purpose of updating the personal data which are outdated.

• When he/she notices any contradiction with the law in relation to processing of personal data, it shall inform   the relevant manager,

• Making necessary referrals for the exercise of legal rights related to personal data,

9. LEGAL RIGHTS OF INDIVIDUALS AND METHODS FOR EXERCISING THESE RIGHTS

9. 1. Rights Related to Personal Data in the Context of LPPD

Rights which can be exercised by individuals in relation to personal data as stated in LPPD Clause 11, are specified below:

• Learn whether or not personal data have been processed,

• Request information on the procedure, if personal data have been processed,

• Obtain information on the purpose of processing personal data and find out whether personal data were used as fit for the purpose,

• Obtain information about the third persons to whom personal data were communicated domestically or abroad,

• Request the correction of personal data that may have been incompletely or inaccurately processed,

• Request the deletion or destruction of personal data within the provisions set forth in applicable legislation,

• Request that the third parties to whom personal data are transferred are informed about the transaction carried out pursuant to sub-paragraphs (d) and (e),

• Object to an outcome which is detrimental to the concerned as a result of the analysis of the processed data exclusively through automatic systems,

• Request compensation for damages in the case that damages are sustained as a result of the illegal processing of personal data.

9. 2. Principles in Relation to Exercising Rights in Relation to Personal Data

To exercise their rights relating to personal data, FABRIQA members may submit their application via e-mail with the e-mail address they have registered into the system during their membership process, to info@kartelam.com.

9. EFFECTIVENESS AND UPDATABILITY

This hereby POLICY has entered into force on date of publication. The Policy may be updated for the purpose of adaptation to changing conditions and compliance with the legislation. Information regarding the relevant update will be provided via www.kartelam.com

The original of this Agreement has been issued in Turkish language. In any case of discrepancy between the Turkish version of the Agreement and the version in another language, the Turkish version shall prevail.

ANNEX-1 DEFINITIONS STATED IN THE POLICY

Express Consent:

Consent in relation to a specific matter, which is based on informing and which is expressed with free will.

Anonymization:

Anonymization of personal data is to render it impossible for personal data to be associated in any manner with the identity of a real person who is   is identified or identifiable, even if they are matched with other data.

Personal Data Owner:

Real persons whose personal data is being processed. For example, Members, Customers... Personal Data: means any kind of information about an identified or identifiable real person.

Private Personal Data:

Data in relation to race, ethnic origin, political opinion, philosophic belief, religion, sect or other beliefs, appearance, membership to associations, foundations or unions, health, sexual life, imprisonment and security measures and biometric and genetic data are private personal data.

Personal Data Protection:

Any transaction carried out with the data, such as obtaining, recording, storage, preservation, alteration, reorganization, disclosure, transfer, takeover, making available, classifying the personal data or blocking its   usage by full or partly automatic means, or by non-automatic means provided that they are part of a data entry system.

Data Processor:

Real and legal persons who process personal data on behalf of the data supervisor depending on the authorization granted by the data supervisor. Data Responsible: Real and legal persons who determine the aims and tools with which personal data will be processed, real and legal persons responsible for responsible for the establishment and management of the data record system.

KVKK:

Means the Law on the Protection of Personal Data No. 6698

You can reach Kartelam from the following contact information:

FABRIQA İNOVASYON A.Ş.

Adress:

Fatih Mah. 830.sok. No:11/B Küçükçekmece/İstanbul Turkey

E-mail: info@kartelam.com