Personal Data Protection and Processing Policy

Pursuant to the Personal Data Protection Law No. 6698 (PDPL)

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1) Purpose

As RYS Rota İnşaat Metal Yapı Sistemleri Sanayi ve Ticaret Limitet Şirketi ("RYS Rota" or the "Company"), we attach great importance to the protection of personal data belonging to natural persons we come into contact with during our commercial activities, and to the full fulfillment of the requirements set out in the Personal Data Protection Law No. 6698 ("PDPL"), which has been in force since its effective date of April 7, 2016.

The primary purpose of this Policy is to provide explanations regarding the personal data processing activities carried out by RYS Rota in a lawful manner and the systems adopted for the protection of personal data, and to ensure transparency by informing data subjects.

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2) Scope

This Policy applies to the personal data of our employees, interns, apprentices, main contractor officials and employees, company officials-shareholders-partners, authorized representatives, visitors, registered individuals, potential and current supplier officials and employees, administrative authority officials, product or service recipients, and all third parties with whom we have a relationship — and is applied across all processes of RYS Rota.

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3) Application of the Policy and Relevant Legislation

The applicable legal regulations in force regarding the processing and protection of personal data shall take precedence. In the event of any inconsistency between the applicable legislation and this Policy, the Company acknowledges that the applicable legislation shall prevail.

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4) General Principles for Processing Personal Data

RYS Rota processes personal data in accordance with the procedures and principles set out in the PDPL and other relevant laws. In this context, full compliance is ensured with the following principles:

• Processing in accordance with law and the rule of good faith • Ensuring that personal data is accurate and up to date when necessary • Processing for specific, explicit and legitimate purposes • Being relevant, limited and proportionate to the purposes for which they are processed • Retention for the period prescribed by the relevant legislation or required by the purpose for which they are processed

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5) Personal Data Protection Measures

In accordance with Article 12 of the PDPL, RYS Rota has taken the necessary technical and administrative measures to prevent unlawful processing of the personal data it processes, to prevent unlawful access to data, and to ensure the safekeeping of data.

Technical measures include: up-to-date anti-virus systems, encryption, firewalls, penetration testing, user account management and authorization control systems.

Administrative measures include: preparation of disclosure texts, creation of a personal data processing inventory, data security training for employees, and signing of confidentiality agreements.

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6) Transfer of Personal Data

RYS Rota may transfer personal data of data subjects to third parties by taking the necessary security measures in line with lawful personal data processing purposes. In this regard, the Company acts in accordance with the regulations set out in Articles 8 and 9 of the Law.

Personal data may be transferred to parties such as the Social Security Institution, authorized public institutions and organizations, certified public accountants, suppliers, the Revenue Administration, relevant banks, occupational health and safety service providers, tax offices, and business partners for the purpose of fulfilling regulatory obligations and conducting business processes.

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7) Rights of Data Subjects

Pursuant to Article 11 of the PDPL, data subjects have the right to:

• Learn whether personal data is being processed • Request information if personal data has been processed • Learn the purpose of processing personal data and whether it is being used for its intended purpose • Know the third parties to whom personal data is transferred domestically or abroad • Request correction of personal data if it is incomplete or incorrectly processed • Request deletion or destruction of personal data • Object to a result that is detrimental to themselves arising from analysis through automated systems exclusively • Request compensation for damages in case of unlawful processing of personal data

To exercise these rights, you may send an email to [email protected] or use the Data Subject Application Form.

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8) Contact

RYS Rota İnşaat Metal Yapı Sistemleri San. ve Tic. Ltd. Şti.

Saray Mah. Keresteciler Sanayi Sit. 15. Sokak No:25 Kazan / ANKARA

Phone: +90 (312) 815 22 41

Email: [email protected]

Web: www.rysrota.com