REFLEKS FIRE SECURITY SYSTEMS JOINT STOCK COMPANY

PROTECTION OF PERSONAL DATA LIGHTING TEXT

As Refleks Fire Safety Systems Anonim Şirketi ( Reflex or the Company ), we show intense sensitivity and attach importance to the protection of your personal data. With this awareness, we process all kinds of personal data belonging to all persons associated with Reflex in accordance with the Law on Protection of Personal Data No. 6698 ( KVKK ). As defined in the KVKK, Reflex processes your personal data with care and attention, in the capacity of “Data Controller”, with the purposes and methods explained below, within the limits set by the legislation;

1. Definitions

Within the scope of this Clarification Text; Personal Data: All kinds of data relating to an identified or identifiable natural person (name, surname, TR ID number, address, telephone, system entry/exit times, current location, CVs, place of birth, date of birth, e-mail address, image records) and all other similar data), Sensitive Personal Data: All kinds of data (race, ethnic origin, political thought, religious belief, sect, dress, union membership, health , biometric data and all other similar data), Processing of Personal Data: All kinds of operations performed on personal data, including obtaining, recording, storing, changing, sharing with third parties and transferring personal data to abroad, automatically or non-automatically provided that it is a part of any data recording system, KVKK: Law on Protection of Personal Data No. 6698, which was published in the Official Gazette on April 7, 2016, Institution: Personal Data Protection Authority, Data Processor: The natural or legal person who processes Personal Data on behalf of the data controller, based on the authority given by the data controller, Data Controller: The natural or legal person who determines the purposes and means of processing Personal Data and is responsible for the establishment and management of the data recording system, Data Owner: The natural person whose personal data is processed, Refleks or Company: Refleks Fire Safety Systems Joint Stock Company, means.

2. Collection, Collection Method and Processing of Personal Data

Our customers, potential customers, employees, employee candidates, company officials, suppliers, business partners, employees of the companies we cooperate with, visitors and other 3rd parties. the personal data of the persons under our responsibility, within the framework of the relevant legislation, primarily the Constitution of the Republic of Turkey, the international agreements to which our country is a party, and the Law on the Protection of Personal Data No. 6698, by automatic or non-automatic methods, the relevant units of our Company, contact forms, miscellaneous agreements, e-mail or Our Company, verbally, in writing or electronically, through similar means. It will be able to be collected and processed by reflex . Since the Personal Data processed may differ according to the Relevant Person, the following Personal Data categories and Personal Data may differ for each Relevant Person and may vary according to the nature of the relevant service. Therefore, within the scope of KVKK, as Data Controller, we would like to enlighten you on the Processing of Personal Data.

3. Your Personal and Private Data Collected, Obtained and Processed within Refleks

1. Personal Data Protection Law , 5th and Your personal data in accordance with Articles 6;

• In accordance with the law and the rules of honesty,
• In connection with the purposes of processing, in a limited and measured way,
• Accurately and up-to-date when necessary,
• For specific, explicit and legitimate purposes,
• They will be stored and processed for the period required for the purpose for which they are processed or stipulated in the relevant legislation.

2. Transfer of Your Personal Data

Your personal data, 8 of the KVKK. Our shareholders, business partners, suppliers, business contacts, performance assistants, and in line with the Company’s field of activity and purpose, or in cases stipulated by the relevant legislation, regulatory, supervisory institutions and official authorities, provided that they are limited to the above-mentioned purposes, by taking necessary technical/administrative measures. can be transferred to or from abroad.

3. Storage and Deletion of Data

Our company stores the personal data it processes for the periods determined in the legislation, Company procedures and Company policies. In the event that the legislation also does not specify a time; Personal data is stored for the period that requires processing in accordance with the practices of our Company and the practices of commercial life, depending on the services our company provides while processing that data, and after this period, only for the periods determined to be necessary in practice in order to constitute evidence in possible legal disputes. After the expiry of the specified periods, the personal data in question are deleted, destroyed or anonymized by the methods defined in the company procedures and policies.

4. Your Rights as Data Owner
   • 11 of KVKK. within the framework of the article,

• Learning whether your personal data is processed or not,
• If your personal data has been processed, requesting information about it,
• Learning the purpose of processing personal data and whether they are used in accordance with the purpose,
• Knowing the third parties to whom your personal data is transferred, in the country or abroad,
• Requesting correction of your personal data if it is incomplete or incorrectly processed,
• To request the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK legislation and other legislation,
• When you request the deletion or destruction of your personal data with the correction of incomplete or inaccurate data, requesting that this situation be notified to the third parties to whom your personal data has been transferred,
• Objecting to the emergence of a result against you by analyzing the processed data exclusively through automated systems,
• If you suffer damage due to unlawful processing of personal data, to request the elimination of this damage,

You have the rights. To use your above-mentioned rights, Article 13 of the KVKK. 1 of the article. Pursuant to paragraph 11 of the KVKK, with the necessary information identifying your identity. A signed copy of the form by filling out the form at “https://reflexfire.com/” , including your explanations about your right that you request to use from the rights specified in the article; “ Reflex Fire Safety Systems Inc. Cumhuriyet Mah. Abdi İpekçi Cad. Marble Street No:2 pk. 34876 Kartal / ISTANBUL ” by mail or by hand, By scanning the form and by registered e-mail to [email protected] , You must forward it. In the application that includes your explanations regarding the right you have as the personal data owner and that you will make and request to use the above-mentioned rights;

• The matter you request is clear and understandable,
• The subject you request is related to your person,
• If you are acting on behalf of someone else, specifically documenting your authority in this regard,
• Finding identity and address information,
• Attachment of documents proving identity,

required. 8.2. Personal data owner, KVKK 14. In the event that the application is rejected, the answer given is insufficient, or the application is not answered in due time, pursuant to the article; A complaint can be made to the Board within thirty days from the date our company learns of the answer, and in any case within sixty days from the date of application with the approval of the person. Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and within 30 (thirty) days at the latest; but 13 of the Law. The Company reserves the right to charge you a fee according to the tariff to be determined by the Personal Data Protection Board, in case of any additional cost within the framework of the article. 8.3. Pursuant to article 28/2 of KVKK; In the following cases, personal data owners cannot claim their other rights, except for the right to demand the compensation of the damage;

• Personal data processing is necessary for the prevention of crime or for criminal investigation,
• Processing of personal data made public by the personal data owner,
• Personal data processing is necessary for the execution of supervisory or regulation duties and for disciplinary investigation or prosecution by authorized and authorized public institutions and organizations and professional organizations in the nature of public institution, based on the authority given by the law,
• The processing of personal data is necessary for the protection of the economic and financial interests of the state with regard to budgetary, tax and financial matters.

9. Circumstances in which Refleks May Process Your Personal Data Without Your Express Consent pursuant to KVKK

9.1. 5 of KVKK. In the following cases, Refleks may process your personal data stated above and received in accordance with the law, without your explicit consent;

• Where expressly provided for by law,
• If you, as the data owner, are unable to express your consent due to actual impossibility, or in cases where your consent is not legally valid, it is necessary to process your personal data in order to protect your or someone else’s life or physical integrity,
• Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
• It is mandatory for Refleks to fulfill a legal obligation,
• Your personal data has been made public by you,
• Data processing is mandatory for the establishment, exercise or protection of a right,
• Data processing is mandatory for the legitimate interests of Refleks , provided that it does not harm your fundamental rights and freedoms.

10. In case of inconsistency between the current legislation and this Clarification Text, the Data Controller accepts that the applicable legislation will find an area of application.

The Clarification Text is published on the website “https://reflexfire.com/” and made available to personal data owners. In order to adapt to the changing conditions and legislation, changes and updates can be made in the Clarification Text and can be submitted to personal data owners via the relevant website.

Refleks Fire Safety Systems Joint Stock Company

Phone: +90 (216) 469 10 78
Email: [email protected]
KEP : [email protected]