TURHAN & TURHAN LAW FIRM CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

As Turhan & Turhan Law Firm (“Turhan & Turhan”), we show the necessary sensitivity regarding the security and protection of your personal data and we would like to inform you that we take all necessary measures in this regard.

We attach great importance to the processing of all kinds of personal data belonging to visitors and employees of the organizations we cooperate with, shareholders, officials, employees of our office, employee candidates and all other related persons, including the persons who benefit from our legal consultancy services, in accordance with the Law No. 6698 on the Protection of Personal Data (“PDP Law” or “Law”) and other relevant legislation. For this reason and with the awareness of our responsibility, as the Data Controller, we aim to inform you with this text on the protection of personal data (“Clarification Text”) within the scope of the data controller’s obligation to inform you about our activities regarding the processing and protection of personal data.

1) Scope

This Clarification Text includes explanations about the content of the personal data we process, the way they are used and processed, the conditions for their storage, your rights as a data subject, and the measures taken for the security and protection of your personal data.

2) Purpose of Processing Personal Data

As Turhan & Turhan, we process your personal data in accordance with Article 4 of the PDP Law, in accordance with the law and good faith, in an accurate and up-to-date manner, for specific, explicit and legitimate purposes and in connection with, limited and measured for these purposes. In addition, we retain your personal data for the period required for the purpose for which they are processed and stipulated in the PDP Law and the relevant legislation.

Your personal data shall be processed by the Data Controller Turhan & Turhan in accordance with Article 20 of the Constitution of the Republic of Turkey, Article 4 of the PDP Law and the principles of protection of personal data;

a) Providing the services you request in line with your needs in terms of visitors, existing and potential clients and business partners, Performing all kinds of advocacy and legal consultancy activities and providing additional / complementary services related to these activities (e.g. translation, notary etc.), Providing information on various current legal developments, Planning commercial and / or legal business strategies,

Carrying out the financial and accounting affairs of the office, reviewing proposals for client meetings, consultancy offers, preparation of legal reports and other legal services within our law office, Establishing and / or executing legal consultancy agreements,

Execution of client relations processes, Execution of contract processes and determination and control of the signature authorities of the parties signing the relevant documents, Recording the identity, address, tax number and other information necessary for determining the owners and addressees of all kinds of business and transactions, arranging on paper or in electronic environment, Providing information to the Competent Court, Execution Office, institutions and / or organizations, Execution of the information security process,

b) Administering and providing payments for Employees and Employee Candidates, including administering and providing salary payments, payroll processing, payroll bonus, share options and other incentives, maintaining employee personnel file, ensuring compliance with applicable workplace procedures and ensuring work order, Ensuring communication with employees and employee candidates, Communicating with the persons specified by the employee in case of emergency, Responding to and fulfilling requests and legal requests from regulators or other authorities in the country or abroad, Ensuring confidentiality and security in the workplace, SSI, Fulfillment of notification, reporting, information storage and other transactions stipulated by law before Turkish Employment Agency (İŞKUR) and all other administrations and authorities (e.g. recruitment, termination of employment, work accidents etc.) Making leave arrangements for employees, Recording the curriculum vitae and similar data collected during the job application and interview of employees, It can be processed for the purposes of ensuring that the packages received by cargo and courier are delivered to the relevant employee, following the salary attachments placed on the employee’s salary and making payments related to salary deductions to the execution file, implementing court decisions, fulfilling obligations in accordance with the Constitution, laws, regulations and all other legal legislation in force.

3) Processing of Personal Data

Your personal data and sensitive personal data may be processed with your explicit consent in accordance with Articles 5 and 6 of the Law and for the purposes set out above. However, in the presence of one of the following conditions, your personal data may be processed without explicit consent:

a) It is clearly stipulated in the laws.

b) It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his/her consent due to actual impossibility or whose consent is not legally valid.

c) It is necessary to process personal data belonging to the parties of a contract, provided that it is directly related to the establishment or performance of a contract.

ç) It is mandatory for the data controller to fulfill its legal obligation.

d) It is made public by the data subject himself/herself.

e) Data processing is mandatory for the establishment, exercise or protection of a right.

f) Data processing is mandatory for the legitimate interests of the data controller, provided that it is not harmful to the fundamental rights and freedoms of the data subject.

4) To Whom and For Which Purposes the Personal Data May Be Transferred

Your personal data shall not be used and processed for purposes other than those stated above and shall not be shared or transferred to third parties without your explicit consent within the scope of legal obligations and with third parties other than official institutions/organizations.

In accordance with Article 8 of the Law, your personal data may be transferred to business partners, lawyers, data processors, archive companies, authorized courts and/or enforcement offices, public institutions and organizations for legal and financial audits in Turkey. In addition, in accordance with Article 9 of the PDP Law, your personal data may be transferred directly or indirectly by Turhan & Turhan to third parties abroad from whom Turhan & Turhan receives or plans to receive consultancy, support or legal services, third parties from whom Turhan & Turhan receives or plans to receive consultancy, support or services in other matters, legally authorized institutions and organizations within the framework of the specified personal data processing conditions and purposes.

5) Methods of Collection of Personal Data

Your personal data is collected by the Data Controller through different channels and on the basis of different legal grounds for the purposes stated above, in order for Turhan & Turhan Law Firm to fulfill its legal obligations in full. Turhan & Turhan may collect personal data verbally or in writing in physical or electronic media by means of automatic or non-automatic methods such as verbal communication, electronic mail, website, mobile applications, application form, fax, telephone, mail, courier, hand delivery.

6) Storage, Destruction and Security of Personal Data

In accordance with Article 12 of the Personal Data Protection Law No. 6698, in order to ensure data security by our Office,

All necessary technical and administrative measures are taken to prevent unlawful processing of personal data, to prevent unlawful access to personal data, to ensure the level of security required to ensure the protection of personal data.

Your personal data shall be stored for the periods required by the processing purposes stated above. In the event that the reasons requiring the processing of your Personal Data disappear, these data shall be deleted, destroyed or anonymized spontaneously or upon the request of the person concerned, without prejudice to the cases required to be kept by law.

7) Rights of the Data Subject

Pursuant to Article 11 of the Law, personal data owners have the following rights; To learn whether their personal data are processed, To request information if their personal data is processed, To learn the purpose of processing their personal data and whether they are used in accordance with their purpose, To know the third parties to whom their personal data are transferred domestically or abroad, To request correction of their personal data in case of incomplete or incorrect processing and to notify third parties to whom personal data are transferred within this scope, To request the deletion/destruction of their personal data within the framework of the conditions stipulated in Article 7 of the PDP Law and to notify third parties to whom personal data are transferred within this scope To request the deletion/destruction of personal data within the framework of the conditions stipulated in Article 7 of the PDP Law and to notify third parties to whom personal data is transferred in this context, To object to the occurrence of a result against them by analyzing the processed data exclusively through automated systems, To request compensation in case they suffer damage due to the processing of their personal data in violation of the PDP Law.

8) Application of the Data Subject

You may submit your requests regarding the use of the above-mentioned rights by hand with a wet signed petition or by registered letter with return receipt requested to Leylak 1 Sk. Nursanlar İş Merkezi Kat 3 Daire 13 Şişli/İstanbul/Turkey or by using secure electronic signature, mobile signature or your e-mail address that you have previously notified us and is included in our records, to the e-mail address [email protected] with the phrase “Personal Data Information Acquisition Request” in the subject line.

Depending on the nature of your request, your applications shall be finalized free of charge as soon as possible and within thirty days at the latest and you shall be informed about this matter. However, if the transaction requires an additional cost, Turhan & Turhan shall charge you the fee in the tariff determined by the Personal Data Protection Board.

Turhan & Turhan Law Firm

Leylak1 Sk. Nursanlar İş Merkezi K.3 D.13 Şişli/İSTANBUL