MAKİM MAKİNA TEKNOLOJİLERİ SANAYİ VE TİCARET A.Ş.

CLARIFICATION TEXT PURSUANT TO LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

Makim Makina Teknolojileri Sanayi ve Ticaret A.Ş. (“MAKİM”) respects your privacy and places great importance on the security of your personal data. In this context, this clarification text has been prepared to inform you, in accordance with the Law No. 6698 on the Protection of Personal Data (“Law”) and other relevant legislation.

The provisions of Articles 8, 9, 11, 13, 14, 15, 16, 17, and 18 of Law No. 6698 entered into force as of October 7, 2016.

The purpose of the Law is to protect fundamental rights and freedoms of individuals, especially the right to privacy, in the processing of personal data, and to regulate the obligations and procedures and principles to be followed by natural and legal persons who process such data. Accordingly, this text is provided to fulfill the obligation of clarification arising from the Law and is presented for the information and review of all individuals related to MAKİM, including but not limited to suppliers, customers, supplier employees, customer employees, MAKİM employees, and any person whose personal data is processed by MAKİM in any manner.

MAKİM hereby declares, represents and undertakes that it shall not transfer, sell, lease, or otherwise disclose to third parties, for any purpose other than legal obligations, the personal data entrusted to us or provided via forms on MAKİM’s website, including but not limited to your name, email address, business and home address, telephone number, and other personal data.

Processing of Personal Data
Processing of personal data refers to any operation performed on data such as collection, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, acquisition, making available, classification, or prevention of use, whether by fully or partially automated means or non-automated means provided that they form part of a data recording system.

Data Controller and Representative
In accordance with the Law, your personal data may be processed by MAKİM, as the data controller, within the scope defined in this text. MAKİM is responsible for determining the purposes and means of processing personal data recorded in its database and for establishing and managing the data recording system.

Purposes for Processing Your Data
Your personal data may be processed in accordance with Articles 5 and 6 of the Law for the following purposes: compliance with legal obligations; carrying out internal operations to provide products and services; conducting studies with relevant business units and partners to offer products and services tailored to your consumption and purchase preferences; ensuring proper human resource management and legal safety of individuals and MAKİM arising from relationships established; and other similar purposes necessary for the execution of commercial decisions and activities of our company.

Without your explicit consent, your personal data may be processed by MAKİM as the data controller in the following circumstances:

• Where it is necessary to protect the life or physical integrity of the data subject or another person, who is unable to express consent due to physical impossibility or whose consent is not legally valid;

• Where processing of personal data of the parties to a contract is necessary, provided that it is directly related to the performance of the contract;

• Where it is necessary to process data for the data controller to fulfill its legal obligations;

• Where the data has been made public by the data subject;

• Where processing is necessary for the establishment, exercise, or protection of a right;

• Where processing is necessary for the legitimate interests of the data controller, provided that such processing does not violate the fundamental rights and freedoms of the data subject.

Your personal data may be processed for the following purposes:

• To communicate with you and others as part of our services;

• To send important information regarding changes to our terms of service and other administrative notifications;

• To enhance quality, training, and security (e.g., via recorded or monitored calls to our contact numbers);

• To handle complaints and process requests for data access or correction;

• To comply with applicable laws and regulatory obligations, including those outside your country of residence, and to respond to lawful requests from public and government authorities;

• To manage our infrastructure and business operations, including audits, finance and accounting, billing and collections, IT systems, data and website hosting, business continuity, and records and print management;

• To determine and defend legal rights; to protect our operations, rights, privacy, safety, or property, or that of our partners, you, or others; and to pursue available remedies or limit our damages;

• To conduct market research and analysis, including satisfaction surveys.

Transfer of Personal Data: Recipients and Purposes
Your collected personal data may be transferred, in accordance with the personal data processing conditions and purposes set forth in Articles 8 and 9 of the Law, to our business partners, suppliers, shareholders, authorized public institutions, and private individuals for the purposes of ensuring legal and commercial security, delivering personalized services and products, determining business strategies, and executing human resources policies.

Methods and Legal Grounds for Collecting Personal Data
Your personal data may be collected by our Company through various channels and on different legal grounds to conduct our commercial activities. These personal data may be processed and transferred within the scope of the purposes specified in Articles 5 and 6 of the Law.

Rights of Data Subjects Under Article 11 of the Law
If you submit your requests regarding your rights as a data subject to our Company by the methods specified below, our Company will respond to your request free of charge as soon as possible and no later than thirty (30) days, depending on the nature of the request. However, if a cost arises, the tariff determined by the Personal Data Protection Board will apply. In this context, data subjects have the right to:

• Learn whether personal data is processed;

• Request information if personal data has been processed;

• Learn the purpose of the processing and whether the data is used in accordance with that purpose;

• Know the third parties to whom personal data is transferred domestically or abroad;

• Request correction of personal data if it is incomplete or inaccurately processed and to request notification of the correction to third parties;

• Request deletion or destruction of personal data when the reasons for processing no longer exist and request notification of such to third parties;

• Object to any outcome that is to their detriment as a result of analysis exclusively through automated systems;

• Request compensation for damages arising from the unlawful processing of personal data.

Pursuant to Article 13 of the Law, you may submit your request to exercise your rights in writing or by other methods determined by the Personal Data Protection Board. Since the Board has not determined any other methods at this stage, written applications must be submitted to our Company.

To exercise your rights, you may complete and sign the application form and send it along with documents identifying your identity:

• by hand to: MAKİM Makina Teknolojileri Sanayi ve Ticaret A.Ş., Sincan ASO 1st Organized Industrial Zone, Erkut Street No:20, Sincan / ANKARA, Turkey;

• via notary public;

• or by sending a secure electronically signed form to: makim@hs01.kep.tr.

DATA CONTROLLER
MAKİM MAKİNA TEKNOLOJİLERİ SANAYİ VE TİCARET A.Ş.