Protection of Personal Data

The clarification and consent text hereby is prepared by Kalyon İnşaat Anonim Şirketi ('Company') acting in the capacity of data responsible person and other union companies in order to clarify the data owners in terms of the issues specified in article 10 and rights of the related person specified in article 11 of the law during taking open consent of data owners in accordance withLaw On Protection of Personal Data number 6698 ('Law') for processed personal data and specific quality personal data and achieving personal data.

Personal data, specific quality personal data and data processing concepts used in the clarification and consent text are used in relation to definitions made in the law. 'Personal data' concept mentioned in the law refers to any information in relation to real person, whose identity is certain or may be specified, and 'processing personal data' concept refers to any procedures performed on the data such as achieving, recording, storing, maintaining, changing, re-arranging, explaining, transferring, taking over, making achievable, classifyig or preventing usage of personal data wholly or partially, automatic or non-automatic provided to be a part of any data recording system.

Personal information belonging to data owner as per article 4 of the lawwill be processed within the scope of below-mentioned purposes by data responible company in accordance with law ad honesty rules; for correct and when needed, curent; specific, clear and legal purposes; in connection, limited to and proportionate to the purposes they are processed; in accordance with maintenance rules as long as required for the purpose projected in the related legislation or they are processed.

Your personal data collected will be processed within personal data processing terms and purposes specified in articles 5 and 6 of the law on the purposes of performing required works by work units to make you benefit from the products and services presented by our Company and Union Companies, recommending products and services presented by our Company and Union Companies for your admiration by customizing according to your usaga habits and needs, supply of legal and commercial security of the our company, union companies and people within business affairs with our company (Administrative operations for communication conducted by our Company, providing physical safety and audit of the locations belonging to the company, business partner/customer/supplier (authorized people or employees) evaluation processes, prestige research processes, legal compliance process, financial works etc.), determining and applying commercial business strategies of our company and supply of conducting human resources policies of our company.

Your personal data collected may be transferred in accordance with articles 8 and 9 of the law to union companies and real and legal persons within business relationships with our company on the purposes of performing required works by work units to make you benefit from the products and services presented by our Company and Union Companies, recommending products and services presented by our Company and Union Companies for your admiration by customizing according to your usaga habits and needs, supply of legal and commercial security of the our company, union companies and people within business affairs with our company (Administrative operations for communication conducted by our Company, providing physical safety and audit of the locations belonging to the company, business partner/customer/supplier (authorized people or employees) evaluation processes, prestige research processes, legal compliance process, financial works etc.), determining and applying commercial business strategies of our company and supply of conducting human resources policies of our company.

Your personal data may vary depending on services provided by our company and commerial activities of our company and also they may be collected in written or electronically by means of automatic or non-automatic methods, departments and offices of our company, union companies, internet site, social media channels,mobile applications and similar methods. Your personal data may be processed in accordance with the periods projected by the laws as long as you benefit from the products and the services submitted by our company and union companies.

Data owners have the rights to learn whether personal data of them is processed by applying to the company acting as data responsible person; to request information related to the fact if personal data is processed; to learn the purpose of personal data processing and whether it is used accordingly; to be notified about third persons, to whom personal data is transferred within and out of the country; to request correction of personal data in case it is processed deficiently or incorrectly; to request deletion or destruction of personal data within the framework of terms projected in article 7 of the law number 6698; to request that the procedures performed as per clauses (d) and (e) of article 11 of the law are notified to third persosn, to whom personal data is transferred; to reject ocurrrence of any result to the detriment of the person by means of analyzing data processed by means of automatic systems; to demand for elimination of damages in case the person incurs a loss due to the fact that personal data is processed illegally.

Data owners have the rights to learn whether personal data of them is processed by applying to the company acting as data responsible person; to request information related to the fact if personal data is processed; to learn the purpose of personal data processing and whether it is used accordingly; to be notified about third persons, to whom personal data is transferred within and out of the country; to request correction of personal data in case it is processed deficiently or incorrectly; to request deletion or destruction of personal data within the framework of terms projected in article 7 of the law number 6698; to request that the procedures performed as per clauses (d) and (e) of article 11 of the law are notified to third persosn, to whom personal data is transferred; to reject ocurrrence of any result to the detriment of the person by means of analyzing data processed by means of automatic systems; to demand for elimination of damages in case the person incurs a loss due to the fact that personal data is processed illegally.

Details in relation to camera monitoring system of Kalyon are given and informing about security measures to protect personal data, confidentiality, fundamental rights and legitimate interests of the ones included in the monitoring areas are made in Video Camera Monitoring Policy ("Policy") hereby. The policy hereby is based on arrangements of personal data protection legislation.

The Policy hereby and correspondingly video camera monitoring activity are applied in Central Office buildings and add-ons of Kalyon. There are totally 10 cameras as 8 cameras are in floors in all these listed areas and 2 of them are in building entries and exits. Specified numbers of camera is required to ensure security in our company and they are limited to this purpose. Cameras are divided into two as interior and exterior cameras. Interior cameras are located to see corridors and office entries and exits excluding areas of directly working areas of employees and washbasins, dining halls, kitchen. The locations of the cameras are carefully specified to maintain monitoring activity in minimum level and in a limite way on the purpose of monitoring.

Videos are viewed by means of computers of authorized persons. Video camera records are protected over the system.

Video monitoring system is entirety of video and observation and recording activities. All cameras are recording 24 hours a day, 7 days a week and images are kept for the periods specified according to security needs of the environment recorded through recording devices within the company.

Monitoring by using video camera is a part of Kalyon security program. Kalyon conducts this system only on the purpose of providing security of the buildings and facilities, controlling of entries to the buildings and facilities.

Only a limited number of Kalyon employees have access to records, which are recorded and maintained in digital environment. Administrative works department authorized person has authority to access to records. A limited number of people, who have access to the records, declare that they will protect confidentiality of data they have accessed through "Confidentiality Policy".

Technical and organizational measures are taken to provide integrity of video monitoring activities and sacurity of personal data. An access policy, by which only authorized people may have access to date obtained within this scope, is adopted and obtained data is never transferred to 3rd persons excluding legally authorized persons or institutions.

Image records obtained by camera monitoring activities never exceed one week in any circumstances by Kalyon. Records are automatically deleted at the end of one week.

Monitoring activities of Kalyon through video camera arepublished in information text hereby and internet site of Kalyon. In addition to it, informing is performed that monitoring is made by video camera in building and facility entries of Kalyon.

Each related person has the rights to learn whether personal data is processed by Kalyon, to request information in case personal data is procese, to learn processing purposes of personal data and whether they are used in accordance with the purposes, to know third persons, to whom personal information is transferred, to request correction in case personal data is processed deficiently or incorrectly, to request deletion or disposal of personal data in accordance with the legislation, to reject occurrence of any result to the detriment of the person by means of analyzing personal data and to request for recovery of losses due to processing personal data against law. Related person may send requests in relation to above-listed rights through e-mail to the address of hukuk@kalyongrup.com.

Contact will be made by Kalyon in relation to requests made within 30 days at the latest as a rule. IF no contact is made, the reason of it will be reported to the related applicant.

Kalyon declares that it may not carry out requests of the related person in case criminal or disciplinary investigations are conducted about the related person. Apart from it, the request may be caried out being subject to certain limitations, if fulfilling the request of the related person may likely restrain rights and freedoms of other people.

Best Regards,