CLARIFICATION TEXT ON THE PROCESSING AND PROTECTION OF PERSONAL DATA


DATE: 11.11.19
VERSION NO: PO-017

DATA CONTROLLER
As LİDERSAN SAĞLIK VE GIDA ÜRÜNLERİ A.Ş. (hereinafter referred to as the “COMPANY”), we place utmost importance on the security of the personal data you share with us, whether through our website, application forms, or other channels. Accordingly, we ensure that the personal data of all individuals related to our company, including those benefiting from our products and services, are processed and stored in compliance with the Constitution of the Republic of Turkey, international agreements Turkey is a party to, and the Law on the Protection of Personal Data No. 6698 (the “Law”). Aware of this responsibility, as the “Data Controller” defined in the Law, we would like to explain how your personal data may be processed, the collection methods, legal purposes, and transfer of your data.

COLLECTION, PROCESSING, PURPOSES OF PROCESSING, TRANSFEREES, AND LEGAL GROUNDS FOR YOUR PERSONAL DATA
COLLECTION, PROCESSING, AND PURPOSES OF PROCESSING YOUR PERSONAL DATA
Your personal data is processed by our Company to perform our activities, provide our products and services within the prescribed legal framework, and fulfill our contractual and statutory obligations correctly and completely. Your personal data is processed for the purposes specified in this clarification text in accordance with the principles stipulated in the Law and the data processing conditions and purposes outlined in Articles 5 and 6 of the Law.

Purposes of Data Processing Include:
– Execution of Internal Company Operations
– Management of Customer-Facing Processes and Operations
– Execution of Marketing Operations
– Execution of Legal, Technical, and Administrative Activities
– Management of Corporate Communication Operations

For the purposes above, your personal data is processed to provide the best service for all brands of our Company, tailor products and services offered by our business units and partners to your preferences, habits, and needs, promote and market such services, ensure post-sales support, inform you about the content of these products and services, obtain your consent for sending commercial electronic messages, and develop business strategies. Your data may also be processed for purposes such as tracking complaints, conducting surveys, responding to inquiries, conducting ethical compliance reviews, ensuring legal and procedural compliance, and safeguarding the legal, technical, and commercial security of our Company and individuals in business relationships with the Company.

The personal data of individuals who do not currently benefit from our services but may do so in the future can also be processed for purposes such as tracking customer interactions, registering potential customers, evaluating employee performance, and planning sales processes for products and services.

Details regarding the purposes for processing your personal data and the data destruction policy can be accessed at:
– [http://www.altunkayagroup.com/kvkk.php](http://www.altunkayagroup.com/kvkk.php)
– [http://www.altunkayagroup.com/kvkk_imha.php](http://www.altunkayagroup.com/kvkk_imha.php)

TRANSFEREES AND PURPOSES OF TRANSFER
Your personal data may be shared with our business partners, suppliers, company officials, shareholders, employees, regulatory authorities, subcontractors, assistants, legally authorized public institutions, and private persons for the following purposes, in accordance with the data processing conditions specified in Articles 8 and 9 of the Law:

– Execution of Internal Company Operations
– Management of Customer-Facing Processes and Operations
– Execution of Marketing Operations
– Execution of Legal, Technical, and Administrative Activities
– Management of Corporate Communication Operations

For Company operations, personal data may be stored on a file server to facilitate access between departments, and no cloud systems are used. Personal data processed through Microsoft Office programs may be transferred abroad only for the management of the service agreement. Necessary administrative and technical measures will be implemented to prevent unauthorized access.

LEGAL GROUNDS FOR THE COLLECTION OF PERSONAL DATA
Your personal data is collected by our Company in accordance with the principles of legality, transparency, and proportionality. Depending on the circumstances, it may be collected through channels such as email, phone, website, social media, or customer service platforms for sales, service delivery, handling inquiries/complaints, and campaign/competition participation. These methods comply with Articles 5 and 6 of the Law.

PROTECTION OF CHILDREN’S PRIVACY
Our Company is committed to protecting children’s privacy. We operate our websites in compliance with applicable laws regarding the collection of data from individuals under the age of sixteen (16), or thirteen (13) where permitted by law. Children under the age of sixteen (or thirteen, as applicable) must obtain consent from their parent/guardian before providing any personal data. Should we identify that personal data has been collected from a child without proper consent, we will discontinue its use and processing. Parents/guardians may contact us to review, delete, or restrict the processing of their child’s data.

DATA SUBJECT RIGHTS UNDER ARTICLE 11 OF THE LAW
Under Article 11 of the Law, data subjects have the following rights:

– To learn whether their personal data is being processed,
– To request information regarding processed data,
– To learn the purpose of processing and whether data is used in compliance with the purpose,
– To know the third parties to whom their data is transferred domestically or abroad,
– To request correction of incomplete or incorrect data and request notification of this to third parties,
– To request deletion or destruction of data when the reasons for processing no longer exist and request notification of this to third parties,
– To object to decisions made solely through automated processing,
– To request compensation for damages arising from unlawful processing.

To exercise these rights, you may submit your request with a completed form available at [www.altunkayagroup.com](http://www.altunkayagroup.com), along with required identification documents, to the following address:
Başpınar (Organize) OSB Mah. O.S.B. 4. Bölge 83409 Nolu Cad. No: 3 Şehitkamil/Gaziantep/Turkey

Alternatively, you may email your request with a secure electronic signature to **lidersan@lidersan.hs.03.kep.tr**. Your request will be processed free of charge within thirty (30) days, unless a fee is determined by the Personal Data Protection Board.