PERSONAL DATA PROTECTION INFORMATION NOTICE

At Sarcina Ambalaj Ltd. Şti., your privacy is respected and importance is attached to your data security. Within this scope, this text has been prepared in order to inform and enlighten you within the scope of the Personal Data Protection Law No. 6698 (“Law”) and other relevant legislation.

  1. IDENTITY OF THE DATA CONTROLLER

Your personal data may be processed by Sarcina Ambalaj Ltd. Şti., acting as the data controller, within the scope explained below pursuant to the Personal Data Protection Law No. 6698 (“Law”).

Sarcina Ambalaj Ltd. Şti.

Company Address: İkitelli OSB Eskoop Industrial Site C6-4 Block No:371 Başakşehir – İstanbul

Company E-mail Address: info@sarcina.com.tr

Company Phone Number: +(212) 856 05 50

  1. PURPOSE OF PROCESSING PERSONAL DATA

a) Carrying out the necessary operational activities within the company in order to provide you with the products and services offered by our company,

b) Carrying out the necessary works with the relevant business units and business partners in order to recommend products and services suitable for your consumption and purchasing motivations,

c) Ensuring human resources management by our Company and securing the rights of real persons, taking the necessary steps for making, implementing and executing commercial decisions by our Company, and ensuring the legal security of our Company and the real and legal persons with whom we have business relations arising from such relations,

d) Monitoring of Finance and Accounting Affairs,

e) Planning and Execution of Business Continuity Activities,

f) Planning, auditing and execution of information security processes,

g) Establishment and management of information technologies infrastructure,

h) Planning and execution of corporate communication activities,

i) Planning and execution of logistics activities,

j) Planning and execution of access authorizations of business partners and suppliers to information,

k) Event management,

l) Planning and execution of activities,

m) Planning and execution of supply chain management processes,

n) Planning and execution of corporate governance activities,

o) Planning and execution of activities regarding efficiency/productivity and appropriateness analyses of business activities,

p) Planning and execution of corporate sustainability activities,

r) Follow-up of contractual processes and/or legal claims,

s) Planning and execution of sales processes of products and/or services,

t) Planning and execution of customer relationship management processes,

u) Planning and/or execution of after-sales support service activities,

v) Collection and evaluation of customer complaints, requests and suggestions,

y) Planning and execution of additional services supporting sales,

z) Planning of loyalty and campaign management processes and planning and/or execution of customer satisfaction activities.

  1. CASES WHERE PERSONAL DATA MAY BE PROCESSED WITHOUT EXPLICIT CONSENT

Your Personal Data may also be processed by Sarcina Ambalaj Ltd. Şti., acting as the Data Controller, without seeking your explicit consent in the following cases:

a) Where 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, or of another person,

b) Provided that it is directly related to the performance of a contract, where processing of personal data belonging to the parties of the contract is necessary,

c) Where it is mandatory for us to fulfill our legal obligations as the data controller,

d) Where the relevant person has made the data public himself/herself,

e) Where data processing is mandatory for the establishment, exercise or protection of a right,

f) Provided that it does not harm the fundamental rights and freedoms of the relevant person, where data processing is mandatory for the legitimate interests of the data controller,

and may be used for the purposes specified below based on any of these conditions.

  1. METHOD OF PROCESSING PERSONAL DATA

Processing of your personal data refers to any operation performed on data such as obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data wholly or partially by automatic means or by non-automatic means provided that it is part of any data recording system. Pursuant to the Law, your personal data may be processed by Sarcina Ambalaj Ltd. Şti., acting as the data controller, within the scope explained in this text.

  1. TO WHOM AND HOW THE PROCESSED PERSONAL DATA MAY BE TRANSFERRED

Your collected personal data may be transferred to our business partners, shareholders, legally authorized public institutions and private persons within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law, for the purposes of ensuring the legal and commercial security of persons within our Company, carrying out the necessary works by our business units in order to enable you to benefit from the products and services offered by our Company, customizing and recommending the products and services offered by our Company according to your preferences, usage habits and needs, determining and implementing the commercial and business strategies of our Company, and ensuring the execution of our Company’s human resources policies.

  1. Method and Legal Reason for Collecting Personal Data

Your personal data is collected by our Company through different channels and based on different legal reasons in order to carry out our commercial activities. Your personal data collected for these legal reasons may also be processed and transferred for the purposes specified in Articles (b) and (c) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law.

  1. RIGHTS OF THE PERSONAL DATA OWNER

Regarding the rights listed in Article 11 of the Personal Data Protection Law, if you submit your requests concerning your rights as Personal Data Owners to our Company through the methods regulated below in this Information Notice, our Company shall conclude the request free of charge as soon as possible and within thirty days at the latest depending on the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by our Company shall be charged. Within this scope, personal data owners have the following rights:

a) To learn whether personal data is processed,

b) To request information if personal data has been processed,

c) To learn the purpose of processing personal data and whether they are used in accordance with their purpose,

d) To know the third parties to whom personal data is transferred domestically or abroad,

e) To request correction of personal data if processed incompletely or inaccurately and to request notification of the transaction made within this scope to third parties to whom the personal data has been transferred,

f) To request deletion or destruction of personal data in the event that the reasons requiring processing disappear despite being processed in accordance with the Personal Data Protection Law and other relevant laws, and to request notification of the transaction made within this scope to third parties to whom the personal data has been transferred,

g) To object to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,

h) To request compensation for damages in case of damage due to unlawful processing of personal data.

Pursuant to paragraph 1 of Article 13 of the Personal Data Protection Law, you may submit your request regarding the exercise of your above-mentioned rights to our Company in writing. Within this framework, the channels and procedures through which you will submit your written applications to our Company within the scope of Article 11 of the Personal Data Protection Law are explained below.

In order to exercise your above-mentioned rights, you may fill out the form containing the necessary information identifying your identity and your explanations regarding the right you request to exercise among the rights specified in Article 11 of the Personal Data Protection Law, and deliver a signed copy of the form in person together with identity documents to the address of Sarcina Ambalaj Ltd. Şti., İkitelli OSB Eskoop Industrial Site C6-4 Block No:371 Başakşehir – İstanbul, or send it via notary public or registered electronic mail (KEP) address.