As Sen Pazarlama Gayrimenkul Anonim Sirketi(“Sen Pazarlama”), we have prepared this clarification text in order to inform our Visitors, Online Visitors, Customers, Potential Customers, Supplier Employees, Supplier Officials for the processing, retention and transfer of your personal data within the framework of their activities arising from the Personal Data Protection Law No. 6698 (“PDPL”) and the relevant legislation and legal regulations.

1) What are the Categories of Personal Data We Process and for What Purposes Do We Process Them?

Your personal data can be processed by Sen Pazarlama Gayrimenkul Anonim Sirketi for the purposes specified below within the scope of our established and ongoing business relationships with our business partners (it is possible for a person to be included in more than one category) in accordance with the following principles;

(i) Compliance with the law and rules of honesty,

(ii) Being accurate and up-to-date when necessary,

(iii) Being processed for specific, explicit and legitimate purposes,

(iv) Being relevant, limited and proportionate to the purpose for which it is processed,

(v) Being retained for the period stipulated in the relevant legislation or required for the purpose for which it is processed

as stipulated in the Article 4.2. of the PDPL.

A. Our Visitors

Identity information (e.g. name, surname) and physical location security information (e.g. camera recordings) of our visitors will be processed for the purposes of;

a) creating and following up the visitor records,

b) ensuring the physical location security.

B. Müşterilerimiz

Transaction security information (e.g. your IP address information), marketing information (e.g. shopping history information, cookie logs) and (if you have notified us*) identity information and contact details (e.g. your e-mail address) belonging to our online visitors who use our website can be processed for the purpose of;

a) carrying out the activities in accordance with the legislation,

b) carrying out the information security processes,

c) following up the requests/complaints,

d) carrying out the communication activities,

e) informing the authorized persons, institutions and organizations,

f) ensuring your access to our website via the Internet.

C. Müşterilerimiz

Identity information, contact details, customer transaction information (e.g. order details), physical location security information, finans bilgileri financial information (e.g. balance sheet information),legal transaction information, marketing information (e.g. shopping history information) belonging to the officials and/or employees of our natural person customers or our legal person customers will be processed for the purposes of;

a) carrying out the activities in accordance with the legislation,

b) conducting the financial and accounting affairs,

c) carrying out/supervising the business activities,

d) carrying out the logistics activities,

e) carrying out the after-sale support services for goods/services,

f) conducting the goods/service sales processes,

g) conducting the marketing analysis procedures,

h) carrying out the contract processes,

i) informing the authorized persons, institutions and organizations,

j) ensuring the physical location security,

k) resolving the legal disputes,

l) carrying out the retention and archiving activities,

m) carrying out the risk management processes,

n) carrying out the advertising/campaign/promotion processes, sending commercial electronic messages,

o) carrying out the company/product/services commitment processes,

p) carrying out communication activities.

D. Potential Customers

Identity details, contact details, customer transaction information, physical location security information, marketing information belonging to the officials and/or employees of our natural person customers or our legal entity customers will be processed for the purposes of;

a) managing the sales processes of goods/services,

b) carrying out the contract processes,

c) ensuring the physical location security,

d) carrying out the advertising/campaign/promotion processes, sending commercial electronic messages,

e) conducting the marketing analysis procedures.

E. Our Supplier Employee

Identity details, contact details, physical location security information, professional experience information (e.g. vocational training information) belonging to our supplier employee will be processed for the purposes of;

a) carrying out the communication activities,

b) carrying out / supervising the business activities,

c) ensuring the physical location security,

d) carrying out the supply chain management processes,

e) carrying out the logistics activities,

f) carrying out the activities in accordance with the legislation,

g) carrying out the occupational health/safety activities.

F. Our Supplier Official

Identity details, contact details, physical location security information, customer transaction information, financial information, marketing information, legal transaction information belonging to the officials of our natural person suppliers or legal person suppliers will be processed for the purposes of;

a) carrying out / supervising the business activities,

b) carrying out the goods/service procurement processes,

c) carrying out the financial and accounting affairs,

d) conducting the contract processes,

e) carrying out the investment processes,

f) ensuring the physical location security,

g) following up and conducting the legal affairs.

2) What are the Methods of Collecting Your Personal Data?

Your personal data specified in categories above is collected through physical means such as order forms, contracts, visitor forms or by automatic or non-automatic means through information systems and electronic devices (e.g. telecommunication infrastructure, computers and telephones), third parties (e.g. KKB and Findeks), our website and other documents declared by the data subject.

3) What is the Legal Reason for Collecting Your Personal Data?

Your personal data is processed by Sen Pazarlama Gayrimenkul Anonim Sirketi based on the following legal reasons as set forth in the Article 5 of the PDPL in line with the achievement of the purposes clarified above;

(i) It is explicitly stipulated in the laws,

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

(iii) It is mandatory for the data controller to fulfill its legal obligation,

(iv) Data processing is mandatory for the establishment, exercise or protection of a right,

(v) Data processing is mandatory for the legitimate interests of the data controller, provided that it does not cause harm to the fundamental rights and freedoms of the data subject.

(vi) Identity and contact details of our Customers and Potential Customers will be processed for the purposes of carrying out the advertising, campaign, promotion activities and sending commercial electronic messages based on their explicit consent.

4) Do We Transfer Your Personal Data to a Third Party?

a) The personal data belonging to our visitors may be shared with the law enforcement agencies and judicial authorities for the purpose of resolving the legal disputes and if requested in accordance with the relevant legislation.

b) The personal data belonging to our online visitors may be shared with the judicial authorities and authorized public institutions and organizations for the purpose of resolving the legal disputes and if requested in accordance with the relevant legislation.

c) The personal data belonging to our customers, within the scope stipulated by the legal regulations, is transferred to the authorized public institutions and organizations for the purpose of carrying out the activities in accordance with the legislation, following up and conducting the legal affairs, informing the authorized persons, institutions and organizations; to our group companies, information company, suppliers, courier companies, insurance companies, banks and our financial advisor to the extent necessary for carrying out / supervising the business activities, carrying out the risk management processes and performing our services properly. Furthermore, such personal data may be transferred to the law office and judicial authorities from which we receive services in order to be used as evidence in the legal disputes that may arise in the future.

d) The personal data belonging to our potential customers may be transferred to the law office and judicial authorities in order to be used as evidence in the legal disputes that may arise in the future.

e) The personal data belonging to our supplier employees, within the scope stipulated by the legal regulations, is transferred to the authorized public institutions and organizations for the purpose of carrying out the activities in accordance with the legislation, following up and conducting the legal affairs, informing the authorized persons, institutions and organizations, carrying out / supervising the business activities; to the group companies, information company, suppliers, courier companies, banks and our financial advisor to the extent necessary for the proper performance of the service. Furthermore, such personal data may be transferred to the law office and judicial authorities from which we receive services in order to be used as evidence in the legal disputes that may arise in the future.

f) The personal data belonging to our supplier official, within the scope stipulated by the legal regulations, is transferred to the authorized public institutions and organizations for the purpose of carrying out the activities in accordance with the legislation, following up and conducting the legal affairs, informing the authorized persons, institutions and organizations, carrying out / supervising the business activities; to the group companies, information company, suppliers, courier companies, banks and our financial advisor to the extent necessary for the proper performance of the service. Furthermore, such personal data may be transferred to the law office and judicial authorities from which we receive services in order to be used as evidence in the legal disputes that may arise in the future.

5) Do We Transfer Your Personal Data to Abroad?

As Sen Pazarlama Gayrimenkul Anonim Sirketi, we do not transfer your personal data to abroad.

6) How Can You Exercise Your Rights Regarding Your Personal Data?

You can forward to us your requests under the Article 11 of the PDPL regulating the rights of the data subjects with the “Application Form to the Data Controller” prepared for your convenience in accordance with the “Communiqué on the Procedures and Principles for Application to the Data Controller” at the address of “https://sengrup.com/” belonging to Sen Pazarlama Gayrimenkul Anonim Sirketi.

Data Controller: Sen Pazarlama Gayrimenkul Anonim Sirketi

Address:Mahmutbey Mah. Taşocağı Yolu Cad. Balance Güneşli, No.: 19/6 Güneşli / İstanbul

E-mailkvkk@sengrup.com