As a company, in accordance with Article 10 of Law No. 6698 on the Protection of Personal Data (KVKK), we would like to inform and clarify to you our personal data processing activities.

Identity of the Data Controller

Pursuant to Law No. 6698 on the Protection of Personal Data, your personal data may be processed, recorded, stored, classified, updated, and, within the limits permitted by legislation and/or for the purposes for which they are processed, disclosed/transferred to third parties by Resolution7 Teknoloji A.Ş, with its registered address at Tozkoparan, General Ali Rıza Gürcan Street, No:29, A Block, 34173 Güngören/Istanbul, as the data controller, in accordance with the law and principles of fairness.

Purposes of Processing Personal Data

Your personal data may be processed by our Company for various purposes depending on the services we provide and our commercial activities. Personal data may be collected automatically or non-automatically, via consents and/or signatures on contracts, information forms, or other documents; by our company departments and units; through the website, social media platforms, mobile applications, or other means; orally, in writing, or electronically.

Furthermore, personal data may be processed when you use our website to access company services, visit our website, or participate in trainings or events organized by our Company.

Your personal data will also be used to provide guidance on products that may interest you based on your usage habits, to provide information about campaigns, and for promotional, marketing, and campaign activities related to our products and services.

The personal data collected by the Company will be processed in accordance with the conditions and purposes of personal data processing specified in Articles 5 and 6 of the Law.

Your personal data may also be used within the scope of activities aimed at improving the quality of services we provide and for promotional, marketing, and campaign activities in sales and marketing processes.

Personal data may also be processed to ensure:

• Planning and/or execution of customer/user relationship management processes

• Tracking customer/user requests and/or complaints

• Monitoring contractual processes and/or legal claims

This is to protect the legal, technical, and commercial security of Resolution7 Teknoloji A.Ş and relevant parties with whom it has business relationships.

Purposes and Methods of Processing Personal Data

Our Company processes personal data within the purposes and conditions specified in Articles 5 and 6 of Law No. 6698 on the Protection of Personal Data, including:

• Where the Company’s activity regarding the processing of personal data is explicitly permitted by law,

• Where processing personal data is directly related to and necessary for the establishment or performance of a contract,

• Where processing personal data is necessary for the Company to fulfill its legal obligations,

• Where personal data has been made public by the data subject, limited to the purpose of public disclosure,

• Where processing is necessary for the establishment, exercise, or protection of the rights of the Company, the data subject, or third parties,

• Where processing is necessary for the Company’s legitimate interests, provided it does not harm the fundamental rights and freedoms of the data subject,

• Where processing is necessary to protect another person’s life or bodily integrity, and the data subject is unable to provide consent due to legal or factual impossibility,

• Where the processing of personal data other than health and sexual life is permitted by law,

• Where processing health and sexual life data is carried out by persons or authorities bound by confidentiality for the purposes of public health, preventive medicine, medical diagnosis, treatment and care, and planning and management of healthcare services and financing.

In cases where none of the above conditions apply, the Company obtains explicit consent from the data subjects before processing personal data.

Within these conditions, the Company may process personal data for purposes including, but not limited to:

• Performing necessary work and associated business processes to carry out commercial activities,

• Planning and execution of business continuity activities,

• Monitoring finance and/or accounting operations,

• Providing information to authorized institutions as required by law,

• Planning and executing corporate communications activities,

• Planning and executing production and/or operational processes,

• Planning and execution of access authorizations for business partners and/or suppliers,

• Planning and execution of customer relationship management processes,

• Tracking customer requests and/or complaints,

• Planning and execution of marketing processes for products and/or services,

• Planning and/or execution of post-sale support activities,

• Conducting market research for sales and marketing of products and services,

• Planning and execution of sales, post-sales operations, and procurement processes,

• Ensuring loyalty to products and/or services offered by the Company.

Collected personal data may also be processed to:

• Personalize recommendations of products and services according to your preferences, usage habits, and needs,

• Implement the Company’s human resources policies,

• Ensure legal and commercial security of the Company and related parties,

• Determine and execute the Company’s commercial and business strategies,

All processing is carried out in accordance with the conditions and purposes of personal data processing outlined in Articles 5 and 6 of Law No. 6698.

Necessary technical and administrative measures are taken to prevent unlawful processing of your personal data, unauthorized access, and to ensure secure storage.

Recipients and Purposes of Sharing Personal Data

Within the scope of the above purposes, personal data may be shared, in compliance with the principles of KVKK and Articles 8 and 9 of the Law, with:

• Public legal entities and authorities,

• Our subsidiaries,

• Companies operating as intermediaries/agents,

• Third parties providing services to carry out our main business activities (information systems, software),

• Domestic and international partners (Amazon Cloud AWS / Google Cloud / Microsoft Azure Cloud),

• Business partners, institutions, and independent audit firms.

Necessary security measures are applied when personal data is shared.

Method of Personal Data Collection and Legal Basis

Your personal data may be collected by the Company via customer representatives, websites, mobile applications, or social media accounts you allow access to, electronically. Processing and sharing is done in accordance with Articles 5 and 6 of KVKK and the purposes outlined in this disclosure.

Rights of the Data Subject

As a data subject, you have the right to submit requests regarding your personal data. The Company will respond free of charge within 30 (thirty) days, unless additional costs arise, in which case a fee may be charged in accordance with the Personal Data Protection Board’s tariff. Data subject rights include:

• To learn whether personal data is being processed,

• To request information if personal data has been processed,

• To learn the purpose of data processing and whether it is used accordingly,

• To know domestic or foreign third parties to whom personal data has been transferred,

• To request correction of incomplete or inaccurate personal data and have this notification sent to third parties,

• To request deletion or destruction of personal data if processing reasons no longer exist, with notification to third parties,

• To object to automatic profiling that produces a negative outcome,

• To request compensation in case of damage due to unlawful processing of personal data.

Methods of Application

You can submit your request in writing to Resolution7 Teknoloji A.Ş, Tozkoparan, General Ali Rıza Gürcan Street, No:29, A Block, 34173 Güngören/Istanbul, with identity verification documents, either in person, by mail with signature, via notary notification, or by secure electronic signature via email.