As ÖZKA LASTİK VE KAUÇUK SANAYİ TİCARET ANONİM ŞİRKETİ (which will be referred to as “ÖZKA”, “Company” or “Us”), we attach significant importance to processing personal data of our customers in accordance with the law. With the Notification about Protection and Processing of Personal Data (“Notification”), we are aiming to ensure compliance with Personal Data Protection Law with no 6698 and national legislation in force with respect to personal data.

Ensuring security of personal data of our customers is among our primary objectives. For this reason, in order for personal data of our customers to be stored safely and to avoid all kinds of illegal access or leakages in relation to these data, we are only sharing the data of our customers with our reliable business partners at minimum level and we are taking security measures in conformity with the legislation in force.

Transparencyis one of the most important topics for us in the field of personal data protection. We have prepared this Notification to fulfill our obligations arising from the law, as well as to provide you with the necessary information while we process your personal data to give you a better customer experience. You can find detailed descriptions of which personal data is processed for what purposes under the headings “Which personal data do we process” and “For what purposes we process your personal data”.

Another important issue for us is the right of our customer to control their data. We take the necessary measures to manage our customers' preferences about their data and we respect their preferences at the maximum level. In this context, you can send your requests to us through the communication channels under the heading "Exercise of rights by data owners". You can also find detailed explanations on this subject under the heading "Rights of Data Owners". You can find the explanations of the terms used in the notification under the heading “Definitions”.

Data security, transparency and the right of people to control their personal data constitute the most important basis for us in terms of compliance with the Law. In this regard, we hereby provide you with detailed information about the processing of your personal data with this Notification.

FOR WHICH PURPOSE ARE WE PROCESSING YOUR PERSONAL DATA

The notification includes our declarations and explanations regarding the processing of personal data of our customers and natural persons contacting us in compliance with the provisions of the Law, especially national legislation.

We reserve the right to make changes to the Notification in order to provide up-to-date information on practices and legal regulations within the framework of personal data protection. However, we will notify data subjects through appropriate channels if substantial changes are made to the Notification.

The Notification has been prepared in order to provide information about what personal data ÖZKA processes while processing its commercial activities, for which purpose it handles this data, and for which purposes it can be transferred to which third parties. The notification basically covers personal data collected through the following channels.

WHICH OF YOUR PERSONAL DATA ARE WE PROCESSING

A) YOUR PERSONAL DATA BEING PROCESSED WITHIN CONTEXT OF COMMUNICATION SERVICES

We can process some data about you through the "Communication Services" channels we have created in order to benefit you from our products and services, to resolve your requests / complaints and suggestions, to provide information, to evaluate your applications and to provide you with a better service.

1 - Processing of your personal data through our call centers

When you call our call center numbers related to our brands such as ÖZKA, GTK, PULMOX or when we contact you through these channels, your personal information such as your name, last name and T.R.ID No, your mobile phone number, your contact information such as your e-mail, and your personal data such as your request/complaint details can be processed. These personal data can be processed for carrying out the processes of loyalty to companies / products / services, conducting communication activities, conducting customer relations management processes, conducting activities for customer satisfaction, organization and event management, conducting social responsibility and civil society activities, following legal requests, conducting contract processes, can be processed for purposes such as tracking demands/complaints, conducting marketing processes of products / services, ensuring that data is accurate and up to date, and similar purposes. The processing of your personal data for the purposes set out here may be based on establishing or executing a contract between you, fulfilling our legal obligations, establishing, exercising or protecting a right, or legitimate interests of our Company. If at least one of these legal reasons does not exist, we are looking for your express consent to process your data.

2 - Processing of your personal data through our internet sites

Your contact name, e-mail, mobile phone, address, request / complaint information can be collected and processed through the contact forms on the websites of our company and our brands. In some of our websites it is asked if you want to be informed about our campaigns. If you indicate that you want to be informed about our campaigns, we can process your identity and contact information you provide us with the purpose of informing you about our campaigns, discounts, new products and opportunities. You can revoke your consent at any time to receive news from campaigns and us. Some of our websites have live help sections. Your personal data, such as your mobile phone number, request / complaint information, can be collected through live help. Some of your personal data that you provide in e-mails that you send to info e-mail addresses of our websites can be processed. Some personal data, such as your usage habits, likes, frequency of visit, can be collected through the cookies used on our websites that use cookies. For detailed information on what cookies are used and what you need to do to remove cookies, we suggest you take a look at the Cookie Policy of the relevant site. Your personal data collected through our websites can be processed for purposes such as conducting communication activities, planning and executing requests, complaints and information receiving processes, conducting loyalty processes to companies / products / services, conducting communication activities, conducting customer relationship management processes, conducting activities for customer satisfaction, establishment or execution of a contract, legal liabilities, establishment, usage or protection of a right, or in relation to legitimate interests of our company based on legal grounds.

3 - Processing of your personal data through your social media accounts

To reach existing and potential customers on social media platforms, ÖZKA can publish content with both “organic” and “paid” methods. “Organic methods” mean publishing of social media content at the social platform on the page/pages of ÖZKA or their being shown as part of social media content as a result of your following up the social media accounts. For example, in the case where you follow up Instagram page of ÖZKA. “Paid methods” defines screening of social media content for users who generally do not follow up the page/pages of ÖZKA. For example, such as screening of advertisement posts within Twitter content flow. In addition, when you contact us through our social media accounts such as Twitter, Facebook, Google Plus, Instagram, you can share your personal data with us such as your surname, username, e-mail address, telephone and / or mobile phone number, request / complaint information. In this situation your said personal data can be processed for purposes such as conducting company / product / service loyalty processes, conducting communication activities, conducting customer relationship management processes, conducting activities for customer satisfaction, following legal requests, conducting contract processes, planning and / or increasing the commitment to the products and / or services offered by the Company, and / or execution, tracking requests / complaints, ensuring that the data are accurate and up to date, establishment or execution of a contract, legal liabilities, establishment, usage or protection of a right, or in relation to legitimate interests of our company based on legal grounds. However, we would like to remind you that; ÖZKA does not have direct access to your personal data in your social media accounts. However, ÖZKA is not responsible for the processing, protection and data security policies of your personal data of social media organizations. For detailed information on how these organizations use your personal data, we recommend that you take a look at their privacy policies on their websites.

B. PROCESSING OF PERSONAL DATA OF DEALER’S AND/OR ITS EMPLOYEES

If you have applied to become a reseller of ÖZKA, some information is requested from you in order to evaluate your application. Applications to become a dealer can be made through the websites of ÖZKA or our brands or by direct document delivery method. Processed personal data of those making dealer applications and of dealer officers and employees can vary from one process to the other but generally, they can be comprised of process security information such as name, last name, address, mobile phone, title, user name, log records, IP information, instructions and related records, T.R.ID No, information stated on signature circular, instructions and records, and education details. On the other hand, although the information about legal persons is not considered as personal data, your personal data such as IBAN, account no., receivable and debt balance, financial transaction information can also be processed if our dealers are private companies. When you contact us through our dealer support line, the Company can keep a record of your call as well as your personal data mentioned in this topic. Your personal data in question can be processed for the following purposes, based on the legal reasons for the establishment or performance of the contract, legal obligation, establishment, use or protection of a right and the legitimate interests of ÖZKA:

• Conducting communication activities,
• Ensuring the security of ÖZKA operations,
• Follow-up and / or audit of business activities of dealer employees,
• Planning and execution of business activities,
• Follow-up of requests / complaints,
• Ensuring that the data are correct and up-to-date,
• Planning and / or execution of business continuity activities,
• Execution of advertising / campaign / promotion processes,
• Carrying out financial and accounting works, 
• Following and executing legal affairs,
• Execution of risk management processes,
• Carrying out activities in accordance with the legislation
• Planning and / or execution of the activities of effectiveness / efficiency and / or on-site analysis of business activities,
• Planning and execution of market research activities for the sales and marketing of products and services,
• Conducting audit / ethical activities,
• Execution of marketing processes of products / services,
• Execution of access rights,
• Execution of custody and archive activities,
• Conducting internal audit / investigation / intelligence activities,
• Conducting commitment processes to companies / products / services,
• Organization and event management,
• Carrying out training activities,
• Carrying out logistics activities,
• Conducting goods and services purchasing and after sales support processes,
• Planning and execution of corporate communication activities.
• Conducting dealer relationship management processes,
• Execution of goods / services production and operation processes,

C. PROCESSING OF PERSONAL DATA OF SUB-EMPLOYER OFFICER AND/OR EMPLOYEES

If you are an officer or employee of companies serving as a subcontractor to ÖZKA, we may need to process your personal data due to the business relationship and some of our obligations. In general, we can process your personal data to achieve the following objectives:

• Conducting communication activities,
• Planning and execution of business activities,
• Organization and event management,
• Giving information to authorized people / institutions and organizations,
• Planning and execution of production and / or operation processes,
• Planning and / or execution of occupational health and / or safety processes,
• Carrying out financial and accounting works,
• Follow-up and execution of legal affairs,
• Execution of risk management processes,
• Execution of contract processes,
• Management of relations with subcontractors,
• Planning and / or execution of business continuity activities,
• Planning of human resources processes,
• Conducting internal audit / investigation / intelligence activities,
• Fulfilling legal obligations for subcontractor employees,

D. PROCESSING OF PERSONAL DATA OF SUPPLIER AND BUSINESS PARTNER OFFICER AND/OR EMPLOYEES

We have some business partners and suppliers with whom we have entered into a business relationship in order to provide services and support to ÖZKA on some issues. In this context, because you are an employee or a signatory of these companies, we need to process some of your personal data in order to fulfill our obligations in the business relationship between us. For example, in order to contact you within the scope of the service we receive, your personal data such as your e-mail address and phone number can be processed. Due to the reason that you are one of the officers or employees of our suppliers or business partners, we can process your personal data for purposes such as execution and control of business activities, execution of communication activities, execution of financial and accounting works, execution of production & service operations and sales processes, execution of activities in accordance with the legislation, as based on legal reasons such as legal liabilities, establishment or execution of a contract, and legitimate interests of ÖZKA.

E. PROCESSING OF PERSONAL DATA OF VISITORS

If you come to ÖZKA buildings, facilities as a visitor, some personal data can be processed within the scope of creating and tracking visitor records before entering or while entering the campuses. Our personal data processing activities are presented below for your information:

1 - Processing of your personal data by keeping internet visitor access records

When you are connected to the ÖZKA internet network as a guest for internet access, ÖZKA is obliged to save your internet access records to their own systems electronically and keep them for two years. Within context of this liability, your personal data among internet access records such as internet usage start and end time, IP address, MAC address, internet pages you visit, log records can be recorded and stored by ÖZKA. ÖZKA, processes your personal data for below purposes or similar ones:

• Carrying out the activities in accordance with the legislation,
• Follow-up and execution of legal affairs,
• Giving information to authorized people / institutions and organizations,
• Ensuring the security of ÖZKA operations, database and internet access,
• Establishing and operating the infrastructure of information technologies,
• Planning and execution of information security processes.

By keeping visitor internet access records, your personal data can be processed based on legal reasons such as its being clearly foreseen in the law (Law with no 5651), legal liabilities (Regulation about Collective Internet Usage Providers-Date and no of Official Gazette: 11.04.2017, 30035), establishment, usage or protection of a right (Provision of internet access to you as a visitor).

2 - Processing of your personal data by keeping camera records

ÖZKA buildings and facilities are monitored by security cameras in order to ensure security by ÖZKA. In this context, personal data can be processed by taking image records of our visitors through the camera and monitoring system of ÖZKA at the building, facility entrances and inside the facility. Your personal data being collected in relation with the said personal data processing activity, can be processed for purposes such as ensuring security of ÖZKA campuses, buildings and/or facilities, formation and follow up of visitor records, and giving information to authorized institutions as per the legislation and as based on legal reasons such as establishment, usage or protection of a right, legitimate rights and fulfillment of ÖZKA’s legal liability.

F. PROCESSING OF YOUR PERSONAL DATA WITHIN CONTEXT OF JOB APPLICATIONS

When you apply for a job to join ÖZKA and be a part of our team, you share some of your personal data with us. In this context, your personal data is transmitted to us through job application channels on our websites, through the companies that we support during the recruitment process, or through other channels.

Your personal data collected during the job application processes can be your name, surname, address, telephone, e-mail, date of birth, place of birth, education history, knowledge of foreign language, reference information, certificate and professional qualification, information on your resume, and information about your past experiences without being limited with these. However, if you disclose to us, your criminal record or health information may be processed from time to time. This information can be used to assess your suitability for work (for example, whether your health status is suitable for the relevant position or if your criminal record prevents you from working in certain jobs by law).

Your personal data which you have disclosed to us can be processed for purposes such as conducting recruitment processes, evaluating your suitability, conducting reference processes, conducting human resources processes, conducting employee candidates' application processes and based on legal reasons such as establishment, usage or protection of a right, establishment or execution of your employment contract and the legitimate rights of ÖZKA.

YOUR REQUESTS AND YOUR EVALUATIONS

Your personal data may be processed in order to take necessary steps regarding questions, requests or complaints sent by you through digital media or other written or verbal media.Your feedback is extremely important to us. For this reason, your personal data may be processed within the scope of the survey or evaluation studies in order to evaluate the service we offer.

TRANSFER OF PERSONAL DATA

Your personal data can be shared with our suppliers, social media agencies, contractors, sponsors, business partners, and group companies from which we get support for the establishment, execution and termination of your relationship with us, as including the parties providing products and services in our name and the parties we cooperate with. Your personal data can also be shared with authorized public institutions and private individuals within the scope of their authorizations. In these cases where your personal data is shared, we take the necessary measures to carry out processing and transfer activities in accordance with the rules in the Notification and the provisions of the legislation.

Your personal data may be shared with our affiliates, business partners, suppliers, legally authorized public institutions and organizations and legally authorized private institutions within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law and as being limited with these purposes, they can be transferred abroad within frame of rules and principles stated in article 9 and the decisions of Personal Data Protection Council. Within this framework, your personal data may be shared with the relevant authorities of the country where the operation is taking place, limited to the purpose of fulfilling the operational requirements and acting in accordance with the international legislative requirements.

Transfer of your personal data abroad can be realized;

• If you have given your explicit consent or,
• In situations where your explicit consent has not been given but one or a few of the other ata processing conditions being stated in law have been met:
• If there is adequate protection in the country where data are transferred as per the decision of Personal Data Protection Council or,
• If there isn’t adequate protection in the country where data are transferred, if our company undertakes adequate protection together with the data responsible in the relevant foreign country and if the permit of Personal Data Protection Council is obtained.

STORAGE OF PERSONAL DATA

When determining the retention periods of personal data, we determine it by considering the legislation in force and the purposes of processing the data subject to the process. In this context, timeout periods related to legal obligations related to personal data processing are definitely taken into consideration. If the purpose of personal data processing disappears, the data is deleted, destroyed or anonymized, unless there is another legal reason or basis for the retention of personal data.

As ÖZKA, the retention periods of your personal data are reviewed periodically. According to these periods, your personal data is destroyed if there is no other legal reason that requires us to process it. If you no longer want us to contact you, for example, if you do not want to receive commercial messages to be aware of the campaigns, we will maintain a minimum amount of information about you. Keeping a minimum of information in this way is necessary so that we can prevent future contact with you.

If you request that we delete all the information about you, but wish to use our products or use our services at a later date, we would like to point out that your request to not be contacted previously may not be noticeable. Therefore, along with your request that you do not wish to communicate, your minimum personal data should be stored so that this request can be kept in our records.

PERSONAL DATA PROCESSING RULES

“To act in accordance with the law and honesty rules”, “Accuracy and timeliness”, “To process data for specific, clear and legitimate purposes”, “To be connected, limited and measured for the purpose for which personal data are processed”, “Keeping them for the period foreseen in legislation or being required for the relevant purpose” constitute our basic principles regarding our personal data processing activities.

USAGE OF COOKIES

As ÖZKA, we use some technologies (“Cookies”) such as cookies, pixels, to improve your experience during your visits to our online channels. The use of these technologies is carried out in accordance with the legislation we are subject to,especially the Law and GDPR.

To get detailed information about cookies, we request from you to examine ÖZKA Cookie Policy Text that is available at the address of Identification Information

USAGE OF DIGITAL ENVIRONMENTS

Your personal data which are obtained during when you use digital environments, can be processed for purposes such as conducting studies for operating and managing the site, improving and developing the user experience related to the site and application, monitoring the ways in which the site is used, providing and supporting the use of location-oriented tools, managing your online accounts if available and providing information about the services that can be used in your location.

If you wish to take advantage of the products or services offered within the scope of the application, your personal data is processed only to ensure that you benefit from those products or services.

RIGHTS OF DATA OWNERS

According to Article 11 of the Law, data owners have the following rights against the data responsible.

• Finding out if personal data about him is processed.
• Requesting information if personal data about him has been processed.
• Learning the purpose of processing personal data and whether they are used in accordance with its purpose.
• Knowing the third parties to whom personal data are transferred domestically or abroad.
• Request rectification if personal data are missing or incorrectly processed.
• Request the deletion or destruction of personal data within the framework of the conditions stipulated in the relevant legislation.
• Requesting notification of actions taken as a result of requests for correction, deletion and destruction to third parties to whom personal data are transferred.
• To object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems.
• Requesting the removal of the damage in case the personal data is damaged due to the illegal processing of the data.

USAGE OF RIGHTS BY DATA OWNERS

We respond to data owners who wish to exercise these rights within the limits set forth in the Law, within a maximum of thirty days, as foreseen in the Law. In order for third parties to make an application request on your behalf, you must have a special power of attorney issued by the notary public on behalf of the person to apply.

Although your applications are processed free of charge as a rule, if a fee schedule is foreseen by the Personal Data Protection Board, a fee may be charged on this tariff. In order to determine whether the applicant is the Data Owner, we can request information from the relevant person, and in order to clarify the issues specified in the application, we can ask questions regarding the application to the Data Owner.

If you wish to use one or a few of the rights stated above, you may fill in “Data Owner Application Form (Appendix 4) that is available at the address of APPLICATION FORM and by forwarding it to us through below methods:

You can send it by e-mail to the address of [email protected]

ÖZKA LASTİK VE KAUÇUK SAN. TİC. A.Ş Management Building

Mahmutpaşa Mah. Kanalyolu Cad. No: 129 Başiskele/KOCAELİ

0090262 349 50 00

[email protected]

DATA SECURITY

In order to ensure the security of your personal data, we take reasonable technical and administrative measures to prevent unauthorized access risks, accidental data loss, deletion or damaging of data.

• We ensure data security by using software and hardware that includes protection systems from viruses and similar malware, firewalls and intrusion prevention systems.
• Within the partnership, we conduct access to personal data within the framework of authorization per unit / role / application and in a controlled process in accordance with the quality of the data.
• We ensure that necessary inspections are carried out in order to ensure the enforcement of the provisions of the Law pursuant to Article 12 of the Law.
• We ensure compliance of data processing activities with the Law through internal policies and procedures.
• We subject access to special quality personal data to more stringent measures.
• In case of external access to personal data, such as outsourcing, we receive commitments by the external service provider to ensure compliance with the Law.
• We take the necessary actions to inform all our employees, especially those who are authorized to access personal data, regarding their duties and responsibilities under the Law.

DEFINITIONS

• Explicit consent: It expresses the consent declaration on a specific subject, based on information and announced by the data owners with free will.
• Anonymizing: It refers to making personal data unrelated to an identifiable or identifiable natural person under any circumstances, even by matching with other data.
• Contact person / data subject: It refers to the real person whose personal data is processed.
• Personal data: It refers to all kinds of information related to a real or identifiable natural person.
• Specialized personal data: means data that has been subjected to a more stringent protection regime under the Law, which may cause Data Owner to be victimized or discriminated against in cases of disclosure or loss.
• Processing of personal data: Acquisition, recording, storage, preservation, alteration, reorganization, disclosure, transfer, acquisition, making available of the personal data in a completely or partially automated manner or non-automated provided that it is part of any data recording system. It refers to any action taken on data, such as its classification or inhibition of its use.
• Data recording system: It refers to the recording system in which personal data is processed according to certain criteria.
• Data controller: It refers to the real or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.