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Personal Data Protection and Processing Clarification Text

Purpose and Scope

The purpose of this Personal Data Protection and Processing Clarification Text (the "Clarification") is to fulfill the information obligation imposed by Article 10 of the Personal Data Protection Law No. 6698 (the "Law") regarding the use of personal data obtained during the use of the website located at https://www.marmarametal.com ("Site") and/or obtained from third parties, and to inform users/members about their legal rights under the Law on the Protection of Personal Data No. 6698.

"Marmara Metal" processes personal data in accordance with the Personal Data Protection Law No. 6698 and other relevant legislation, and in compliance with the principles and requirements set forth in these laws. In this regard, "Marmara Metal" processes personal data in a manner that is lawful and in good faith, accurate, and updated when necessary, for specific, clear, and legitimate purposes, and for the duration required for the purposes of processing, in a way that is relevant, limited, and proportionate.

"Marmara Metal" reserves the right to make unilateral changes at any time regarding its privacy, personal data storage-usage, and destruction policies, as well as the terms of use of the "Site." These changes will become valid as soon as they are announced by "Marmara Metal" through the "Site" or other appropriate methods (e-mail, SMS, etc.).

In compliance with the Law and other relevant legislation, the processing conditions for personal data and sensitive personal data are detailed in this Policy, and the purposes for processing personal data by our company are as follows:

• Planning and/or execution of Marmara Metal’s commercial and/or business strategies.
• Planning and/or execution of Marmara Metal’s human resources policies and processes.
• Carrying out necessary activities by relevant departments for the execution of commercial and/or operational activities carried out by Marmara Metal.
• Ensuring the legal and technical security of individuals involved in a business relationship with Marmara Metal.
• Ensuring that individuals benefit from the products and/or services provided by Marmara Metal and/or on behalf of Marmara Metal, and carrying out the necessary activities and related business processes.

Definitions and Terms

"Explicit Consent": Refers to consent that is given voluntarily, based on information, and for a specific matter.

"Personal Data Owner": The real person whose personal data is processed (data processing for legal entities is not covered by the Law).

"Personal Data": Any information related to an identified or identifiable natural person.

"Sensitive Personal Data": Data related to race, ethnicity, political opinions, philosophical beliefs, religion, sect, or other beliefs, attire, membership in associations, foundations, or trade unions, health, sexual life, criminal convictions, and security measures, as well as biometric and genetic data.

"Processing of Personal Data": Any operation performed on personal data, whether by automatic means or not, such as obtaining, recording, storing, preserving, altering, organizing, disclosing, transferring, acquiring, making available, classifying, or blocking its use.

"Law": The Personal Data Protection Law No. 6698.

"Relevant Person": The real person whose personal data is processed.

"Data Controller": A real or legal person who determines the purposes and means of processing personal data, and is responsible for establishing and managing the data filing system.

"Data Processor": A real or legal person who processes personal data on behalf of the data controller, based on the authority granted by the data controller.

"Data Filing System": A filing system where personal data is processed based on certain criteria.

"Site": The website and mobile application owned by "Marmara Metal" located at the domain name https://www.marmarametal.com and its subdomains.

"Member": A user who becomes a member of the "Site" by accepting, declaring, and committing to the provisions of the Membership Agreement, and benefits from the services offered by "Marmara Metal" under the conditions determined by "Marmara Metal."

Data Controller

According to the Personal Data Protection Law No. 6698 ("Law"), your personal data may be processed by the data controller, Marmara Metal, as explained below.

Personal Data Collected by Marmara Metal

Marmara Metal collects various static (fixed) and dynamic (variable) data from users through the following methods. The data collected by Marmara Metal depends on the services and features used by the users.

The following personal data is processed under the services provided by Marmara Metal and is considered personal data under the Personal Data Protection Law:

• Name and Contact Information: Full name, ID number, identity copy, phone number, home address, work address, email address, invoice information.
• Identity Verification Information: Membership details, user credentials, passwords, password hints, advertisement and publication information related to products/services, user numbers, contact details.
• Demographic Data: Gender, marital status, date of birth, age, education level, occupation, interests, preferred language.
• Location Data: Data related to the precise or approximate location of the users.
• Payment Data: Invoice and payment information of the member/user/visitor and seller (name, surname, invoice address, ID number, tax ID number), invoices sent to the member, and payment receipts obtained from the members.
• Messages That Violate Usage Terms or Get Filtered: Site messages identified as violating usage terms based on complaints or notifications.
• Content Data: Documents requested to verify the authenticity of the brand (e.g., invoice, guarantee certificate), documents showing ownership or rights to a product (e.g., title deed, license, trademark registration certificate).
• Usage Data and Favorites: Search reasons, pages visited, time spent on the "Site", actions taken by visitors/members during their visit, and related data.

Storage and Processing of Personal Data

The personal data obtained may be stored and processed in Marmara Metal’s or its affiliates', subsidiaries', or service providers' establishments in other countries, for the purposes outlined in this Clarification Text.

Purpose of Processing Personal Data

The personal data will be processed in accordance with the principles set out in the Law and for the following purposes:

• Communication, customer registration, post-sale processes, business development, collection, and customer portfolio management.
• Processing personal data to ensure legal and technical security, improve services, marketing, advertising, sales, and post-sales services.

Duration of Retention of Personal Data

"Marmara Metal" will retain the collected personal data for as long as necessary to fulfill the purposes set out in this Clarification Text and the Membership Agreement. In case of any disputes arising from the Membership Agreement, personal data will be stored for the duration of the statutory limitations period.

Sharing Personal Data

"Marmara Metal" may share personal data with external service providers, business partners, suppliers, expert firms, and legal or judicial authorities as necessary for the performance of its obligations or for legal reasons. This includes sharing personal data with payment institutions for identity verification.

Cookies

Personal data collected via cookies may also be shared with third parties as outlined in this Clarification Text.

Measures and Commitments Regarding Data Security

"Marmara Metal" commits to protecting personal data securely and taking all necessary administrative and technical measures to prevent unauthorized disclosure, access, transfer, or security breaches.

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