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www.ngn.com.tr is possessed by NGN Bilgi ve İletişim Hizmetleri Ticaret A.Ş. and information security of our clients that visit this website is very important for NGN. This text was prepared to inform you about information security.

NGN BİLGİ VE İLETİŞİM HİZMETLERİ TİCARET ANONİM ŞİRKETİ INFORMATION ON THE LAW ABOUT PROTECTION OF PERSONAL DATA

We, as NGN Bilgi ve İletişim Hizmetleri Ticaret A.Ş. (“Company”), place importance to protecting the confidentiality and security of your personal data. In this regard, we wish to inform you about your personal data in accordance with the provisions of the Law no 6698 on Protection of Personal Data (LPPD) that was prepared and came into force for the main purposes of protecting personal data and the confidentiality of private life and fundamental rights and freedoms. You can get more information about the purposes of the Company to process your personal data by reviewing NGN’s Policy on Protection and Processing of Personal Data at the website www.ngn.com.tr (“Policy on PPD’’”).

1. Purposes of Processing and Transferring Personal Data

Our Company processes your personal data collected by us in the capacity of data supervisor under the Law on Protection of Personal Data in accordance with the following information and purposes.

Personal data refers to all information about identified or identifiable natural person. Data about race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, dress, membership in association, foundation or union, health, sexual life, criminal conviction and security measures and biometrical and genetic data are recognized as exclusive personal data.

We would like to notify you that our Company may process your personal data for the purposes of providing our services to our clients, recording your suggestions and complaints, planning and executing the commercial and working strategies of the Company, conducting the necessary operations by our relevant business units to fulfill the commercial activities executed by the Company and managing associated business operations in accordance with the Law on Protection of

Personal Data and other relevant legislations. As Data Supervisor, we can process your personal data for the following purposes:

· Negotiating, concluding and executing Contracts,

· Presenting products and services,

· Customizing the products and services provided in line with the demands; upgrading and improving the products and services in accordance with customer needs and legal and technical developments,

· Identifying users in the system based on the products and services provided,

· Providing call center and remote support services, monitoring the numbers and contents of calls,

· Communicating the new or existing products and services, managing the sales and marketing activities,

· Conducting market researches,

· Creating statistics and analyzing usages,

· Paying, collecting and selecting the method of collection of product, service and maintenance charges,

· Establishing contact/communication with the relevant individuals,

· Managing the business relationships with the cooperation partners, suppliers, resellers and service providers,

· Submitting reports in line with cooperation,

· Assessing the business partnership application process of resellers,

· Developing commercial strategies and making the plans of the Company,

· Contacting the relevant individuals to conduct satisfaction measurement surveys for the Company,

· Creating records on participants of the events/trainings organized by the Company and issuing their certificates/participant documents,

· Managing judicial/administrative processes, giving responses to the requests received from public authorities and organizations, fulfilling legal obligations in accordance with legal regulations and resolving legal disputes,

· Managing investor relationships,

· If the Company conducts a merger or demerger transaction or it is transferred partly or fully; ensuring the consequences arising from such legal transaction,

· Introducing Company employees, Natural Person Resellers/Clients and Authorized Officers of Resellers/Clients in social media posts,

· Conducting job interviews, assessing job applications,

· Establishing, managing and terminating employment relationship/contract,

· Enabling Company employees to benefit from the primary and secondary rights arising from employment contracts and assessing their performances and activities,

· Opening user account and providing internal ID and meal card for employees,

· Arranging the transportation of Company employees, monitoring the pool cars of the Company,

· Creating participant’s records, if an individual attends an event on behalf of the Company,

· Creating training participation and certification records for employees,

· Creating and following up visitor records,

· Ensuring the internal and environmental security of the Company, its website and applications,

· Conducting website usage analysis,

· Creating personal data inventory,

· Assessing and responding to all questions, requests, suggestions, complaints and applications received in writing, orally or electronically, including those related to personal data.

We can transfer your personal data to the following individuals and entities for the above-mentioned purposes under the LPPD and other legislations:

• Companies and representatives to which we grant authorization to act for and on behalf of us,

• Supervisory and regulatory authorities, relevant public authorities and similar organizations as well as individuals or entities authorized in accordance with the provisions of the Turkish Commercial Law and other relevant legislations and legally-authorized public and/or private law legal entities, being limited to the purposes requested by them according to their legal authorizations,

• Business partners, suppliers and contractors, banks, credit risk and financial organizations and other natural or legal entities, for the designated purposes,

• Third parties that provide us with consulting services including but not limited to tax and similar consultants, mandatory individuals, authorities, organizations and inspectors in relation with the legal monitoring processes, and domestic and overseas business partners, third party service providers and authorized individuals and entities in connection with the above-mentioned purposes.

2. Method and Legal Reason for Collection of Personal Data

Our Company may collect personal data in writing, orally or electronically such as through websites, social media channels and electronic mail as well as during the promotion activities and meetings organized by our Company, in order to operate more efficiently and provide you with the best experience.

Our data collection process may be executed through i) Website, e-mail, digital channels of third parties including recruitment portals or software; ii) contracts, applications, forms, call centers, remote support, sales and marketing department, cookies at the Websites, business cards and telephone etc.; or iii) face-to-face meetings and interviews with the Data Owner.

Your personal data may be also processed and disclosed under the personal data processing conditions and purposes specified in the Article 5 and 6 of the Law on Protection of Personal Data and for the legal reasons and purposes described in the Article 1 of this information text.

3. Your Rights about Processing the Personal Data

In relation with your personal data in accordance with the Article 11 of the Law on Protection of Personal Data, you, as personal data owner, are entitled:

• To know whether your personal data has been processed or not,

• If your personal data has been processed, to ask for information about processing of such data,

• To know the purpose of processing your personal data and to know whether such data is used in accordance with the purpose

• To know the third parties inland or abroad, to whom such personal data has been disclosed,

• If your personal data has been processed incompletely or wrongly, to ask for correction of it,

• To ask for deletion or disposal of your personal data, although your personal data has been processed in accordance with the provisions stipulated in the Law on Protection of Personal Data and the other relevant laws, but the reasons that require processing of your personal data have disappeared; and to ask for providing information to third parties, to whom such personal data has been disclosed, in connection with such deletion or disposal,

• To object to the occurrence of any negative results about data owner through analysis of your processed data exclusively by automatic systems,

• To ask for the indemnification of the loss suffered due to the processing of your personal data in violation of the law.

Click for NGN Personal Data Protection and Processing Policy.

Click for the Application Form.