GENERAL INFORMATION NOTICE REGARDING THE PROCESSING OF PERSONAL DATA

This General Information Text Regarding the Processing of Personal Data has been prepared in accordance with the Personal Data Protection Law No. 6698 (“KVKK”) and related secondary legislation, NOKSEL Steel Pipe Industry Inc. (“Company” or “NOKSEL”) as the data controller.

In accordance with Article 10 of the KVKK, our Company fulfills its obligation to inform you by informing you about the purposes for which your personal data is processed, the methods by which it is collected, the legal grounds on which it is based, to whom and under what conditions it may be transferred, and your rights under Article 11 of the KVKK.

Our company processes your personal data in accordance with the principles of legality and fairness, accuracy and timeliness, specific, clear, and legitimate purpose, relevance, limitation, proportionality, and retention for the period specified in the relevant legislation, as stipulated in the KVKK.

1. مسؤول معالجة البيانات وممثله

In accordance with the KVKK, NOKSEL, as the data controller, may process, record, store, classify, and update your personal data in a manner that is relevant, limited, and proportionate to the purposes described below, in accordance with the law and principles of good faith, and in an accurate and up-to-date manner. In addition, your personal data may be disclosed and transferred to third parties in cases where disclosure or access is required or permitted by law and/or within the scope of the purpose for which it is processed.

2. الغرض من معالجة البيانات الشخصية

Personal data such as name, surname, email address, phone number, and customer transaction data that may be included in the message content, if shared, through the contact form on the Company's website at https://www.noksel.com/ and the phone number indicated at the same address, are processed in accordance with the basic principles set forth in the KVKK.

The aforementioned personal data is processed based on the legal grounds of being directly related to the establishment or performance of a contract, in accordance with Article 5/2(c) of the KVKK, in the processes of receiving and fulfilling the requests of existing or potential customers and following up on requests and complaints.

In cases where obligations such as record keeping and providing information must be fulfilled under the relevant legislation, personal data may be processed based on the legal grounds of the data controller fulfilling its legal obligations in accordance with KVKK m.5/2(ç).

Data processing activities carried out for the purposes of conducting customer relationship management processes, carrying out activities aimed at customer satisfaction, carrying out strategic planning activities, and developing product/service loyalty processes are carried out based on the legitimate interest of the data controller in accordance with KVKK m.5/2(f), provided that it does not harm the fundamental rights and freedoms of the relevant person.

The processing of data for the purpose of sending commercial electronic communications is carried out with explicit consent, in accordance with the relevant legislation.

Personal data is stored securely in electronic form for the specified purposes and for the retention periods stipulated in the relevant legislation.

When filling out the application, offer, information request, and communication forms on the Company's website at https://www.noksel.com/, where personal information is requested, special category personal data should not be shared through these fields. It is expected that special category data such as religion, race, health information, and similar data unrelated to the subject of communication with the Company will not be communicated through this form. It is important for data subjects to pay attention to the nature of the data they share via the contact form, and the data subject is responsible for any risks that may arise if special category personal data is shared in a manner that is not appropriate for the purpose of the form.

3. نقل البيانات الشخصية

Personal data processed within the scope of this Disclosure Statement may be transferred to the recipient groups specified below in accordance with the fundamental principles set forth in the KVKK and within the framework of the data transfer conditions stipulated in Articles 8 and 9 of the KVKK.

3.1. Transfer Within the Country

Personal data such as name, surname, email address, phone number, and other personal data that may be included in the message content provided through the contact form;

• Receiving and responding to applications,
• Execution of service processes,
• Operating information systems and ensuring their security

for the purposes of;

• Establishing or performing a contract in accordance with KVKK m.5/2(c),
• Fulfilling the legal obligations of the data controller in accordance with KVKK m.5/2(ç),
• The legitimate interests of the data controller in accordance with KVKK m.5/2(f)

legal grounds;

• To information technology and infrastructure providers from whom services are obtained,
• To software suppliers related to the management of electronic communication permissions and explicit consents,
• To NOKSEL group companies (if the support request falls within the scope of the relevant company's activities),
• To legally authorized public institutions and organizations,
• To professional advisors under confidentiality obligations

may be transferred.

Communication information related to commercial electronic communication is processed with the consent of the relevant person and is transferred to the Ministry of Trade of the Republic of Turkey and the Union of Chambers and Commodity Exchanges of Turkey for the purpose of recording it in the Communication Management System (İYS) in accordance with Law No. 6563 and relevant legislation. This transfer is based on the legal grounds of the data controller fulfilling its legal obligation in accordance with Article 5/2(c) of the KVKK.

Additionally, personal data may be transferred to legally authorized public institutions and organizations and professional advisors for the purposes of fulfilling legal obligations, establishing or performing contracts, or establishing, exercising, or protecting legal rights.

3.2. Transfer Abroad

Personal data transmitted via the contact form is processed through the Company's corporate email infrastructure for the purpose of directing applications to the relevant departments. If some of the software used in the website infrastructure and the servers related to the email infrastructure are located abroad, personal data may be transferred abroad.

The transfer of personal data abroad will be carried out in accordance with the conditions set forth in Article 9 of the KVKK. Within this framework, the transfer may be carried out:

• To countries with adequate protection,
• By providing appropriate safeguards (e.g., standard contract, commitment letter, or binding corporate rules),
• Based on the explicit consent of the relevant person, if necessary.

If the relevant person does not give their explicit consent to the transfer abroad, they may contact the Company.

4. Method of Collection and Legal Basis for Personal Data

Your personal data is collected electronically by NOKSEL through the contact and application forms available on the website. Your data is processed only for the purposes specified in this Disclosure Statement, in a limited and proportionate manner.

Your personal data may be processed based on the following legal grounds, in accordance with the basic principles set out in Article 4/2 of the KVKK and depending on the nature of the relevant data processing activity:

• Pursuant to Article 5/2(c) of the KVKK, it is directly related to the establishment or performance of a contract,
• Pursuant to KVKK Article 5/2(ç), it is necessary for the data controller to fulfill its legal obligations,
• Pursuant to KVKK Article 5/2(f), it is necessary for the data controller's legitimate interests, provided that it does not harm the fundamental rights and freedoms of the data subject,
• Where necessary, the data subject's explicit consent is obtained.

When your personal data is transferred, the transfer operations are also carried out in accordance with the conditions set out in Articles 8 and 9 of the KVKK.

NOKSEL acts in accordance with the legislation in force in the processing of personal data and may update its practices in line with any changes in the legislation.

5. Rights as the Data Subject Pursuant to Article 11 of the KVKK

You may submit your requests regarding your rights under the KVKK in writing, along with documents proving your identity and explanations regarding the right you wish to exercise, to the Company's address at Yukarı Öveçler Mah. Lizbon Cad. No:10 Çankaya/Ankara, either in person or by registered mail, or to the email address noksel@noksel.com.tr.

Your requests will be processed free of charge as soon as possible and within a maximum of 30 (thirty) days, in accordance with Article 13 of the KVKK, depending on the nature of the request. However, if the process incurs additional costs, the fee determined by the Personal Data Protection Board may be charged.

Subject to the exceptions stipulated in Article 28 of the KVKK, data subjects may apply to our Company to:

• learn whether their personal data has been processed,
• request information about the processing if it has been processed,
• learn the purpose of the processing and whether it is being used for that purpose,
• know the third parties to whom it has been transferred within or outside the country,
• request the correction of incomplete or incorrect data,
• request the deletion or destruction of data if the reasons for processing no longer exist,
• request that third parties to whom the data has been transferred be notified of the correction, deletion, or destruction,
• object to a result that is detrimental to them due to analysis exclusively by automated systems,
• to request compensation for any damage suffered as a result of the unlawful processing of personal data.

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