PERSONAL DATA PROTECTION LAW CLARIFICATION TEXT

Your privacy is respected, and your data security is prioritized at GROUP SAGUN AND OUR AFFILIATED COMPANIES (Kemal Balıkçılık İhracat Ltd. Şti, Tsm Deniz Ürünleri Sanayi ve Ticaret A.Ş, Marines Gıda Ürünleri Sanayi ve Ticaret A.Ş, Merlion Deniz Ürünleri Sanayi ve Ticaret A.Ş, Sagun Aqua Kültür Balıkçılık Sanayi ve Ticaret A.Ş, Sagun Su Ürünleri Ltd. Şti, Feed Co Yem Hammaddeleri Katkı Malzemeleri İthalat İhracat Ticaret A.Ş).
In this context, this clarification text has been prepared to explain, inform, and illuminate you regarding the processing of your personal data, particularly for the purpose of protecting fundamental rights and freedoms, including the privacy of private life, under the Personal Data Protection Law No. 6698 (“KVKK”) and other applicable legislation.

You may access more detailed information on the processing of your personal data in the Group Sagun Personal Data Protection and Privacy Policy (KVK) available on our homepage.

1. INFORMATION

The Personal Data Protection Law No. 6698 (“KVKK”) was adopted on March 24, 2016, and published in the Official Gazette on April 7, 2016.
Article 32 titled “Enforcement” stipulates that Articles 8, 9, 11, 13, 14, 15, 16, 17, and 18 entered into force on October 7, 2016.

The Law aims to protect fundamental rights and freedoms, especially the privacy of private life, in the processing of personal data and to regulate the obligations of persons who process personal data and the procedures and principles to be followed.

This clarification text is presented to fulfill the obligation of informing and to provide visitors with information regarding the “Protection of Personal Data and Personal Data Sharing Consent.”

Group Sagun undertakes not to sell, rent, or make available to third parties your name, e-mail address, home or work address, telephone number, or other personal data submitted through the forms on this site.

2. PURPOSE OF PROCESSING PERSONAL DATA

Your personal data is processed by our Company:

• To enable relevant persons to benefit from our services and products,
• To carry out necessary work and related business processes within relevant departments,
• To conduct commercial activities and related processes,
• To plan and execute business and/or commercial strategies,
• To ensure the legal, technical, and commercial security of our Company or persons involved in a business relationship with our Company,
• To create a membership record and perform identity verification on our website,
• To provide and improve services offered through our website,
• To develop suitable software versions,
• To respond to communication requests submitted via our website,
• To fulfill obligations inherent to the services offered on our website,

pursuant to Articles 5 and 6 of the KVKK.

3. FUNDAMENTAL PRINCIPLES IN PROCESSING PERSONAL DATA

Our Company complies with the general principles and legal requirements in the legislation and acts in accordance with the principles below to ensure that personal data is processed lawfully and in accordance with the Constitution and KVKK.

3.1. Principle: Personal Data Processing is Prohibited Unless Allowed

Our Company processes personal data only within the limits permitted by legislation and based on the following legal grounds:

1. Explicit Consent of the Data Subject
   Explicit consent must relate to a specific subject, be informed, and be given freely.
   If other legal grounds below apply, explicit consent is not required.
2. Explicitly Provided by Law
   Personal data may be processed without consent if explicitly permitted by legislation.
3. Inability to Obtain Consent Due to Actual Impossibility
   If it is necessary to process personal data to protect someone’s life or physical integrity when consent cannot be given.
4. Processing is Necessary for Establishment or Performance of a Contract
5. Processing is Necessary to Fulfill a Legal Obligation of the Company
6. Personal Data Made Public by the Data Subject
7. Processing is Necessary for the Establishment, Use, or Protection of a Right
8. Processing is Necessary for Legitimate Interests of the Company, provided fundamental rights are not violated.

If the processed personal data is special-category personal data, it may only be processed with explicit consent or with adequate safeguards determined by the Board.

3.2. Compliance with Law and Principles of Good Faith

Our Company processes personal data lawfully, fairly, and transparently in accordance with Article 4 of the KVKK.

3.3. Purpose Limitation, Data Minimization, and Proportionality

Our Company determines the purposes for processing personal data and avoids processing irrelevant or unnecessary data.

3.4. Accuracy and Up-to-Date Data

Our Company ensures that processed personal data is accurate and up to date, relying on the declarations of the data subjects.

3.5. Data Processed for Specific, Explicit, and Legitimate Purposes

Our Company collects and processes personal data only for legitimate and lawful purposes and retains them only for the period required.

3.6. Data Security Principle

Our Company takes all necessary technical and administrative measures to ensure the security of personal data.

4. METHOD AND LEGAL GROUNDS FOR COLLECTION OF PERSONAL DATA

Personal data may be collected during commercial transactions, recruitment, employment, and various communication channels.

5. PARTIES TO WHOM PERSONAL DATA MAY BE TRANSFERRED AND PURPOSES OF TRANSFER

Personal data may be transferred domestically or abroad to group companies, partners, and authorized institutions.

6. DATA SECURITY MEASURES AND COMMITMENTS

Our Company undertakes to prevent unlawful processing and access, and ensures secure retention of data.

7. RIGHTS OF THE DATA SUBJECT

Under Article 11 of KVKK, individuals have the right to information, correction, and deletion of their data.