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Privacy Notice

PRIVACY NOTICE ON THE PROTECTION AND PROCESSING OF PERSONAL DATA
AŞICI GRUP PREFABRİK İNŞ. LTD. ŞTİ. · In Short: AŞICI GRUP · Effective Date: 06.09.2026

1. PURPOSE AND SCOPE

As AŞICI GRUP PREFABRİK İNŞ. LTD. ŞTİ. (“AŞICI GRUP” or “Company”), we attach great importance to the protection, lawful processing, and security of personal data. This Privacy Notice has been prepared within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data (“KVKK”) to fulfill the data controller’s obligation to inform. This Privacy Notice covers our existing customers, potential customers, website visitors, factory and workplace visitors, suppliers, potential suppliers, business partners, service providers, employees, employee candidates, subcontractors, transportation/logistics providers, and all other natural persons who enter Company facilities or whose personal data are processed.

2. DATA CONTROLLER

In accordance with Article 3/1-(ı) of the KVKK, the data controller is AŞICI GRUP PREFABRİK İNŞ. LTD. ŞTİ., and the short name AŞICI GRUP is used in our business operations. The current address, telephone, and contact information of our Company are available on our website's contact section.

3. PERSONAL DATA THAT MAY BE PROCESSED

Depending on the nature of your relationship with our Company, the following personal data may be processed: Name, surname, phone number, e-mail address, physical address, company and title details, customer/supplier information, quotation, order, contract, invoice, and financial transaction records, request/complaint information, technical information regarding website usage, IP address, connection logs, visitor log books, and CCTV camera images/incident records within the factory and facilities.

4. PURPOSES OF PROCESSING PERSONAL DATA

Your personal data may be processed for the following purposes: Managing customer/supplier relations, evaluating requests from potential customers, providing information about products/services, preparing quotations, executing sales, marketing, order, and contract processes, purchasing and logistics operations, performing accounting and invoicing operations, carrying out occupational health and safety processes, ensuring factory/facility security, protecting Company assets against theft or unauthorized entry, investigating security incidents, establishing, exercising, or protecting legal rights, and responding to lawful requests from authorized public institutions.

5. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

In accordance with Article 5/1 of the KVKK, personal data cannot be processed without explicit consent. However, pursuant to Article 5/2, data may be processed without explicit consent under the following legal grounds: m.5/2-a: Clearly prescribed by law; m.5/2-c: Necessary for the establishment or performance of a contract; m.5/2-ç: Mandatory for compliance with a legal obligation; m.5/2-e: Necessary for the establishment, exercise, or protection of a right; m.5/2-f: Necessary for the legitimate interests of the Company, provided it does not violate fundamental rights.

6. CAMERA RECORDINGS IN FACTORIES AND FACILITIES

Closed-Circuit Television (CCTV) camera systems are active at building entrances/exits, production areas, warehouses, shipping/loading zones, and parking lots of AŞICI GRUP to record video for security purposes. Video recordings are processed based on legal obligations (m.5/2-ç) and legitimate interest (m.5/2-f) to ensure the safety of facilities, employees, and visitors. In compliance with the decisions of the Personal Data Protection Board and the principle of "proportionality", general and continuous audio recording is strictly not performed.

7. AUDIO RECORDINGS WITHIN THE FACTORY

In compliance with the principle of "proportionality" in Article 4/2-ç of the KVKK and data processing conditions in Article 5, general and continuous audio recording is not active within the factory. Security camera systems are operated only to capture images. In accordance with the decision of the Personal Data Protection Board dated 30.11.2023 and numbered 2023/2007, capturing video recordings is deemed sufficient to ensure security, and audio recording is avoided as it requires separate proportionality assessments.

8. RETENTION PERIOD OF AUDIO AND VIDEO RECORDINGS

Security camera footage obtained within the factory is stored on the NVR (Network Video Recorder) device for 20 (twenty) days. At the end of the 20-day period, the recordings are automatically overwritten and deleted by the system. This process complies with the principle of "retention for the period required for the purpose" (KVKK m.4/2-d).

9. BACKUP AND RETENTION IN CASE OF DISPUTES OR INCIDENTS

In case of occupational accidents, theft, fire, sabotage, security breaches, commercial disputes, or official law enforcement requests, relevant records may be backed up before the 20-day retention period expires. Backed-up recordings are stored solely for the resolution of the concrete case or the protection of a right (KVKK m.5/2-e). Access is restricted to authorized personnel, and data will be destroyed in accordance with legislation once the legal process is finalized.

10. PRIVACY AREAS

Cameras are absolutely not positioned, and no video or audio recording is conducted in areas where individuals have high privacy expectations, such as restrooms, changing rooms, shower areas, and similar private spaces. Numan positioning complies with the principle of proportionality under Article 4/2-ç.

11. WEBSITE VISITORS

When you visit our website or fill out contact forms, your digital data (name, e-mail, phone, message content, IP address, and access time) are processed to manage communication, evaluate quotation requests, and ensure website security. Necessary cookie notification mechanisms are implemented.

12. METHOD OF COLLECTING PERSONAL DATA

Personal data are collected through websites, e-mails, telephone, physical applications, quotation/order forms, contracts, invoices, visitor logbooks, and CCTV systems, by automated or non-automated means provided that they form part of a data filing system, ensuring compliance with the minimum mandatory content of the obligation to inform under Article 10.

13. TRANSFER OF PERSONAL DATA

Your personal data may be transferred, strictly to the extent necessary, to authorized public institutions, courts, legal/financial advisors, IT service providers, security firms, banks, shipping/logistics companies, suppliers, and business partners under Article 8 of the KVKK. A right may be protected under m.5/2-e during transfer.

14. DATA SECURITY

AŞICI GRUP takes all necessary technical and administrative measures (access controls, network security, physical protection) in accordance with Article 12/1 of the KVKK to prevent unlawful processing of and unauthorized access to personal data, and to ensure data retention.

15. RETENTION AND DESTRUCTION OF PERSONAL DATA

Personal data are stored for the period prescribed by legislation or required by processing purposes. Camera footage is kept for 20 days. Upon expiry of retention periods, data shall be erased, destroyed, or anonymized in accordance with the principle of "retention for the period required for the purpose" (KVKK m.4/2-d).

16. YOUR RIGHTS UNDER THE KVKK

Pursuant to Article 11 of the KVKK, you have the right to learn whether your data are processed, request information if processed, learn the purpose of processing, know the third parties to whom data are transferred domestically/abroad, request correction of incorrect data, request erasure or destruction under Article 7, object to automated analysis, and claim compensation for damages.

17. RIGHT OF APPLICATION

In accordance with Article 13 of the KVKK, you can submit your requests regarding your personal data to the data controller AŞICI GRUP. Applications must comply with the Communiqué on the Procedures and Principles of Application to the Data Controller and will be finalized within legal periods.

18. DISTINCTION BETWEEN INFORMATION OBLIGATION AND EXPLICIT

CONSENT This text fulfills the obligation to inform under Article 10 of the KVKK. Information obligation and explicit consent are distinct legal concepts. If data processing is based on legal grounds specified in Article 5/2, separate explicit consent is not required. Explicit consent under Article 3/1-a must be freely given and based on information.

19. UPDATES

AŞICI GRUP reserves the right to update this Privacy Notice in line with amendments to the legislation, decisions of the Personal Data Protection Board, and changes in Company processes. The current text is published on our website.

DATA CONTROLLER CONTACT INFORMATION Physical Address: [Insert Address Here] E-Mail: [Insert E-mail Here] KEP Address: [Insert KEP Address Here]