PROTECTION OF PERSONEL DATA COMMUNICATION AND COOKIE POLICY

Pak Holding A.Ş. (PAK HOLDING)processes your personal data in the capacity of data controller in accordance with the Law on the Protection of Personal Data No. 6698 (KVKK) and related legislation.

Pursuant to Article 10 of the KVKK, which regulates the Obligation to Inform, data controllers are obliged to inform the data subjects whose personal data they process about certain matters.

This disclosure has also been drafted in accordance with the Communique On Principles And Procedures To Be Followed In Fulfillment Of The Obligation To Inform, published by the Personal Data Protection Authority, in order to fulfill the legal obligation.

Data Subject

You, whose personal data are processed by PAK HOLDING, are defined as a Visitor (Internet) due to your visit to our website and you are considered to be a Data Subject by the Law.

Data Controller

PAK HOLDING is the data controller, who determines the purposes and means of processing your personal data, and is responsible for the establishment and management of the data recording system.

Obtaining Your Personal Data

Your personal data obtained and the methods of obtaining your personal data are provided below. The same personal data can be obtained by more than one method.

Method / Environment

Data

Directly from you with automated methods

Electronically

Name, Surname, E-Mail Address, Telephone Number, Subject of Communication, Communication authorization, Communication Authorization Source, Communication Authorization Time, Message Content, IP Address, Posting Time, Posting Date, Persistent cookie and Session cookie;

Purposes and Legal Reasons for Processing Your Personal Data

The following table lists the legal grounds and purposes of processing your personal data.

Since it is mandatory for the data controller to fulfill their legal obligation in KVKK Art.5/2d

For the purpose of carrying out storage and archiving operations

Pursuant to the Retention of Communication Permissions (Article 13/2) in the Regulation on Commercial Communication and Commercial Electronic Messages;

E-Mail Address, Telephone Number, Communication Authorization, Communication Authorization Source, Communication Authorization Time, and IP Address

Provided that the fundamental rights and freedoms of the data subject in Article 5/2g of the KVKK are not violated if data processing is mandatory for the legitimate interests of the data controller.
To carry out activities for customer satisfaction	Session cookie and Persistent cookie
To carry out performance evaluation processes	Analytical-Performance Cookies and Targeting-Advertising Cookies
To carry out communication activities	Communication Authorization Source, Communication Authorization Time, and IP Address
To carry out marketing analysis studies	Analytical-Performance Cookies and Targeting-Advertising Cookies
For the purpose of carrying out storage and archiving operations	Name, Surname, E-Mail Address, Telephone Number, Subject of Communication, Message Content, Posting Date, and Posting Time

In case you grant your explicit consent according to KVKK Art.5/1
To carry out communication activities	Name, Surname, E-Mail Address, Telephone Number, Subject of Communication, Communication Authorization, Message Content, Posting Date, and Posting Time

In case you grant your express consent regarding the transfer of personal data abroad, which is regulated in Article 9/1 of the KVKK;
To carry out marketing analysis studies	Analytical-Performance Cookies and Targeting-Advertising Cookies

Transfer of Your Personal Data

Your personal data may be transferred to the relevant authorities without the obligation to inform and without your explicit consent in case they are requested within the framework of Article 28/1 of the KVKK.

In unforeseen circumstances apart from this, your personal data may be transferred to public institutions (administrative authorities such as ministries, Presidential boards, etc.) specified in the law, within the scope and limitations stipulated in the law, if requested in cases clearly stated in the law.

Apart from our legal obligations that do not require the obligation to inform and do not require your explicit consent;

The following table shows the recipients of your transferred personal data and the purposes for which they are transferred.

Buyer / Purpose

Data

to Google Inc.

To carry out website analysis and marketing activities

Analytical-Performance Cookies and Targeting-Advertising Cookies;

Your Rights Regarding Your Personal Data

Data subjects must first apply to the data controller in order to exercise their rights regarding their personal data. According to Article 14 of the Law, no direct complaint can be made to the Personal Data Protection Authority.

In accordance with the law, you may exercise the following rights regarding your personal data by applying to the data controller, i.e. us.

a) Learn whether their Personal Data is processed or not,
b) Request information about your personal data if they have been processed,
c) Learn the purpose of processing the personal data and whether they are used appropriately for their purpose,
d) Know the third parties to whom personal data is transmitted in the country or abroad,
e) In case personal data is processed deficiently or incorrectly, request the correction of such,
f) Request the deletion or destruction of your personal data in case the reasons that require processing are eliminated,
g) Request that the transactions conducted as per sub-clauses (e) and (f) be notified to the third parties to whom your personal data is transferred,
h) Object to the occurrence of a consequence against you through analyzing the processed data exclusively on automated systems,
i) Request the remedy of damages in case of any damages suffered due to illegal processing of the Personal Data.

Method of Application to the Data Controller

You can apply using one of the following methods:

In writing to Gayrettepe Mahallesi Prof. Dr. Bülent Tarcan Cadde No: 5 Beşiktaş / Istanbul;

By e-mail to Pakholding@hs01.kep.tr Registered E-Mail (REM) address using your REM address

By e-mail to kvkk@pakgrp.com using your e-mail address registered as yours in our systems.

Detailed information on the procedures and principles to be followed when making an application can be found in the Communiqué on Procedures and Principles of the Application to Data Controller of the Personal Data Protection Authority.

Pak Holding A.Ş.