Türkiye Privacy Notice

Effective Date: March 1, 2025

SCALIBIT.COM INFORMATION ON THE LAW ABOUT PROTECTION OF PERSONAL DATAs

We, as SCALIBIT.COM (“SCALIBIT”), 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/KVKK) 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 SCALIBIT to process your personal data by reviewing SCALIBIT’s Notice on Protection and Processing of Personal Data at the website www.scalibit.com/legal (“Notice on PPD’’”).

1. Purposes of Processing and Transferring Personal Data

SCALIBIT 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 SCALIBIT 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 SCALIBIT, conducting the necessary operations by our relevant business units to fulfill the commercial activities executed by the SCALIBIT 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 SCALIBIT,

• Creating records on participants of the events/trainings organized by the SCALIBIT 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,

• To enforce our Terms of Service, Anti-Spam Policy, Use Policy or any other applicable policies,

• TTo protect our operations or those of our affiliates and ensure safety of the Site, SCALIBIT confidential and proprietary information, and SCALIBIT employees,

• To manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations,

• To comply with applicable law and legal process, and to respond to requests from public and/or government authorities,

• 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,

• To fulfil our legal obligations, such as compliance with court orders, orders/requests or other documents issued by competent authorities, applicable legislation, etc. In such cases the legal basis for the data processing is the compliance with a legal obligation to which we are subject.

• To prevent, detect, investigate, and address actual or suspected fraud, violation of law or our Terms, claims and other liabilities, or any threat of physical or financial harm to u, our staff or any other individuals or entities; and

• As may be otherwise disclosed at the time of collection.

• As Required By Law and Similar Disclosures. We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request including requests made by public authorities to meet national security or law enforcement requirements; (ii) enforce this Privacy Notice and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

• 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.

Disclosure of Personal Information

We may disclose personal data about Site visitors, users of our Services, or our suppliers or customers as permitted or required by law, and for the following business purposes:

• To satisfy any laws, regulations, or governmental or legal requests for such data,

• As necessary to identify, contact, or bring legal action against someone who may be violating our Terms of Service, Acceptable Use Policy or other user policies,

• To protect ourselves, our subscribers, and the general public. We specifically reserve the right to disclose any and all information (including personal data) to law enforcement in the event that a crime is committed, is suspected, or if we are compelled to do so by lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process.

• To cooperate with law enforcement authorities, private-party litigants, and others seeking information about our end users to the extent required by applicable law. Examples of such cooperation include lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process,

• In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)

• To comply with any laws, regulations or valid governmental or legal demands for such data, including in response to any criminal, civil, or administrative process, discovery request, subpoena, court order, writ, or other demand by authorities, private-party litigants, or other persons or entities that we believe to have the legal authority to obtain such data;

• In connection with certain essential purposes described above (e.g., to comply with legal obligations).

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

SCALIBIT 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. Cookies

Our Site uses cookies. More information about our use of cookies can be found in our cookie policy https://www.scalibit.com/legal/cookie-policy.

4. Children

The Site is not for use by children under the age of 18 years and SCALIBIT does not knowingly collect, store, share or use the personal data of children under 18 years. If you are under the age of 18 years, please do not provide any personal data, even if prompted by the Site to do so. If you are under the age of 18 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify SCALIBIT and SCALIBIT will delete all such personal data.

5. Security

We take measures, including data encryption, to protect the transmission of all sensitive end-user information. We make reasonable efforts to ensure the integrity and security of our network and systems. Nevertheless, we cannot guarantee that our security measures will prevent third-party 'hackers' from illegally obtaining this information. We take all reasonable measures to prevent such breaches of security, but given the resourcefulness of cyber-criminals we are unable to guarantee that our security is 100% breach-proof. You assume the risk of such breaches to the extent that they occur despite our reasonable security measures.

6. Retention of Your Personal Data

We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

With respect to marketing, we retain your personal data for 18 months after your last request for service or other contact you initiate.

7. External Links

The Site may contain links to third party sites. Since SCALIBIT does not control nor is responsible for the privacy practices of those Sites, we encourage you to review the privacy policies of these third party sites. This Notice applies solely to personal data collected by our Sites or in the course of our business activities.

8. 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.

9. Contact Information

If you have additional questions regarding your rights under the KVKK, please refer to the SCALIBIT Privacy Notice and contact us at kvkk@scalibit.com.

Personal data of our customers in Turkey is managed by our partner company, "Mitues Global Teknolojiler Veri Merkezi Hizmetleri Tic. Ltd. Şti."

SCALIBIT.COM (SCALIBIT TECHNOLOGY)
E-posta: kvkk@scalibit.com