DISCLOSURE TEXT OF PERSONAL DATA PROTECTION AND PROCESSING POLICY

GENERAL INFORMATION

1. Definitions and Explanation
If you are an individual acting on behalf of our company's customer or supplier or authorized to represent them, or if you are an "applicant for employment" with our company, MIGGRA TECHNOLOGY INC. ("Company") located in Turkey, operates as the data controller.

In this document, we inform you that your personal data obtained in the ways specified in the content will be processed by us within the framework of the purposes requiring processing within the scope of our commercial relationships or our business relationship with you, limited to the purposes of this processing, and in connection with this purpose and in a manner that is related, limited, and proportionate, it will be recorded, stored, preserved, rearranged, shared with competent authorities legally authorized to request such personal data, transferred to third parties domestically or abroad, transferred, classified, and processed in other ways specified in the KVKK legislation.

Our company attaches importance to the security of personal data and, in accordance with the Law on the Protection of Personal Data No. 6698 and other relevant legislation, has prepared and announced this information text to inform the data subjects. As known, the Law on the Protection of Personal Data No. 6698 regulates the rules and obligations of individuals and legal entities processing personal data in addition to protecting personal data.

This information text also informs website visitors and reminds them of the rights arising from the Law on the Protection of Personal Data No. 6698. The names, surnames, email addresses, phone numbers, business and home addresses, and other similar personal information of visitors to this website are recorded with high security for the purpose of appropriate use and will not be sold, donated, rented, or used in any way.


1. PERSONAL DATA CATEGORIES

• Identity Data
• Personal Identification Data
• Vehicle Information
• Contact Data
• Sensitive Personal Data
• Health Data
• Visual Data
• Website/Application Usage Data
• Third-Party Information
• Financial Data
• Legal Data
• Comment and Complaint Data

2. PROCESSING OF PERSONAL DATA AND DATA CONTROLLER
Pursuant to the Law on the Protection of Personal Data No. 6698 and other relevant legislation, the processing of your personal data involves operations such as:

• Automatic or non-automatic obtaining
• Recording
• Storage
• Preservation
• Modification
• Reorganization
• Disclosure
• Transfer
• Retrieval
• Takeover
• Anonymization
• Classification
• Rendering unusable

Your personal data may be processed by MIGGRA TECHNOLOGY INC. as the data controller in accordance with the Law on the Protection of Personal Data No. 6698. MIGGRA TECHNOLOGY INC. is responsible for determining the purposes and methods of processing personal data, establishing and managing the data recording system, and will register the data controller record as soon as the Data Controllers Registry is opened.

3. PURPOSE OF PROCESSING PERSONAL DATA AND TRANSFER WHEN NECESSARY
As a company, we collect and process your personal data with the legitimate interest of fulfilling our legal obligations, performing service contracts, conducting the purchase and sale of products and services offered by the company, fulfilling the notification obligation to law enforcement authorities concerning employees in the workplace, and opening a bank account.

Always prioritizing your fundamental rights and freedoms, we collect your personal data, which we request from you or is transmitted physically or electronically by third parties, for the purpose of the legitimate interest of improving and making our company's services more effective, through the use of cookies on our website.

Information collected about individuals under the age of 18 is limited to their name, surname, age, and degree of relationship. This data can only be provided by the relevant adult, and it pertains to the performance of the employment contract and our legal obligations concerning our employees. We kindly request you to contact us for the destruction of data transmitted to our company without the consent of the relevant employee.

We do not collect sensitive information such as race, ethnic origin, political opinions, religious or philosophical beliefs, union memberships, health information, or sexual orientation. If you notice that such information has been transmitted to our company without our request, please inform us so that we can proceed with the destruction of this data. Your personal data is collected by our company through various methods and channels based on various legal reasons to generally conduct our commercial activities. Personal data collected for legal reasons can be processed and transferred within the scope of the purposes specified in Articles 5 and 6 of the Personal Data Protection Law No. 6698.

As a company, we collect and process your personal data for the following purposes:

• To fulfill our legal obligations, perform service contracts, and carry out the purchase and sale of products and services offered by the company.
• To conduct job interviews and placement processes for job candidates applying to our company for employment.
• To communicate with you as part of the activities carried out by our company.
• To inform you of important information such as changes in the terms of service, changes in services provided, changes in electronic systems, and changes in the company's contact information.
• To monitor the quality of services offered by our company, analyze the training needs of our company's human resources, ensure timely and accurate service, prevent unfair competition, and ensure the economic and commercial security of our company.
• To resolve complaints related to the activities carried out by our company, collect information about the complainant and the subject or person involved in the complaint, and access the data.
• To prevent unlawful or criminal situations contrary to the law.
• To conduct analyses for managing open and imminent commercial risks.
• To respond to information requests required by laws from judicial authorities or authorized state institutions.
• To keep accounting records, conduct independent audits and financial audits, accounting and financial transactions, invoice issuance, and collection activities.
• To comply with internal policies and procedures, including information systems, data, and website hosting; to comply with policies and procedures.
• To carry out activities related to fire, natural disasters, general health, occupational health and safety, and SEÇ.
• To conduct surveys, field and market research, R&D activities, market research, and analysis studies.
• To carry out social responsibility projects, award scholarships, provide social assistance, award, organize promotions, competitions, and lotteries.
• To manage social media shares about our company and control activities.
• To create electronic systems for individual internet users, generate personal commercial and reputational goals via electronic systems.
• To make necessary notifications to the Identity Notification System of the General Directorate of Security.
• To perform identity verification.
• To create legal documents in accordance with accounting standards and store them.
• To conduct quality control and improve service quality.
• To ensure the security of the company.
• To improve the website.
• To ensure the security of billing processes.
• To establish healthy communication with customers and suppliers.

4. CONDITIONS WHERE PERSONAL DATA CAN BE PROCESSED WITHOUT OPEN CONSENT
Your personal data, as the data controller, may be processed without the need for explicit consent in the following cases:

• Works explicitly permitted by the legislation or works related to fulfilling the legislation,
• Emergence of open mandatory situations such as health, safety, protection of the right to life,
• Cases directly requiring the processing of personal data by the parties to the contract for the performance of any contract,
• Fulfillment of legal obligations,
• Previously publicly disclosed personal data by the relevant person,
• Personal data processing is compulsory for the establishment, use, or protection of any legal or contractual right provided that it does not harm the fundamental rights and freedoms of the data subject,
• Processing of personal data is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject, based on the legal reasons specified in this document.

5. TRANSFER OF YOUR PERSONAL DATA
We may share your personal data with third parties both domestically and abroad in the following cases:

• To our business partners, both domestically and abroad, for the purpose of ensuring the legal and commercial security of individuals in business relationships and the economic and administrative management of the company.
• To law enforcement authorities within the framework of our obligations under the Identity Notification Law.
• To company personnel for the continuation of the company's activities.
• To third-party payment service providers such as banks and credit card companies for the verification and execution of payments.
• To third parties both domestically and abroad who perform these activities, in accordance with our internal policies and procedures, for the audit and reporting of accounting and financial transactions, including budget management, current card opening, and billing.
• To third-party archive companies for the storage of records containing your personal data throughout the retention period.
• To our lawyers and relevant institutions within the framework of our obligation to fulfill legal requests such as court decisions or evidence requests, and to use our legal defense rights.
• To third-party consultants serving our company for services related to labor law and SGK procedures regarding the personal data of employees working in the workplace or applying for a job, in accordance with the internal policies of our company.
• To our business partners, to carry out the obligations and responsibilities arising from the contracts concluded with them, as part of the activities carried out by our company, limited to the purposes of this processing, to fulfill the obligations in the contracts, and to benefit from the service offered by our business partners.

6. YOUR RIGHTS REGARDING PERSONAL DATA

As individuals whose personal data is collected and processed within the framework of the legislation, you have the following rights:

6.1. You have the right to know whether your personal data is being processed.

6.2. If your personal data has been processed, you have the right to request information about this processing.

6.3. You have the right to know the purpose of processing your personal data and whether they are being used for that purpose.

6.4. You have the right to know the third parties to whom personal data is transferred, whether domestically or internationally, and the reasons for such transfer.

6.5. In case your personal data is incomplete or incorrectly processed, you have the right to request their correction and to request that the correction be communicated to third parties to whom your personal data has been transferred.

6.6. If the reasons requiring the processing of your personal data cease to exist, you have the right to request the deletion or destruction of your personal data and to request that this deletion or destruction be communicated to third parties to whom your personal data has been transferred.

6.7. You have the right to object to the occurrence of a result against yourself by the exclusive analysis of the processed data through automated systems.

6.8. If you suffer damage due to the unlawful processing of your personal data, you have the right to request compensation for the damage.

6.9. In cases where your consent is required for the processing of your personal data, you have the right to inform our company at any time that you have withdrawn your consent.


7. REQUEST FOR THE PROTECTION OF YOUR PERSONAL DATA

In accordance with Article 13, paragraph 1 of Law No. 6698 on the Protection of Personal Data, you can submit your request related to exercising your rights in writing or through other methods determined by the Personal Data Protection Board. As the Personal Data Protection Board has not specified any method at this stage, the channels and procedures for your applications are explained below.

To exercise the rights mentioned above and benefit from the rights specified in Article 11 of Law No. 6698 on the Protection of Personal Data, proving your identity:

7.1. Electronic Application: You can submit your request electronically by filling out the form on the website www.miggra.com.

7.2. Written Application by Filling Out the Form: By filling out the "Personal Data Protection Request Form" and sending it with a wet signature to our company's address: Merkez Mah. Vezir Sok. No: 10-12 İç kapı no: 4 Çekmeköy/Istanbul.

7.3. Notarized Application: You can also submit your application to our company in writing through a notary public. As the data subject, if you submit your requests related to your rights arising from Law No. 6698 on the Protection of Personal Data to our company, our company will conclude your request as soon as possible, not exceeding 30 days. Depending on the nature of the request, if the expenses related to the information to be received exceed 50 (fifty) TL (postage, photocopy, transportation, notary, etc.), our company may request the amount exceeding this limit and document-based expenses.


8. COOKIE POLICY

As is known, the term "cookie," commonly used in the field of information technology, is defined as a small text file that a website stores on your PC, tablet, smartphone, or other devices, containing data related to the navigation on that site.

The use of cookies aims to facilitate the basic settings of web users (language, country, etc.), ensure the proper functioning of our company's website, ease your website usage, develop and optimize the website, and engage in personalized advertising activities.

The "cookies" used as the main method of information storage by our company's website are also used in the browser's "local storage" area for the same purpose. We do not store sensitive personal information such as your address, password, credit card, or bank card details in the cookies we use.

You have the right to avoid the use of cookies on the website. If you do not want our company's website to use cookies, you should first disable cookie usage in your browser and then delete the cookies stored in your browser associated with this website. You can use this option at any time to prevent the use of cookies. By following the steps mentioned above, you can change your browser settings at any time to restrict, block, or delete cookies used on our company's website. Although settings may vary in each browser, cookies are generally found in the "Preferences" or "Tools" menu.

CONTACT INFORMATION
MIGGRA TECHNOLOGY INC.
Mersis No: 0621103358800001
Contact Link: www.miggra.com / E-Mail: info@miggra.com
Address: Merkez Mah. Vezir Sok. No: 10-12 İç kapı no: 4 Çekmeköy/Istanbul