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CLARIFICATION NOTICE ON THE PROTECTION OF PERSONAL DATA

SİNPAŞ GYO
CLARIFICATION NOTICE ON THE PROTECTION OF PERSONAL DATA


This Information and Clarification Form is arranged in relation to the processing and transferring of the "Personal Data" of natural persons regulated by the Turkish Personal Data Protection Law no 6698 ("PDP Law"). Pursuant to the Law no 6698, all kinds of your updated personal information you have shared with our company shall be considered as "Personal Data". The safety of your personal data is of utmost importance for us and your personal data will be retained in accordance with the conditions provided by the legislation and in the safest manner possible and for a period of time as required by legal obligations.

a) Data Controller and Representative
In accordance with the Turkish Personal Data Protection Law ("PDP Law") Law No 6698, your personal data may be processed by Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş. as the "Data Controller" under those explained below.

b) The Purposes of Processing your Personal Data
Your collected personal data may be processed in accordance with the terms and purposes of personal data processing set forth in Articles 5 and 6 of Law No. 6698 with a view to fulfill the obligations of our company and of natural and legal persons having business relations with our company, to be able to inform about updates, establishment and execution of contracts to be entered into with you, to remind and fulfill any legal obligations, to engage in various advertising and marketing activities, to carry out and follow up financial, accounting and legal affairs, to follow-up your requests and complaints - to follow up contractual process and/or legal request, to obtain your opinion through survey and voting within the scope of planning and execution of customer satisfaction activities, to identify suitable products, projects and services for you, to customize and develop them for you, to provide effective customer service, to notify the changes in legislation and company policies that concern you or to make other related notifications, to celebrate birthdays, to invite to lotteries and competitions, to give gifts and to carry out other similar activities, promotions and campaigns in your favor, to inform by electronic mail, SMS and fax, to notify you about campaigns, to send you printed bulletins, magazines and campaign letters, to define our visitor profiles, to evaluate your requests, demands and complaints, to conduct the human resources policies of our company and to respond to your requests and questions.

c) To whom and for what purpose your processed personal data can be transferred
Your collected personal data shall be processed in acordance with the principles of law and good faith, proper, updated where necessary, defined, clear and legitimate purposes, retained for a limited and constrained period of time linked to the purpose for which they are processed, limited and proportunate and as stipulated in the relevant legislation or as required for the purpose of processing. In addition, provided however that the conditions set forth in Articles 8 and 9 of the PDP Law are observed and the necessary security measures are taken, and limited to the purposes listed under Article (b) of this clarification notice and in accordance with the terms and purposes of personal data processing set forth in Articles 8 and 9 of Law No. 6698, it may share the personal data with our direct/indirect local/foreign affiliates/subsidiaries, local/foreign/international public/private institutions and organizations, companies and other 3rd parties from whom our company purchases services/support/advise or is in cooperation or has project/program/financing partnerships, our company's subsidiaries, advisors, shareholders or other group companies as solution partners, Central Registry Agency and other authorised institutions and organizations, suppliers and subcontractors. SİNPAŞ GYO may process and retain your personal data in servers located within or out of Turkey or in other electronic environments, provided that the required security measures are taken, that sufficient protection is ensured in the foreign country to which personal data will be transferred; if no sufficient protection is ensured in the relevant foreign country, then on the condition that Sinpaş GYO and the data controller located in the relevant foreign country undertakes to provide sufficient protection in writing, and with the permission of the Board. ç) The Method and the Legal Reason for Collecting Personal Data
Your personal data may be collected by our Company through various channels (with your participation in training, conferences and similar settings to be held by SİNPAŞ GYO through its headquarters, branches, agencies, sales offices or other subcontractors or business partners and the office and other physical settings where you can get in contact with, call centers, websites, mobile applications and similar electronic operation platforms,, social media and other public channels, as well as by means of investigation method, through other group companies or other persons and entities with whom they are contracted, in written and oral or audio or video recording or in other physical or electronic settings, etc.). Your personal data may be collected, processed, transferred and retained for the purposes specified in Articles (b) and (c) herein within the data processing conditions and purposes set forth in Articles 5 and 6 of the PDP Law. Your personal data are retained for a period of time as required by legal obligations or as permitted by legislation and under the conditions to the extent permitted by legislation.

d) Your Rights as Personal Data Subject
As personal data subject, if you send your claims for your rights to our Company pursuant to the below described method, our Company shall bring your claim to a conclusion at no charge as soon as possible depending on the nature of your claim but not later than thirty days. However, if any fee is stipulated by the Personal Data Protection Council, a fee in the tariff determined by our Company shall be charged. In this context, personal data subjects have the right to;

• Find out whether the personal data has been processed,
• Request information if the personal data has been processed,
• Find out the purpose of processing the personal data and whether the data has been used for the intended purpose,
• Find out about the third persons within or out of the country to whom the personal data has been transferred,
• Request the correction any data if they are incompletely or incorrectly processed and request that the third parties to whom the data has been transferred be informed of such correction,
• Even though the personal data have been processed in accordance with the provisions of PDP Law and other relevant law, in the event that the reasons that require processing have ceased, herewith request erasure and destruction of personal data and request that the third parties to whom the personal data transferred be informed of the transaction carried out in this context,
• Even though the personal data have been processed in accordance with the provisions of PDP Law and other relevant law, in the event that the reasons that require processing have ceased, herewith request deletion and destruction of personal data and request that the third parties to whom the personal data transferred be informed of the transaction carried out in this context,
• Object any result arisen from the analysis of the data being processed exclusively through automated systems,
• Request to indemnify that damage if any damage incurred from illegal processing of the personal data.

In accordance with Paragraph 1 of Article 13 of the PDP Law, you may convey your written request to our Company to exercise your rights listed above. You may submit your request including a description of the rights you wish to exercise, as mentioned in Article 11 of the PDP Law, by filling in the form at www.sinpas.com.tr and along with the documents to prove your identity, in person or send it through notary to “Dikilitaş Mah. Yenidoğan Sok. Sinpaş Plaza No:36 Dikilitaş-Beşiktaş/İSTANBUL” addressed to SİNPAŞ GYO Customer Relations Department

Our Company reserves its right to make changes in this clarification notice in case of any possible amendments to the PDP Law and based on the methods to be defined by the Personal Data Protection Council.