POLICY ON THE PROTECTION AND THE PROCESSING OF PERSONAL DATA

PURPOSE
As VİAL ALUMINUM, we respect the privacy of your personal data, attach importance to data security, and consider this matter among the priorities of our company. We adopt the principles of collecting, processing, and protecting personal data of our customers, potential customers, website users, employees, job applicants, former employees of VİAL ALUMINUM, interns, company shareholders, company officials, business partners, group company employees, and visitors in accordance with the regulations stipulated in the Law on the Protection of Personal Data No. 6698.

Therefore, we recommend that you carefully read this text explaining how we process your personal data, with whom we share it, and how you can exercise your rights.

Including individuals benefiting from our services, all kinds of personal data belonging to individuals associated with VİAL ALUMINUM will be recorded, stored, updated, and processed within the framework of specific, clear, and legitimate purposes in compliance with the Law on the Protection of Personal Data No. 6698, with due regard to legality and honesty, as long as your relationship with our company continues, and may be shared with third parties.

As defined in the Law on the Protection of Personal Data, VİAL ALUMINUM determines the information obtained from you within the scope of our relationship with you as the "Data Controller."

DEFINITIONS
In this information text:
Personal Data: Any kind of information related to an identified or identifiable natural person, Processing of Personal Data: Any operation performed on personal data, whether wholly or partially automated, or non-automated means, provided that it is part of any data recording system, including collection, recording, storage, retention, alteration, reorganization, disclosure, transmission, acquisition, making available, classification, or use of data.

Law on the Protection of Personal Data No. 6698 "KVKK": The Law on the Protection of Personal Data No. 6698 published in the Official Gazette on April 7, 2016,
Institution: Personal Data Protection Authority
Board: Personal Data Protection Board,
Data Processor: Natural or legal person who processes personal data on behalf of the data controller based on the authorization given by the data controller,
Data Controller: Natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.
Data Subject: Natural person whose personal data is processed,
Contact Person: The person who ensures communication with the institution and relevant individuals. The contact person is not a representative of the Data Controller. The contact person does not have the authority to act on behalf of the Data Controller but is the person to whom requests from the Institution are communicated. (The contact person is not an evaluating authority for questions and requests from Data Subjects, but only serves as a contact provider.)

DATA CONTROLLER
Data Controller: VİAL ALUMINUM
Address: Göksu mah. Gazi Bulv. 6807.sokak No:14/A Eker plaza Kepez/Antalya
Phone: +90 (242) 410 70 69
Email: info@vialaluminyum.com.tr

PRACTICE
As VİAL ALUMINUM;
We care about ensuring the protection, collection, processing, transmission, and destruction of personal data within the framework of relevant legislation, including the Constitution of the Republic of Turkey, international agreements to which our country is a party, and Law No. 6698 on the Protection of Personal Data, for all individuals related to our customers, potential customers, website users, employees, job applicants, former employees of VİAL ALUMINUM, interns, company shareholders, company officials, business partners, group company employees, visitors, and third parties under our responsibility, within the scope of our activities and purposes.

In this context, we may process your personal data that you share with us in accordance with Law No. 6698 KVKK, limited to our activities and purposes, in a relevant and proportionate manner, transfer it to third parties within the country and abroad, store it, use it for profiling, and classify it.

Purpose of Processing Your Personal Data
In accordance with Articles 4, 5, and 6 of Law No. 6698 KVKK, your personal data may be processed under the following conditions:

In cases explicitly envisaged by laws, for the establishment or performance of a contract, to fulfill our legal obligations, for the establishment, exercise, or protection of a right, as required by legitimate interests, or with your consent, personal data may be processed without the need for explicit consent. In addition, all processed personal data;

Will be processed in accordance with the law and honesty,

Will be accurate and up to date,

Will be processed for specific, clear, and legitimate purposes,

Will be limited to the purpose for which they were processed, relevant, and proportionate,

Will be retained for the period prescribed by the relevant legislation or necessary for the purpose for which they were processed.

Your personal data may be processed by our company for the following purposes without compromising our quality:

Conducting occupational health and safety activities,

Planning and monitoring activities with business partners, dealers, or suppliers,

Creating and managing customer records,

Conducting customer relations and monitoring corporate governance activities,

Managing and monitoring customer requests and complaints,

Ensuring Business Continuity,

Monitoring contract processes,

Monitoring legal processes and communication processes with official institutions,

Ensuring legal and commercial security,

Developing and improving the services provided by our company,

Determining and implementing commercial and business strategies,

Conducting market research,

Planning and organizing activities to ensure loyalty to products and services and/or increase loyalty,

Sustaining business and operations,

Conducting sales and purchasing processes,

Fulfilling warranty obligations,

Designing contractual processes such as sales, post-sales support, executing all necessary transactions, and monitoring, executing contract processes, planning and executing operational processes related to sales

Creating efficiency reports by obtaining information about customer-based developments,

Planning and implementing activities to ensure or increase loyalty to products and services,

Conducting company activities and procedures,

Conducting financial and accounting transactions,

Conducting financial, accounting, and financial transactions, including invoicing related to sales, risk management,

Conducting internal audit processes,

Fulfilling notification obligations to relevant/authorized public institutions,

Conducting job and internship application and evaluation processes,

Creating personnel files and conducting processes related to job entry,

Conducting Human Resources processes,

Fulfilling contractual and legal obligations for employees,

Conducting training activities,

Conducting physical security processes,

Planning information security processes, establishing and managing information technology infrastructure,

Conducting risk management,

For logging activities,

Method and Legal Basis for Collecting Your Personal Data

Your personal data may be collected verbally, in writing, or electronically, wholly or partially automatically or non-automatically as part of any data recording system, as outlined in the above purposes and scope.

Within the framework of activities for conducting commercial processes; communication forms, fair organizations, business cards, supplier information request forms, other commercial documents, payment information and documents, valuable documents, employee and intern candidate application forms, resumes, electronic mail, website, various contracts, mobile applications, consumer complaint forms, our customers, our suppliers, and other 3rd parties, including those outside our company, may be collected through various methods in verbal, written, or electronic form.

We process the personal data we collect for you in accordance with Law No. 6698 KVKK under the following conditions: Article 5/2-c of the Law on the Protection of Personal Data (KVKK) - In order to establish a contract and fulfill it, Article 5/2-c of the Law on the Protection of Personal Data (KVKK) - To fulfill our legal obligations, Article 5/2-f of the Law on the Protection of Personal Data (KVKK) - We process your personal data within the framework of our legitimate interests as a company or with your explicit consent for the purposes specified above.

Transfer of Your Data
Your personal data may be transferred to authorized public institutions and organizations due to legal obligations and needs, financial intermediary institutions to assess financial risks, independent audit firms for conducting audit processes, institutions providing intermediary/agency services in business trips and organization and fair processes, our business partners, our suppliers, our shareholders, local/international organizations that we cooperate with within the framework of relevant contracts for the performance of VİAL ALUMINUM activities, and other third parties, directly or indirectly, domestically or abroad, together with VİAL ALUMINUM, in accordance with Law No. 6698 KVKK and the applicable legislation, and will be jointly responsible.

Storage and Deletion of Data
According to the legislation, relevant personal data must be stored for certain periods. Therefore, it is our responsibility to store personal data in compliance with the legislation and for the necessary period. These storage periods are detailed on a data-by-data basis in the prepared personal data inventory. Personal data is kept for the period prescribed by the legislation or required by the purpose for which it is processed. Data is stored in physical or electronic form. Necessary security measures have been taken for the storage and preservation of data, and a secure environment has been provided by our company. Personal data whose storage period has expired is destroyed at six-month intervals. (deletion/destruction/anonymization)

Your Rights as the Data Subject
Within the scope of Article 11 of Law No. 6698 KVKK,
Learning whether your personal data has been processed,
Requesting information if your personal data has been processed,
earning the purpose of processing your personal data and whether they are used appropriately for that purpose,
Knowing the third parties to whom your personal data has been transferred domestically or abroad,
Requesting correction of your personal data if it is incomplete or inaccurate,
Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK legislation,
In case of requesting the correction of incomplete or inaccurate data and the deletion or destruction of personal data, requesting that this situation be notified to third parties to whom your personal data has been transferred,
Objecting to the emergence of a result against you by analyzing the processed data exclusively through automated systems,
In case of suffering damage due to the unlawful processing of personal data, requesting the compensation of the damage, you have the right.
You can exercise your rights by filling out the Information Request Form on our website www.vialaluminyum.com or by submitting a petition containing your request to our address "Göksu mah. Gazi Bulv. 6807.sokak No:14/A Eker plaza Kepez/Antalya" in writing or by sending an email from your defined email address in our system. Depending on the nature of your request, your request will be concluded free of charge or in accordance with the fee schedule determined by the KVKK Board within the shortest time possible (within 30 days at the latest).
As a data subject, within the scope of Article 14 of Law No. 6698 on the Protection of Personal Data, if your application is rejected, the response is found insufficient, or if there is no response to the application within the deadline; you can lodge a complaint with the Authority within thirty days from the date you learned the response or within sixty days from the date of your application, in any case with your consent.
In accordance with Article 28/2 of Law No. 6698 KVKK; personal data subjects cannot claim their other rights mentioned above except for the right to request the remedy of damages in the following cases:
If processing personal data is necessary to prevent crime or for criminal investigation.
If processing personal data has been made public by the data subject himself/herself. If processing personal data is necessary for the exercise of the supervision or regulatory duties of authorized public institutions and organizations, professional organizations with public institution status, or for the conduct of disciplinary investigation or prosecution.If processing personal data is necessary for the protection of the State's economic and financial interests regarding budget, taxation, and financial matters.

OTHER ISSUES
Legal regulations in force regarding the processing and protection of personal data will be primarily applied in processes related to the processing and protection of personal data within the scope of this Personal Data Protection and Processing Information Text.

The Information Text is published on the website "www.vialaluminyum.com" and made accessible to relevant individuals. Changes and updates may be made to the Information Text to comply with changing conditions and legislation and will be made available to relevant individuals through the above-mentioned website.