PROTECTION OF PERSONAL DATA
CLARIFICATION TEXT UNDER THE PERSONAL DATA PROTECTION LAW OF DAP GAYRİMENKUL GELİŞTİRME ANONİM ŞİRKETİ

In accordance with the Personal Data Protection Law No. 6698 ("KVKK"), this clarification text has been prepared by Dap Gayrimenkul Geliştirme Anonim Şirketi to provide necessary information to third parties whose data is processed, other than our employees, in our capacity as the data controller. As the data controller, our company may process, store, classify, update, and, where permitted by legislation, transfer to 3rd Parties the Personal Data/Special Category Personal Data of third parties, limited to the purposes stated below and in accordance with the law.

1. Definitions
Law: Personal Data Protection Law No. 6698 (KVKK).
Personal Data: Any information relating to an identified or identifiable natural person.
Special Category Personal Data: Data relating to race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dressing, membership of associations, foundations or trade unions, health, sexual life, criminal conviction and security measures, and biometrics and genetics, etc.
Processing of personal data: Any operation performed upon personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or provided that the process is a part of any data registry system.
Data Subject/Relevant Person: The natural person whose personal data is processed.
Data Processor: The natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller.
Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data registry system.

2. Purpose of Processing Your Personal Data/Special Category Personal Data
Your personal data/special category personal data obtained by Dap Gayrimenkul Geliştirme Anonim Şirketi will be processed within the scope specified below:
Execution of Emergency Management Processes, Execution of Information Security Processes, Execution of Employee Candidate / Intern / Student Selection and Placement Processes, Execution of Application Processes of Employee Candidates, Execution of Audit / Ethical Activities, Execution of Training Activities, Execution of Access Authorizations, Execution of Activities in Compliance with Legislation, Execution of Finance and Accounting Affairs, Execution of Loyalty Processes to Company / Products / Services, Ensuring Physical Space Security, Execution of Assignment Processes, Follow-up and Execution of Legal Affairs, Execution of Internal Audit/ Investigation / Intelligence Activities, Execution of Communication Activities, Planning of Human Resources Processes, Execution of Recruitment and Evaluation Processes, Execution / Audit of Business Activities, Execution of Occupational Health / Safety Activities, Business partnership/ signing of purchase-sale contract negotiations and contracts, Receiving and Evaluating Suggestions for the Improvement of Business Processes, Execution of Activities for Ensuring Business Continuity, Execution of Logistics Activities, Execution of Goods / Services Purchasing Processes, Execution of Goods / Services After-Sales Support Services, Execution of Goods / Services Sales Processes, Execution of Goods / Services Production and Operation Processes, Execution of Customer Relationship Management Processes, Execution of Activities for Customer Satisfaction, Organization and Event Management, Execution of Marketing Analysis Studies, Execution of Performance Evaluation Processes, Execution of Advertising / Campaign / Promotion Processes, Execution of Risk Management Processes, Execution of Storage and Archive Activities, Execution of Contract Processes, Execution of Sponsorship Activities, Execution of Strategic Planning Activities, Follow-up of Requests / Complaints, Ensuring the Security of Movable Property and Resources, Execution of Supply Chain Management Processes, Execution of Wage Policy, Execution of Marketing Processes of Products / Services, Execution of Power of Attorney and Signature Circular Procurement Processes, Ensuring the Security of Data Controller Operations, Execution of Investment Processes, Execution of Talent / Career Development Activities, Providing Information to Authorized Persons, Institutions and Organizations, Execution of Management Activities.

3. Transfer of Your Personal Data/Special Category Personal Data
Processed within the scope of the explained purposes, your personal data may be transferred to our business partners, shareholders, Affiliates and subsidiaries, suppliers, Group Companies, authorized public institutions and organizations, support service companies and real persons to carry out our activities, and to independent audit companies within the framework of legal obligations and legal restrictions, in accordance with the basic principles stipulated in the KVKK and within the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK.

4. International Transfer of Your Personal Data/Special Category Personal Data
As Dap Gayrimenkul Geliştirme Anonim Şirketi, your data is not transferred abroad. In the event of data transfer abroad, the necessary notification will be made by our company, and if explicit consent arising from the law is required, the transfer can be made after providing the necessary clarification to the relevant person and obtaining their explicit consent.

5. Method of Collecting Personal Data/Special Category Personal Data
Your personal data is collected by Dap Gayrimenkul Geliştirme Anonim Şirketi through applications to the Company, e-mail, and different channels, and based on the legal grounds specified below, in order to carry out our activities.

6. Legal grounds for the processing of your aforementioned personal data by the Company;
Your personal data is collected, used, recorded, stored, and processed by our Company in a clear and understandable written notification to personal data subjects, by obtaining their explicit consent if necessary, in accordance with the law and the rules of good faith, for the establishment of an employment contract, the exercise of your rights arising from the law and the contract, and for the Company to fulfill its legitimate interests or legal obligations, connected and limited to the legitimate purpose clearly stated above, and within the framework of the principle of proportionality. Your personal data collected in this process is securely collected in physical and electronic environments during the initiation and continuation of the contractual relationship to carry out the processes listed above and to conduct our commercial and operational activities. Furthermore, if a special retention period is stipulated in the laws regarding the relevant data, your data will be securely stored in physical and electronic environments for the stipulated retention period. In this context, your special category personal data / personal data can be processed and transferred by obtaining explicit consent in light of the principles stipulated in Article 4(2) of the KVKK, or in the presence of the situations stipulated in Articles 5(2) and 6(3), without obtaining explicit consent.

7. Ensuring the Security of Personal Data
Our company takes the measures stipulated in Article 12, Paragraph 1 of the KVKK to ensure the appropriate level of security necessary for the protection of personal data.

8. Your Rights as a Data Subject under KVKK
The rights you have in accordance with Article 11 of the KVKK are as follows:
• To learn whether your personal data is processed or not,
• To request information if your personal data has been processed,
• To learn the purpose of processing your personal data and whether they are used appropriately for their purpose,
• To know the third parties to whom personal data is transferred domestically or abroad,
• To request the rectification of incomplete or inaccurate data, if any,
• To request the erasure or destruction of your personal data under the conditions stipulated in Article 7,
• To request reporting of the operations carried out pursuant to subparagraphs (d) and (e) to third parties to whom your personal data have been transferred,
• To object to the occurrence of a result against the person themselves by analyzing the processed data exclusively through automated systems,
• To claim compensation for the damage arising from the unlawful processing of your personal data.

9. Your questions and requests
If you submit your requests regarding your rights mentioned in the articles above to our company's address at Altayçeşme Mahallesi, Zeytindalı Sokak, No:16 B Blok Maltepe / İstanbul or to the registered email address dapgayrimenkul@hs01.kep.tr, your relevant request will be concluded free of charge within thirty (30) days at the latest. However, if the transaction requires an additional cost, the fee in the tariff determined by the Board will be charged by us.