CLARIFICATION TEXT ON PROTECTING YOUR PERSONAL DATA AS PART OF THE LAW ON THE PROTECTION OF PERSONAL DATA NO. 6698 (LPPD)

1.GENERAL INFORMATION

The objective of the Policy on Protection and Processing of Personal Data("Policy") is to determine the terms and conditions with regards to processing, storing, and sharing the personal data collected from all the employees and users("User") providing data entries into the Human Resources and Staff Management System("ZEOPS/Platform") which is provided on zeops.com("Website") owned by Zeta Global and used by our Company.We hereby undertake to process your personal data by storing, under any circumstances, corresponding to the legislation and good faith, with the certain, explicit, and lawful purposes, in conjunction with the intended objectives and in a limited and restrained manner, and for a period of time stipulated by the relevant statute or as required by the intended purposes.

2.DATA CONTROLLER

Your personal data will be saved, stored, updated, and disclosed/transferred to the third parties as permitted by the legislation, also classified and processed as defined in LPPD by zeops.com, acting in the capacity of the Data Controller within the scope as outlined below.

3.PROCESSED DATA

The data provided by the User to ZEOPS and/or obtained from the Users during the use of the Platform and also considered as personal data according to the Law on the Protection of Personal Data No. 6698 (Law No. 6698) is listed under this topic Unless otherwise expressed, the "personal data" statement shall mean the below definitions as part of the terms and conditions stipulated within the frame of the Policy.

Zeops collects the below data provided by the User on the digital environment in the phases of the member login and payment processes for the relevant pack.
• Credentials such as name, surname, etc.
• Contact details such as an address, work or personal e-mail address, phone number, etc.
• Details about your medical condition, blood type, criminal record, education status, certificate and diploma information, language skills, training and capabilities, seminars and courses, computer skills, and alike data you have provided during creating your personal file or in your CV.
• Photos, video CVs, footages owned by a real person
• Overall knowledge and work experience (company name, working period, job description)
• Passwords and alike security and operation details used for authorization and account access
• Bank Account Details
• Product/Service Usage Information
• Process Security Details
• Financial Information
• Zeops obtains the details of the Users about the Website and Platform usages by logging the IP information and signal data to record the pages and locations used by deploying cookies, which are the technical communication files, and also collects the IP information via the cookies to determine the habits of usage and access to the services provided on the Platform.

4.PURPOSE OF DATA PROCESSING

The collected personal data will be processed to secure the execution of the human resources policies, determine and evaluate the inclination of the employee/candidate profiles to the company operations, verify the information provided in writing, electronically and/or verbally, check whether the responsibilities and obligations arising from the legislation are followed, specify and apply the commercial and business strategies, within the scope of terms and purposes regarding the personal data processing as specified in articles 5 and 6 of LPPD aimed to carry out the operations intended for intelligence, measuring and increasing our service quality, selection, placement and providing employment opportunities in line with the operational purposes of our company in the physical or electronic environment.Moreover, such personal data can be processed/stored to contact the Users or improve the experience of the Users on the Platform (developing the current services, creating new services, and providing tailor-made services); and also used for performing various statistical evaluations, generating a database and conducting market surveys as part of the Zeops reporting and business development activities without disclosing the credentials of the User.Besides, in line with the intended use of the Platform, the behaviors of the Users on the platform are processed via a cookie, along with the browser-specific information unit called User-Agent, access time, all the user information, and linking such information to the external technological tools, the number of the viewed pages, visit duration and target completion duration and count, and also alike metrics.

Our company shall process the personal data and share it with the third parties in compliance with articles 5 and 8 of the Law and/or depending on the existence of the conditions in the relevant statute without additionally seeking the Users' consents. The primary circumstances where the personal data can be processed without the explicit consents of the Users are indicated as below:
• If explicitly stipulated by the legislation,
• If it is obligatory for a person whose consent cannot be sought due to physical impossibilities or whose consent is not granted legal validity to keep himself/herself or other persons alive or keep the bodily integrity of himself/herself or other persons,
• If it is required to process the personal data provided that such processing is directly related to entering or executing an agreement,
• If it is compulsory in terms of fulfilling the legal obligations,
• If the personal data has been made public by the User,
• If the data processing is obligatory to establish, use or protect a right,

As described above, the Platform shall use cookies, IP, and any other suchlike technological, software, hardware, etc.tools and share the personal data with the third parties as within the defined scope of this policy.The aforesaid technical communication files are the small-size text files being sent to the browser so as to be stored in the main memory.The technical communication file saves the status and preference settings of a website and facilitates internet usage within this regard.The technical communication file is designed to collect statistical data about how many, for which purposes, how many times and how long the persons use the internet websites on a time-based proportioning, and to facilitate the dynamical generation of the advertisements and contents from the user pages tailored for the User; accordingly, it is used only for the above purposes. The technical communication file has not been designed to obtain any other personal data from the main memory unit. Most of the browsers are designed in a manner to accept the technical communication file; however, if they want, the users can always change their browser settings in a way to ensure the technical communication is not accepted or to warn them whenever the technical communication file is sent.

5.STORAGE DURATION OF PERSONAL DATA

To enable our Company and the User benefit from the Platform and to provide the services subject to the Platform, and for the purposes specified in this policy, the personal data owned by the Users shall be stored as long as the legal relationship between the User and our Company is maintained, and also for 5 years after such legal relationship is terminated.Additionally, the personal data will be stored by being restricted to the time expected for submitting the necessary defenses within the scope of the conflict and/or for as long as the periods of limitation outlined in the relevant statute in case of any conflict that may arise between the Company and/or User.

6.RIGHTS OF THE PERSONAL DATA OWNER

According to article 11 of LPPD regarding your personal data, you are entitled to;
• Learn whether your personal data is processed,
• Request information if your personal data has been processed,
• Learn the purposes of personal data processing and whether such data is used as intended,
• Know the domestic or international third parties to whom the personal data is transferred,
• Request for correction, if the personal data has been processed imperfectly or inaccurately and ask for notifying the third parties to whom the personal data is transferred about the correction respectively,
• Request deletion or disposal of the personal data if the reasons for processing the personal data have been ruled out, though having been processed in line with LPPD and the other relevant provisions of the Law, and ask for notifying the third parties to whom the personal data is transferred about the deletion and/or disposal accordingly,
• Object to any disadvantageous results that may be posed against you as the processed data is exclusively analyzed via automated systems,
• Request compensation if any loss is incurred as the personal data has been processed unlawfully

Within this respect, you should physically or electronically submit your request on using your foregoing rights in pursuance of article 13 of LPPD "in writing" or via other methods as outlined by the Personal Data Protection Committee to our relevant Company.To claim your preceding rights, by specifying which of your right you would like to use as defined in article 11 of LPPD you can submit your request to us via a registered letter with a return receipt or to [email protected] via an e-mail along with the necessary details required for your credentials and a statement on the right you want to use. The Company can use additional verification methods (by sending an SMS, calling you, etc.) to specify whether you have lodged the application and thus to protect your rights depending on the nature of your request and application method.