GENERAL INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA

Data Controller (Employer): Scrap Danışmanlık Hizmetleri Ticaret Anonim Şirketi

As Scrap Danışmanlık Hizmetleri Ticaret Anonim Şirketi (“Scrap” or the “Data Controller”), we place the utmost importance on the protection and security of your personal data. Accordingly, in order to protect fundamental rights and freedoms—particularly the right to privacy—and in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”), we would like to inform you in this Information Notice, in our capacity as Data Controller, about the methods of collection, purposes of processing, legal grounds, and your rights concerning your personal data.

1. Purpose of Processing Personal Data

Your personal data is processed within the scope of Scrap Danışmanlık Hizmetleri Ticaret Anonim Şirketi’s commercial activities for the following purposes:
Fulfilling employment and legal obligations; managing employee benefits and entitlements; conducting product/service marketing processes; carrying out and monitoring business activities; executing audit and ethical compliance; conducting training activities; implementing process improvement measures; managing communication activities; handling legal affairs; managing finance/accounting operations; managing contracts; ensuring information security; managing access authorizations; carrying out occupational health and safety activities; providing information to authorized individuals and institutions; recording and monitoring visitors; ensuring physical space security; managing procurement processes; processing employee applications, recruitment and placement procedures; planning HR activities; securing movable assets and resources; and ensuring compliance with relevant legislation.

If the purposes of processing personal data listed in this Notice change, your explicit consent will be requested separately.

2. Data Transfers and Purpose of Transfer

In accordance with Articles 8 and 9 of the Law, your personal data may be transferred to relevant institutions, organizations, and office personnel within the framework of the purposes outlined in Section 1.

3. Method and Legal Basis of Collection

Your personal data may be collected—automatically or non-automatically—through any written, verbal, or electronic means in line with the purposes stated in this Notice.
Data is processed based on the legal grounds set forth in Articles 5 and 6 of the KVKK, including:

• Explicitly stipulated in laws,
• Fulfilling the legal obligations of the Data Controller,
• Fulfillment of contractual obligations,
• Legitimate interest of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

If none of the legal grounds under the Law apply, your personal data will only be processed upon obtaining your explicit consent as per Article 5/1 and 6/2.

4. Retention Period of Personal Data

Your personal data is stored for the period specified in the relevant legislation or as long as necessary for the purposes of processing. In addition, in the event of a legal dispute that may arise between you and Scrap Danışmanlık Hizmetleri Ticaret Anonim Şirketi, data may be retained within the statute of limitations for the purpose of legal defense. If the processing purpose ceases or the retention period expires and no other legal basis exists, the data will be deleted, destroyed, or anonymized.

5. Data Subject Rights

Under Article 11 of the Law, as a data subject, you have the right to:

• Learn whether your personal data is being processed,
• Request information if your personal data has been processed,
• Learn the purpose of processing and whether it is used in accordance with that purpose,
• Know the third parties to whom personal data is transferred domestically or abroad,
• Request the correction of incomplete or inaccurate personal data,
• Request the deletion or destruction of personal data if the reasons for processing no longer exist—even if it was processed in accordance with the law—and request notification of such actions to third parties,
• Object to the emergence of a result against you through the exclusive analysis of processed data via automated systems,
• Request compensation for damages incurred due to unlawful processing of personal data.

Pursuant to Article 13/1 of the KVKK, to exercise your rights listed above, you must submit your request in writing—along with identification documents—to our office located at:

Atatürk Mahallesi Alemdağ Caddesi Öztürk İş Merkezi No:35 Kat:4 D:11 Ümraniye / ISTANBUL
or send it via notary, or submit it with a mobile signature to: info@scrap.com.tr

Your request will be evaluated and finalized within 30 (thirty) days.

If the response to your request incurs a cost, a fee may be charged in accordance with the tariff set by the Personal Data Protection Board.