Promaks Software Industry and Trade Inc. Internet Privacy Policy

Promaks respects the privacy of your information. In this context, as Promaks Software, to ensure the lawful processing of personal data, we take all necessary measures and actions to comply with the provisions of the Law No. 6698 on the Protection of Personal Data (“Law”), the decisions of the Personal Data Protection Board (“Board”) and, to the extent applicable, the provisions of the European Union Data Protection Regulation (“GDPR”). This policy outlines the personal information you share with us and how we may use it. This policy also explains other important matters related to your privacy.”

Contents:

Promaks Internet Privacy Policy

Your Consent

Restrictions on the Collection, Use, and Disclosure of Personal Information

Information Collected Through the Promaks Website and How It Can Be Used Sharing of Personal Information

Security of Personal Information

Retention of Personal Information

Children and Parents

Questions About This Policy or Privacy Statements

Changes to This Policy and Our Privacy Declarations.”

Promaks Internet Privacy Policy

It is Promaks’ policy to comply with all prevailing privacy and data protection laws. This commitment reflects the value we place on earning and retaining the trust of our employees, customers, business partners, and others who share their personal information with us.

The Internet privacy policy describes how Promaks protects your privacy when we collect personal information through the Promaks website. The term “personal information” refers to information that identifies you personally, either alone or with other information available to us.

This Policy generally applies to all Internet Sites operated by or on behalf of Promaks and business units operated worldwide (each referred to as the “Promaks Internet Site”).

In this context, as a Promaks internet site, www.promaks.com.tr, we pay utmost attention to the security of your personal data. Your personal data is processed and stored in accordance with the Law No. 6698 on the Protection of Personal Data (“PDPL”).”

Your Consent

By using the Promaks website or by providing us with your personal information, you consent to the collection, use, and disclosure of your personal information as described in this policy and in any country or website’s privacy statement that may be applicable.

In accordance with Law No. 6698 (PDPL), your personal data shared with www.promaks.com.tr can be fully or partially acquired, recorded, stored, altered, rearranged, in short, subjected to any kind of operation, automatically or in a non-automatic manner provided that it is part of any data recording system. Within the scope of PDPL, any operation performed on data is considered as “processing of personal data”.

If you do not consent to the collection, use, and disclosure of your personal information as described in this Policy (and in any applicable Country or Website Privacy Statement), do not use the Promaks Internet Sites.”

Restrictions on the Collection, Use, and Disclosure of Personal Information

To the extent required by applicable law, whenever Promaks collects personal information from its website, it will:

• Notify you timely and appropriately about its data practices.
• Collect, use, and disclose your personal information with your explicit or implicit consent, depending on the sensitivity of the personal information, legal requirements, and other factors.
• Collect your personal information only for specific, limited purposes. The information collected will be relevant, adequate, and not excessive in relation to the purpose for which they are collected.
• Process your personal information in a manner consistent with the original purpose of collection or any other purpose you subsequently consent to.
• Take reasonable steps to ensure that your personal information remains reliable, accurate, complete, and up to date as relevant to its intended use.
• Do Not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”.
• Take appropriate measures to ensure that personal information disclosed to a third party or transferred to another country, including transfers within Promaks, is adequately protected, whether through contracts or other means.

Information Collected from the Promaks Website and How This Information Can Be Used

When you use the Promaks website, we may collect information about you:

1. Information sent to us by your web browser

1. • Promaks collects information that is automatically sent to us by your web browser. This information typically includes your internet service provider’s IP address, the name of your operating system (like Macintosh® or Windows®), and the version of your web browser (like Internet Explorer® or Mozilla®). Please check your browser if you want to learn what kind of information it sends or how to change your settings.
   • The information provided by your browser doesn’t identify you personally. We use this information to generate statistics that help us improve our site and make it more compatible with the technology used by our internet visitors.

2. Information collected by placing a “Cookie” on your computer

1. • Promaks may collect information about you by placing a “tag” on your computer’s hard drive, known as a “cookie”.
   • The Promaks website uses “session cookies”. A session cookie is used to tag your computer with a unique identifier generated by a computer when you log onto our site. A session cookie doesn’t personally identify you and expires once you close your browser. We use session cookies to collect statistical information about how visitors use our site – which pages they visit, which links they use, and how long they stay on each page. We statistically analyze this information (clickstream data) to better understand our visitors’ interests and improve our site’s content and functionality.
   • If you do not want to accept cookies, you can set your browser to reject them or notify you when a cookie is being placed on your computer. Although you don’t have to accept cookies when visiting a Promaks website, if your browser rejects cookies, you may not be able to use all of the site’s features.

3. Information you provide voluntarily

1. • When using the Promaks website, we collect information you voluntarily provide, such as when you sign up for email alerts, fill out a survey, or ask a question or send an email for feedback. In many cases, this information will be personal information.
   • Promaks uses this information for the purpose you provided it. For example, if you signed up for email alerts and provided your email address, we use your email address to send you the email alerts you requested.
   • We may use the information collected from the Promaks website for various business purposes, such as customer service, fraud prevention, market research, improving our products and services, and offering you and your company information and offers we believe you might be interested in.
   • The Promaks site allows you to make choices about the use of your personal information. In many cases, we ask you to indicate your choices at the time and on the page where you provide your personal information.

Sharing of Personal Information

Promaks Software will not sell the information it has collected to mailing list brokers without your explicit consent. Promaks Software can share your personal information with other Mikro Software business units. When we do this, these other Promaks Software units will use your information primarily for the purpose it was originally collected (or for the purpose you subsequently consented to) and will only use it in accordance with this policy, any applicable country or website privacy declarations, and all applicable data protection laws.

In specific, limited circumstances, we may share or transmit your personal information with unrelated third parties. For instance, we might share personal information with a third party (i) upon your request, (ii) to comply with a legal requirement or court order, (iii) to investigate a potential crime like identity theft, (iv) in connection with the sale, purchase, merger, reorganization, liquidation, or dissolution of Mikro Software or a Mikro Software business unit, or (v) in similar situations. If such an event occurs, we will take appropriate steps to protect your personal information.

Promaks Software’s website allows you to make choices regarding the disclosure and/or transmission of your personal information. In many cases, we ask you to indicate your choices at the time and on the page where you provide your personal information.

Security of Personal Information

Your personal information will generally be stored in Promaks Software’s databases.

Promaks Software provides reasonable safeguards to protect the confidentiality, security, and integrity of personal information. Although we take security measures to help protect your personal information from unauthorized disclosure, misuse, or alteration, as is the case with all computer networks connected to the internet, we cannot guarantee the security of information provided over the internet and will not be responsible for breaches of security beyond our reasonable control.

Promaks Software, in accordance with Article 12 of the KVKK (Personal Data Protection Law), is obliged to take software measures like hashing, encryption, transaction logging, and access management, as well as physical security precautions, to prevent personal data from being processed unlawfully, to prevent unauthorized access, and to safeguard them. If it is learned that personal data has been obtained by others unlawfully, the situation will immediately be reported to the Personal Data Protection Board in accordance with legal regulations.

Keeping Personal Data Accurate and Updated

In accordance with Article 4 of the KVKK, Promaks Software has an obligation to keep your personal data accurate and up-to-date. In this context, in order for Promaks Software to fulfill its obligations arising from current legislation, our members need to share accurate and up-to-date data or update it on our website.

Retention of Personal Information

Promaks Software retains personal information collected via our website for as long as necessary to provide the services, products, and information you request, or as permitted by applicable law.

Children and Parents

The Promaks Software site is generally not designed for users under the age of 13. Except where permitted by law, Promaks Software does not knowingly request or collect personal information from children or about children through its websites. If you believe your child has provided personal information and you wish to have it removed from our records, you can do so by emailing iletisim@invenco.com.tr.

Rights of the Personal Data Subject According to the Law No. 6698 on Protection of Personal Data (KVKK)

In accordance with Article 11 of Law No. 6698 (KVKK), the rights of the Personal Data Subject are as follows:

• The Personal Data Subject, by applying to Promaks Software (data controller), can inquire:
• Whether personal data related to him/her is processed,
• If personal data has been processed, request information regarding this,
• Learn the purpose of processing of personal data and whether they are used in accordance with their purpose,
• Know the third parties to whom personal data is transferred domestically or abroad,
• Request correction of personal data if it is processed incompletely or inaccurately,
• Request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of KVKK,
• Request that the operations such as correction, deletion, and destruction of personal data be notified to third parties to whom personal data is transferred,
• Object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
• Claim compensation for the damages incurred due to unlawful processing of personal data.

Questions About This Policy or Privacy Declarations

If you have any questions about this policy, a country’s privacy statement, or our use of personal data, please contact us by emailing iletisim@promaks.com.tr.

Changes to This Policy and Our Privacy Declarations

Promaks Software reserves the right to update or modify this policy at any time and without prior notice, and to revise its updated version.