INFORMATION NOTICE ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

PERSONAL DATA PROTECTION AND PROCESSING DISCLOSURE STATEMENT

Pursuant to the provisions of the Personal Data Protection Law No. 6698 (“KVKK”), any information relating to an identified or identifiable natural person, including your special categories of personal data, shall be processed by Makrochemical Industrial Chemicals Industry and Trade Inc. (hereinafter referred to as the “Company”) acting as the Data Controller, within the scope explained below.

The concept of “Processing of Personal Data” is a legal term and refers to any operation performed on personal data such as obtaining, recording, storing, preserving, altering, reorganizing, disclosing, transferring, acquiring, making available, classifying, or preventing the use of personal data, as defined under Law No. 6698.

Your personal data shared with our Company as a subscriber, customer, supplier, consumer, physical or online visitor, business partner, or employee (including apprentices and interns) may be processed in compliance with the KVKK, in connection with and limited to our business activities and service purposes; transferred to third parties domestically and internationally; stored; used for profiling or other commercial purposes related to our business; and classified.

As a Company, we attach the utmost importance to the security of your personal data. We take the highest possible level of security measures to protect your privacy during the collection, storage, processing, and, where necessary, sharing of your personal data in compliance with applicable laws in all products and services we provide.

The purpose of publishing this Disclosure Statement is to clearly inform you about the methods of collecting your personal data, the purposes for which it is processed, the legal grounds for processing, and your legal rights.

The following information and concepts are of significant importance regarding the protection and processing of personal data and are provided to ensure that you are fully informed.

A) WHO IS THE DATA CONTROLLER?

Pursuant to the Personal Data Protection Law No. 6698, the Data Controller is Makrochemical Industrial Chemicals Industry and Trade Inc.

Your personal data may be collected and processed by Makrochemical Industrial Chemicals Industry and Trade Inc. (hereinafter referred to as the “Company”) within the scope explained below.

B) PURPOSES FOR WHICH YOUR PERSONAL DATA IS OR WILL BE PROCESSED

Your personal data may be processed for the purposes of fulfilling contractual obligations, carrying out evaluations required for the services provided, ensuring compliance with domestic and international legislation, particularly tax legislation and Social Security Institution regulations, complying with risk monitoring and notification obligations, fulfilling information sharing, reporting and notification obligations imposed by authorities, meeting legal record retention requirements, preventing fraud, ensuring security, conducting planning and statistical activities required by our Company, determining and implementing our commercial and business strategies, carrying out finance, communication, market research and procurement operations, maintaining internal system and application management operations, managing legal processes, implementing social responsibility projects, and providing you with uninterrupted, improved and reliable services, in accordance with Articles 5 and 6 of Law No. 6698 regarding personal data processing conditions and purposes.

In addition to the above, your personal data may be processed for the development and provision of products and services tailored to you, establishing communication regarding products and services you have received or may receive, and, where you have granted consent, for promotional activities, product/service offers, marketing and campaign activities, development of suitable products and services, customer satisfaction studies, new product development, market research, target customer identification, and similar purposes.

Within the scope of contracts concluded or activities carried out jointly with third-party natural or legal persons with whom our Company has business relations, your personal data may be processed for the fulfillment of legal and commercial obligations arising from such contracts, establishment and protection of rights, commercial and legal evaluation processes, legal and commercial risk analyses, and management of financial affairs.

Personal data belonging to job applicants contacted as part of our human resources activities may be processed for recruitment, evaluation, communication, placement, and other human resources activities, and in the event that an application results negatively for any reason, may be retained and processed by our Company for up to ten (10) years for evaluation regarding other suitable positions.

C) TO WHOM AND FOR WHAT PURPOSES PROCESSED PERSONAL DATA MAY BE TRANSFERRED

Your personal data may be transferred, within the limits prescribed by applicable legislation and solely for the purposes stated above and for fulfilling legal obligations, to authorities such as the Revenue Administration of the Ministry of Treasury and Finance of the Republic of Türkiye, the Social Security Institution, ministries, judicial authorities and other legally authorized public institutions, support service providers and contracted organizations that complement or support our activities, consultants and organizations with whom we cooperate where permitted by law, financial institutions, audit and independent audit firms, and banks, in accordance with Articles 8 and 9 of Law No. 6698 concerning the transfer of personal data and transfer abroad.

D) METHOD AND LEGAL BASIS FOR COLLECTING PERSONAL DATA

Your personal data may be collected through channels such as our Company’s website, mobile or digital applications, social media platforms, customer meetings, SMS communications, written or digital applications made through our Company and other websites, direct sales teams, support service organizations, and other channels through which our Company or institutions, organizations, and individuals authorized to represent our Company communicate with you or may communicate with you in the future.

Such personal data may also be collected, where legally required and within the limits permitted by applicable legislation and contractual relationships, with your consent where necessary, including through access to databases maintained by various institutions and organizations.

The personal data collected through these methods may be processed and transferred for the purposes specified in this Disclosure Statement in accordance with the personal data processing conditions and purposes set forth in Articles 5 and 6 of Law No. 6698.

E) YOUR RIGHTS AS A PERSONAL DATA SUBJECT UNDER ARTICLE 11 OF LAW NO. 6698

To learn whether your personal data is being processed

To request information if your personal data has been processed

To learn the purpose of processing your personal data and whether it is used in accordance with that purpose

To know the third parties to whom your personal data is transferred domestically or abroad

To request the correction of incomplete or inaccurate personal data and request notification of such correction to third parties to whom the data has been transferred

To request the deletion or destruction of your personal data where the reasons requiring processing no longer exist, despite being processed in accordance with Law No. 6698 and other relevant legislation, and to request notification of such action to third parties to whom the data has been transferred

To object to any adverse result arising from the analysis of your personal data exclusively through automated systems

To request compensation for damages suffered due to the unlawful processing of your personal data

If you submit your requests regarding these rights through the methods specified below, our Company will finalize the request free of charge as soon as possible and no later than thirty (30) days, depending on the nature of the request.

However, if the process requires additional costs, a fee determined by the Personal Data Protection Board may be charged.

Pursuant to Article 13/1 of Law No. 6698, you may submit your requests regarding the exercise of your rights in writing or through other methods determined by the Personal Data Protection Board.

For this purpose, after completing and signing the Data Subject Application/Request Form available at www.makrochemical.com, or by preparing and signing your own petition, you may submit your application through one of the following methods:

By hand delivery to our Company’s secretariat at A.O.S.B., 10044 Street No:7, 35620 Çiğli / İzmir, Türkiye, together with documents verifying your identity;

By sending it through a notary public to A.O.S.B., 10044 Street No:7, 35620 Çiğli / İzmir, Türkiye;

By sending it with a secure electronic signature via a registered electronic mail (KEP) address to makrochemical@hs01.kep.tr.

Respectfully submitted for your information.

Makrochemical Industrial Chemicals Industry and Trade Inc.