SPS LABEL PRINTING AND PACKAGING INDUSTRY AND TRADE LIMITED COMPANY
CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA

As SPS Label Printing and Packaging Industry and Trade Limited Company (“Company”), we place the utmost importance on the security of your personal data. With this awareness, we prioritize the processing and storage of all types of personal data belonging to all individuals associated with our Company, including those benefiting from our products and services, in compliance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and relevant legislation. Acting with full awareness of this responsibility, as the “data controller” defined in KVKK, we process personal data as explained below and within the limits imposed by legislation.

a) Data Controller and Its Representative

Pursuant to KVKK, your personal data may be processed by our Company, acting as the data controller, within the scope explained below.

b) Purposes for Processing Personal Data and Sharing with Third Parties

Your collected personal data may be processed in compliance with the law and KVKK, for purposes including but not limited to:

• Planning, executing, and managing our Company’s commercial collaborations, management, and communication activities effectively;
• Ensuring that personal data owners can benefit from our products and services in the best way possible by customizing them to meet individual needs;
• Ensuring the highest level of data security;
• Enhancing the services offered on our website and resolving errors on the site;
• Communicating with personal data owners to address their requests and complaints, as well as managing these processes effectively;
• Managing events, fulfilling legal obligations to authorized organizations, creating and monitoring visitor records;
• Securing the legal and commercial safety of our Company, our group companies, and individuals with whom we have business relationships (administrative operations for communication, ensuring physical security and supervision of Company locations, business partner/customer/supplier/employee evaluations, compliance processes, audits, financial operations, etc.);
• Establishing and implementing our Company’s commercial and business strategies;
• Implementing human resources policies.

Your personal data may be processed within the personal data processing conditions and purposes stated in Articles 5 and 6 of KVKK and shared with our business partners, suppliers, group companies, Company authorities, shareholders, legally authorized public institutions, and private individuals under the conditions outlined in Articles 8 and 9 of KVKK.

If the processing activity does not meet one of the conditions specified in the Law, your explicit consent will be obtained for the relevant activity.

c) Methods and Legal Grounds for Collecting Personal Data

Your personal data is collected through various technical and procedural methods conducted via channels such as agents, websites, and physical applications. This is done based on legal grounds such as legislation, contracts, requests, commercial customs, and the principles of honesty. Data is processed:

• To fulfill the Company’s legal obligations;
• To meet the requirements of the business relationship established with you and ensure mutual rights are protected;
• To protect the legitimate interests of the Company while safeguarding the fundamental rights and freedoms of data subjects.

d) Rights of Personal Data Owners

As personal data owners, you may submit your requests regarding your rights to us, and our Company will conclude these requests free of charge within 30 days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, a fee may be charged according to the tariff determined by the Personal Data Protection Board.

Within this scope, personal data owners have the following rights:

• To learn whether their personal data has been processed;
• To request information if their personal data has been processed;
• To learn the purpose of data processing and whether this data is being used in accordance with its purpose;
• To know the third parties to whom personal data has been transferred domestically or abroad;
• To request the correction of incomplete or incorrect personal data and to have the changes notified to third parties to whom the data has been transferred;
• To request the deletion or destruction of personal data if the reasons for processing no longer exist, even if it has been processed in compliance with the law and other relevant legislation, and to have this action notified to third parties to whom the data has been transferred;
• To object to a result arising solely from the analysis of data by automated systems that negatively affects the data owner;
• To request compensation for damages incurred due to the unlawful processing of personal data.

To exercise the above-mentioned rights, you must submit your request to our Company in writing, in accordance with KVKK and the Communiqué on the Principles and Procedures for the Request to Data Controllers, along with the necessary identification information and details regarding the right you wish to exercise.

You can submit your application by:

• Delivering it in person;
• Sending it via notary;
• Sending it via registered electronic mail (REM) to our Company’s registered electronic address ([email protected]) signed with a secure electronic signature as defined in the Electronic Signature Law No. 5070.

For the application form and more details, please visit our website.