At Özbekoğlu Import Export Construction Contracting and Engineering Ltd. Co. (Mentioned as Özbekoğlu” or the “Company”), we place the utmost importance on the protection and confidentiality of your personal data.

In line with this commitment, and in accordance with the Law on the Protection of Personal Data No. 6698 (“the Law”) as well as all relevant national and international legislation currently in force, our Company has prepared and implemented this Privacy Policy.

1. Purpose of the Personal Data Protection and Processing Policy

The primary purpose of this Policy is to provide information regarding the processing and protection of personal data in accordance with the objectives of the Law on the Protection of Personal Data No. 6698 (“the Law”), and to inform individuals whose personal data is processed by our Company.

The protection of personal data constitutes a fundamental policy of the Company.

2. Scope and Amendments of the Personal Data Protection and Processing Policy

This Policy has been prepared by the Company in accordance with the Law. The general and special categories of personal data (hereinafter referred to as “personal data”), obtained with your consent or on other lawful grounds as specified in the Law, are processed by the Company for purposes such as ensuring corporate security, delivering the services we offer in a complete, timely, and accurate manner, enhancing our quality, conducting our commercial activities, and fulfilling our legal obligations.

This Policy applies to all personal data belonging to natural persons that are obtained through automated or non-automated means, including but not limited to the shareholders, representatives, employees of the Company’s shareholders and business partners; the Company’s own employees, employee candidates, and interns; shareholders, representatives, and employees of our customers; visitors; and any third parties with whom the Company has a relationship for any reason.

Özbekoğlu reserves the right to amend this Policy, provided that such amendments comply with the Law and are aimed at ensuring better protection of personal data.

3.Rules and Principles Regarding the Processing of Personal Data

The Company adheres to the following rules in relation to the processing of personal data:

a) Compliance with the Law and Principles of Fairness: Özbekoğlu inquires into the source of the data it collects or receives from other parties and places great importance on ensuring that such data is obtained lawfully and in accordance with the principles of fairness.

b) Being Accurate and Up to Date When Necessary: The Company takes care to ensure that all data it holds is accurate and does not contain misleading or incorrect information. It places importance on updating personal data when notified of any changes.

c) Processing for Specific, Explicit, and Legitimate Purposes: The Company processes data solely for purposes related to its operations and limited to the objectives outlined in the Law.

d) Being Relevant, Limited, and Proportionate to the Purpose for which They Are Processed: Data is used only to the extent necessary and relevant to the specified purpose.

e) Retention for the Period Prescribed by Relevant Legislation or as Required for the Purpose of Processing: Özbekoğlu retains personal data for the period specified in the applicable legal regulations or, if such a period is not defined, for the duration necessary as determined in accordance with its operational requirements. Upon the expiration of this period, personal data is destroyed in accordance with the Company’s data destruction policy.

Our Principles Regarding Personal Data Are as Follows:
Transparency
This Policy has been prepared to ensure that you are properly informed both while we fulfill our legal obligations and while we process your personal data to provide better services. Detailed explanations regarding which personal data is processed and for what purposes can be found under the sections titled “What Personal Data Do We Process?” and “Purposes of Data Processing.”

Data Minimization Principle / Principle of Frugality
According to our principle known as data minimization or the principle of frugality, only the data that is strictly necessary is processed by Özbekoğlu. For this reason, the types of data collected are determined according to the intended purpose. Data that is not required is not collected. Any surplus or unnecessary information is not processed and is either deleted or anonymized.

Deletion of Personal Data
Once the legally required retention periods expire, judicial processes are completed, or other relevant obligations no longer apply, such personal data is deleted, destroyed, or anonymized by the Company, either automatically or upon request by the data subject.

Accuracy and Data Currency
As a general rule, the data held by Özbekoğlu is processed based on the declarations of the individuals concerned, and exactly as declared. Özbekoğlu is neither legally obligated nor operationally required to verify the accuracy of the data provided by customers or those who interact with us. The declared data is accepted as accurate. Nevertheless, the principle of accuracy and data currency is adopted by Özbekoğlu. The Company updates the personal data it processes based on official documents received or upon request by the data subject.

4. How Do We Collect Your Personal Data?

Personal data is collected by Özbekoğlu through various means, including verbal, written, and electronic channels, as well as other methods, in order to fulfill the purposes outlined in this Policy or within the scope of legal rights and obligations. These data are then processed by Özbekoğlu in accordance with applicable laws and this Policy.

5. What Personal Data Do We Process?

The personal data collected by us may vary depending on the nature of your legal relationship with the Company. Personal data collected through all channels, including digital platforms, is categorized as follows:

Identity information
Contact information
Personnel information, including information on family members and relatives obtained within this context
Customer transaction information
Transaction security information
Risk management information
Financial information
Professional experience information (may be requested from employees and employee candidates)
Physical location security information
Legal transaction and compliance information
Health information (collected in cases stipulated by the law)
Criminal conviction and security measures information (collected in cases stipulated by the law)
Military service information (collected from employees and employee candidates during job applications)
Request/complaint management information (information collected in connection with requests and complaints submitted to the Company)
Visual and audio data

6. Purposes of Data Processing

The collection and processing of personal data by Özbekoğlu shall be carried out in accordance with the purposes specified in this Policy. These purposes include, but are not limited to:
Planning, execution, and management of recruitment processes,
Fulfillment of mandatory obligations arising from relevant laws, regulations, purchase orders, or contracts,
Ensuring the legal, operational, and physical security of our Company, its shareholders, and other business partners,
Ensuring data security,
Communicating with data subjects who submit requests and complaints, and managing the complaint resolution process,
Planning, executing, and improving processes involving suppliers,
Carrying out and monitoring financial reporting and risk management procedures,
Providing information to authorized institutions and organizations,
Creating and tracking visitor records.

7. Data of Customers, Prospective Customers, and Business & Solution Partners

Collection and Processing of Data for Contractual Relationships

If a contractual relationship has been established with our customers, prospective customers, or suppliers, the personal data collected may be used without obtaining their explicit consent. However, such use shall be strictly limited to the purposes of fulfilling the objectives of the contract.
Business and Solution Partner Data
Özbekoğlu is committed to acting in compliance with the law when sharing data with its business and solution partners. Personal data is shared with such partners only to the extent required by the service being provided, and always under a data confidentiality agreement. These partners are strictly required to implement appropriate data security measures.

Data Processing Based on Legal Obligations or Explicit Legal Provisions
Personal data may be processed without obtaining additional consent if such processing is explicitly stipulated in the relevant legislation or is necessary to fulfill a legal obligation defined by law. The type and scope of such data processing activities must be necessary for the lawful purpose and must comply with the relevant legal provisions.

8. Employee Data

Processing of Data for Employment Purposes

The personal data of our employees may be processed without obtaining their explicit consent, to the extent necessary for the employment relationship and the performance of their duties. However, Özbekoğlu ensures the confidentiality and protection of all employee-related personal data.

Processing Based on Legal Obligations
Özbekoğlu may process personal data of its employees without obtaining additional consent when such processing is explicitly required by the relevant legislation or necessary to fulfill a legal obligation as defined by law. This type of processing is strictly limited to obligations arising directly from the law.

Processing for the Benefit of Employees
Özbekoğlu may process personal data without consent for activities that benefit its employees. Additionally, personal data may also be processed in cases of disputes arising from the employment relationship.

Processing of Special Categories of Personal Data
Under the Law, the following are considered special categories of personal data: data relating to an individual's race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations or trade unions, health, sexual life, criminal convictions, and security measures, as well as biometric and genetic data.

Special category personal data may only be processed without the individual's explicit consent in circumstances explicitly permitted by law and only to the extent relevant and limited to those circumstances. Any special category data collected from employees for the purpose of providing insurance and health services is used solely for that specific purpose.

Telecommunications, Internet, and Equipment Usage
Any equipment, computers, telephones, email accounts, and other applications assigned to employees within the Company are provided strictly for business purposes. Employees may not use any of these tools for personal use or private communication. The Company reserves the right to monitor and inspect all data on such devices.

Upon commencement of employment, the employee agrees and undertakes not to store any personal or unrelated data or information on the Company’s assigned computers, phones, or other tools.

9. Transfer of Personal Data Within and Outside the Country

Personal data may be shared by Özbekoğlu with its business and solution partners for the purpose of providing services. In accordance with the conditions specified in the Law and those established by the Data Protection Authority, Özbekoğlu is authorized to transfer personal data both within the country and abroad, provided such transfers comply with the legal requirements outlined in the Law.

10. In accordance with the Disclosure Statement and Application Form publicly available on Özbekoğlu’s official website, individuals whose personal data is processed have the following rights:

a) To learn whether their personal data is being processed and, if so, to request information regarding such processing,
c) To learn the purpose of personal data processing and whether it is being used in accordance with that purpose,
ç) To know the third parties to whom personal data is transferred domestically or abroad,
d) To request the correction of personal data if it is incomplete or inaccurately processed,
e) To request the deletion or destruction of personal data under the conditions set forth in Article 7 of the Law,
f) To request that the transactions carried out pursuant to subparagraphs (d) and (e) be notified to third parties to whom the data has been transferred,
g) To object to a result that is detrimental to the data subject and arises from the analysis of personal data exclusively through automated systems,
ğ) To request compensation if the data subject suffers damage due to unlawful processing of personal data.

However, individuals have no rights with respect to anonymized data within the Company. Özbekoğlu may share personal data with authorized institutions and organizations in compliance with judicial duties or when required by the exercise of legal authority by a government entity, as part of business or contractual obligations.

To exercise the above-mentioned rights, data subjects may submit a request using the Application Form made available by the Company on its official website at www.ozb.com.tr. Applications must be submitted in accordance with the procedures and principles specified on the website.

Your requests will be responded to as promptly as possible, and no later than 30 days following receipt by the Company, depending on the nature of your request. Only the part of the request that concerns the applicant will be addressed; applications made on behalf of a spouse, relative, or friend will not be accepted. Özbekoğlu reserves the right to request additional relevant information or documentation from the applicant.

11. Data and Transaction Security

Your personal data is protected by Özbekoğlu in accordance with the conditions and principles set forth in the Law. The Company takes all necessary technical and administrative measures to ensure an appropriate level of security to prevent the unlawful processing and unauthorized access of personal data, and to ensure the safe storage of such data. Within this scope, relevant audits are conducted regularly.

In the event that personal data is obtained by unauthorized parties through illegal means, the Company will act in compliance with the procedures specified in the Law.

12. Principle of Confidentiality

All data held by Özbekoğlu—whether pertaining to employees or other individuals—is considered confidential. No one may use, copy, reproduce, transfer to others, or utilize such data for any purpose other than legitimate business purposes, unless it is permitted by contract or by law.

13. Contact

For any questions or requests regarding this Policy, please first refer to the explanations provided on our official website at www.ozb.com.tr  After reviewing the information, you may print, complete, and sign the Application Form available on the website. Once completed, please submit the form to our Company using one of the methods and formats specified within the Application Form.