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Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or using personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. Any action performed on data, such as blocking, is considered processing of personal data.

Personal data is processed in accordance with the procedures and principles stipulated in the relevant legislation. ZRV GLOBAL, personal data; It is processed in accordance with general principles, in accordance with the law and the rules of honesty, accurate and up-to-date when necessary, for specific, clear and legitimate purposes, in a limited and proportionate manner, in connection with the purpose for which it is processed, provided that it is kept for the period foreseen in the relevant legislation or necessary for the purpose for which it is processed. The Company processes personal data with the explicit consent of the relevant person, except for the exceptions written in the Law. The Company may process personal data and sensitive personal data without explicit consent in exceptional cases stipulated in Articles 5 and 6 of the Law.

-Processing of Personal Data

Our company carries out its personal data processing activities in accordance with the data processing conditions set forth in Article 5 of the Law. The Company obtains the express consent of the relevant person, except in the following cases.

If it is clearly foreseen by law, the personal data of the person concerned may be processed in accordance with the law without obtaining the person's explicit consent, if it is clearly provided for by law. (For example, identification in accordance with the procedure determined in accordance with article 5 of the Regulation on Measures for the Prevention of Laundering Proceeds of Crime and Financing of Terrorism). It is necessary for the protection of the life or physical integrity of the person or someone else who is unable to express his/her consent due to actual impossibility or whose consent is not given legal validity. If the relevant person is unable to express his/her consent due to actual impossibility, or if it is necessary to process the personal data of the relevant person whose consent cannot be validated in order to protect his or her own life or physical integrity, personal data may be processed without obtaining the person's explicit consent (For example, if a person within our Company is suffering from illness). removing our visitor to the infirmary and recording his/her contact information). It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract. Provided that ZRV GLOBAL is directly related to the establishment or execution of a contract, if it is necessary to process personal data of the parties to the contract, personal data may be processed without the express consent of the relevant person (For example, obtaining billing information of a person receiving a service from our Company). It is mandatory for our company to fulfill its legal obligations. If processing is mandatory for ZRV GLOBAL to fulfill its legal obligations, personal data may be processed without obtaining the explicit consent of the relevant person (For example, answering questions asked by public institutions such as MASAK, BTK, BDDK and sending the requested documents).Personal data has been made public by the relevant person. If personal data has been made public by the relevant person, personal data may be processed without obtaining explicit consent (For example, contacting an official whose corporate e-mail address is published on the corporate website). Data processing is mandatory for the establishment, exercise or protection of a right. If data processing is mandatory for the establishment, exercise or protection of a right, personal data may be processed without obtaining the explicit consent of the relevant person. (For example, processing personal data in order to exercise our Company's legal rights in case of a possible dispute). It is mandatory to process data for the legitimate interests of ZRV GLOBAL. If it is necessary to process data for the legitimate interests of our Company, provided that it does not harm the fundamental rights and freedoms of the relevant person, personal data may be processed without the express consent of the relevant person (For example, to ensure the security of our Company campus, camera recording in a way that does not violate the fundamental rights and freedoms of people). One or more personal data processing conditions that make a personal data processing activity lawful may be applied simultaneously.

-Processing of Special Personal Data

Some personal data are considered sensitive in the eyes of the Law and special protection rules and special measures to be taken are envisaged. In particular, personal data that carries the risk of causing situations such as victimization and/or discrimination when processed unlawfully are designated as "special nature" in Article 6 of the Law. These data; Data regarding race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, appearance and clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data.

ZRV GLOBAL carries out the processing of personal data specified as special in accordance with the data processing conditions set forth in Article 6 of the Law. In the processing of special personal data, adequate measures determined by the Board are also taken.

As a rule, special personal data are not processed without the explicit consent of the relevant person. However, provided that adequate measures determined by the Board are taken, special personal data of the relevant person may be processed in the following cases, despite the lack of explicit consent.