Our Personal Data Protection Law Policy

İMECAR ELECTRONICS LTD. ŞTİ.
MEMBERSHIP AGREEMENT INFORMATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

1 - PROTECTION OF INFORMATION
İMECAR LTD. ŞTİ. As ("COMPANY"), the Personal Data Protection Law No. 6698 ("KVKK") published in the Official Gazette No. 29677 dated April 7, 2016, which aims to protect the fundamental rights and freedoms of individuals, especially the privacy of private life, in the processing of personal data. In accordance with the 10th article titled "Information Obligation" and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Information Obligation published in the Official Gazette dated 10 March 2018 and numbered 30356, we would like to inform you with this Information Text about your personal data processed by the COMPANY and listed below. . This information is about informing the COMPANY, which is the Data Controller, of the purposes of preserving, processing and sharing personal data with third parties, their legal reasons, the persons and organizations to which personal data may be transferred, the methods of collecting personal data and your rights and authorities within the scope of KVKK.

2 - WHAT IS PERSONAL DATA?
Personal data is defined in KVKK as any information regarding an identified or identifiable natural person. Accordingly, your information such as your name, surname, e-mail address and telephone number are called personal data.

3 -WHICH PERSONAL DATA DO WE COLLECT?

Personal Data Category	Description
Identity	Name-surname, T.R. Identity number, identity card and driver's license information,
Contact Information	Phone number (extension - mobile phone), address, e-mail address, postal code, sms
Location	Location information
Legal Procedure	Information in correspondence with judicial and administrative authorities, information in the case/enforcement file
Customer Transactions	Data such as call center records, member number, transaction number, support and request information, usage information, service type
Transaction Security	IP address information, password information, website access information, username and password information
Risk Management	Information processed to manage commercial, technical and administrative risks
Other	Vehicle information, vehicle license plate information, charging station usage date and time, amount of electricity used, instantaneous current drawn, charge rate of the vehicle battery, etc.

4 - WHAT IS THE METHOD AND LEGAL REASON FOR COLLECTING YOUR PERSONAL DATA?

Your personal data is collected through all kinds of verbal, written and electronic media. Your personal data within the scope of Article 5, paragraph 2 of KVKK No. 6698, "Provided that it is directly related to the establishment or execution of a contract, it is necessary to process the personal data of the parties to the contract", "Provided that it does not harm the fundamental rights and freedoms of the relevant person, the data controller has a legitimate It is collected based on the legal reasons "it is mandatory for the personal interest of the data controller" and "it is mandatory for the data controller to fulfill its legal obligation", "data processing is mandatory for the establishment, use or protection of a right" and is processed within the scope of these legal reasons. In this context, your personal data:

• - Your personal data listed in identity, contact, location and other categories. "Provided that it is directly related to the establishment or execution of a contract, it is necessary to process personal data of the parties to the contract",
• - Your data listed in the legal transaction, customer transactions and transaction security category is "obligatory for the legitimate interest of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person"

It is collected based on legal reasons and processed within the scope of these legal reasons.

5- FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

Your personal data is collected through all kinds of verbal, written and electronic media.
If you approve the İMEŞARJ Membership Agreement via İMECAR's website or mobile application, you will become a member of İMEŞARJ. Within the scope of the contract by İMEŞARJ; Services such as infrastructure services for the use of charging stations established to charge your electric vehicles and provision of static information about the stations will be provided. In this context; Providing charging services and ensuring that these activities are carried out in accordance with the relevant legislation,

• Within the scope of our activity, the provision of services in contracts and the quality of these servicesincreasing, carrying out the COMPANY's sales and after-sales support activities,
• Ensuring legal and commercial security,
• Regulation and compliance and management of legal processes,
• Maintaining relations with public institutions and other organizations,
• Execution and execution of occupational health and safety, customer relations and call center processes,
• Execution of support services and obligations, customer satisfaction and corporate communication activities,
• Planning and execution of corporate sustainability, corporate management, strategic planning and information security processes,
• Preparation of applications and continuity of existing ones,
• Conducting financial operations and monitoring financial matters,
• Responding to consumer complaints,
• Conducting lawsuits and enforcement proceedings to which our COMPANY is a party,
• Conducting consultancy, business partnership, purchasing, tender and sales transactions,

In case you have explicit consent, Identity Information (such as name, surname, date of birth, TR ID number, occupation information), Contact Information (such as internal phone number, mobile phone number, e-mail, address), Location (such as Location Information), Customer Transaction Information. (data such as member number, transaction number, support and request information, data such as usage service type), Location (such as Location Information), Marketing (behavior information and cookies on websites and mobile applications created to offer, use or promote products and services Your personal data regarding other (vehicle information, vehicle license plate information, date and time of charging station usage):

• Carrying out campaigns, sweepstakes and competitions,
• Increasing customer satisfaction,
• Measuring and improving brand perception,
• Carrying out market research and survey processes,
• Conducting segmentation and marketing analysis studies, presenting offers, gifts and promotions, performing analysis and profiling, making targeted promotions; Special celebrations, wish transmission, prizes, raffles and delivery of content that is liked, that you want to access again, and that you may be pleased to be reminded of,
• Customizing the products and services offered by the Company according to your likes, usage habits and needs and sending commercial electronic messages in this context,
• Promotion and marketing of personalized and/or personalized campaigns, products and services to all customers, communicating with them, and informing them about campaigns and discounts; Providing opportunities to benefit from membership, events and economic advantages and carrying out the necessary procedures for their use,
• Organizing events and trainings and identifying participants.
• Promotion of the products and services we provide with our business partners, suppliers, group companies and direct or indirect shareholders, as well as their own products and services.

It is processed for limited purposes. Your personal data is used and processed by the COMPANY in strict confidentiality, within the framework and under the control of KVKK, for the purpose of serving you. While processing your data, the COMPANY pays attention to the law and the rule of honesty, ensuring that the data is accurate, not used outside the scope of processing, processed for legitimate purposes, kept up to date and preserved for a reasonable period of time required for the targeted purpose.

6 -TO WHOM DO WE TRANSFER YOUR PERSONAL DATA AND FOR WHAT PURPOSES?

Your personal data, for the purposes stated above, to the extent permitted by the legislation and required by our business processes,

• To the Energy Market Regulatory Authority (EPDK) in order to ensure transparency within the scope of its regulatory and auditing powers in accordance with the Electricity Market Law and its secondary legislation, to resolve disputes and to use it as evidence in disputes that may arise,
• To public authorities, private law and public law legal entities, real persons, group companies, direct or indirect shareholders, if it is clearly provided for in the law,
• Provided that it is directly related to the establishment or execution of a contract, banks and financial institutions, insurance companies, individuals and organizations carrying out digitalization, information and technology businesses, natural persons including local administrations and infrastructure organizations, and to private law legal entities, our shareholders, suppliers, group companies and authorized public institutions,
• To our suppliers, business partners, group companies, direct or indirect shareholders, authorized private law and public law legal entities, including local administrations and infrastructure organizations, as it is mandatory for the fulfillment of our legal obligations.persons and real persons,
• To public authorities, authorized private law and public law legal entities and real persons for the establishment, use or protection of a right,
• The data controller is Imecar Ltd. within the scope of the legitimate interest of our company and the legislation regulating the provisions of the group company. Ltd. We transfer it from company to company.
• In case of your explicit consent, we transfer personal data to business partners, service providers and suppliers, limited to fulfilling the processing purposes based on explicit consent.

In order to fulfill the legal obligations arising from the legislation such as the current shareholding structure of the COMPANY, the new partnership structure in case it changes in the future, system use and tax regulations, name-surname, T.R. ID number, address, telephone number and e-mail address data Imecar Elektronik Ltd.Şti. are kept in their systems and processed for the period required by the above-mentioned policies and procedures and legal regulations. These data are processed within the framework of our policies and procedures determined in accordance with the Regulation on Deletion, Destruction or Anonymization of Personal Data, for the period required by the COMPANY's activities and legal regulations, and are deleted in cases where you no longer have a relationship with the COMPANY and there is no reasonable or legal requirement or compliance.

7 - WHAT ARE YOUR RIGHTS AS A DATA OWNER AS MENTIONED IN ARTICLE 11 OF KVKK?

In accordance with Article 11 of KVKK, your personal data;

• To find out whether it is processed or not,
• Requesting information if processed,
• To learn the purpose of processing and whether they are used for their intended purpose,
• Knowing the third parties to whom personal data is transferred domestically or abroad,
• Requesting correction of any incomplete or incorrect processing,
• To request the deletion or destruction of personal data in case the reasons requiring processing are eliminated, even though it has been processed in accordance with the provisions of KVKK and other relevant laws,
• Requesting notification of the transactions made in accordance with clauses (e) and (f) above to third parties to whom it has been transferred,
• To object to the emergence of a result against you by analyzing it exclusively through automatic systems,
• To request compensation for the damage in case you suffer damage due to illegal processing,

We hereby inform you that you have the rights.

8 - HOW CAN YOU USE YOUR RIGHTS REGARDING YOUR PERSONAL DATA THAT HAVE BEEN NOTIFIED TO US?

Your requests within the scope of Article 11 of the Law, which regulates the "rights of the relevant person", can be submitted to the COMPANY headquarters in writing, through the information shown in the table, in accordance with the "Communiqué on the Procedures and Principles of Application to the Data Controller", to the Registered E-mail Address ("KEP"). You can send it with your secure electronic signature or mobile signature, or to the COMPANY e-mail address* by using your e-mail address that has been previously notified to our company and registered in our system.
In your application, specified in the 2nd paragraph of Article 5 of the Communiqué on the Procedures and Principles of Application to the Data Controller ("Communiqué");

• Name, surname and signature if the application is written,
• T.R. for citizens of the Republic of Türkiye. identification number, nationality for foreigners, passport number or identification number, if any,
• Residence or workplace address subject to notification,
• Notification e-mail address, telephone and fax number, if any, and
• The subject of the request It is mandatory to be present. We would like to point out that you can send us your Relevant Person Application by filling out the "Relevant Person Application Form". Your application will be answered as soon as possible and within thirty (30) days at the latest, following the identity verification by our COMPANY.

* You can find information about the Data Controller Company below.

Data Controller	İMECAR ELEKTRONİK LTD. ŞTİ.
Address (Written Application)
Email Address

9 - CHANGES

The COMPANY reserves the right to make changes in its policies and procedures regarding personal data to ensure compliance with legislative changes.