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KÜÇÜKASYA MADENCILIK A.Ş.

DISCLOSURE REGARDING PROCESSING OF PERSONAL DATA

As Küçükasya Madencilik A.Ş. (“Company”), protecting the right to privacy, providing and maintaining information security, respecting ethical values, and, most importantly, protecting fundamental rights and freedoms are among our core principles. Accordingly, we process and protect all personal data belonging to all persons associated with the Company, including those who make use of our products and services, in compliance with the Law No. 6698 on Protection of Personal Data (“KVKK”).

Purposes of Personal Data Processing

In accordance with the KVKK, your personal data are processed as hard copy and/or with wet-ink signature or on electronic media using automatic or non-automatic means for the purposes of;

·         Providing/supplying the products and services which are provided/supplied by our Company or affiliates or subsidiaries with which our Company is associated directly or indirectly (“Çolakoğlu Group of Companies”) and carrying out related works,

·         In case you have given your explicit consent, contacting you for matters regarding the provided/supplied products and services, and ensuring the legal and commercial security of our Company, Çolakoğlu Group of Companies, and persons who have business relations with our Company (ensuring the physical security of and auditing Company premises),

·         Assessment processes for customers/suppliers/business partners (officials and employees) of our Company and Çolakoğlu Group of Companies,

·         Reputation investigation processes, event management, compliance process, auditing, financial affairs etc.,

·         Determining and implementing our Company's commercial and business strategies,

·         Ensuring the implementation of our Company's principles and policies,

·         Helping our business units carry out the works required for the utilization of the products and services provided/supplied by our Company or Çolakoğlu Group of Companies,

·         Customization of the products and services provided by our Company according to your tastes, usage habits, and needs, improving customer satisfaction, getting to know our customers and using this information in the customer circle analyses and in various marketing and advertising activities, and to this end conducting surveys through contractors on electronic and/or physical media,

·         Ensuring the legal and commercial security of our Company, Çolakoğlu Group of Companies, and persons who have business relations with our Company (ensuring the physical security of and auditing Company premises),

·         Assessment processes for customers/suppliers/business partners (officials or employees) of Çolakoğlu Group of Companies, reputation investigation processes, event management, compliance process, auditing, financial affairs etc.,

·         Determining and implementing our Company's commercial and business strategies,

·         Planning and executing information system processes,

·         Ensuring that data which are used in carrying out activities that have legal, technical, and administrative consequences are correct and up-to-date, and

·         Enforcing our Company's principles and policies, ensuring its legal and contractual responsibilities.

Transferring Your Personal Data

Çolakoğlu will be allowed to transfer your personal data to following relevant persons and organizations at home or abroad in compliance with KVKK and other related regulations and in accordance with the foregoing purposes:

·         Direct or indirect shareholders, affiliates and subsidiaries of our Company,

·         Persons and companies from whom our Company receives services and/or consultancy with the option to make a confidentiality agreement being in our Company's discretion,

·         Business partners, suppliers, and legally authorized public bodies or private persons.

The Method and Legal Reason of Collecting Personal Data

Your personal data are collected from our Company's various units, other group companies, our website, social media, third parties, and authorities, through any printed, oral, or electronic media.

Your personal data are collected, used, recorded, stored, and processed by our Company by giving explicit and comprehensible written notification to personal data owners, seeking their explicit consent if necessary, in compliance with law and in good faith, in line with the legitimate purposes explicitly stated above and in a limited manner, and in accordance with the principle of proportionality.

Your personal data are processed in line with the following legal purposes stated in the KVKK Article 5/2 and shared with persons and organizations specified above:

·         It is explicitly provided for by the laws.

·         It is mandatory for the protection of life or physical integrity of the data subject or of any other person who is physically incapable of giving their consent or whose consent is not deemed legally valid.

·         Processing personal data belonging to the parties to a contract is necessary, provided that it is directly related to the conclusion or execution of that contract.

·         It is mandatory for the data controller to be able to perform their legal obligations.

·         The data concerned have been made available to the public by the data subjects themselves.

·         Data processing is mandatory for the establishment, exercise, or protection of any right.

·         Data processing is mandatory for the legitimate interests of the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.

Personal Data Retention Period

The retention period for your personal data is determined according to the obligations set out in regulations. Besides regulations, purposes of processing personal data are also taken into consideration when the retention period is determined. In case purpose of processing data is no longer valid, data will be erased, destroyed, or anonymized, provided that there is no other legal reason or basis for data to be retained.

If the purpose of processing your personal data is no longer valid and the retention period set by the relevant legislation and our Company ended, data could be retained only as an evidence to be used for potential legal conflicts or only for the purposes of claiming relevant right in connection with the personal data or establishing the defense. For establishing the retention periods in these circumstances, statutes of limitations related to the claiming the said right and the previous cases where our Company faced similar claims despite the limitations ended are taken into consideration. In this case, retained personal data are not accessed for any other reason and only relevant personal data are accessed when their usage is necessary for the said legal conflict. Again, personal data will be erased, destroyed, or anonymized following the end of the said period.

Rights of Data Subject under the KVKK Article 11

As per the KVKK Article 11, you are entitled to apply to our Company and:

·         To learn whether your personal data are processed or not,

·         In case your personal data are processed, to request information,

·         To learn the purpose of processing your data and whether they are used for the intended purposes or not,

·         To learn the third parties at home or abroad to whom your personal data are transferred,

·         If your personal data are processed incompletely or inaccurately, to request correction, and, accordingly, to request that third parties to whom your personal data were transferred be notified of such action,

·         Even if your personal data are processed in compliance with the KVKK and other applicable regulations, if the reasons requiring data processing are no longer valid, to request erasure or destruction of your personal data, and, accordingly, to request that the third parties to whom your personal data were transferred be notified of such action,

·         To raise objections against the processing of your personal data exclusively by automatic means which leads to an unfavorable consequence for you, and

·         To request compensation for the damage arising from the unlawful processing of your personal data.

To exercise your rights stated above, you could apply to our Company with your personally identifiable information and a statement specifying which rights among the rights stated in the KVKK Article 11 you intend to exercise by completing the application form on www.asiaminormining.com; delivering in person a signed copy of the application form to Rüzgarlıbahçe Mahallesi Kavak Sokak No:16 Kat:2 Kavacık, Beykoz, İstanbul and producing documents confirming your identity; sending the application form through public notary or other methods specified in the KVKK; or sending the form to the email address This email address is being protected from spambots. You need JavaScript enabled to view it.This email address is being protected from spambots. You need JavaScript enabled to view it.with secure electronic signature. To enable us to respond efficiently to your claims, it is recommended that you present the content of your claim explicitly, comprehensibly, and, if possible, specifying the date.

For further information on your Personal Data and for the application form please visit www.asiaminormining.com

Data Controller:

Küçükasya Madencilik A.Ş.

İstanbul Ticaret Sicil Müdürlüğü – 745298 / 0

Rüzgarlıbahçe Mahallesi Kavak Sokak No:16 Kat:2 Kavacık, Beykoz, İstanbul

www.asiaminormining.com