Personal Data Protection

DENGE YATIRIM HOLDİNG ANONİM ŞİRKETİ

INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA

We, DENGE YATIRIM HOLDİNG ANONİM ŞİRKETİ (“DENGE HOLDİNG” or the “Company”), in our capacity as data controller, process your personal data within the scope of Law No. 6698 on the Protection of Personal Data (“KVKK” or the “Law”) and the relevant legislation. At the same time, we make every effort to protect the data we process by taking the technical and administrative measures specified in the KVKK, the secondary legislation enacted pursuant to the KVKK, the binding decisions of the Personal Data Protection Board, and other applicable legislation.

Through this notice, we aim to provide you with detailed information about the processing, storage, and transfer of the personal data we process specifically in relation to your activities, namely:

- our Website Visitors,

- our Investors,

- our Supplier Representatives, and

- our Supplier Employees.

I. PERSONAL DATA PROCESSED, COLLECTION METHODS AND PROCESSING PURPOSES

A. WEBSITE VISITORS

Your personal data is processed by DENGE HOLDİNG when you visit and use the websites accessible at https://dengeholding.com.tr and owned by DENGE HOLDİNG (the “Website”).

1. METHOD OF COLLECTING YOUR PERSONAL DATA

DENGE HOLDİNG collects the personal data of our Website visitors through wholly or partially automated means, by means of:

➢ visiting the Website,

➢ cookies located on the Website,

2. PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data we obtain through the collection methods described above is set out in the table below:

The personal data listed in the relevant table is processed for the following purposes:

● To fulfill our obligation to retain traffic records, as expressly stipulated in Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed through Such Publications and the relevant legislation, so that our activities may be conducted in compliance with the law,

● To ensure more effective, fast, and easy use of the Website,

● To carry out the work necessary for you to benefit from our services and activities,

● To take all necessary technical and administrative measures within the scope of data security,

Your personal data is collected by DENGE HOLDİNG on the legal grounds specified in Article 5 of the KVKK, namely: processing of the personal data of the parties is necessary because it is directly related to the establishment or performance of the relevant contract; it is expressly stipulated by law; processing is mandatory for DENGE HOLDİNG to fulfill its legal obligations; and processing is mandatory for the legitimate interests of DENGE HOLDİNG, provided that it does not harm the fundamental rights and freedoms of the data subject.

B. INVESTORS

1. METHOD OF COLLECTING YOUR PERSONAL DATA

As data controller, we collect the personal data of our patients through wholly or partially automated means, or through non-automated means provided that they form part of a data recording system, by means of:

➢ Requests for information submitted to the Company by our investors via telephone, e-mail, or other means,

➢ Investor lists and attendance lists obtained from MKK before the general assembly,

➢ Security cameras located at various places within our workplaces,

2. PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data processed in relation to DENGE HOLDİNG’s patients, classified by data category, is set out in the table below:

The personal data of persons receiving products or services specified in the relevant table is processed for the following purposes:

● Conducting storage and archive activities,

● Conducting investor relations activities.

C. SUPPLIER REPRESENTATIVES

1. METHOD OF COLLECTING YOUR PERSONAL DATA

DENGE HOLDİNG collects the personal data of our Suppliers’ representatives through documents sent to the Company by e-mail, current account forms, a copy of the signature circular, a copy of the tax certificate, a copy of the registration in the Trade Registry Gazette, the contracts we have signed with you and the documents attached thereto, and security cameras located at various places within our hospitals.

2. PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data we obtain through the collection methods described above is set out in the table below:

The personal data listed in the relevant table is processed for the following purposes:

● Conducting financial and accounting operations,

● Ensuring physical premises security,

● Conducting storage and archive activities,

● Conducting processes relating to the establishment and performance of the contract.

D. SUPPLIER EMPLOYEES

1. METHOD OF COLLECTING YOUR PERSONAL DATA

DENGE HOLDİNG collects the personal data of our Suppliers’ employees through correspondence with supplier representatives and supplier employees, current account records, contracts and documents attached to the contracts, and security cameras located at various places within our hospitals.

2. PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data we obtain through the collection methods described above is set out in the table below:

The personal data listed in the relevant table is processed for the following purposes:

● Conducting financial/accounting operations,

● Ensuring physical premises security,

● Carrying out follow-up and confirmation procedures to ensure that the subject matter of the contract is duly performed.

II. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

Your personal data is collected by DENGE HOLDİNG on the legal grounds specified in Article 5 of the KVKK, namely: it is expressly stipulated by law; processing of personal data is mandatory for the Company to fulfill its legal obligations; processing of the personal data of the parties is necessary because it is directly related to the establishment or performance of the sales contract; processing is mandatory for the establishment, exercise, or protection of a right; and processing is mandatory for the legitimate interests of DENGE HOLDİNG, provided that it does not harm the fundamental rights and freedoms of the data subject.

III. PERSONS TO WHOM YOUR PERSONAL DATA IS TRANSFERRED AND
PURPOSE OF TRANSFER

Your personal data may be transferred:

1. To our Group Companies, from which we receive services, for the administration of the Company, the conduct of business, and the implementation of Company policies;

2. To financial advisors, lawyers, and other third parties from whom we receive consultancy services, so that we may conduct our business processes in compliance with the law and our other legitimate interests and exercise our right of defense in a possible judicial proceeding;

3. To regulatory and supervisory authorities, relevant official institutions such as courts and enforcement offices, and other public institutions or organizations authorized to request your personal data, provided that the request complies with the law and due process, for the purpose of fulfilling our legal obligations;

4. To your authorized attorneys and representatives, in order to fulfill your requests,

within the scope of the personal data processing conditions and purposes specified in Article 8 of the KVKK.

IV. PERSONAL DATA TRANSFERRED ABROAD

DENGE HOLDİNG does not transfer your personal data abroad.

V. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Regarding your personal data, you have the right to:

1) Learn whether your personal data is being processed,

2) Request information if your personal data has been processed,

3) Learn the purpose of processing your personal data and whether it is used in accordance with that purpose,

4) Know the third parties to whom your personal data is transferred domestically or abroad,

5) Request correction of your personal data if it has been processed incompletely or inaccurately,

6) Request deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK,

7) Request notification of the transactions carried out pursuant to subparagraphs (d) and (e) to the third parties to whom the personal data has been transferred,

8) Object to any result arising against you through the analysis of your processed data exclusively by automated systems,

9) Request compensation for damage if you suffer damage due to the unlawful processing of your personal data.

You may submit your requests within the scope of the above rights by using the Data Subject Application Form, in person or in writing through a notary public, or by using your registered electronic mail (KEP) address, secure electronic signature, mobile signature, or the e-mail address previously notified by you to the Company and registered in the Company’s system, in accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller”.

Your application will be answered in accordance with the relevant provisions stipulated in the KVKK, and DENGE HOLDİNG may request certain verifying information from you to confirm that the applicant is the correct person; such information will be requested solely to identify the actual data subject and to share the application results with the correct person.

VI. CONTACT INFORMATION

DENGE YATIRIM HOLDİNG ANONİM ŞİRKETİ

KEP Address :

Contact Link : https://dengeholding.com.tr

Address : Gürsel Neighborhood, İmrahor Avenue, Premier Campus Office Block No: 29A,
Interior Door No: 181, Kağıthane / Istanbul