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BARI GLOBAL PERSONAL DATA PROTECTION POLICY (No. 2021/01)

This policy sets out how BARİ GLOBAL MİMARLIK VE TİCARET ANONİMŞİRKETİ handles your personal information, including when and why it is collected, usedand disclosed and how it is kept secure, pursuant to 6698 numbered Law on Protection ofPersonal Data, enacted by the Republic of Turkey. This policy may change, so please checkthis page from time to time to ensure that you’re happy with any changes.

1. HOW AND WHAT PERSONAL INFORMATION WE COLLECT

We may collect and process the personal information you give us by entering information via our websites or our social media pages or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give us includes your name, contact details (e.g., phone number, email address, home address), enquiry details and your opinion of our services. We will also store personal information only if you share that information; for instance, by filling out a registration form, contact form, survey, or to execute the service contract between you and us. We will, store only the data we are allowed to keep based on consent given by you or in accordance with the applicable law.

In addition to above mentioned personal information, we store certain information about the browser and operating system you are using; the date and time of your visit; the status of interaction (e.g. whether you were able to access the website or received an error message); the usage of features on the website; any search phrases you entered; how often you visit individual websites; the names of files you access; the amount of data transferred; the Web page from which you accessed our website; and the Web page you visited after visiting our website, whether by clicking on links on our websites or entering a domain directly into the input field of the same tab (or window) of the browser in which you have our websites open. Likewise, we store your IP address and the name of your internet provider for seven days. This is for security reasons; in particular, to prevent and detect attacks on our websites or attempts at fraud.

We hereby inform you that you are neither legally nor contractually obligated to share your personal information. However, certain features of our website and services may depend on the sharing of personal information. If you do not provide your personal information in such cases, you may not be able to use those features or services, or they may be available with limited functionality.

We may process your individual details (e.g., name, address, e- mail address, telephone number, gender, family details, date and place of birth); your identification details (e.g., passport or identification card numbers, driver license numbers, tax identification numbers); your location information (e.g., your IP address, GPS location)

2. HOW WE USE YOUR PERSONAL INFORMATION

2.1 Where you have provided CONSENT: We may use and process your personal information where you have consented for us to do so for the following purposes:

2.2.You may withdraw your consent for us to use your information in any of these ways, at any time. Please see Withdrawing your consent in Section 8.4 for further details.

2.3 Where required to perform a CONTRACT with you: We may use and process your personal information where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including for the following purposes:

2.4 Where it is in allowed by the APPLICABLE LAW: We may use your personal information where the applicable law gives us the authority to do so.

2.5 Where required to comply with our LEGAL OBLIGATIONS: We will use your personal information to comply with our legal obligations including: (i) to assist the Financial Crimes Investigation Board, Ministry of Trade or any other public authority or criminal investigation body; (ii) to identify you when you contact us; (iii) prepare and file the paperwork and records we are legally obliged to hold pursuant to the Ministry of Trade secondary legislation, and (iv) to verify the accuracy of data that we hold about you.

2.6 Where there is a LEGITIMATE INTEREST: We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

3. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

We may transfer your personal data to the parties indicated below where your consent covers such transfer or where we rely on another legal ground for the collection and transfer of your personal data. The parties indicated below may be residing in the Republic of Turkey or any other country, but if a party is residing abroad, we may transfer your personal data only if that country has the prerequisite protection on personal data.

3.1 Group companies: We may share your information with other companies that we have a direct or indirect management or shareholding connection. They may use your personal information in the ways set out in “How we use your personal information” in Section 2, in connection with products and services that complement our own range of products.

3.2 Our suppliers and service providers: We may disclose your information to our third- party service providers, agents, subcontractors and other organizations for the purposes of providing services to us or directly to you on our behalf. Such third- parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us. When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

3.3 Authorized agents in our network: We may share your information with other companies within our authorized agents’ network. They may use your personal information in the ways set out in “How we use your personal information” in Section 2 or in connection with products and services that complement our own range of products and services.

3.4 Third- parties who provide products and services: We work closely with various third parties to bring you a range of products and services which are complimentary to ours. When you enquire about or purchase one or more of these products or services through us (e.g., via our websites), the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. These third- party product providers may share your information with us which we will use in accordance with this policy. In some cases, they will be acting as a controller of your information and therefore we advise you to read their privacy policy.

3.5 Other ways we may share your personal information: We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganization. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligations, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.

4. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary, and this duration does not exceed 10 years under normal circumstances, after the last occasion on which we have used your personal information in one of the ways specified in How we use your personal information in Section 2. The only exceptions to this are where: the law requires us to hold your personal information for a longer period, or delete it sooner; you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted in this section 5, or because we are required under the law (see further Erasing your personal information or restricting its processing in Section 5.5); and in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

YOUR RIGHTS

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, after we have received your request. You may exercise your rights by using the form attached at the end of this Policy.

5.1 Accessing and learning your personal information

You have the right to ask whether your personal data is processed by us and ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

5.2 Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.

5.3 Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information in Section 2, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

5.4 Objecting to our use of your personal information and automated decisions made about you

Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information in Section 2, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information; we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data. You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool. You may also contest a decision made about you based on automated processing by contacting the data protection department.

5.5 Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. You may also ask us to report the situation to the parties that we have transferred your personal data.

5.6 Learning to which local and international parties your personal data has been transferred.

5.7 Learning the purposes of the data processing and whether your personal data is being used pursuant to the stated purposes.

5.8. If you suffered a harm as a result of unlawful processing of your personal data, you may ask for compensation; and complain to the TR data protection regulator:

You have the right to complain to the www.kvkk.gov.tr if you are concerned about the way we have processed your personal information. However, 6698 numbered Law Article 28 carves out the instances in which you don’t have the right to exercise the abovementioned rights. We may reject your requests pursuant to any of those exceptions.

6. ADMINISTRATIVE AND SECURITY MEASURES

We apply certain administrative measures to protect and manage your personal data. Our Data Protection Officer overseas the issues concerning the personal data collected by us, and regularly reports the issues to the management.

We use technical and organizational security measures to protect the personal information supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information whilst in transit to our website and any transmission is at your own risk. Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

7. COOKIES / LINKS / SOCIAL PLUGINS

A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to "remember" your actions or preferences over time. Most Internet browsers support cookies; however, users can set their browsers to decline certain types of cookies or specific cookies. Further, users can delete cookies at any time. We use cookies to learn how you interact with our content and to improve your experience when visiting our website(s). For example, some cookies remember your language or preferences so that you do not have to repeatedly make these choices when you visit one of our websites. We also use cookies to help us with geolocation tracking in order to present you with the closest Shell station and office locations. Additionally, cookies allow us to serve you specific content, such as videos on our website(s). We may employ the learnings of your behavior on our website(s) to serve you with targeted advertisements on third-party website(s) in an effort to “re-market” our products and services to you. We use both first-party and third-party cookies on our website, as well as session cookies and persistent cookies. Same principles applies to the links and social plugins we use on our website.

8. CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. If you do not agree with any aspect of the updated policy, you must promptly notify us and cease using our services.

9. CONTACT US

To exercise your data protection rights, please contact us through the contact details below: Data Protection Officer, Bari Global Mimarlık ve Ticaret Anonim Şirketi, Ayazağa Mah. Mimar Sinan Sok. Seba Office Boulvard D Block No. 70, İstanbul, Turkey or email [email protected] You also have a right to complain to the www.kvkk.gov.tr which regulates the processing of personal data.

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