Privacy Policy for processing and protection of personal data

1. introduction

The law on protection of personal data No. 6698 (“Law”), took effect on April 7, 2016. By the definition of the law your personal data with them for the protection of the principles responsible for the processing of data and these data have been given to the capacity of the conditions that people should adhere to. According to the law on personal data “identified or identifiable natural person”is any information on S. The processing of personal data “personal data record to be a part of any data recording system with automatic or non-automatic means be obtained by, be saved, storage, modification, including the transfer of personal data to be shared with third parties, and any operation that is performed on abroad” refers to. Sacit Altun ATL production company (“SetCrews”) SetCrews Platforms in terms of compliance with the law in order to provide the relevant law relating to the processing by adopting the principles of protection of personal data and the necessary administrative and technical measures. The relevant legal regulations in force on personal data protection as priority processing and will be implemented. If a discrepancy is found between the Policy and the legislation in force, is to find the area of application of the applicable legislation acknowledges that setcrews. On 26/07/2017 policy was enacted. In the case of the renewal of the policy or all of certain substances, we will update the effective date of the policy. The internet site policy setcrews (www.setcrews.com) publication for the owners of personal data are accessible. Changing conditions in order to ensure compliance with legislation and policy changes and updates are to be made and the respective internet sites to your personal data, it shall be submitted to the owners.

1. PROCESSING OF PERSONAL DATA

II.I. PRINCIPLES IN RELATION TO THE PROCESSING OF PERSONAL DATA

The Constitution of m. 20/III personal data, however, can be processed according to the law by specifying with the person's consent, or where personal data protection is guaranteed. SetCrews afforded to the owners of personal data the personal data specified in the relevant legislation in the right direction or in cases where the person's consent in accordance with the principles operates in accordance with the following principles: - honesty and the rule of law in accordance with the Processing - ensuring that personal data shall be accurate and where necessary up to date - Specific, Explicit and legitimate purposes, Processed - in connection with the purpose they are processed , Limited and restrained to be stipulated in the relevant legislation or for the purpose they are processed keeping until the time that is required

II.II. THE REQUIREMENTS AND OBJECTIVES OF THE PROCESSING OF PERSONAL DATA

Personal data in principle, however, is located in the express permission of the owner of personal data can be processed. 5 of the act. with personal data in Item 6. in the article in relation to the processing of personal data have been given to special conditions. The law, causing victimization or discrimination of persons when it is processed as a violation of the law, who may be at risk of personal data “personal data private qualified” is determined. 6 of the law. special personal data in a limited manner in the article were counted, and of these persons, race, ethnic origin, political opinion, philosophical belief, religious, sectarian or other beliefs, costume and clothing, Association or trade union membership, health, sexual life, criminal convictions and security measures, with data on genetic and biometric data. Under the policy, as specified above, the customer/user, etc. qualified special personal data, we do not. The express consent of the owner of the data related to a specific topic, based on informed and with freewill should be explained. One or more of the below mentioned conditions, in the presence of the personal data, the owner of Express you will be able to be processed without consent. In any case setcrews 4 of the law on personal data. in accordance with the general principles specified in the item, the following objectives and operates in accordance with the conditions. Related to the personal data of a general character; - the laws regarding the processing of your personal data publicly in the presence of setcrews related activities foreseen in - SetCrews of personal data to be transmitted in the processing of personal data by the owner or someone else's life or physical integrity protection is mandatory, and in this case also the owner of personal data to explain the invalidity consent to be due to actual or legal - your personal data processed by setcrews be directly related and necessary to the formation or performance of a contract - the processing of your personal data to fulfill the legal obligation, mandatory for setcrews of your personal data made publicly available by you, provided that your alenilestirme in a limited way in order committed by SetCrews - SetCrews your personal data processed by setcrews or your or third parties' it is mandatory for the use of the property or the protection of rights - the basic rights and freedoms to harm the legitimate interests of you SetCrews subject to processing personal data personal data by the activities in this context, it is mandatory to have made setcrews operates for the following purposes: - the process of Information Security Planning, Control and performance of the information technology infrastructure creation and management - employees access to user information to the planning and execution of Finance and/or accounting of their work, the pursuit of law tracking - business activities of efficiency/productivity and/or timeliness of the analysis planning implementation activities and/or execution, the planning and execution of the business activities of the members of the planning and execution of access to information – management of relations with members - business continuity of Operations Planning and/or execution, the planning and execution of corporate communication activities - the planning and execution of logistics activities Customer/user relationship management the process of planning and execution, Customer/user satisfaction planning of activities and/or execution - customer/user request and/or complaints tracking - users/customers for the identification of activities of the financial risks of making after-sales support service activities, planning and/or execution of the company's audit activities the planning and execution of the company's operations company procedures and/or relevant legislation in accordance with the planning and execution for the execution of operational activities - the provision of the safety of the company's operations - the company is offering the highest benefit from the products or services for obtaining the planning and execution of the relevant processes - Contract processes and/or the pursuit of legal claims - the execution of strategic planning activities - Production and/or operation of the process planning and execution, sales and marketing of products and services for the planning and execution of research activities Sunday's products and/or services and the marketing process the planning and execution of products and/or services and the planning and execution of the sales process - ensuring that the data are accurate and up to date - giving information to the public authorities, the legislation sourced from

III. THE TRANSFER OF PERSONAL DATA

III.I. GENERAL PRINCIPLES IN RELATION TO THE TRANSFER OF PERSONAL DATA

8 of the law. and 9. of personal data within the country and abroad to be transferred to the item required for have been given. SetCrews in accordance with the law for the purposes of data processing the personal data that you have obtained the owner of the data by taking appropriate security measures of personal data/ specific personal data to third parties we may transfer qualified. The personal data processing conditions specified in Section II SetCrews in this direction and in the presence of one of the terms specified below transfer to third parties will be able to: - have the express consent of the owner of personal data the - there is a regulation in the law clear on how your personal data is transferred if the owner or someone else's life or physical integrity of personal data and the protection of personal data is mandatory for the owner of consent due to the actual impossibility is incapable of explaining, or if the legal validity of consent recognized if the formation of the contract shall be directly related with the performance of a contract, or transfer of personal data to parties if it is required - it is mandatory to fulfil the legal obligation setcrews the transfer of personal data if personal data, the owner of personal data by is made publicly available - if the transfer of personal data required for the protection of the property right of use or if - the owner of the personal data is provided to prevent damage to fundamental rights and freedoms, the transfer of personal data is mandatory for the legitimate interests setcrews.

III.II. PERSONAL DATA BE TRANSFERRED ABROAD

SetCrews legitimate and in compliance with the law of the holder of the processing of personal data for the purposes of personal data abroad will be able to transfer the personal data in the following cases: - the express consent of the owner or in the presence of Data - data is the express consent of the owner of the absence, however, in the presence of one or more of the above-mentioned conditions; (i) there should be adequate protection in the country where the data is transmitted and (II) in the absence of adequate protection in the country where the data is transmitted, the SetCrews responsible for adequate protection in the foreign country in conjunction with the relevant data and commit in writing KVK Obtaining the permission of the board with recording

III.III. PERSONAL DATA IS TRANSFERRED TO THIRD PARTIES

8 SetCrews mentioned above and in accordance with the terms of the law. and 9. data managed in accordance with the policy of the owners of parties we may transfer the personal data specified below: - Business of the establishment of the partnership for the purpose of ensuring that the objectives are fulfilled anonymous partners (explicit consent is required if a transfer is taken as further data.) Supplier of outsourced services and provided as necessary to fulfill setcrews setcrews setcrews from commercial activities on a limited basis in order to ensure that is presented to suppliers - SetCrews the subsidiary that require the participation of commercial activities on a limited basis for ensuring the execution of associates - SetCrews design strategies related to commercial activities, in accordance with company procedures to inform the shareholders in accordance with the provisions of relevant legislation within their legal powers to demand for audit purposes on a limited basis for the purpose on a limited basis to the relevant public institutions and private legal entities

1. PROTECTION OF PERSONAL DATA

SetCrews, projected and committed to ensure the security of personal data in accordance with relevant legislation, which will be declared by the board of KVK other administrative and technical measures to ensure the protection and processing of personal data in accordance with the law, will. In this context, SetCrews, the lawful processing of personal data stored in a secure environment, with the risks of unauthorized access to any other unlawful access to prevent loss of data that occur incidental to the Prevention of intentionally causing harm to prevent deletion of data the cost of a reasonable degree of technological possibilities and application are also discussed in the technical and administrative measures. That is to say: - checked with the activities of the technical system of processing personal data established SetCrews - Received periodic reports technical measures in relation to the making of SetCrews that processes personal data on behalf of the employees of the law on protection of personal data and personal data processing information about the lawful and education - are determined on the basis of the business unit and legal compliance requirements for provision of awareness and in particular to the relevant business units the establishment and application of the rules created company policies and training to ensure the sustainability of these issues of control and regulation that governs the contract and the legal relationship between employees and SetCrews documentation, instructions and the law laid down in SetCrews exceptions to reprocess the personal data, non-disclosure and that obliges me to decline the records and employees ' awareness creation are determined on the basis of the business unit and legal compliance requirements in accordance with authorizations and access the limitation of access privileges to be done and accordingly, - the establishment and operation of hardware and software, including virus protection and firewall, - SetCrews due to technical requirements regarding the storage of personal data, personal data, including the parties that receives a service from the outside is transferred in accordance with the contracts concluded with the law of persons; the person of the personal data transferred and will take the necessary security measures to protect personal data in order to comply with our relationship that he would provide these measures in their own organizations the inclusion of provisions - technical security systems in compliance with the law for the establishment of hiding fields using backup programs, SetCrews of the law 12. personal data is processed in accordance to the legal ways in the shortest possible time if not others be obtained by the owner of this situation and the personal data relevant to the board conducts a system that allows to be notified of KVK. If deemed by the board of KVK in this situation shall be announced on the internet site of the European Council or by other means.

1. the elucidation of the owner of personal data, rights and INFORMING

The elucidation of the owner of V. I. personal data

Law 10. the item should be illuminated with the owners of personal data during the acquisition of personal data stated. SetCrews in this direction, the activities that are specified in the relevant legislation in accordance with the general principles of processing personal data personal data to other owners of their personal data during the Acquisition; (II) if the identity of the representative, (ii) personal data processed for any purpose, (iii) to whom and for what purpose can be transferred, (iv) the method of personal data collection and legal reason (v) in relation to the rights of the owner of personal data, informs.

1. II. RIGHTS OF HOLDERS OF PERSONAL DATA

11 of the law. were considered to be the owner of the rights of personal data in the item. That is to say, the owner of the data; - Personal data has been processed, if learning - personal data is processed, to claim knowledge of it, whether it is used according to their purpose of personal data processing purposes and learning - your personal data is transferred within or outside the country, the knowledge of third parties, - if it is missing or incorrectly processed personal data, ask to have them corrected and, in this context, the process the personal data transferred to third parties request to be notified, - is processed in accordance with the provisions of this law and other relevant laws, although in the case of the disappearance of the reasons requiring processing, and to the destruction or deletion of your personal data in this context, personal data transferred to third parties of the request to be notified of the process, the processed data exclusively through automated systems by analyzing one's self against, the result appeal - damages in case of damage due to unlawful processing of personal data has the right to ask for it to be fixed. However, The Law 28. according to the article, the above-mentioned rights may not be invoked in the following cases: - by making anonymous of personal data with official statistics, research, planning and may be processed for statistical purposes. - Personal data of National Defense, National Security, Public Safety, Public Order, economic security, privacy or personal rights not to violate or did not constitute a crime, provided that art, history, literature, or scientific purposes or for the freedom of expression may be under processed. - Personal data of the National defense, national security, public safety, public order, as well as the provision of economic security duties and powers granted by law or by the public institutions conducted preventive, protective, and may be processed within the scope of intelligence activities. - Personal data of the investigation, prosecution, trial or execution would be handled by judicial authorities or authorities in relation to the execution process. In accordance with the law 28/2; the owners of personal data in the following cases, except for the damage the right to demand the elimination of the above-mentioned rights advanced they can: - processing of personal data is necessary for prevention of the crime or the investigation of crime. - Personal data publicly available by the owner of the processing of personal data by himself. - The processing of personal data on the basis of the authority of the law in the nature of the participation of the competent public authorities and public institutions, professional organizations, checking or editing a disciplinary investigation or prosecution with the execution of the tasks is required. - The processing of personal data of budget, tax and financial matters of the state on economic and financial interests of the protection is required.

1. III. INFORM THE OWNERS OF PERSONAL DATA

The owners of personal data, 20 of the Constitution. according to the article, the personal data about themselves with knowledge about the above mentioned rights are considered to be among “requesting information” in the right direction by SetCrews requests for information that are made in accordance with the law are met. SetCrews personal data to the owners of the information you need in order to be made of the law of 13. In accordance to the required channels, internal functioning, administrative and technical arrangements engages in. In line with this rights to the owners of the above-mentioned personal data relating setcrews that responds to the demands of the case, to respond to a reasoned request, demand, according to the nature (positive/negative) reveals a response within thirty days free of charge. However, the process also requires a cost, if SetCrews, KVK will receive fees as determined by the board in the schedule. The above-mentioned rights of personal data owners will be achieved through one of the following methods:

- info@setcrews.com Mail the request to be sent to the address (in this case the applicant truly holds the references of the applicants from the channel that owns the rights for detecting whether the owner of the personal data; identify the ID and the registered owner's claim to determine whether this really is a reference to the contact with will be contacted via telephone. In this context, the applicant confirmed that the latest information with the person who made the request and in case of pairing the owner of the data, the application will be taken into consideration.)

- To follow a method prescribed by the personal data protection board.

On behalf of the owner of personal data of a third party will refer the application on behalf of the person by the owner in order to request data via a notary power of attorney there must be regulated private.

SetCrews the applicant to determine whether the relevant person may request information from the owner of personal data, to clarify the issues stated in the application, the owner can ask the questions on the application of personal data. 14 of the law of personal data owner. in accordance with the application is rejected, the response to the application must be insufficient or the failure to provide the answer at the time; the response is received from the date setcrews thirty, and in each case within sixty days from the date of application may apply to the board of KVK.

1. OWNER AND DATA CATEGORIZATION OF PERSONAL DATA

VI.I. THE OWNER OF THE DATA CATEGORIZATION

SetCrews committed within the owners of personal data has been categorized in the following manner. Categorization of data that is created within the scope of this policy the following are associated with the owners of the personal data owner. Data that fall outside this scope demands in line with the policy holders will be able to direct SetCrews.

Category Of Personal Data Of The Owner

Customer/user/the person who receives the product or service: SetCrews in any contractual relationship with, regardless of whether the products and services that our company has to offer, use or who have used real people

Potential Customer: demand or interest that may have the interest in using our products and services found or has been assessed in accordance with commercial practices and the rules of honesty, corporate real person

Third parties: This policy and personal data protection and processing Policy SetCrews Employees that are not covered by other real people

Partner, Shareholder, Officer, Employee: SetCrews is located in any business relationship in organizations where employees, shareholders and officials of these institutions, including real people

Supplier, Shareholder, Officer, Employee: setcrews of obtaining the product or service and is located in the business relationship in organizations where employees, shareholders and officials of these institutions, including real people

Partner Candidate: I predicted setcrews of real persons or legal entities to establish any business relationship with the employees, shareholders and the authorities are a real person with your visitors SetCrews 's campus that has entered the physical for various purposes are real people who visit our web sites or

VI.II. CATEGORIZATION OF PERSONAL DATA

Under this policy, the personal data that is processed by SetCrews have been categorized. The owner of the data mentioned above in the category of personal data, the categories of personal data of the owners of personal data have been associated with specified below.

Categorization Of Personal Data

Profile information: user name, such as profile-specific information.

Contact information: ID which belongs to a specific or identifiable natural person; partially or in a completely automatic way, or data recording system as part of the non-automatic are processed in a way; the phone number, address, e-mail address, fax number, such as IP address info

Location data: ID which belongs to a specific or identifiable natural person; partially or in a completely automatic way, or data recording system as part of a non-automated way are processed; personal data of the owner of the business units within the framework of operations that are executed by SetCrews, employees of our institutions while using collaborative tools setcrews setcrews that detects the position where the information is located

The customer which belongs to a natural person, identified or identifiable, transaction information, and data recording system is located within the records with the use of our products and services for the customer's instructions and necessary for use of products and services such as requests for information

Process Safety Information: ID belongs to a specific or identifiable natural person, and which is located within a data recording system; conducting our business activities in the technical, administrative, legal and commercial security of our processed to ensure the IP address (system login information), log in credentials, user wallet system in the context of movements (password reset, password, such as creating, such as personal data

Financial information: ID which belongs to a specific or identifiable natural person; partially or in a completely automatic way, or data recording system as part of a non-automated way are processed; personal data according to the established legal relationship with the owner of setcrews created indicating the type of the result is all kinds of financial information, personal data processed in relation to documents and records and bank account number, IBAN number, credit card information, financial profile, data assets, data such as income information

Which belongs to a natural person identified or identifiable legal transaction information, and data recording system located within; of our rights and legal detection, tracking, and fulfil statutory obligations to our debts with our company policies and compliance within the scope of processed personal data

Marketing information: the ID which belongs to a specific or identifiable natural person, data recording system and is located within the habits of the owner of personal data our products and services, according to the tastes and needs by customizing the results of processing this personal data is processed, and marketing in making reports and assessments created as a result of

Risk management information: the person associated with the company's commercial reputation and the purpose of protecting the collected data (e.g. Twitter and Facebook from our company top-level executives and shareholders to the detriment of sharing-related information collected in relation to it that is created with an evaluation report and action taken in relation to information about it

VII. THE RETENTION PERIOD OF PERSONAL DATA RELATING TO PRINCIPLES OF

SetCrews personal data and in accordance with legal obligations for the periods prescribed by the relevant legislation are stored. Throughout the duration of the personal data that should be kept for a while if it is held in legislation, the personal data of its data processing activities in connection with setcrews setcrews that require time to be processed according to commercial practice, with applications being processed until then deleted, destroyed or made anonymous. Over by the owners of personal data with the purpose of processing personal data deletion/to be " anonymized personal data which have been requested, by the end of the specified retention period has been reached setcrews relevant legislation and, if possible only serve as evidence in legal disputes, related to personal data or a right to be asserted, or can be stored for the purpose of the defense establishment. SetCrews personal data are stored in determining the period, the period of limitation prescribed in the relevant legislation is based on. For this purpose, the stored personal data only to the relevant persons by legal disputes that should be used in limited time is being accessed for any purpose other than the purpose is accessed. The personal data being deleted at the end of this period, being destroyed or made anonymous.

VIII. DELETION OF YOUR PERSONAL DATA, DESTRUCTION AND CONDITIONS TO BE ANONYMIZED

138 Of The Turkish Criminal Code. in the Article 7 of the law. in the article laid out processed in accordance with the provisions of the relevant law, although in the case of the disappearance of the reasons requiring processing, the personal data according to the decision of setcrews or upon the request of the owner of your personal data will be deleted, destroyed or made anonymous.