THE PROCESSING AND PROTECTION OF PERSONAL DATA

clarıfıcatıon text for personal data processıng and protectıon

As TOYO PRINTING INKS INDUSTRY AND TRADE INC. (“The Company”) and TOYOINK GROUP, we show utmost care in the security of your personal data that you submit to us either when using our web site or by filling any application form or via other means. Therefore, as the Company, we attach great importance to the processing and storage of all kinds of personal data concerning the persons related to the Company, including but not limited the persons using our products and services,

in accordance with the Constitution of the Republic of Turkey, to the conventions to which our country is a party and to the Law on the Protection of Personal Data No: 6698 (“LPPD”). Fully aware of our responsibility hereof and as the “Data Supervisor” as duly described in LPPD, we would like to clarify the matters below, providing you an insight on: e.g. for what purposes your personal data can be processed, the method to be used to collect your personal data, legal ground, to whom the data can

be transferred, etc. collectıon and processıng of personal data, purposes of processıng, to whom the processed data are transferred, and legal grounds collectıon and processıng of personal data, purposes of processıng

Your personal data is processed through various channels, pursuant to the legislation and the Company’s policies, so that our operations can be carried out by our Company, our products and services can be introduced within the defined legal framework and thus our Company can fulfil the obligations arising from the convention and the LPPD, duly and properly. Your personal data can be processed and transferred for the purposes specified in the clarification text, as part of the conditions of personal data, provided for in the Articles 5 and 6 of LPPD, in accordance with the principles set out in the LPPD.

• Execution of internal operations of the company,
• Execution of Processes and Operations That Are Related With Customer,
• Execution of Marketing Operations,
• Realization of Activities with legal, technical and administrative consequences
• Execution of Corporate Communication Operations

Within the scope of above purposes, data will be processed for procurement of such purposes namely carrying out the necessary work through our business units in order for our company to provide the best service on behalf of all brands; planning and/or execution of the activities required for recommending, promoting, marketing, selling, after-sales of products and services offered by our Company and its business partners, solution partners, suppliers, subsidiaries and global and local companies directly or indirectly by customizing them according to their tastes, usage habits and need; making efforts so as to recommend and promote the products and services offered by the Company to the persons concerned by customizing them according to their tastes, usage habits and needs; giving information about the contents of such products and services; being able to send commercial electronic messages by obtaining approval in accordance with legal regulations; carrying out the necessary works by our relevant business units for the realization of activities and developing the related business strategies and carrying out the business processes; technical management of our Company's websites, follow-up of customers and complaints, product surveys and follow-up of questions you submit to our Company, administrative operations for communication conducted by our Company, conducting reputation research processes, compliance with ethical values and the legal purposes, including the purposes set out in the Policy and the conduct of our Company’s legal work and procedures; and executing business-specific commercial activities and/or enforcement of our Company; legal, technical and commercial safety of our Company and its business associates with the Company.

Personal data of data owners who do not benefit from the products and services offered by our company but who may benefit from it in the future will also be processed for the purpose of monitoring contacts with customers, opening potential customer records, evaluating employee performance and planning product and service sales processes.

You can access the Policy with detailed information about the purposes for which your personal data is processed by our Company via web address of www.toyoink.com.tr and our Company.

to whom and for what purpose the processed personal data can be transferred

Once collected, your personal data can be transferred by our Company in accordance with the basic principles stipulated in the LPPD and within the scope of the conditions the processing of personal data as set out in the Articles 8 and 9 of LPPD, to our business partners, suppliers, Company’s officials, shareholders, employees, auditing corporations, sub-contractors, executive assistants, legally-authorized public institutions and private persons in line with the following purposes:

• Execution of internal operations of the company,
• Execution of Processes and Operations That Are Related With Customer,
• Execution of Marketing Operations,
• Realization of Activities with legal, technical and administrative consequences.
• Execution of Corporate Communication Operations legal grounds for collectıon of your personal data

Your personal data is collected, used, recorded, stored and processed within the framework of the principle of proportionality, in connection with and limited to the legitimate purpose expressed above, in accordance with LPPD and the rules of honesty, by giving written information to the owners of personal data by our company in a clear and understandable manner, with their express consent if necessary. Your personal data in this context are collected by Company via channels (methods) namely e-mail telephone our web site, social media, our mobile internet site and request/complaint platforms and/or product and/or thanks to sales, submission and/or follow up products and/or services, evaluation of requests/complaints as well as by receiving campaign/competition and promotion participation requests. Any written or oral data collected within this scope can be processed and transferred within the scope of Purposes stated in this Clarification Text and personal data processing conditions stated in Articles 5 and 6 of the LPPD.

Protectıon of privacy of Children

Our Company takes it very seriously the protection of the privacy of children. We enforce all applicable legislation in the jurisdictions, the sites of which are given below. We do not collect the Personal Data of the persons under sixteen (16) legally or the persons under thirteen (13) in cases permitted by the applicable law. Before submitting to the Site any Personal Data of the persons under sixteen (16) legally or the persons under thirteen (13) in cases permitted by the applicable law, the consent of the parents/guardians of such persons is required. In the event that we find out during the collection that the user is under such age, we do not use the Personal Data of such person without obtaining the consent of his/her the parent/guardian. However, the child is not allowed to join certain activities without such consent, either. A parent/guardian can contact us by using one of the options listed in the section “Managing Your Personal Data” and review, cancel, or change the collection and use of the Personal Data of his/her child or decline the collection and use of further data (please indicate the name, address and e-mail address of the child).

the rıghts of personal data owner as set out ın artıcle no 11 of lpdd

Article No 11 of LPPD No. 6698 sets out the rights you are entitled to.

Within this scope, personal data owners shall have the right to;

• Learning whether your personal data has been processed,

• Requesting information, if personal data has been processed,

• Learning about the purpose of processing his/her personal data and whether such data is used in accordance with the intended purposes,

• Getting to know about the third persons, to whom the personal data is conveyed, at home or abroad,

• Requesting any incompletely or inaccurately processed data to be corrected and such corrected data to be communicated to the third parties to whom the personal data is conveyed,

• Requesting any personal data to be deleted or removed and such transaction to be communicated to the third parties to whom the personal data is conveyed in case the reasons requiring the processing of personal data disappear although such data was already processed in accordance with the provisions of LPPD and other relevant legislation,

• Raising an objection to any consequence encountered by the person himself/herself, for the reason that the processed data is analysed exclusively by means of automated systems,

• Requesting the compensation of any damage incurred by himself/herself, because the personal data was processed against the law.

Whenever you need to exercise any of the above mentioned rights you are entitled, you can submit your request including your remarks about the right you request to use, among the rights mentioned in the article numbered 11 of LPPD, along with the documents as an evidence of your personal ID details, by way of filling out the form available at www.toyoink.com.trand sending a signed copy of the form (with wet-ink signature) to Organize Sanayi Bolgesi 5.Kisim Hasan Turek Bulvari No: 6 45030 Yunus Emre/MANISA along with the documents as an evidence of your personal ID details; or submit your request by the other methods specified in LPPD or you can send the related form to dyomatbaa@hs01.kep.tr, signed with secure electronic signature

If you submit your claims regarding your rights as owners of personal data to our Company by the methods set out above, depending on the nature of the request, our company will finalize the request free of charge within 30 (thirty) days at the latest. However, if a fee is stipulated by the Personal Data Protection Board, the tariff set by our Company will be charged.