Privacy Notice (KVKK)

PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA

“Talos Denizcilik ve Uluslararası Taşımacılık Anonim Şirketi”, pursuant to Article 10 of Personal Data Protection Law No. 6698 (“KVKK”), we would like to inform you about the processing of personal data, the transfer of your processed personal data, the methods and legal basis for collecting your personal data, and your other rights listed in Article 11 of the KVKK.

Within the scope of the purposes explained below, we may process, record, store, classify and update your personal data in accordance with the law and the rules of good faith, and disclose/transfer it to third parties where permitted by legislation and/or limited to the purpose for which it is processed.

DATA CONTROLLER AND REPRESENTATIVE Under the Law, the data controller is “Talos Denizcilik ve Uluslararası Taşımacılık Anonim Şirketi”, operating at “Koşuyolu Mah.İbrahim Ağa Zaviyesi Sok.Murtazaoğlu İş Merk.No:10/5 Kadıköy- İstanbul – Türkiye” (hereinafter referred to as “Talos”).

YOUR PERSONAL DATA PROCESSED Within the scope of your use of our company’s products and services, the following personal data is processed:

Your Identity Information (identity data by which we can identify you, such as your name, surname and Turkish ID number), Your Contact Information (your address, mobile phone number, e-mail address and other contact data), Your Financial Data (financial data such as your bank account number, IBAN, credit card information, payment information and billing information), Customer Transaction (such as order and request information and purchase history), Transaction Security (such as website browsing information, IP address, website login/logout information and password information), Other personal data you provide in person in connection with your requests, suggestions and complaints

PURPOSE OF PROCESSING PERSONAL DATA Your personal data is processed so that you can benefit from the services we offer as Talos, in accordance with the basic principles set out in the KVKK and related legislation, based on your explicit consent and/or the other cases provided for in Article 5/2 of the KVKK, primarily the legislation to which we are subject. Talos’s purposes for processing personal data are:

Your personal data will be processed within the conditions and purposes for processing personal data specified in Articles 5 and 6 of Law No. 6698, for the purposes of: fulfilling the requirements of the commercial activities carried out by our company, performing the service and enabling the relevant persons to benefit from the products and services offered by our company; carrying out the necessary work by the relevant business units of our company, conducting the related business processes and preparing reports; determining our company’s commercial and operational business strategies and suitable services; planning and carrying out customer-specific sales and marketing activities (for our guests and customers who have given commercial electronic message consent: analysing their preferences, interests and needs and providing guest/customer-specific promotions, opportunities and benefits); evaluating requests and complaints; ensuring that our company’s activities are carried out in accordance with company procedures or relevant legislation; carrying out work with our business partners in sectors with differing needs and managing reference relationships; fulfilling the information sharing, reporting and notification obligations prescribed by public institutions and all authorities; fulfilling information and document retention obligations arising from legislation; conducting our finance, communication, market research and purchasing operations; managing our legal processes; and providing you with better and more reliable service without interruption.

METHOD OF COLLECTING PERSONAL DATA AND LEGAL BASIS

Your personal data may be obtained by our company through different channels (in writing, verbally, by audio or video recording or in other physical or electronic media, through Talos’s head office or offices and other physical environments where you can contact business partners, the call centre, the web, websites and similar electronic transaction platforms, social media or other public media, or through other group companies or other persons and organisations with which they have agreements).

We process your personal data collected through the methods above on one or more of the following legal bases:

Your explicit consent (for advertising/promotion/marketing activities, commercial communication activities and domestic/international data transfer); the processing being required by the provisions of laws and regulations in force in the Republic of Türkiye (your data may be processed where relevant legislation makes data processing necessary and mandatory, in particular the Code of Obligations, the Commercial Code, the Consumer Law, Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed through Such Publications, and Law No. 6563 on the Regulation of Electronic Commerce); the processing of personal data of the parties to a contract being necessary, provided that it is directly related to the conclusion or performance of that contract; the processing being mandatory for the fulfilment of a legal obligation (this constitutes the legal basis for data processing purposes such as fulfilling lawful requests under secondary legislation and regulatory and supervisory activities, conducting and concluding alternative dispute resolution and litigation processes, and requests from courts); and the processing of your personal data being necessary for our legitimate interest, provided that it does not harm your fundamental rights and freedoms.

For detailed information, please see the “Personal Data Processing and Protection Policy”.

PARTIES TO WHOM PROCESSED PERSONAL DATA IS TRANSFERRED AND PURPOSE OF TRANSFER

Your personal data is processed by our company in accordance with the principles of being lawful and fair, accurate and, where necessary, up to date, processed for specific, explicit and legitimate purposes, relevant, limited and proportionate to the purposes for which it is processed, and retained for the period stipulated in the relevant legislation or required for the purpose for which it is processed.

In order to continue our company’s activities and business processes, your personal data may be transferred, within the conditions for processing personal data specified in Articles 8 and 9 of Law No. 6698 and the purposes stated above, to our business partners in Türkiye and/or abroad with whom we cooperate; to our company’s consultants or solution partners; to our suppliers providing logistics services and delivery companies; to consultancy firms from which we receive support in areas such as law, accounting, customs and tax; to legally authorised public institutions and private persons; and to our service providers in Türkiye and/or abroad that process personal data on behalf of our company and from which we receive support in areas such as storage, archiving and information technology support (servers, hosting, software, cloud computing, etc.).

RIGHTS OF THE DATA SUBJECT WHOSE PERSONAL DATA IS PROCESSED

We hereby inform you that, as a data subject, you have the following rights pursuant to Article 11 of the Law: to learn whether personal data is processed; to request information if personal data has been processed; to learn the purpose of processing personal data and whether it is used in accordance with that purpose; to know the third parties to whom personal data is transferred in Türkiye or abroad; to request the correction of personal data if it has been processed incompletely or incorrectly; to request the deletion or destruction of personal data; to request that the third parties to whom personal data has been transferred be notified of the correction, deletion or destruction; to object to an outcome to the person’s detriment arising from the analysis of the processed data exclusively through automated systems; and to claim compensation for damages if the person suffers loss due to the unlawful processing of personal data. Pursuant to Article 4 of Law No. 6698 on the Protection of Personal Data, the personal data we collect and process must be accurate and, where necessary, up to date. Therefore, if there is any change in your personal data, you can notify us of your current and accurate personal information using the methods set out below.

IF YOU WISH TO CONTACT US REGARDING YOUR REQUESTS For written requests, you may deliver a wet-signed copy of the “KVKK Application Form” available on our website (https://www.talos.com.tr/) in person together with a document proving your identity, or by proxy with a notarised power of attorney showing that you are authorised to apply regarding the rights listed under Article 11, or send it via a notary public to “Koşuyolu Mah.İbrahim Ağa Zaviyesi Sok. Murtazaoğlu İş Merk.No:10/5 Kadıköy- İstanbul – Türkiye”.

For electronic requests: You may sign the KVKK Application Form with an electronic or mobile signature holding a “secure electronic signature” certificate as defined in Electronic Signature Law No. 5070 and send it to our company’s Registered Electronic Mail (KEP) address, or send it to the e-mail address “[email protected]” using the e-mail address you previously notified to our company and which is registered in our systems.

(We may request additional verification (such as sending a message to your registered e-mail address or calling you) in order to determine whether the application belongs to you and to protect your rights. If the application is made by third parties on behalf of data subjects, the data subject must give the applicant a special power of attorney issued by a notary public.)

Your requests submitted to our company will be answered in writing or electronically as soon as possible and within thirty days at the latest, depending on the nature of your request.

TALOS DENİZCİLİK VE ULUSLARARASI TAŞIMACILIK ANONİM ŞİRKETİ Our Contact Details Address: Koşuyolu Mah.İbrahim Ağa Zaviyesi Sok. Murtazaoğlu İş Merk.No:10/5 Kadıköy- İstanbul – Türkiye Phone: +90 (216) 449 34 05 E-mail: [email protected]