Protection Of Personal Data

INFORMATION NOTICE ON THE PROTECTION OF PERSONAL DATA

In accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), as ŞİMŞEK MAKİNA TAKIM (SMOXH CUTTING TOOLS), we place great importance on the lawful processing and protection of your personal data. In this context, as the data controller, we process your personal data within the framework outlined below.

1. Purposes of Processing Personal Data

Your collected personal data is processed for the following purposes:

• Managing customer and supplier relationships,
• Conducting sales and after-sales service processes,
• Providing technical support and maintenance-repair services,
• Managing procurement and logistics processes for goods/services,
• Carrying out financial and accounting operations,
• Improving internal company operations and business processes,
• Maintaining communication activities,
• Fulfilling legal obligations.

2. Categories of Processed Personal Data

Depending on the purpose of processing, your personal data may be collected under the following categories:

• Identity information: Name, surname, identification number,
• Contact information: Phone number, email address, physical address,
• Customer transaction information: Purchase history, order and quotation details,
• Financial information: Invoice, bank account details, payment information,
• Information specific to job applicants: CV, references, educational background.

3. Method and Legal Basis for Collecting Personal Data

Your personal data is collected verbally, in writing, or electronically, either directly from you or through our business partners and digital platforms. The processing of your data is carried out based on the legal grounds specified in Articles 5 and 6 of the KVKK, which include:

• Being directly related to the establishment or performance of a contract,
• Being necessary for our company to fulfill its legal obligations,
• Being required for the legitimate interests of our company, provided that it does not violate your fundamental rights and freedoms,
• The presence of your explicit consent (where necessary).

4. Transfer of Personal Data

Your personal data may be transferred—limited to the purposes stated above—to the following parties, in accordance with Articles 8 and 9 of the KVKK:

• Consultancy firms such as financial advisors and law offices,
• Logistics and courier service providers,
• Our suppliers and business partners,
• Authorized public institutions and organizations,
• Other third parties as required by legal obligations.

5. Your Rights Under the KVKK

Pursuant to Article 11 of the Law on the Protection of Personal Data (KVKK), as the data subject, you have the following rights:

• To learn whether your personal data is being processed,
• If processed, to request information regarding such processing,
• To learn the purpose of the processing and whether the data is being used in accordance with that purpose,
• To learn the third parties to whom the data is transferred domestically or abroad,
• To request the correction of any incomplete or inaccurate data,
• To request the deletion or destruction of your data within the scope of Article 7 of the KVKK,
• To request notification of the correction, deletion, or destruction to third parties to whom the data has been transferred,
• To object to any outcome against you that arises from the analysis of your data solely through automated systems,
• To claim compensation for damages if you suffer harm due to unlawful processing of your data.

PERSONAL DATA PROTECTION AND PROCESSING POLICY

1. PURPOSE

The purpose of this policy is to ensure that personal data obtained during production, sales, service, and procurement processes by ŞİMŞEK MAKİNA TAKIM (SMOXH CUTTING TOOLS) is processed and protected in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK") and relevant legal regulations.

2. SCOPE

This policy covers personal data belonging to the following individuals:

• Customers and potential customers
• Dealers and authorized service providers
• Suppliers
• Employees and job candidates
• Trade fair participants, visitors, and business partners

3. DEFINITIONS

Below are definitions of the terms used within the scope of KVKK:

• Personal Data: Any information relating to an identified or identifiable natural person.
• Sensitive Personal Data: Health data, biometric data, religion, sect, criminal records, etc.
• Data Subject: The natural person whose personal data is processed.
• Explicit Consent: Consent that is informed and freely given for a specific matter.
• Destruction: The deletion, destruction, or anonymization of personal data.
• Law/KVKK: The Law on the Protection of Personal Data No. 6698.
• Recording Medium: Any environment containing personal data processed by automated or non-automated means as part of a data recording system.
• Processing of Personal Data: Any operation performed on personal data, wholly or partially by automated means or by non-automated means which form part of a filing system, such as collection, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, acquisition, making available, classification, or prevention of use.
• Anonymization of Personal Data: Rendering personal data impossible to link with an identified or identifiable person, even when matched with other data.
• Deletion of Personal Data: Making personal data inaccessible and unusable for relevant users.
• Destruction of Personal Data: Rendering personal data irrecoverable through the destruction of the data storage medium.
• Sensitive Personal Data: Data concerning a person’s race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, clothing and appearance, membership in associations, foundations or trade unions, health, sexual life, criminal convictions, and security measures, as well as biometric and genetic data.
• Periodic Destruction: The deletion, destruction, or anonymization of personal data at regular intervals in accordance with a destruction policy, when the reasons for processing no longer exist.

4. Purposes of Processing Personal Data

SMOXH CUTTING TOOLS processes personal data for the following purposes:

• Managing customer relations and quotation processes
• Responding to and tracking technical service requests
• Dealer and distributor management
• Providing after-sales support services
• Managing supply chain processes
• Keeping records of visitors (factory, showroom, trade fairs, etc.)
• Conducting marketing and promotional activities (e-newsletters, campaigns, product announcements, etc.)
• Evaluating job applications
• Fulfilling obligations arising from relevant legislation

5. Methods of Data Collection

Personal data is collected through:

• Trade fairs, seminars, training sessions, and technical training records
• Communication via website, supply, contact forms, and emails
• Information and registration forms used to advance sales and procurement processes
• Technical registration systems and visitor entry records
• Information requested from candidates or employees within recruitment and human resources processes

6. Transfer of Data

Personal data may be transferred, limited to the purpose of processing, to:

• Dealers, distributors, intermediary firms involved in business processes, and authorized service providers
• Logistics companies and other firms providing technical services
• Group companies
• Public institutions and authorized bodies legally entitled to receive such data

Transfers are carried out in compliance with Articles 8 and 9 of the KVKK.

7. Rights of Data Subjects

Pursuant to Article 11 of the KVKK, data subjects have the following rights:

• To learn whether their personal data has been processed,
• To request information if their data has been processed,
• To learn the purpose of processing and whether it has been used appropriately,
• To know the third parties and institutions their data has been transferred to domestically or abroad,
• To request correction if their data is incomplete or inaccurately processed,
• To request deletion or complete destruction if their data has been processed unlawfully,
• To object to results arising from automated system analysis,
• To claim compensation for damages.
• 8. Storage and Destruction
• Personal data is deleted, destroyed, or anonymized when the need for retention or the legal retention periods expire, or when the purposes for processing are no longer valid. These procedures are implemented by SMOXH CUTTING TOOLS.

9. Security Measures

Technical and administrative measures to protect personal data include:

• Firewalls and antivirus systems used in browsers or information providers
• Encrypted data storage services
• Restrictions on access rights to prevent unauthorized use
• Confidentiality and data protection commitments by personnel
• Obtaining commitments from third parties processing data through contracts or processes