DIGITAL PALS PRIVACY POLICY AND DISCLAIMER ON PROTECTION OF PERSONAL DATA

We, as Digital Pals Teknoloji ve Danışmanlık Anonim Şirketi (“Digital Pals”), process personal data of all people related to Digital Pals including but not limited to the people provided with the goods and services of Digital Pals in accordance with the Law no. 6698 on the Protection of Personal Data (“the Law”). In this scope, the information on the processing of personal data according to the Law and other legislation are provided below in order to inform you fully.What is Personal Data?Personal data is defined in the Law as all kinds of information and data related to an identified or identifiable natural person. For example, your name, surname, date of birth, identity number, electronic mail address, phone number etc. shared with us are named and termed as Personal Data for the purposes hereof.Digital Pals does not collect or transfer your personal data other than the ones you share with us directly with your explicit consent.What kind of personal data is processed?

1. Our Customers and Potential Customers;
   1. ID information (Name, surname)
   2. Contact information (phone number, e-mail address)
   3. If requested to appear on the invoice (Turkish ID number, tax number, company information)
   4. Information on signature circular
   5. Personal data processed in order to answer your requests and complaints
   6. For marketing purposes, your contact information to be used for e-commerce e-mails
   7. Personal data provided by yourself during the provision of services or use of products
2. Employees and Representatives of Providers/Business Partners
   1. ID information (Name, surname, Turkish ID number)
   2. Contact information (phone number, e-mail address)
   3. If requested to appear on the invoice (Turkish ID number, tax number, company information)
3. Employee Candidates
   1. ID information (Name, surname, birth date and place, Turkish ID number)
   2. Contact information (address, e-mail address, phone number)
   3. Education and professional information
   4. Information of your references
   5. Information on your CV
4. Employees
   1. ID information (Name, surname, birth date and place, Turkish ID number)
   2. Contact information (address, e-mail address, phone number)
   3. Medical report
   4. Photo
   5. Information on your CV
   6. As employer, mandatory data to be processed in scope of administration rights and relevant legislation,
   7. Data collected through the security cameras in workplace
   8. Tracking of the electronic devices used.
5. Our Visitors
   1. ID information (Name, surname)
   2. Data collected through the security cameras in workplace

What are the purposes and legal grounds of processing of your personal data?Digital Pals collects and processes your personal data in order to contact you for sharing the information on goods and services requested by you and evaluating and resolving the complaints related to the goods and services and also for recruitment purposes.For the abovementioned purposes and in scope of the above, Digital Pals processes your personal data based on your explicit consent, or without your consent where the processing is necessary for the establishment or performance of our agreement with you, or to the extent legitimate interests of Digital Pals require, provided that it does not harm your fundamental rights and freedoms.To whom are we transferring and disclosing your personal data?Your Personal Data may be shared by Digital Pals with competent courts and other governmental bodies and public entities for the performance of our legal duties and obligations. Digital Pals may also share your personal data and traffic information in connection with your visit this website to ensure your security and to fulfill Digital Pals’ obligations under the applicable legislation with the authorities and institutions.How are we storing and keeping your personal data?Your personal data shared with Digital Pals is being kept and stored in Digital Pals’ local/foreign secure servers in strict compliance with the applicable laws and regulations, the provisions of the Law. Digital Pals takes the necessary technical and administrative security measures specified under the legislation to protect the security of your personal data.How long do we keep your personal data for?In accordance with Article 7/1 of the Law, once the purposes for processing the data no longer exist and/or upon expiration of the legal retention periods during which we are obliged to retain your personal data, your personal data will be deleted, destroyed or anonymized.To whom and for which purposes do we transfer your data?Digital Pals transfer personal data;

1. To its local business partner and services providers in order to receive services on information technologies or consultancy services requiring expertise (companies providing services on database, consultancy etc.) and/or to its business partner and services providers abroad by fulfilling the conditions regulated under article 9 of the Law,
2. To administrative and legal authorities in order to fulfill our legal duties to provide information and documents and to use our legal rights,
3. To our business partners in order to provide our services or our providers from which we receive products or services,
4. To our business partners for educational and compliance purposes; to our lawyers, financial advisors, occupational safety specialists etc. in order to fulfill our legal duties; to our customers abroad in order to build connections, conclude, execute and fulfill agreements by fulfilling the conditions regulated under article 9 of the Law.

The list of our service providers and business partners and their privacy policies are as follows:

• Adjust https://www.adjust.com/terms/privacy-policy

• Facebook https://www.facebook.com/about/privacy

• Google LLC (Firebase) https://firebase.google.com/support/privacy

• Game Analytics https://gameanalytics.com/privacy

• Facebook Inc. (FB Ads, FB Audience Network) https://www.facebook.com/about/privacy

• Google LLC (Google Ads) https://policies.google.com/privacy

• Unity Technologies (Unity Ads) https://unity3d.com/legal/privacy-policy

• Apple https://www.apple.com/privacy/

• Snapchat https://www.snap.com/en-US/privacy/privacy-policy/

• Tiktok https://ads.tiktok.com/i18n/official/policy/privacy

What are your rights arising out of the Law?In accordance with Article 11 of the Law, to the extent Digital Pals is processing your data as a data controller, you can benefit the following rights by applying to Digital Pals:

1. learn whether any of your personal data is subject to processing;
2. request information regarding the processing activities;
3. learn the purposes for processing;
4. know local and foreign third persons if, and to whom, personal data are transferred;
5. request correction of personal data if processed incompletely or inaccurately;
6. request deletion or destruction of personal data if the purposes for processing no longer exist;
7. request notification of deletion or correction to third parties to whom personal data is transferred;
8. object to negative consequences which arise as a result of processing of personal data by automatic means; and
9. request indemnification if you suffer damage as a result of illegal processing of your personal data.

The requests through the application form at https://digitalpals.com/contact-us/ will be resolved as soon as possible and within thirty days at the latest.