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HAVELSAN HAVA ELEKTRONİK SANAYİ VE TİCARET A.Ş.  INFORMATION TEXT UNDER LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

This “Information Text” is prepared by HAVELSAN Air Electronics Industry and Trade Inc. (“HAVELSAN”) as the data controller, in accordance with the Personal Data Protection Law No. 6698 (“Law”), to inform you about the methods of collection, processing, use, transfer, and destruction of your personal data, within the framework of Article 10 titled ‘Data Controller's Obligation to Inform’ and Article 11 titled ‘Rights of the Relevant Person’ of GPDR.

Purposes of Processing Personal Data

Your personal data will be processed within the framework of Articles 4, 5, and 6 of Law, through verbal, written, or electronic means for the following purposes:

- Conducting our human resources processes and activities within the determined legal framework,

- Planning, auditing, and executing information security processes,

- Creating and managing information technology infrastructure,

- Monitoring financial and/or accounting tasks,

- Managing contracts, establishing legal actions, and monitoring legal processes,

- Ensuring facility and personnel security,

- Enabling HAVELSAN personnel to benefit from preventive and therapeutic health services,

- Conducting efficiency and/or appropriateness analyses of our commercial activities, planning, and executing these activities,

- Determining and implementing commercial and business strategies,

- Fully and properly fulfilling HAVELSAN’s contractual and legal obligations,

- Evaluating, responding to, and improving suggestions, requests, complaints, and malfunction reports you submit via our website.

Scope of Personal Data

As HAVELSAN, in our capacity as the Data Controller, we process personal data (name-surname, address, profession, education, marital status, date and place of birth, CV, email, phone number, gender, vehicle license plate number, location data opened when entering the website, IP address, and on-campus camera recordings) shared with us to benefit from our activities, either automatically or non-automatically, within the scope of our legal obligations arising from the Turkish Commercial Code No. 6102, GPDR, Labor Law No. 4857, Turkish Code of Obligations No. 6098, Turkish Criminal Code No. 5237, Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by These Publications, and other relevant legislation and regulations. Additionally, according to the Law No. 5201 on the Control of the Production of War Tools and Equipment, Weapons, Ammunition, and Explosive Materials, and Defence Industry Security Directive MSY 317-2 C of the National Defence Ministry, HAVELSAN may obtain, record, store, update, reorganize personal data, transfer it to third parties domestically or abroad as permitted by legislation, and process it in other forms as approved by law, taking necessary administrative and technical measures.

These personal data will be processed based on your explicit consent or if explicitly provided for by laws, necessary for the establishment or performance of the contract, mandatory for fulfilling legal obligations, or required by legitimate interest, within the purposes and scope specified in this HAVELSAN Personal Data Protection Information Text, with all necessary information security measures taken, and will be retained for the legally prescribed period or as long as necessary for the processing purpose. At the end of the necessary period, data will be anonymized and continued to be used by our company or will be destroyed in accordance with GPDR and related legislation and company procedures.

Processing of Personal Data by HAVELSAN

HAVELSAN processes personal data in compliance with the following principles;

- Lawfulness and fairness,

- Being accurate and kept up to date where necessary,

- Being processed for specified, explicit and legitimate purposes,

- Being relevant, limited and proportionate to the purposes for which they are processed,

- Being stored for the period laid down by relevant legislation or the period required for the purpose for which the personal data are processed.

HAVELSAN pays utmost attention to the security of your personal data and takes all necessary technical, administrative, and legal measures for its protection.

Sharing Personal Data with Third Parties

HAVELSAN may share your personal data, only with your explicit consent or as stipulated by the legislation we are subject to, for establishing or performing a contract, fulfilling a legal obligation, or required by legitimate interest, in accordance with the security and confidentiality principles specified in Law, for the execution of company activities with direct/indirect/domestic/abroad subsidiaries, legal and real persons with whom we have agreements, suppliers, subcontractors, business partners, shareholders, legal, financial, and tax advisors, auditors, auditing companies, or public institutions or organizations authorized to request these data by legal obligation, within the conditions and purposes of personal data processing specified in Articles 8 and 9 of Law.

Rights Under the Law on the Protection of Personal Data

Under Article 11 of Law, except for the cases stipulated in Article 28 titled “Exceptions,” personal data owners have the following rights:

- To learn whether your personal data is processed or not,

- To request information if your personal data has been processed,

- To learn the purpose of processing your personal data and whether it is used for its intended purpose,

- To know the third parties to whom your personal data is transferred domestically or abroad,

- To request correction if your personal data is processed incompletely or inaccurately,

- To request deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of Law,

- To request notification of the transactions made pursuant to subparagraphs (e) and (f) to third parties to whom your personal data has been transferred,

- To object to the occurrence of a result against you by analysing your data processed exclusively through automated systems,

- To request compensation for damages arising from the unlawful processing of your personal data.

It is important that the information/data you share with HAVELSAN to be correct and accurate, and properly transferred to HAVELSAN, so that you would be able to exercise your rights and powers hereunder.Any liability arising from providing deficient or defective information lies with the party transmitting the information/data to HAVELSAN.

You can submit your requests within this scope in writing or via registered electronic mail address, secure electronic signature, mobile signature, or by using the electronic mail address previously notified to HAVELSAN and registered in our systems. Additionally, you can personally apply to HAVELSAN’s head office at Mustafa Kemal Mahallesi 2120 Cad. No:39 P.K.:06510 Çankaya-ANKARA with the application form provided on our website (www.havelsan.com.tr) containing your explanations regarding the right you wish to use, along with your name-surname, signature, T.C. identity number, residential or workplace address, if any, email address, phone, or fax number, or send your application via a notary public or to the registered electronic mail address havelsan@hs02.kep.tr.

HAVELSAN will finalize the request/application free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the fulfilment of your requests requires an additional cost, HAVELSAN reserves the right to charge a fee of 1 Turkish Lira for each page exceeding 10 pages for written responses, and the cost of the recording medium for responses provided in CD, flash memory, or similar recording mediums.