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CCTV Recording Disclosure Statement

Within the Scope of the Law No. 6698 on the Protection of Personal Data

I. Data Controller

The Law No. 6698 on the Protection of Personal Data (“Law”) was enacted to protect the fundamental rights and freedoms of individuals, particularly the right to privacy, in the processing of personal data and to regulate the obligations, procedures, and principles that natural and legal persons processing personal data must comply with.

In accordance with the Law, your personal data within the scope of CCTV recording are processed by Nükte Otomotiv San. Tic. A.Ş. (“Nükte Otomotiv”), acting as the data controller, under the terms explained below.

II. Methods and Legal Grounds for Collecting Personal Data

This CCTV Disclosure Statement has been prepared to inform you that video surveillance equipment has been installed in Nükte Otomotiv San. Tic. A.Ş.’s buildings, facilities, workplaces, annexes, audit areas, courtyards, entrances, external facades, office entrances, event areas, cafeterias, visitor waiting rooms, parking lots, security cabins, floor corridors, and other service areas, as well as in other areas marked with the CCTV warning sign (hereinafter referred to as the “Nükte Otomotiv Premises”).

The video surveillance system records and processes images of individuals and their belongings within the coverage area of these systems. The system operates 24 hours a day, 7 days a week, continuously. Through this video surveillance system, visual data and camera recordings are processed.

Your personal data are processed for purposes such as fulfilling legal obligations (e.g., ensuring safety in parking areas, monitoring compliance with occupational health and safety regulations, detecting and preventing unauthorized access to work areas to ensure information security), safeguarding the legitimate interests of the data controller (e.g., maintaining physical security, detecting and investigating violations of workplace rules), or in cases explicitly stipulated by law (including but not limited to the Private Security Services Law No. 5188, Labor Law No. 4857, and Occupational Health and Safety Law No. 6331).

III. Purposes of Processing Personal Data

Your personal data listed above may be processed for the following purposes:

1. Protection of Nükte Otomotiv San. Tic. A.Ş. premises, individuals, goods, and products located therein from any attack, theft, robbery, or damage
2. Ensuring the safety of Nükte Otomotiv’s facilities, infrastructure, products, and operations and taking measures against any security breaches
3. Providing information to authorized institutions and organizations
4. Ensuring legal, technical, and commercial occupational security of Nükte Otomotiv and its business partners
5. Planning, auditing, and executing information security processes
6. Controlling entry and exit of the workplace
7. Creating and tracking visitor records
8. Planning and/or executing occupational health and safety processes and fulfilling related obligations
9. Preventing fires and similar disasters
10. Managing the areas where the Nükte Otomotiv premises are located (such as technoparks, shopping malls, parking lots, or private zones)
11. Detecting and investigating violations of workplace rules
12. Conducting emergency management processes

IV. Transfer of Personal Data

Nükte Otomotiv San. Tic. A.Ş. processes personal data with due care in accordance with the “need-to-know” and “need-to-use” principles, ensuring necessary data minimization and implementing adequate technical and administrative security measures.

Due to operational needs, including maintaining workplace safety, ensuring compliance with internal regulations, and managing digital infrastructures, continuous data flow with third parties is occasionally required.

For the above-mentioned purposes, personal data may be shared — limited to the fulfillment of these purposes — with legally authorized public institutions and private entities, third parties specifically determined where legitimate interests of the data controller require it, and may be processed domestically or abroad.

In addition:

1. With experts, law firms, and audit companies for audit and compliance purposes, and with public institutions, insurance companies, KVKK consultancy firms, occupational safety firms, social support funds, and business consultants to fulfill legal and contractual obligations,
2. With authorized administrative and supervisory boards and/or other competent regulatory authorities,
3. With judicial or law enforcement authorities when required by relevant legislation or during legal disputes.

V. Rights of the Data Subject

According to Article 11 of the Law, every individual whose personal data are processed may contact Nükte Otomotiv San. Tic. A.Ş. and make the following requests:

1. To learn whether their personal data are processed,
2. To request information if their personal data have been processed,
3. To learn the purpose of processing and whether they are used in line with that purpose,
4. To know the third parties to whom their data have been transferred domestically or abroad,
5. To request correction of incomplete or inaccurate data and notification of such correction to third parties,
6. To request deletion, destruction, or anonymization of personal data when the processing reasons cease to exist,
7. To object to any unfavorable outcome resulting from analysis of personal data exclusively through automated systems,
8. To demand compensation in case of damages due to unlawful processing of personal data.

You may exercise these rights by filling out the Application Form for Data Subjects available on www.nukte.com.tr and submitting it to Nükte Otomotiv San. Tic. A.Ş. in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller.

VI. Updates to the General Information Text on the Protection of Personal Data

This “General Information Text on the Protection of Personal Data” may be updated as necessary to announce changes in our data protection-related services, to introduce new services, or to comply with applicable legal requirements.

Click here to access the Data Subject Application Form.

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