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Any operation performed on personal data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that it is part of any data recording system is considered as the processing of personal data. Personal data are processed in accordance with the procedures and principles stipulated in the relevant legislation. BIGPIPS processes personal data; in line with general principles, in accordance with the law and good faith, accurately and, where necessary, up-to-date, for specific, clear and legitimate purposes, in connection with the purpose for which they are processed, in a limited and measured manner, provided that they are kept for the period stipulated in the relevant legislation or required for the purpose for which they are processed. The Company processes personal data with the explicit consent of the data subject, except for the exceptions written in the Law. The Company may process personal data and sensitive personal data without explicit consent in exceptional cases stipulated in Articles 5 and 6 of the Law. Translated with DeepL.com (free version)

-Processing of Personal Data
5 Of the Law on the personal data processing activities of our Company. it conducts it in accordance with the data processing conditions set out in the article. The Company obtains the explicit consent of the relevant person except in the following cases. To be clearly stipulated in the laws.The personal data of the person concerned may be processed in accordance with the law without obtaining the explicit consent of the person, if it is clearly stipulated in the laws. (For example, identification according to the procedure established in accordance with Article 5 of the Regulation on Measures to Prevent the Laundering of Criminal Proceeds and the Financing of Terrorism). The fact that a person who is unable to disclose his consent due to actual impossibility or whose consent is not granted legal validity is mandatory for the protection of the life or body integrity of himself or someone else. If the data subject is unable to disclose his consent due to actual impossibility, or if the processing of his personal data is mandatory to protect the life or body integrity of the data subject himself or another person whose consent cannot be validated, his personal data may be processed without the explicit consent of the person (For example, removing a visitor who has experienced discomfort in our Company to the infirmary and saving his contact information). It is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract. Provided that BIGPIPS is directly involved in the establishment or performance of a contract, if it is necessary to process personal data belonging to the parties to the contract, their personal data may be processed without obtaining the explicit consent of the relevant person (For example, receipt of billing information of a person receiving a service from our Company). It is mandatory for our company to fulfill its legal obligations. If the processing is mandatory for BIGPIPS to fulfill its legal obligations, its personal data may be processed without obtaining the explicit consent of the relevant person (For example, answering questions asked by public institutions such as MASAK, BTK, BRSA and sending the requested documents). The fact that the personal data has been made public by the relevant person himself.If the personal data has been made public by the relevant person himself, the personal data may be processed without obtaining explicit consent (For example, contacting an official whose corporate e-mail address is published on the corporate website). The data processing is mandatory for the establishment, use or protection of a right.If data processing is mandatory for the establishment, exercise or protection of a right, personal data may be processed without obtaining the explicit consent of the relevant person. (For example, the processing of personal data in order to exercise the legal rights of our Company in a possible dispute). The data processing is mandatory for the legitimate interests of BIGPIPS.If data processing is mandatory for the legitimate interests of our Company, provided that it does not harm the fundamental rights and freedoms of the relevant person, their personal data may be processed without obtaining the explicit consent of the relevant person (For example, camera recording in a way that does not violate the fundamental rights and freedoms of people on the campus to ensure the security of our Company campus). One or more personal data processing conditions that make a personal data processing activity in compliance with the law may be applied simultaneously.

-Processing of Personal Data of a Special Nature
A number of personal data are considered sensitive in the eyes of the Law and special measures to be taken with special protection rules are envisaged. In particular, personal data, which risks causing situations such as victimization and/or discrimination of persons when processed unlawfully, is subject to Section 6 of the Law. it is defined as “special quality” in the article. These data are; race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, disguise and clothing, association, foundation or trade union membership, health, sex life, criminal convictions and security measures related data, as well as biometric and genetic data. BIGPIPS , the processing activity of the personal data specified as of a special nature 6 of the Law. it conducts it in accordance with the data processing conditions set out in the article. In addition, adequate measures determined by the Board are taken in the processing of personal data of a special nature. As a rule, personal data of a special nature are not processed without the explicit consent of the person concerned. However, provided that the adequate measures determined by the Board are taken, private personal data may be processed in the following cases, despite the absence of the explicit consent of the person concerned.