Disclosure Statement on the Processing of Personal Data

Disclosure Text Regarding the Processing of Personal Data

We, as TERA HOLDING INC., attach great importance to the processing and protection of personal data in accordance with the Law No. 6698 on the Protection of Personal Data , the secondary legislation (regulations, communiqués, circulars) enacted and to be enacted under this Law, and binding decisions issued and to be issued by the Personal Data Protection Board.

Identity and Contact Information of the Data Controller

Data Controller: TERA YATIRIM HOLDING INC. (Tax ID: 8391145756)
Address: Maslak Mah. Eski Büyükdere Cad. İz Plaza No:9, İç Kapı No: 60, Sarıyer / İstanbul
Phone: +90 212 970 77 94
E-mail: iletisim@teraholding.com.tr
Registered E-mail (KEP): tera.yatirim@hs01.kep.tr

Purpose of Processing Personal Data

Your personal data is processed by Tera Holding in accordance with the limits set forth in the Law, in a manner that is relevant, limited, and proportionate to the purposes, and in compliance with the principles of good faith. The purposes of processing include but are not limited to:

• Conducting necessary activities to ensure the Company’s commercial operations comply with relevant legislation and corporate policies,

• Planning and executing Tera Holding’s short-, medium-, and long-term commercial strategies,

• Designing and managing human resources policies and processes,

• Fulfilling obligations arising from relevant legislation,

• Managing customer and corporate relations processes,

• Ensuring legal and commercial security of individuals or entities in a business relationship with Tera Holding,

• Organizing events, conferences, seminars, investor meetings, and providing access to products and services offered by Tera Holding or third parties to whom personal data is lawfully transferred,

• Managing sales and marketing processes of the Company’s products and/or services, ensuring customer satisfaction and communication activities,

• Engaging in promotional, campaign, and advertising efforts through electronic media and social media, including subscription services and data analysis tools,

• Fulfilling legal obligations as the data controller,

• Communicating with individuals submitting requests or complaints to Tera Holding.

Transfer of Processed Personal Data

Your personal data may be shared in accordance with Articles 8 and 9 of the Law, with:

• Public institutions and authorities legally authorized to request data,

• Judicial and administrative authorities,

• Natural or legal persons permitted by other applicable legislation,

• Business partners, suppliers, consultants, subsidiaries, shareholders (direct or indirect), affiliates, and service providers of Tera Holding,

• Employees of the Company and group companies,

• Third parties from which the Company receives services or to whom services are provided.

During and after the data transfer process, all necessary technical and administrative measures are taken to ensure data security.

Method and Legal Basis for Collecting Personal Data

Your personal data may be collected through automatic or non-automatic means via channels such as our headquarters, offices, call center, website, e-mail, messaging platforms, social media, mobile applications, physical forms, and closed-circuit camera systems. The collected data may vary depending on the service or activity offered by our Company.

Your personal data is processed on the basis of the data subject’s explicit consent (Article 5(1) of the Law) or one of the lawful grounds listed in Article 5(2), such as necessity for the performance of a contract or compliance with a legal obligation. If your consent is withdrawn and no other lawful basis applies under Article 5(2), your personal data will be anonymized and not used further. Tera Holding regularly reviews whether data should be anonymized and performs anonymization ex officio when required.

Rights of the Data Subject

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

• To learn whether their personal data is being processed,

• To request information if it has been processed,

• To learn the purpose of processing and whether it is used accordingly,

• To know the third parties to whom the data is transferred domestically or abroad,

• To request correction if it is incomplete or inaccurate and to request notification to third parties to whom data was transferred,

• To request deletion or destruction of data when processing purposes no longer exist and to request notification of these actions to third parties,

• To object to the occurrence of a result against themselves through the exclusive analysis of data by automated systems,

• To claim compensation if they suffer damage due to unlawful processing of personal data.

How to Apply and Request Information

According to Article 13(1) of the Law, you may submit your requests regarding the rights specified in Article 11:

• In writing,

• Via the registered e-mail (KEP) address,

• By sending an e-mail from your registered e-mail address previously notified to the Company,

• Or by other methods to be determined by the Personal Data Protection Board.

Applications can be submitted to:

• E-mail: iletisim@teraholding.com.tr

• Address: Maslak Mah. Eski Büyükdere Cad. İz Plaza No:9, İç Kapı No: 60, Sarıyer / İstanbul

• KEP: tera.yatirim@hs01.kep.tr

Applications must include:

a. Your full name and, if in writing, your signature,
b. Your Turkish ID number (for Turkish citizens) or nationality, passport number or ID number (for foreign nationals),
c. Your residential or business address for notification,
d. Your e-mail address, phone number, and fax number (if any),
e. Your request details and any relevant documents.

Tera Holding will respond to your request as soon as possible and no later than 30 (thirty) days, depending on the nature of the request. If your request incurs a cost, you may be charged a fee in accordance with the tariff set by the Personal Data Protection Board.

Please note that applications will only be processed for the applicant’s own personal data. Applications made on behalf of third parties, such as spouses, relatives, or friends, will not be accepted.