HEOXA PRIVACY AGREEMENT

This Privacy and Personal Data Protection Policy has been prepared to provide information on which personal data is collected, how it is used, with whom it can be shared, what rights Users have, how they can use them, and about cookies through our website at www.heoxa.com (hereinafter referred to as 'Site'), of which ERALP YAZILIM VE OTOMASYON SİSTEMLERİ SANAYİ VE TİCARET A.Ş. (hereinafter referred to as 'ERALP YAZILIM') is the content provider and data controller, and other means.

Individuals and organizations (hereinafter referred to as 'User') who visit, use, become members, access, send content such as comments, information, images, videos, pictures, and photos to our Website accept all the terms in this Privacy and Personal Data Protection Policy.

The changes and updates that the Company will make in this Privacy and Personal Data Protection Policy are deemed to have become effective from the moment they are published on our Website. Therefore, we recommend that the User review this Privacy and Personal Data Protection Policy before visiting our Website and take into account the changes and/or corrections made by the User.

1. TRANSFER OF PERSONAL DATA

1.1. : Users are not required to share their personal data to view and visit our Website. However, if the User wants to participate in, benefit from, or use any of the features and services offered by our Website, in this case, various personal and/or demographic data may be requested from them.

1.2. : The term personal data used in this Privacy and Personal Data Protection Policy refers to data intended to identify the User directly or indirectly, including but not limited to name-surname, e-mail address, phone number, date of birth, age, gender, card information, and information that the User consents to share through such accounts if they connect with their social media accounts.

1.3. : The Site uses various third-party or organization tracking systems such as Google Analytics. Google Analytics transfers information collected from users' computers (including IP address) to Google servers in America for statistical purposes and information is stored here. The collected information is used to evaluate the preferences of users on our site, determine customer profiles, conduct statistical studies, prepare activity reports of our site, and improve site services. Google does not combine users' information, including IP address, with other information stored with it and does not share this information with third parties unless there is a legal and lawful reason.

1.4. : Personal data communicated by the User to the Company will be processed within the framework of the purposes specified below and will not be used outside the intended purpose under any circumstances. Personal data belonging to the user obtained from sources such as Reservation and Contact forms; to provide better service by the Company, to answer the User's questions and provide effective customer service, to contact when necessary, to send publications, to send newsletters by e-mail or make notifications, to create a membership account on behalf of the User, to ensure the continuation and improvement of the services provided, to re-access historical information when needed, to identify the User's areas of interest and to carry out and improve operational activities such as business development, marketing, communication with the collected data, to fulfill our obligations arising from the Law and other legislation, to conduct statistical studies and market research, and to create databases.

1.5.: Personal data belonging to the User, browsing, traffic information, and Internet Protocol (IP) address; will be shared with relevant institutions and organizations upon proper request from authorized, administrative, and official authorities in accordance with current legislation in cases where we have an obligation to notify or provide information legally or administratively (including but not limited to fighting crime, threats to state and public security) in order to fulfill our obligation to security and laws.

1.6.: Personal data belonging to the User; by ERALP YAZILIM or natural or legal persons processing data on behalf of ERALP YAZILIM; may be collected verbally, in writing, automatically or non-automatically, or electronically through similar means, including but not limited to contact forms, consumer complaint forms, social networks, website, various contracts, mobile applications, e-mail, application forms, newsletters. 1.7. It is the User's responsibility that the information provided by the User is accurate and complete. If false, misleading, or incomplete information is provided; ERALP YAZILIM will have no responsibility, and the obligation to compensate for the damage incurred for this reason will entirely belong to the User.

2. TRANSFER OF PERSONAL DATA

3.1 Personal data belonging to the User may be shared with all subsidiaries and affiliates of which ERALP YAZILIM is directly and/or indirectly a shareholder within the purposes listed above and in accordance with current legislation, as well as, not limited to those listed; to our business partners, business connections, performance assistants and subcontractors for the purpose of the service we provide, or to regulatory supervisory institutions and official authorities in cases provided for by relevant legislation domestically and/or abroad. The User accepts and declares that they consent to the transfer of their personal data as specified above.

3. RIGHTS OF THE PERSONAL DATA SUBJECT

3.1. Within the scope of the Personal Data Protection Law and other legislation in force, the User;

a) Learning whether personal data has been processed,

b) Requesting information about it if personal data has been processed,

c) Learning the purpose of processing personal data and whether they are used in accordance with their purpose,

d) Knowing the third parties to whom personal data is transferred domestically or abroad,

e) Requesting correction of personal data if they have been processed incompletely or incorrectly and requesting notification of the transaction made in this context to third parties to whom personal data has been transferred,

f) Requesting deletion, destruction, or anonymization of personal data if the reasons requiring processing have disappeared, even though they have been processed in accordance with the Personal Data Protection Law and other relevant legal provisions, and requesting notification of the transaction made in this context to third parties to whom personal data has been transferred,

g) Objecting to the occurrence of a result against the person by analyzing processed data exclusively through automated systems,

h) They have the right to demand compensation for damage in case of suffering damage due to illegal processing of personal data.

3.2. The User can use these rights by;

– Sending a petition bearing their wet signature to ERALP YAZILIM's address at 'Adalet Mahallesi, Şehit Fethi Sekin Caddesi, No: 1 Martı Tower Kat: 13 Daire No 1304 BAYRAKLI/İZMİR' by registered mail with acknowledgment of receipt, or,

– If a separate method is announced by the Personal Data Protection Board, in accordance with this method. In the application that the User will make to exercise the rights specified above; the request must be clear and understandable, the subject requested must be related to the person; if the application is to be made by their representative, in this case the representation authority must be documented, the identity and address information of the applicant User must be included, and documents certifying the identity of the User must be attached to the application.

3.3. To change or update their personal information and communication preferences, the User should communicate their requests to the Company in the manner explained above or via e-mail to info@heoxa.com. The User's request will be evaluated as soon as possible and action will be taken.

4. COOKIE USAGE

a) 4.1. On our Website, we use cookies to facilitate and customize the use of our site. Cookies are small text files placed on your computer's hard drive by your browser. Each time the User visits our Website, the User's web browser sends cookies to our Website; thus, our Website recognizes the User and remembers their information such as User preferences. The cookies we use do not store personal data, i.e., they are anonymous.

b) 4.2. The User can set their web browser to warn them before accepting cookies or simply to reject all cookies; however, if cookies are not accepted, it may not be possible to access all features of our Website. The User can make the necessary changes by clicking the 'help' button of their web browser to learn how to make these settings. Unless the User changes cookie settings, it is accepted that they have given explicit consent to cookie usage in accordance with this Privacy and Personal Data Protection Policy.

5. COMMERCIAL COMMUNICATIONS

a) 5.1. It will be accepted that the User has given permission for their personal data to be collected, stored, processed, used, and transferred to the third parties specified above domestically and abroad for the purpose of providing various advantages and offers, making all kinds of promotional, promotional, advertising, sales, marketing, survey, and similar electronic communications specific to them, and sending all kinds of communication messages.

b) 5.2. If the User does not want the Company to send them newsletters, announcements, commercial communications, or other notifications and/or messages, in this case they should not indicate a request for these notifications or services when becoming a member of the Website. However, if the User gave consent for such communications or notifications to be sent to them when becoming a member of the Website and/or subscribed to ERALP YAZILIM e-newsletter, in this case they will be deemed to have consented to all kinds of electronic communication and other communication messages being sent to them.

c) 5.3. Users who subscribe to the ERALP YAZILIM e-newsletter are offered the option to not receive future notifications in the e-mails sent to them. If the User wants to withdraw their consent to receive newsletters, in this case they can change their preferences on this matter by following the instructions specified in the e-mail sent to them.

6. APPLICABLE LAW AND COMPETENT COURT

Turkish Law will be applied in the interpretation and application of this Privacy and Personal Data Protection Policy and in the resolution of disputes that may arise between the User and the Company, and İzmir Central Courts are authorized in the resolution of all kinds of disputes that may arise from this Privacy and Personal Data Protection Policy.