Disclosure Statement

Privacy and Personal Data Protection Disclosure Statement (“Disclosure Statement”)

Privacy and Personal Data Protection are among the priorities of Frigoblock (“Frigoblock”). In this regard, Frigoblock presents the following information to the attention of our valued customers, suppliers, and all stakeholders using our website at www.frigoblock.com.tr to fulfill the disclosure obligation arising from Article 10 of the Law on the Protection of Personal Data No. 6698 and the Regulation on the Principles and Procedures for Fulfilling the Disclosure Obligation (“Regulation”).

This Disclosure Statement explains the collection, processing, sharing with third parties, storage, and security of your personal data, as well as your rights regarding these matters.

Frigoblock collects and processes personal data in accordance with the provisions of the KVKK and other relevant legislation, primarily in line with the Constitution of the Republic of Turkey. This Disclosure Statement has been created to demonstrate Frigoblock's commitment to privacy and personal data protection. Your rights regarding privacy and personal data security are our primary concern.

By this Disclosure Statement, you declare that you have been informed about the processing of your personal data and that you consent to the use of your personal data as stated herein.

**Collection, Use, and Processing of Your Personal Data**

Frigoblock may collect personal data that may be necessary for the performance of the services related to our website, in accordance with the KVKK and all relevant legislation. You explicitly consent to the processing of the data you share with Frigoblock within the scope and for the purposes specified in this Privacy and Personal Data Protection Disclosure Statement.

Your personal data may be processed verbally, in writing, or electronically through various means such as activities and fairs, social media platforms, our website, call center, and loyalty program applications, depending on the nature of the service, product, or commercial activity offered by Frigoblock, with the explicit consent or approval of our customers or in accordance with the provisions of legislation.

If you wish to place an order or request products, services, or information through our website (including registration for various services available on this site), you may need to share certain personal information classified as personal data under the KVKK, which enables us to process your order or request. Additionally, we may use this personal data for other commercial purposes, such as inviting you to surveys or informing you about news, products, applications, events, and fairs we participate in.

We also collect information unrelated to your personal data, such as your Internet Protocol (“IP”) address, to help identify issues on our server and manage our website. Furthermore, if you receive newsletters or promotional emails from Frigoblock, your personal data may also be processed using markers, customized links, and similar technologies to determine whether the email was opened and which links were clicked.

However, special categories of personal data such as religion, sect, ethnicity, health, genetic information, sexual life, and membership in associations, foundations, unions, etc., are not processed under any circumstances.

According to Articles 3 and 7 of the KVKK, data that has been anonymized in a non-reversible manner will not be considered personal data under the provisions of this Law, and processing activities related to this data will be carried out without being bound by the provisions of this Disclosure Statement.

**Purpose of Data Processing and Use**

Your personal data will be processed in accordance with the law and principles of fairness, accurately and up to date, for specific, clear, and legitimate purposes within the scope of this Disclosure Statement and/or Frigoblock’s purposes of personal data processing, limited and proportionate to the purposes for which they are processed, and retained for the period required by the relevant legislation or for the intended purposes. Frigoblock may record, store, update, disclose, transfer, classify, and process your personal data as permitted and to the extent allowed by the legislation.

Frigoblock may also process your personal data to ensure your access to our website, to carry out your membership registration if applicable, to improve the services provided, to promote and inform about new services, to provide necessary notifications to you, to contact you, and to fulfill obligations arising from the nature of the services provided.

These personal data may be processed within the scope of Frigoblock’s reporting and business development activities and may also be used for making various statistical evaluations, database creation, and market research without revealing your identity. With your additional consent, this information may be processed, stored, and shared with third parties for direct marketing purposes by those with whom Frigoblock collaborates, and you may be contacted for notifications regarding various applications, products, and services.

Frigoblock may also process personal data without obtaining your consent under Article 5 and 8 of the KVKK and/or in the presence of exceptions in the relevant legislation. The main situations for this are as follows:

- Explicitly provided for by law,
- Necessary for the protection of the life or bodily integrity of a person who is unable to disclose their consent due to actual impossibility or whose consent is not legally valid,
- Necessary for the establishment or performance of any contract directly related to you and Frigoblock,
- Necessary for fulfilling legal obligations,
- Information that you have made public,
- Necessary for the establishment, use, or protection of a right,
- Necessary for the legitimate interests of Frigoblock, provided that it does not harm your fundamental rights and freedoms.

**Information Sharing**

The sharing of personal data with third parties occurs within the scope of consent and, as a rule, personal data cannot be transferred to third parties without explicit consent. However, due to our legal obligations, personal data may be shared with courts and other public institutions, limited to these obligations. Additionally, personal data may be transferred to contracted third parties within the limits prescribed by legislation for providing the services we are committed to and for quality control of those services.

We may share your personal information and new data obtained using this personal information with our affiliates and partners, shareholders, suppliers, company officials, organizations, program partners, domestic and foreign individuals and institutions providing cloud storage services, banks we cooperate with, and survey companies in various marketing activities to provide better service and ensure customer satisfaction in accordance with Articles 8 and 9 of the KVKK.

As a data owner, you accept that the mentioned third parties may store your personal data on servers worldwide, limited to the purposes stated above, and you give your prior consent to this.

Furthermore, necessary technical and administrative measures are taken to prevent rights violations during data transfer to third parties. Frigoblock is not responsible for breaches arising in the area of risk under the responsibility of the third party due to their data protection policies.

**Cookies**

Cookies and other tracking technologies (such as web beacons) are used to enhance your experience on this site and/or our communications, allowing us to tailor our content to your interests. A cookie is a small file made up of letters and numbers that does not contain any personal data, which we store on your browser or the hard drive of your device. A cookie may contain information such as user ID or preferences, which the site uses to personalize content and track the pages you visit.

Our website uses cookies to provide a better service to our visitors and customers. You can find detailed information about cookies in our Cookie Policy.

**Management of Your Information**

At any time, you may request a summary of your personal information held by us or make corrections or updates to this information. We will make reasonable efforts to respond promptly to such requests in accordance with local laws. Our response to such requests may be limited to the information under your direct control.

As a data owner, you have the right to apply to Frigoblock to:

- Learn whether your personal data is processed,
- Request information regarding your processed personal data,
- Learn the purpose of processing your personal data and whether they are used in accordance with that purpose,
- Know the third parties to whom your personal data has been transferred, domestically or internationally,
- Request correction of your personal data if it is processed incompletely or inaccurately,
- Request that the corrections, deletions, and destructions made in accordance with the relevant legislation be notified to the third parties to whom your personal data has been transferred,
- Object to the emergence of a result against you by exclusively analyzing your processed data through automated systems,
- Request compensation for damages arising from the unlawful processing of your personal data.

You may use the Application Form to exercise your rights regarding personal data. We will provide a reasoned positive/negative response to your applications within 30 (thirty) days at the latest, either in writing or digitally. No fee will be charged for necessary procedures related to your requests. However, if the procedures incur a cost, a fee may be charged based on the tariff determined by the Personal Data Protection Board in accordance with Article 13 of the KVKK.

According to Article 4 of the KVKK, Frigoblock has an obligation to keep your personal data accurate and up to date. Therefore, our customers are required to share accurate and up-to-date information with Frigoblock to fulfill the obligations arising from the applicable legislation. As a data owner, you undertake that the information subject to this Disclosure Statement is complete, accurate, and up to date.

Please inform us of any changes to your name, address, title, phone number, email address, or other personal data. You can contact us at [email protected] to protect your personal data regarding change requests. You may request the deletion or removal of your information in your account; however, due to legal compliance, we may not be able to delete all information since we keep records of certain transaction information. If we become aware that the information we have is inaccurate, we will prevent its use until the situation is verified for your and our satisfaction. We would like to note that our company will not have any responsibility for your failure to provide up-to-date information as a