Clarification Text

GP KOMPOZİT ANONİM ŞİRKETİ CUSTOMER CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA PURSUANT TO LAW NO. 6698 FOR TRACKING DEVICES

1. Purpose, Scope, and Definitions of the Clarification Text

The subject of this Clarification Text is to inform and explain the rights of our customers using the GP Garaj mobile application within GP KOMPOZİT ANONİM ŞİRKETİ (GP KOMPOZİT) regarding the processing and transfer of their personal data. This is conducted in accordance with the Law on the Protection of Personal Data No. 6698 (KVKK) to protect fundamental rights and freedoms, especially the privacy of private life.

As the GP KOMPOZİT family, we show maximum sensitivity to the security of our customers’ personal data. With this awareness, we attach great importance to the processing and preservation of all personal data belonging to individuals associated with our Company in accordance with the KVKK, the Constitution of the Republic of Turkey, and international agreements to which our country is a party.

Within the scope of Law No. 6698, we inform you that the personal data you have shared with us or that we have requested may be recorded, stored, preserved, reorganized, shared with institutions legally authorized to request such data, and transferred to domestic third parties under the conditions stipulated by the KVKK. In the event that the conditions written in the KVKK and the Destruction Policy are met, your personal data may be destroyed, deleted, or anonymized.

In this context, GP KOMPOZİT, in its capacity as the Data Controller, will process your personal data within the framework of legal principles, including being lawful, accurate, up-to-date, and limited to specific, clear, and legitimate purposes.

2. Data Controller

The GP Garaj mobile application is a digital platform belonging to GP Kompozit Anonim Şirketi. Pursuant to Law No. 6698 (KVKK), your personal data will be processed by GP KOMPOZİT as the data controller within the scope described below.

3. Method and Legal Basis of Data Collection

GP KOMPOZİT collects your personal data in accordance with the law when you download, register for, or use the GP Garaj Mobile application. This collection occurs through automatic or non-automatic methods—verbally, in writing, or electronically—and is processed within the conditions specified in Articles 5 and 6 of the KVKK. Your personal data is obtained through fully or partially automated means or as part of a data recording system.

4. Processed Personal Data and Purposes of Processing

In order for you to register and use the purchased tracking device, we process the following application usage information:

• Identity: Name-surname, T.R. identity number.
• Contact: E-mail, GSM number.
• Location: Address, coordinates.
• Vehicle/Device: License plate, model, etc..
• Cookies: Usage data and tracking information.

This data is processed in accordance with the contractual provisions between us to ensure you can use the tracking device smoothly and legally.

5. Protection and Storage of Personal Data

Your personal data is protected under the security measures stipulated in the Law. As long as you continue to use the device, your data will continue to be processed for the fulfillment of the service. Upon termination of use, data that we are not legally obligated to retain will be deleted during periodic destruction periods. If there is data you wish to have deleted, you may notify GP KOMPOZİT.

6. Sharing Personal Data with Third Parties and Purpose of Sharing

Your personal data is shared with courts and other public institutions due to legal obligations, ensuring all technical and administrative measures are taken to provide the appropriate security level in accordance with Articles 8 and 9 of the KVKK. Additionally, data is transferred to contracted third parties (such as law/accounting firms and consultants) to provide the committed services and perform quality control. Sharing occurs only when the service provided requires it.

7. Rights of the Data Subject under Article 11 of the KVKK

Pursuant to the Law on the Protection of Personal Data, you have the right to:

• Learn whether your personal data is being processed.
• Request information if your personal data has been processed.
• Learn the purpose of the processing and whether the data is used accordingly.
• Know the third parties to whom personal data is transferred domestically or abroad.
• Request correction of incomplete or incorrectly processed data.
• Request deletion or destruction of data when processing reasons no longer exist.
• Request that correction/deletion/destruction actions be notified to third parties to whom the data was transferred.
• Object to results occurring exclusively through automated systems.
• Claim compensation for damages arising from unlawful processing.

To exercise these rights, you may apply in writing to our address below, via Registered Electronic Mail (KEP), secure electronic signature, mobile signature, or through the e-mail address previously registered in our systems. Applications must be made in Turkish.

8. Changes to Data Security and the Clarification Text

GP KOMPOZİT takes appropriate technical and administrative measures regarding data security under the KVKK. In the event of changes to legal requirements or processing purposes, this text may be updated and re-announced in its most current form.

9. Contact

For all requests and applications:

• Company: GP KOMPOZİT A.Ş.
• Address: Şeyhli Mah. Hızır Reis Cad. No:6 Pendik/İstanbul
• E-mail: info@gpkompozit.com
• Phone: 0850 305 5547