SUBSCRIBER CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA

Sabancı Üniversitesi Inovent Fikri Mülkiyet Hakları Yönetim Ticaret ve Yatırım Anonim Şirketi (the “Company”), acting in its capacity as data controller, shall, in accordance with Law No. 6698 on the Protection of Personal Data (the “Law”) and in particular with due regard to the principle of protecting the right to privacy, collect, record, classify, retain and update the personal data of data subjects; process such personal data in accordance with the conditions for processing stipulated under the Law; and transfer such personal data to third parties to the extent and in the circumstances permitted by applicable legislation.

This Clarification Text has been prepared in accordance with the applicable legislation in force, particularly the Law, as well as the rules set forth in the regulations, communiqués, decisions and guidelines issued by the Personal Data Protection Board (the “Board”). If, following the publication date of this Clarification Text, the Law or any other applicable legislation is amended and this Clarification Text becomes inconsistent with such amendments, the amended provisions and rules shall prevail and apply accordingly. All communiqués, decisions and guidelines issued by the Board are monitored by us on an ongoing basis, and the rules set forth in this Clarification Text are kept up to date accordingly.

1. DATA SUBJECT / RELEVANT PERSON

The data subjects within the scope of this Clarification Text are natural persons who register via their e-mail addresses in order to receive e-newsletters, announcements and informational content published by the Company.

2. IDENTITY OF THE DATA CONTROLLER AND ITS REPRESENTATIVE

Pursuant to the Law, your personal data may be collected and processed by the Company, acting as the data controller, within the scope set out below. For any questions regarding the processing of your personal data, you may contact the Company’s Contact Person via info@inovent.com.tr.

3. PURPOSES OF PROCESSING PERSONAL DATA, LEGAL BASES FOR PROCESSING AND METHODS OF COLLECTION

The Company may record, retain, update, transfer to third parties, classify and otherwise process your personal data to the extent and in accordance with the conditions set forth under Articles 5 and 6 of the Law under the heading “Conditions for Processing Personal Data.”. The Company clearly identifies the purposes for which personal data are processed and processes personal data, in connection with its business activities, only for purposes related to such activities.

Your personal data collected through the channels and methods specified in this Clarification Text are processed by the Company for the purposes and on the legal bases set out below:

4. YOUR RIGHTS UNDER THE LAW

As personal data subjects, if you submit your requests regarding your rights through the Data Subject Application Form published at www.inovent.com.tr, or by using the methods specified in the Communiqué on the Procedures and Principles of Application to the Data Controller, the Company shall process and conclude your request free of charge, depending on the nature of the request, as soon as possible and in any event within thirty days at the latest. Within this scope, personal data subjects have the right to:

• learn whether their personal data are being processed;
• request information if their personal data have been processed;
• learn the purpose of the processing of their personal data and whether such personal data are used in accordance with the relevant purpose;
• know the third parties to whom their personal data are transferred, whether domestically or abroad;
• request correction of their personal data where such data have been processed incompletely or inaccurately, and request that the relevant correction be notified to third parties to whom the personal data have been transferred;
• request the deletion or destruction of their personal data where the reasons requiring their processing no longer exist, even though such personal data have been processed in accordance with the Law and other applicable legislation, and request that the relevant action be notified to third parties to whom the personal data have been transferred;
• object to the occurrence of a result against the data subject arising from the analysis of processed personal data exclusively through automated systems; and
• claim compensation for damages suffered as a result of the unlawful processing of personal data.

Our Website contains links to websites operated by third parties. The Company has no involvement in, or responsibility for, the policies and procedures applied by such third parties in relation to the processing of personal data.