HERA EĞLENCE VE MİMARİ AYDINLATMA SİSTEMLERİ İÇ VE DIŞ TİC. A.Ş.  DATA PROTECTION PRIVACY AND DATA SECURITY POLICY

This Privacy and Data Security Policy ("Privacy and Security Policy") of HERA EĞLENCE VE MİMARİ AYDINLATMA SİSTEMLERİ İÇ VE DIŞ TİC. A.Ş.. / Mersis: 0461 0616 2110 0001 (hereinafter referred to as "HERA LED" or the "COMPANY") has been prepared to regulate the principles and procedures regarding how we ensure the confidentiality and security of personal data processed by our organization in accordance with the requirements of the 10th Article of the Personal Data Protection Law No. 6698 ("PDPL") and the Communique on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform.

As HERA LED, we consider the implementation of the Information Security Policy as one of the vital processes of our organization. It is important for us that you are well aware of how we use your information, ensure your security, and protect your privacy during the use of our services. Therefore, we strongly recommend that you take the time to read our Privacy Policy carefully.

1. Processing of Personal Data of Data Subjects

As HERA LED, we process the personal data of visitors to our website ( www.heraled.com ) in order to protect the privacy and rights of our visitors, provide a better user experience, and use internet cookies. The Cookie Usage Policy ("Policy"), owned by our companies, is available on our website and explains the types of cookies used under what conditions to our visitors and users. This Policy is applicable regardless of how you connect to our Website.

Minors If you are under 18 years of age, you must visit the Website under the supervision of your parents. You should not use this Website without the supervision of your parents and should not share any of your personal data.

2. For what purposes do we process your personal data?

• To inform you about the activities and services related to the purpose and activities of "HERA LED" and its affiliated companies/organizations, to offer you the opportunity to benefit from their products, services, and opportunities related to their business areas,
• To use for the purposes of conducting business activities in line with the interests and policies of "HERA LED",
• To conduct statistical studies without disclosing the identity by evaluating personal data and information in order to improve services,
• To inform you about the information, events, and services you request,
• To process your personal data along with your preferences, transactions, and details obtained during your navigation on the channels where you log in to our website,
• To ensure the security of your personal data held by "HERA LED" and to transfer them for the purpose of preserving the security of your data,
• To process your personal data along with your preferences, transactions, and details obtained during your navigation on the channels where you log in to our website,
• To prevent data losses by making copies/backups,
• To manage applications and applications,
• To ensure the fulfillment of legal obligations as required or mandatory by legal regulations;
• For the purposes specified in the PDPL, personal data may be processed by "HERA LED" and affiliated companies/organizations by the other real and/or legal persons specified below.

3. Where are the parties to whom your personal data is transferred and what is the purpose of the transfer? Your personal data obtained by visiting our website may be transferred to our business partners, suppliers, legally authorized public institutions, and private individuals within the scope of the personal data processing conditions and purposes specified in Articles 8 and 9 of the PDPL.

4. What is the method and legal reason for collecting your personal data? Any information that identifies you or makes you identifiable is considered "personal data." Your personal data is collected through technical communication files called cookies on our website in accordance with the personal data processing conditions specified in Articles 5 and 6 of the PDPL when you visit our website.

5. Informing Data Subjects and Their Rights As a personal data subject, in accordance with Article 11 of the Law; you have the right to learn whether your personal data is processed, to request information if your personal data has been processed, to learn the purpose of processing your personal data, to know whether your personal data is used in accordance with its purpose, to know the third parties to whom your personal data is transferred domestically, to request correction of your personal data if it is incomplete or incorrectly processed, and to request notification of the correction made to third parties to whom your personal data has been transferred, to request the deletion or destruction of your personal data in case the reasons requiring its processing disappear, and to request the notification of the deletion or destruction made to third parties to whom your personal data has been transferred, to object to the occurrence of a result against you by analyzing your processed data exclusively through automated systems, and to demand compensation for the damage in case you suffer damage due to the processing of your personal data contrary to the law.

You can reach your applications regarding your rights listed in Article 11 of the PDPL by filling out the Relevant Person Application Form, which you can access on our website ( www.heraled.com ), or by sending it to "HERA LED" with another written document with the same content. Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and at the latest within thirty days; however, if the process requires an additional cost, a fee may be charged by you according to the tariff determined by the Personal Data Protection Board. You can review the Personal Data Processing and Protection Policy on the company's website for comprehensive information on the principles and procedures of protecting and processing your personal data. You can submit all your written requests to our postal address (Güllübağlar Mah. Firketeci Sk. No: 2 P.K:34906 Pendik/ISTANBUL/TÜRKİYE) or our e-mail address (info@heraled.com).

6. Access and Update of Information You can ensure that your contact information, preferences, and other personal data are accurate, complete, and up-to-date through our websites. Passwords, credit card information, or other personal data will never be requested from you by email. We aim to provide you with access to your personal data every time you use our services. If this information is incomplete or incorrect, we will process the necessary procedures to update or delete it (if we do not need to keep it for valid business or legal purposes). When updating your personal data, we may ask you to verify your identity first in order to fulfill your request.

7. Our Data Security Criteria "HERA LED" takes all necessary technical and administrative measures to prevent the illegal processing of personal data, prevent unauthorized access to personal data, and ensure the preservation of personal data, including special qualified personal data, in secure working environments accessible only by authorized "HERA LED" employees (within the scope of the Privacy Agreement with our employees), our agents, and our contractors. We authenticate users who store their personal data on the website or application before accessing this information. "HERA LED" takes all relevant measures, including administrative, technical, and physical measures, to protect your personal data from loss, theft, and misuse, as well as unauthorized access, sharing, alteration, and destruction.

8. Validity of Privacy and Security Policy Our Privacy and Security Policy is valid for all services offered by "HERA LED" (including advertising and research services, etc.).

9. Privacy Questions and Reminders Due to the constant changes in internet technologies and the lack of a fixed structure for internet-based business models, this policy is subject to change. Any changes to our Privacy and Security Policy, including this Policy, will be announced to our visitors through our websites and/or applications. To keep track of changes to our Privacy and Security Policy, we recommend and request that you periodically visit our website. If you have any questions or concerns about "HERA LED's" Privacy and Security Policy or information processing, please contact us.

10. Spam Emails Spamming is the sending of emails for advertising, marketing, or promotional purposes without your consent. As "HERA LED," we do not send spam emails. Sending unsolicited emails for advertising purposes without the consent of the other party is illegal. We do not use your personal data (including your email address) for direct marketing or advertising purposes without your permission. At the same time, we do not share your personal data with any third parties who will use your personal data for spam emails. Our websites, services, and applications offer you the opportunity to receive marketing information by email. Every email sent by "HERA LED" provides you with the opportunity to stop receiving marketing emails at any time. If you believe you have received spam email from "HERA LED" for any reason, please contact us immediately.

11. Legal Reasons and Others Disclosure of your personal data by "HERA LED" may be required in case of law, legal process, lawsuits, and/or requests from public authorities within our country. In accordance with the Law No. 6698 in an appropriate manner; When it is decided that the sharing is necessary or appropriate for the enforcement of national security and other laws or for other matters of importance to the public.

12. Effectiveness of Privacy and Data Security Policy The effective date of the Privacy and Data Security Policy is 26.12.2019. In case the entire Policy or specific articles are renewed, the effective date of the Policy will be updated. The Privacy and Data Security Policy is published on the internet site of "HERA LED" ( www.heraled.com ) and made accessible to the relevant persons upon their request.

Effective Date: 26.12.2019 
Publication Date: 26.12.2019
Version No./Document No: 1.1./PDPL.8.1. 
Revision Date: 24.01.2024

HERA EĞLENCE VE MİMARİ AYDINLATMA SİSTEMLERİ İÇ VE DIŞ TİC. A.Ş.  DATA PROTECTION PRIVACY AND DATA SECURITY POLICY

This Privacy and Data Security Policy ("Privacy and Security Policy") of HERA EĞLENCE VE MİMARİ AYDINLATMA SİSTEMLERİ İÇ VE DIŞ TİC. A.Ş.. / Mersis: 0461 0616 2110 0001 (hereinafter referred to as "HERA LED" or the "COMPANY") has been prepared to regulate the principles and procedures regarding how we ensure the confidentiality and security of personal data processed by our organization in accordance with the requirements of the 10th Article of the Personal Data Protection Law No. 6698 ("PDPL") and the Communique on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform.

As HERA LED, we consider the implementation of the Information Security Policy as one of the vital processes of our organization. It is important for us that you are well aware of how we use your information, ensure your security, and protect your privacy during the use of our services. Therefore, we strongly recommend that you take the time to read our Privacy Policy carefully.

1. Processing of Personal Data of Data Subjects

As HERA LED, we process the personal data of visitors to our website ( www.heraled.com ) in order to protect the privacy and rights of our visitors, provide a better user experience, and use internet cookies. The Cookie Usage Policy ("Policy"), owned by our companies, is available on our website and explains the types of cookies used under what conditions to our visitors and users. This Policy is applicable regardless of how you connect to our Website.

Minors If you are under 18 years of age, you must visit the Website under the supervision of your parents. You should not use this Website without the supervision of your parents and should not share any of your personal data.

2. For what purposes do we process your personal data?

• To inform you about the activities and services related to the purpose and activities of "HERA LED" and its affiliated companies/organizations, to offer you the opportunity to benefit from their products, services, and opportunities related to their business areas,
• To use for the purposes of conducting business activities in line with the interests and policies of "HERA LED",
• To conduct statistical studies without disclosing the identity by evaluating personal data and information in order to improve services,
• To inform you about the information, events, and services you request,
• To process your personal data along with your preferences, transactions, and details obtained during your navigation on the channels where you log in to our website,
• To ensure the security of your personal data held by "HERA LED" and to transfer them for the purpose of preserving the security of your data,
• To process your personal data along with your preferences, transactions, and details obtained during your navigation on the channels where you log in to our website,
• To prevent data losses by making copies/backups,
• To manage applications and applications,
• To ensure the fulfillment of legal obligations as required or mandatory by legal regulations;
• For the purposes specified in the PDPL, personal data may be processed by "HERA LED" and affiliated companies/organizations by the other real and/or legal persons specified below.

3. Where are the parties to whom your personal data is transferred and what is the purpose of the transfer? Your personal data obtained by visiting our website may be transferred to our business partners, suppliers, legally authorized public institutions, and private individuals within the scope of the personal data processing conditions and purposes specified in Articles 8 and 9 of the PDPL.

4. What is the method and legal reason for collecting your personal data? Any information that identifies you or makes you identifiable is considered "personal data." Your personal data is collected through technical communication files called cookies on our website in accordance with the personal data processing conditions specified in Articles 5 and 6 of the PDPL when you visit our website.

5. Informing Data Subjects and Their Rights As a personal data subject, in accordance with Article 11 of the Law; you have the right to learn whether your personal data is processed, to request information if your personal data has been processed, to learn the purpose of processing your personal data, to know whether your personal data is used in accordance with its purpose, to know the third parties to whom your personal data is transferred domestically, to request correction of your personal data if it is incomplete or incorrectly processed, and to request notification of the correction made to third parties to whom your personal data has been transferred, to request the deletion or destruction of your personal data in case the reasons requiring its processing disappear, and to request the notification of the deletion or destruction made to third parties to whom your personal data has been transferred, to object to the occurrence of a result against you by analyzing your processed data exclusively through automated systems, and to demand compensation for the damage in case you suffer damage due to the processing of your personal data contrary to the law.

You can reach your applications regarding your rights listed in Article 11 of the PDPL by filling out the Relevant Person Application Form, which you can access on our website ( www.heraled.com ), or by sending it to "HERA LED" with another written document with the same content. Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and at the latest within thirty days; however, if the process requires an additional cost, a fee may be charged by you according to the tariff determined by the Personal Data Protection Board. You can review the Personal Data Processing and Protection Policy on the company's website for comprehensive information on the principles and procedures of protecting and processing your personal data. You can submit all your written requests to our postal address (Güllübağlar Mah. Firketeci Sk. No: 2 P.K:34906 Pendik/ISTANBUL/TÜRKİYE) or our e-mail address (info@heraled.com).

6. Access and Update of Information You can ensure that your contact information, preferences, and other personal data are accurate, complete, and up-to-date through our websites. Passwords, credit card information, or other personal data will never be requested from you by email. We aim to provide you with access to your personal data every time you use our services. If this information is incomplete or incorrect, we will process the necessary procedures to update or delete it (if we do not need to keep it for valid business or legal purposes). When updating your personal data, we may ask you to verify your identity first in order to fulfill your request.

7. Our Data Security Criteria "HERA LED" takes all necessary technical and administrative measures to prevent the illegal processing of personal data, prevent unauthorized access to personal data, and ensure the preservation of personal data, including special qualified personal data, in secure working environments accessible only by authorized "HERA LED" employees (within the scope of the Privacy Agreement with our employees), our agents, and our contractors. We authenticate users who store their personal data on the website or application before accessing this information. "HERA LED" takes all relevant measures, including administrative, technical, and physical measures, to protect your personal data from loss, theft, and misuse, as well as unauthorized access, sharing, alteration, and destruction.

8. Validity of Privacy and Security Policy Our Privacy and Security Policy is valid for all services offered by "HERA LED" (including advertising and research services, etc.).

9. Privacy Questions and Reminders Due to the constant changes in internet technologies and the lack of a fixed structure for internet-based business models, this policy is subject to change. Any changes to our Privacy and Security Policy, including this Policy, will be announced to our visitors through our websites and/or applications. To keep track of changes to our Privacy and Security Policy, we recommend and request that you periodically visit our website. If you have any questions or concerns about "HERA LED's" Privacy and Security Policy or information processing, please contact us.

10. Spam Emails Spamming is the sending of emails for advertising, marketing, or promotional purposes without your consent. As "HERA LED," we do not send spam emails. Sending unsolicited emails for advertising purposes without the consent of the other party is illegal. We do not use your personal data (including your email address) for direct marketing or advertising purposes without your permission. At the same time, we do not share your personal data with any third parties who will use your personal data for spam emails. Our websites, services, and applications offer you the opportunity to receive marketing information by email. Every email sent by "HERA LED" provides you with the opportunity to stop receiving marketing emails at any time. If you believe you have received spam email from "HERA LED" for any reason, please contact us immediately.

11. Legal Reasons and Others Disclosure of your personal data by "HERA LED" may be required in case of law, legal process, lawsuits, and/or requests from public authorities within our country. In accordance with the Law No. 6698 in an appropriate manner; When it is decided that the sharing is necessary or appropriate for the enforcement of national security and other laws or for other matters of importance to the public.

12. Effectiveness of Privacy and Data Security Policy The effective date of the Privacy and Data Security Policy is 26.12.2019. In case the entire Policy or specific articles are renewed, the effective date of the Policy will be updated. The Privacy and Data Security Policy is published on the internet site of "HERA LED" ( www.heraled.com ) and made accessible to the relevant persons upon their request.

Effective Date: 26.12.2019 
Publication Date: 26.12.2019
Version No./Document No: 1.1./PDPL.8.1. 
Revision Date: 24.01.2024