Protection of Personal Data and Privacy Policy

As NOVVES ELEKTRİK MOTOR ANONİM ŞİRKETİ (“NOVVES”, “Company”, “we”); We attach importance to the privacy and security of the personal data of our customers, suppliers, business partners, employees, prospective employees, visitors, website users and all people who contact us.

This Personal Data Protection and Privacy Policy; It has been prepared to explain the purposes for which your personal data is processed, on what legal grounds it is based, with whom it can be shared, for how long it can be stored, and the rights you have as a data owner, within the scope of the Personal Data Protection Law No. 6698 (“KVKK”), the European Union General Data Protection Regulation (“GDPR”), state-based privacy regulations in the United States of America and other relevant data protection legislation to the extent applicable.

NOVVES; processes personal data in accordance with the law and the rules of honesty, accurately and, when necessary, up to date, in line with specific, clear and legitimate purposes, in connection with the purpose for which they are processed, in a limited and measured manner. Personal data are retained for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed.

This policy is the main umbrella text explaining NOVVES' general privacy and personal data protection approach. Special texts or forms may also be published for website visitors, cookie usage, customer and partner processes, product security contact point and contact person applications.

Your personal data is processed by NOVVES ELEKTRİK MOTOR ANONİM ŞİRKETİ, whose information is given below, as the data controller.

Company Title: NOVVES ELEKTRİK MOTOR JOINT STOCK COMPANY

Address: Taşköprü Merkez Mah. Çaydere St. No:9/1 İç Kapı No:2 Çiftlikköy / YALOVA

Phone: 0216 467 47 52

E-posta: info@novves.com

KEP Adresi: novveselektrik@hs01.kep.tr

Tax Office: Yalova

Tax Identification Number: 6320968919

Trade Registry Number: 9358

MERSİS No: 0632-0968-9190-0002

Website: www.novves.com

KEP adresi; resmi başvurular, hukuki bildirimler ve güvenli elektronik tebligat süreçleri için kullanılabilecek resmi iletişim kanalıdır. Genel bilgi ve iletişim talepleriniz için info@novves.com adresi üzerinden de Şirketimizle iletişime geçebilirsiniz.

This policy may cover the following groups of people:

• website visitors
• Customers and potential customers
• Dealers, representatives and business partners
• Suppliers and service providers
• Project stakeholders, consultants and technical teams
• People visiting company facilities, offices, trade show stands or event venues
• Employees and employee candidates
• People who contact NOVVES via e-mail, phone, form, social media or other channels
• Individuals who submit product safety, technical support, service, maintenance, warranty or documentation requests

The following categories of personal data may be processed by NOVVES, depending on the nature of the relationship and the purpose of processing.

Your personal data may be processed for the following purposes:

• Provision of products and services offered by NOVVES
• Execution of offer, order, sales, delivery, service, maintenance, warranty and after-sales support processes
• Carrying out project-based engineering, field exploration, technical analysis, product selection and solution development processes
• Managing customer, supplier, dealer, representative and business partner relationships
• Establishment and execution of contracts and fulfillment of contractual obligations
• Carrying out finance, accounting, invoicing, collection and payment processes
• Carrying out logistics, shipping, customs, export and import operations
• Carrying out product safety, quality control, testing, certification and technical documentation processes
• Evaluation of product safety notifications, technical support requests and nonconformity notifications
• Conducting human resources, recruitment, employee management, payroll and occupational health and safety processes
• Ensuring the physical security of company facilities, employees, visitors and business processes
• Execution of information security, system management, access control, logging and cyber security processes
• Secure operation of the website, digital platforms and communication channels
• Carrying out customer satisfaction, corporate communication, demand and complaint management processes
• Carrying out marketing, promotion, fair, event, catalogue, campaign and commercial communication activities
• Fulfilling legal storage, reporting, auditing and informing obligations to official institutions
• Ensuring the legal, commercial, technical and operational security of NOVVES
• Preventing disputes, carrying out legal processes and protecting rights

Your personal data may be processed based on the following legal reasons specified in the relevant legislation, especially Articles 5 and 6 of the KVKK:

• It is clearly provided for in the law
• Processing of personal data is necessary for the establishment or performance of a contract
• Data processing is mandatory for our company to fulfill its legal obligations
• Data processing is mandatory for the establishment, exercise or protection of a right
• Data processing is mandatory for the legitimate interests of our Company, provided that it does not harm your fundamental rights and freedoms.
• It has been made public by the person concerned
• Having your explicit consent

personal data in respect of persons within the scope of the European Economic Area, the European Union or the GDPR; It is processed in accordance with legal bases such as performance of the contract, legal obligation, legitimate interest, explicit consent, public interest and vital interest.

In cases where it is necessary for marketing, commercial electronic messages, analytical cookies, advertising cookies or other transactions requiring explicit consent, your express consent or relevant electronic message permission is also obtained.

Your personal data may be collected by automatic or non-automatic methods through the following channels:

• Website contact, quote, catalogue, application and support forms
• Email, phone, social media and other digital communication channels
• Sales, offer, order, contract, invoice and delivery processes
• Fairs, events, meetings, field visits and business development meetings
• Customer, dealer, representative, supplier and business partner communications
• Human resources application processes
• Company offices, production facilities, security cameras and visitor records
• ERP, CRM, accounting, quality, production, service and digital business management systems
• Authorized public institutions, suppliers, business partners and service providers
• Product safety, technical support, service and maintenance notifications

Your personal data may be shared with the following persons and organizations, limited to the processing purposes and in accordance with the relevant legislation:

• Authorized public institutions and organizations
• Courts, enforcement offices, law enforcement units and legal authorities
• Financial advisors, independent auditors, legal advisors and consulting service providers
• Banks, payment institutions and financial service providers
• Suppliers, logistics companies, cargo companies, customs brokers and foreign trade service providers
• Software, cloud, hosting, email, cybersecurity, ERP, CRM and information technology service providers
• Dealers, representatives, business partners and project stakeholders
• Certification, testing, quality control, accreditation and technical inspection organizations
• Insurance companies and occupational health and safety service providers
• Authorized persons and organizations involved in product safety, service, maintenance and technical support processes

Your personal data is transferred only to the extent necessary and in accordance with the relevant legal conditions.

NOVVES can work with customers, suppliers, representatives, business partners and digital service providers operating on a global scale. For this reason, some personal data may be transferred to service providers, business partners, technical stakeholders or authorized institutions abroad, depending on the nature of the business.

Data transfer abroad; It is carried out in accordance with the conditions stipulated in KVKK, GDPR and other applicable data protection legislation. Where necessary, explicit consent, standard contract provisions, adequacy decisions, letters of undertaking or other assurance mechanisms provided for in the relevant legislation are applied.

NOVVES implements reasonable technical and administrative measures to protect the confidentiality, integrity and availability of personal data.

In this context, the following measures can be taken:

• Authorization and access control
• Password, authentication and user authorization management
• Firewall, antivirus, logging and monitoring systems
• Data backup and business continuity measures
• Physical security, visitor records and camera security
• Privacy commitments and employee awareness studies
• Supplier and service provider security checks
• Encryption, masking, anonymization or data minimization when necessary
• Reasonable safeguards against unauthorized access, data loss, misuse and cybersecurity risks

NOVVES takes into account the principles of ISO/IEC 27001 Information Security Management System and ISO/IEC 27701 Privacy Information Management System in its information security and privacy management processes. This statement does not mean that the Company is certified to the relevant standards unless further stated.

Your personal data is stored for the periods stipulated in the relevant legislation or for the period necessary for the purpose for which they are processed.

When determining storage periods, the following criteria are taken into account:

• Storage periods stipulated in relevant laws
• Tax, trade, labor, social security, occupational health and safety legislation
• Continuation of the contractual relationship
• Warranty, service, maintenance and after-sales support obligations
• Product safety, technical documentation and quality processes
• Dispute, lawsuit, enforcement and limitation periods
• Legitimate business and operational needs

Personal data whose storage period has expired or the purpose of processing has ceased; It is deleted, destroyed or anonymized in accordance with the relevant legislation.

Cookies and similar technologies may be used on the NOVVES website to improve user experience, measure site performance, ensure security and carry out digital marketing activities.

Mandatory cookies are used to ensure the secure and proper functioning of the website. Analytical, performance, advertising and marketing cookies are used when necessary, depending on your preferences or explicit consent.

Detailed information about cookies is provided through a separate "Cookie Policy" to be published on our website.

NOVVES can contact you about products, solutions, catalogues, fairs, events, campaigns and corporate announcements.

Commercial electronic messages; It is sent in accordance with the relevant legislation and, where necessary, based on your prior permission. If you do not want to receive commercial electronic messages, you can use the opt-out methods included in the messages or contact us.

In accordance with Article 11 of the KVKK, you have the following rights as a personal data owner:

• Learning whether your personal data is being processed or not
• Requesting information if your personal data has been processed
• Learning the purpose of processing your personal data and whether it is used in accordance with its purpose
• Knowing the third parties to whom your personal data is transferred domestically or abroad
• Request correction of your personal data if it is incomplete or incorrectly processed
• Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in KVKK
• Requesting correction, deletion or destruction to be notified to third parties to whom your personal data has been transferred
• Object to the emergence of a result against you by analyzing the processed data exclusively through automatic systems
• Request compensation for the damage if you suffer damage due to unlawful processing of your personal data.

Persons covered by the GDPR may have the following rights, as far as applicable:

• Right to access personal data
• Right to request correction of personal data
• Right to request deletion of personal data
• Right to request restriction of processing
• Right to data portability
• Right to object to processing based on legitimate interest
• The right to withdraw consent in processing activities based on explicit consent
• Right to object to automated decision-making and profiling
• Right to lodge a complaint with the relevant supervisory authority

In the United States, data protection legislation may differ on a state-by-state basis. If applicable, particularly under regulations such as the California Consumer Privacy Act / California Privacy Rights Act, users may have the following rights:

• Learn what personal information is collected
• Request access to personal information
• Request deletion of personal information
• Request correction of inaccurate information
• The right to opt out of certain data sharing or sales
• Request restriction of use of sensitive personal information
• The right not to be discriminated against for exercising privacy rights

NOVVES does not adopt selling personal data as a core business model. However, since the use of digital advertising, analytics or third-party cookies may be considered within the scope of "sharing", "targeted advertising" or similar concepts according to the relevant legislation, these transactions are also managed by cookie preferences and open consent mechanisms.

NOVVES does not analyze your personal data exclusively through automatic systems and processes it for the purpose of making decisions that will have legal consequences against you or have a similarly significant impact.

In case of limited analysis such as website usage statistics, cookies, marketing preferences or customer segmentation, these processes are carried out in accordance with the relevant legislation and, where necessary, with explicit consent or preference management mechanisms.

NOVVES' products and services are aimed primarily at commercial, industrial and professional users. NOVVES does not knowingly collect personal data of children or conduct marketing activities towards children.

If it is determined that children's personal data have been processed inadvertently, the necessary deletion, destruction or anonymization processes are applied in accordance with the relevant legislation.

The NOVVES website may contain links to third-party websites, social media platforms, document download areas or external digital services.

NOVVES is not responsible for the privacy practices, content or data processing activities of third party sites. You are advised to review the privacy policies of the relevant third parties before visiting these sites.

You can forward your requests regarding your personal data to NOVVES through the following communication channels:

Resmi Başvuru ve Bildirimler İçin KEP: novveselektrik@hs01.kep.tr

Genel İletişim E-postası: info@novves.com

Phone: 0216 467 47 52

Postal Address: Taşköprü Merkez Mah. Çaydere St. No:9/1 İç Kapı No:2 Çiftlikköy / YALOVA

Your application must include your name, surname, contact information, the subject of your request and information that will verify your identity. NOVVES evaluates and finalizes the applications within the periods stipulated in the relevant legislation.

For your security, additional information or documentation may be requested to verify that your request is yours. During this process, only the information required for authentication is requested.

NOVVES may update this Personal Data Protection and Privacy Policy from time to time in line with legislative changes, operational needs, digital system updates or changes in business processes.

The current policy comes into force on the date it is published on www.novves.com.

You can contact us for your questions regarding the protection of your personal data and privacy processes.

NOVVES ELEKTRİK MOTOR ANONİM ŞİRKETİ

Address: Taşköprü Merkez Mah. Çaydere St. No:9/1 İç Kapı No:2 Çiftlikköy / YALOVA

Phone: 0216 467 47 52

E-posta: info@novves.com

KEP: novveselektrik@hs01.kep.tr

Web: www.novves.com

NOVVES sees the protection of personal data as an integral part of corporate trust in its engineering, production, testing, sales, service and global business development activities.