FLEXIGO ULAŞIM SİSTEMLERİ A.Ş.

CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA

As FLEXİGO ULAŞIM SİSTEMLERİ ANONİM ŞİRKETİ (“flexigo” and/or “Company” and/or “Data Controller”), We present the clarification text that we have prepared in accordance with Article 10 of the Law on the Protection of Personal Data No. 6698 (“Law”) and contains information about the company's personal data processing activities.

ARTICLE 1: DATA CONTROLLER

Your personal data may be processed by flexigo in the capacity of data controller within the scope described below. What should be understood from the concept of data controller; is the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. You can use the following channels to contact the data controller:

Address           : 2450 Colorado Avenue, Suite 100E, Santa Monica, CA 90404

Phone              : +1.323.539.8255

E-mail             : hello@flexigo.com

Web Site         : https://www.flexigo.com

ARTICLE 2: PURPOSES OF PROCESSING PERSONAL DATA

Your Personal Data will be processed, recorded, rearranged, stored in a limited and measured manner, as you have informed us, within the framework of the purpose that requires processing, as specified in the relevant provisions regulated under the Personal Data Protection Law (“KVKK”). Personal Data shall also be shared with authorized public institutions and organizations as regulated in the Law.

Your personal data;

- In order to carry out the necessary work by our relevant business units for the realization of the commercial activities carried out by the Company and to carry out the related business processes, and to ensure the legal, technical and commercial-occupational safety of the Company and the persons who have a business relationship with the Company and for the purpose of planning and executing the commercial and/or business strategies of the Company, and also for the purpose of planning and executing the activities necessary for recommending and promoting the products and services offered by the company to the personal data owners by customizing them according to the tastes, usage habits and needs of the personal data owners or for the purposes stated here in below, shall be processed, transferred to domestic or abroad Flexigo shareholders, business and solution partners, suppliers, customers, employees, merchant assistants, representatives, classified and processed in other ways listed in the Law:

1. To be able to provide feedback to visitors who click on the campaigns that we will launch on the Web, social media, print and visual media channels, who want to direct the participants to the website or the relevant link or the Company, and to contact Us,
2. Performance evaluation processes and organization of these processes with business partners and suppliers or within the Company,
3. Carrying out our communication and public relations activities,
4. Providing advertisement, promotion, promotion and similar activities,
5. To be able to continue our commercial activities with our business partners and related persons,
6. Ensuring corporate communication and Company security,
7. To be able to perform statistical studies,
8. To be able to perform services, obligations, works and transactions within the scope of signed and/or committed contracts and protocols,
9. To ensure the fulfillment of legal obligations as required or mandated by legal regulations,
10. To contact real / legal persons who have a business relationship with the Company,
11. Managing call processes,
12. To fulfill the burden of proof as evidence in legal disputes that may arise in the future,
13. Execution/follow-up of Company legal affairs,
14. Informing, promoting products, offering suggestions, providing information about campaigns, promotions, discounts, offers, events, sweepstakes, contests and opportunity activities and Our services, being legally required to enable you to participate in campaigns,
15. Planning and implementing human resources policies in the best way,
16. Planning and execution of intern, student or employee procurement, placement and operation processes,
17. Providing bulk electronic message management and etcetera.

Within the framework of the legal obligation arising from the legislation related to the Law, your personal data, especially listed below, will be processed to enable the Company to fulfill its purposes and legal obligations:

• Name/surname, date of birth, gender, T.R. Identity number and similar non-specific identification information,
• Entry-exit, video, audio and similar security records kept during your visits to our Company headquarters,
• Mobile phone number, phone number, e-mail address, address, social media accounts, IP number, mobile application usage data,
• Navigation and click information on our Website, IP address, location information and the etc.,
• Bank account information and similar commercial and tax records to the extent and limits permitted by law,
• Cookie records, targeting information,
• Call records, commercial communication permission, used campaigns/competitions, order information.

ARTICLE 3: THE PARTIES THAT PERSONAL DATA MAY BE TRANSFERRED AND THE PURPOSE OF TRANSFER

Your Personal Data, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law may be shared with business partners and suppliers of the company, legally authorized institutions and organizations and legally authorized private law real and legal persons for:

- Planning and executing the activities necessary to recommend and promote the products and services offered by the company to the relevant persons by customizing them according to the tastes, usage habits and needs of the persons concerned,

- presenting campaigns and ensuring your participation in these campaigns,

- Carrying out the necessary work by the business units and executing the relevant business processes in order to benefit the relevant people from the products and services offered by the company,

- To carry out the necessary work by the relevant business units for the realization of the commercial activities carried out by the company and to carry out the related business processes,

- Planning and execution of the company's commercial and/or business strategies,

- The purposes of ensuring the legal, technical and commercial-occupational safety of the Company and the persons who have a business relationship with the Company.

ARTICLE 4: PERSONAL DATA COLLECTION METHODS AND LEGAL REASONS

Your personal data is collected through electronic media such as information and request forms on the websites, mobile application and social media, applications downloaded to smartphones, or in physical environments. The legal reasons for the collection and processing of personal data are as follows:

1. Storing personal data as it is directly related to the establishment and performance of contracts,
2. Storing personal data for the purpose of establishing, exercising or protecting a right,
3. It is obligatory to keep personal data for the legitimate interests of the company, provided that it does not harm the fundamental rights and freedoms of individuals,
4. Storing personal data for the purpose of fulfilling any legal obligations of the company,
5. Explicitly stipulating the storage of personal data in the legislation,
6. Explicit consent of data owners in terms of storage activities that require the explicit consent of data owners.

Your personal data shall be collected via the application forms you fill out through “linkedin”, “facebook”, “meta” and similar social media, the directions you accept and the like, are collected through e-mail, contact center, phone call, whatsapp, telegram, SMS and similar messaging communication. In addition, our Company's websites and micro-websites, our Company's social media accounts, information or forms that you will share with our business partners and customers are also collected through fax, CCTV or other physical channels. The relevant collection process is carried out in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law and the purposes specified in this Clarification Text.

ARTICLE 5: SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

Your personal data can be transferred, in line with the above-mentioned purposes and to the extent required by the purpose, in case it is necessary to continue the company's activities within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law;

- to our domestic or foreign company partners, employees, merchant assistants and representatives,

- to our customers with whom we provide services within the framework of contracts, or to our customers' customers and their employees,

- to our suppliers and other service providers, as well as legally authorized public institutions and/or private individuals.

ARTICLE 6: COOKIE POLICY

We use Cookies so that you can make the most of our website and improve your user experience. If you do not prefer the use of cookies, you can delete or block Cookies from your browser's settings. However, we would like to remind you that this may affect your use of our website. Unless you change your Cookie settings in your browser, we will assume that you accept the use of cookies on this site.

WHAT IS A COOKIE AND WHY IS IT USED?

Cookies are small text files that are stored on your device or network server via browsers by the websites you visit.

The main purposes of using cookies on our website are listed below:

• To improve the services offered to you by increasing the functionality and performance of the website,
• To improve the Website and to offer new features on the Website and to customize the features offered according to your preferences;
• To ensure the legal and commercial security of the Website, you and our Company.

CONTROLLING AND DELETING COOKIES

To change your preferences for the use of cookies or to block or delete cookies, simply change your browser settings. Many browsers give you the option to accept or reject cookies, to only accept certain types of cookies, or to be alerted by the browser when a website requests to store cookies on your device so you can control cookies. It is also possible to delete cookies previously saved in your browser. The process of controlling or deleting cookies may vary depending on the browser you use. You can find the instructions for allowing or blocking or deleting cookies of some popular browsers from the link below.

ARTICLE 7: RIGHTS OF DATA OWNERS

The natural person whose personal data is processed is defined as the data subject and has the following rights regarding himself/herself by applying to the Company:

1. Right to learn whether personal data is processed or not,
2. If personal data has been processed, right to request information about it,
3. Right to learn the purpose of processing personal data and whether they are used in accordance with the purpose,
4. d. Right to know the third parties to whom personal data is transferred at home or abroad,
5. h. Right to request correction of personal data if it is incomplete or incorrectly processed,
6. Right to request the deletion or destruction of personal data,
7. Right to request notification of the transactions made pursuant to subparagraphs (e) and (f) to third parties to whom personal data has been transferred,
8. Right to object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
9. Right to request the compensation of the damage in case of loss due to the unlawful processing of personal data.

You can submit your applications regarding your rights listed above to the Data Controller by filling out the Data Owner Application Form, which you can access via the internet address www.flexigo.com or through our Company address or other communication channels, or upon your application to hello@flexigo.com. If the transaction also requires a cost, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Board. You can access detailed information about the purposes of processing your personal data by us at www.flexigo.com.

Best regards,

FLEXİGO ULAŞIM SİSTEMLERİ A.Ş.