Personal Data Protection and Processing Policy

The scope of the data processing activity carried out by IXPANSE TEKNOLOJİ LTD. ŞTİ. (“IXPANSE” or the “Company”), acting in the capacity of data controller pursuant to the Turkish Law on the Protection of Personal Data, No:6698 (“Law”), is explained below:

I. What is the Methodology and the Legal Ground of Obtaining Your Personal Data?

When you visit or interact with our Site, we may collect Personal Data such as:

Contact Information, including your name, physical address, email address, telephone number, fax number, organization name, or job title;
Device Information, including browser and device type, IP address, internet service provider, and other technical information about your device;
Website Interactions, including information about your interactions with our Site, such as referring websites, pages visited, links or buttons clicked, or language preferences;
Communication Records, including call recordings, email exchanges, text details, and chat logs from your communications with us, which we may keep as records of those conversations;
Social Media Information, including social media name, profile, and any direct messages exchanged with us; and
Other information you voluntarily provide to IXPANSE.

Your Personal Data may also be collected through Automated Means, such as:

Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit or interact with our Site.

Cookies and Other Tracking Technologies: We may use cookies, web beacons/pixel tags, and other tracking technologies (collectively, "cookies") to recognize you when you visit our Site. Cookies are small bits of data cached or stored on your computer. These cookies may be delivered in a first-party or third-party context. For example, we may collect information about your browser type and version, operating system, user language, viewed web pages, links that are clicked, IP address, screen resolution, and web pages visited before and after visiting our Site. Our emails to you also may contain tracking technologies to help us understand when you open an email or click links within it.

By collecting this information, we can better understand how you interact with our Site; give you a more personal and optimized online experience by recognizing your preferences; improve our Site; fulfill contracts with our business partners; help confirm receipt of and response to our emails; and provide more effective customer service.

Your personal data is collected to conduct our activities and to ensure compliance with the relevant legislation and Company policies based on the legal requirements.

Your personal data may also be processed and transferred in accordance with the fundamental principles regulated by the Law for the purposes set out under this Information Notice in accordance with the personal data processing requirements and purposes set forth in Articles 5 and 6 of the Law.

II. For What Purposes Do We Use and Process Your Personal Data?

To perform the necessary operations and transactions of our company, to ensure that we conduct our commercial activities in accordance with the legislation and Company policies;
To determine, plan and implement the short, medium and long term commercial policies of IXPANSE;
To plan and perform human resources activities and all type of accounting-banking-finance and legal operations of/in the name and on behalf of IXPANSE;
To give support to the IXPANSE affiliated companies for planning and executing their human resources activities;
To ensure the commercial and legal security of IXPANSE, IXPANSE affiliated companies and the persons involved in business relations;
To protect the commercial standing of and trust created by IXPANSE.

III. To Whom and For What Purposes Do We Transfer Your Personal Data?

Within the scope of the purposes stated below and in accordance with the fundamental principles stated under the Law, and pursuant to the legal grounds and purposes of processing that are stated in Articles 8 and 9 of the Law, your personal data may be transferred to our business partners, suppliers, IXPANSE affiliated companies, shareholders, public institutions, and private persons that are authorized by law:

To perform the necessary operations and transactions of our company, to ensure that we conduct our commercial activities in accordance with the legislation and Company policies;
To determine, plan and implement the short, medium, and long term commercial policies of IXPANSE;
To plan and perform human resources activities and all type of accounting-banking-finance and legal operations of/in the name and on behalf of IXPANSE;
To give support to the IXPANSE affiliated companies for planning and executing their human resources activities;
To ensure the commercial and legal security of IXPANSE, IXPANSE affiliated companies and the persons involved in business relations;
To protect the commercial standing of and trust created by IXPANSE.

We may disclose your personal data to the following recipients and purposes:

Affiliates. Our affiliates, in the ordinary course of business, only use your Personal Data for the purposes described in the previous section of this Privacy Policy.
Service Providers. We engage contractors, suppliers, and other vendors who provide services on our behalf and at our instruction, such as assisting with processing and fulfilling orders; delivery and logistics; data storage; fraud prevention; data and Site analytics, including the placement and use of cookies; our communications and direct marketing; advertising and marketing, including the effectiveness of our advertising and marketing efforts; or other services in support of our business, such as, but not limited to, accounting, banking and legal.

We may use and disclose any Personal Data as reasonably necessary to comply with law and legal requirements, cooperate with and respond to law enforcement requests, or as otherwise required by applicable law, court order, or government regulations. We also use Personal Data we collect as necessary to maintain appropriate records for internal administrative purposes, to protect our rights and interests or those of others, to resolve any disputes, to enforce our policies, or to prevent harm. Any Personal Data we collect may be provided to our professional advisors, including accountants, auditors, consultants, and lawyers, when reasonably necessary for our professional advisors to perform services for us and give us appropriate advice. Any and all Personal Data we collect may be given to another company in the unlikely event of a sale, merger, or other acquisition of some or all of our assets or business or as part of the negotiation or evaluation of such sale, merger, or other acquisition.

IV. What are Your Rights as a Data Subject Regulated under Article 11 of the Law?

In accordance with Article 11 of the Law, you are entitled to:

Learn whether your personal data are being processed;
Request further information if your personal data have been processed;
Learn the purpose of processing of your personal data and whether your personal data are being processed in accordance with such purpose;
Learn the third-party recipients to whom your personal data are disclosed within the country or abroad;
Request rectification of your personal data that is incomplete or inaccurate and to request notifying the third persons, to whom your personal data are disclosed, about the rectification process;
Despite being processed in accordance with the provisions of the Law or other related laws; request erasure or destruction of your personal data upon disappearance of the grounds of the process and request notifying the third persons, to whom your personal data are disclosed, about the erasure or destruction processes;
Object to negative consequences about you that arise as a result of analysis of your personal data made by solely automatic means;
Demand compensation for the damages that you have suffered as a result of an unlawful processing operation.

You may exercise your rights by filling out the Data Subject Request Form which can be accessed via our website (https://ixpanseteknoloji.com.tr)

Depending on the content of your request, our Company shall conclude your request as soon as possible and within thirty (30) days at the latest and free of charge. However, if this activity requires a cost, you will be charged from the rate determined by the Personal Data Protection Board.

IXPANSE TEKNOLOJİ LİMİTED ŞİRKETİ

Last Update: 19.10.2026