PRIVACY POLICY FOR OUR CUSTOMERS AND SUPPLIERS
Pursuant to Turkey regulations (Personal Data Protection), Vintage Tekstil as owner of all processing rights, hereby informs its customers and suppliers that all personal data provided for commercial purposes shall be processed only in compliance with the above mentioned Legislative Decree. The following information relates to data processing.

PERSONAL DATA
Personal data collected shall essentially relate to:

• identity data: company name or trading name, registered office, telephone and fax numbers,
  e-mail address, data for fiscal purposes etc.
• data relative to economic and commercial activity: orders, solvency, bank and financial data,
  accounting and fiscal data etc.

This data shall be provided directly from your side or may be collected from independent third parties appointed as owners of processing rights, like agents in case of contracts and orders as well as public registers and data banks for credit reports and financial solvency.

PURPOSES OF DATA PROCESSING
Your personal data shall be processed by Vintage Tekstil Ltd. for the following purposes:
1. execution of contracts and of all relevant obligations2. fulfillment of all legal obligations connected to the contract
3. management of the contract: all relations with agents and contractors for the management of all
activities to be carried out at customer’s premises
4. any possible external professional collaboration for the fulfillment of all legal obligations
5. protection of contractual rights
6. internal statistical analysis
7. marketing activities through the transmission of promotional and advertising material relative to
products or services which are similar to those which are the object of current commercial relations
8. information on the solvency of our customers.

SUBMISSION OF DATA
The submission of data and the related processing is mandatory in relation to purposes no. 1, 2 and 5, which are related to the fulfillment of contractual and legal obligations. The submission is also mandatory in relation to purposes no. 3 and 4, which relate to the execution by the undersigned of all activities that are necessary for the fulfillment of legal and contractual obligations. Any refusal to

supply data for these purposes may result in the impossibility for the undersigned to enter into contractual relations and to comply with legal obligations. The submission of data and the whole related processing shall be optional in all other situations.

DATA PROCESSING METHODS
Personal data shall be processed using manual and electronic means and shall be stored in the relevant data banks (customers, suppliers, administration, management) which may be accessed by employees in the commercial, production and administration department expressly designated by the undersigned as data processors and who may consult, use, process and compare the data and carry out any other operations, including automated operations, in compliance with all provisions of the law and guaranteeing, the confidential nature and security of data as well as the accuracy, the
updating and the relevance of data according to the declared purposes of data processing.

CATEGORIES WITH WHOM DATA MAY BE SHARED AND DISCLOSURE OF DATA 
In relation to purposes no. 1, 2 and 5 data may be shared with the following entities or categories of
entities:

• forwarding agents, for all aspects connected with the delivery of goods and all custom
  procedures
• banking institutes for the management of collection and payments
• financial administrations and other enterprises or public bodies while executing legal
  obligations

legal societies and law offices for the protection of contractual rights. For purposes no. 3 and 4 data may be shared with agents and brokers working for the undersigned, contractors, independent workers and customer companies. For purpose no. 6 data will not be shared with the exception of disclosure of statistics in an aggregate and anonymous form. For purpose no. 7, data shall not usually be shared, with the exception of communication to the agents of the undersigned dealing with the presentation or the transmission of material in those situations already authorized by the customer by express agreement.
For purpose no. 8, data may be shared with credit status agencies and companies. Personal data may not be disclosed.

DATA SUBJECT’S RIGHTS
In relation to the above mentioned purposes the data subject may exercise the rights detailed in Section 7 of Legislative Decree no. 196/2003 (full text in attachment) within the limits and in accordance with Sections 8, 9 and 10 of this Legislative Decree. Further information on the processing and sharing of personal data (directly submitted or otherwise acquired) may be obtained from the Administrative Office at company headquarters.

DATA CONTROLLER

Data controller is Vintage Tekstil Ltd. in the person of his Legal Representative, who is domiciled in the registered office of the undersigned for the purposes of this law. This document does not exclude the possibility for the undersigned to o rally share information during the collection of data. Legislative Decree no. 196/2003 Section 7 – Right to access personal data and other rights

1. A data subject shall have the right to obtain confirmation as to whether or not personal data
concerning him exist, regardless of their being already recorded, and communication of such data in
intelligible form.

2. A data subject shall have the right to be informed

a) of the source of the personal data;
b) of the purpose and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative
designated as per Section 5(2);
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

3.  A data subject shall have the right to obtain

a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purpose for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

4. A data subject shall have the right to object, in whole or in part
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

Section 9 – Mechanisms to Exercise Rights

1. The request addressed to the data controller or processor may also be conveyed by means of a registered letter, facsimile or e-mail. The Garante may specify other suitable arrangements with regard to new technological solutions. If the request is related to exercise of the rights referred to in Section 7(1) and (2), it may also be made verbally; in this case, it will be written down in summary fashion by either a person in charge of the processing or the data processor.

2. The data subject may grant, in writing, power of attorney or representation to natural persons, bodies, associations or organizations in connection with exercise of the rights as per Section 7. The data subject may also be assisted by a person of his/her choice.

3. The rights as per Section 7, where related to the personal data concerning a deceased, may be exercised by any entity that is interested therein or else acts to protect a data subject or for family- related reasons deserving protection.

4. The data subject’s identity shall be verified on the basis of suitable information, also by means of available records or documents or by producing or attaching a copy of an identity document. The person acting on instructions from the data subject must produce or attach a copy of either the proxy or the letter of attorney, which shall have been undersigned by the data subject in the presence of a person in charge of the processing or else shall bear the data subject’s signature and be produced jointly with a copy of an ID document from the data subject, which shall not have to be certified true pursuant to law. If the data subject is a legal person, a body or association, the relevant request shall be made by the natural person that is legally authorized thereto based on the relevant regulations or articles of association.

5. The request referred to in Section 7(1) and (2) may be worded freely without any constraints and may be renewed at intervals of not less than ninety days, unless there are well-grounded reasons.

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