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US BRAINWORKS Inc. Central Personal Data Protection Disclosure Text

This is the information text that we have prepared on how the personal data transmitted to US BRAINWORKS Inc. (hereafter will be referred to as US Brainworks Inc. in this information text.) can be protected and processed within the scope of the Personal Data Protection Law No. 6698 (“KVKK”). While preparing this text, the Personal Data Protection Law No. 6698 (“KVKK”) was taken into consideration as the legal basis. US Brainworks Inc., by sharing this information text, has also fulfilled its obligation to inform arising from Article 10 of the Personal Data Protection Law No. 6698 (“KVKK”). We would also like to state separately that the ‘DISCLOSURE ABOUT THE PROTECTION OF PERSONAL DATA’ text published by us will be subject to updates in case of changes in the legal legislation.

1. Definitions

• Personal Data: Any kind of information related to an identified or identifiable natural person,

• Processing of Personal Data: All kinds of activities performed on personal data from the collection to the deletion, destruction, or anonymization, including but not limited to obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, making them available, classifying, preventing their use,

• Law on the Protection of Personal Data (KVKK): Law No. 6698 on the Protection of Personal Data,

• Data Controller: Real or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system,

• Data Subject: The identified or identifiable natural person whose personal data is processed.

2. Principles Governing the Processing of Personal Data and Types of Data That Can Be Processed

Our company processes personal data in accordance with the following principles and in compliance with all legal principles for the protection of privacy:

• Compliance with the law and honesty,

• Being accurate and up-to-date when necessary,

• Processing for specific, explicit, and legitimate purposes,

• Being relevant, limited, and proportionate to the purposes for which they are processed,

• Being retained for the period required by the relevant legislation or for the purpose for which they are processed.

Our company, in line with the principles stated in the relevant legislation, can process the following types of data depending on the type and nature of the relationship between the Data Subject and our company:

• Data for identifying the data subject, such as name, surname, title, tax status, and information about parents, guardians, and representatives,

• Contact information such as home, business or temporary residence address, phone number, email, and fax number,

• Photograph, video, and audio recording,

• Corporate email correspondences, Corporate phone records,

• User access logs, Internet access logs,

• Camera images and entry-exit records, Magnetic card information,

• User account data and usage history on our online services,

• Meeting records, Reports, Audit Interviews.

Credit card, debit card, and virtual card information are not processed by our company.

3. Methods of Collecting Personal Data and Legal Basis for Processing

Personal data are collected electronically from individuals who fill out the email and membership form on the website www.brainworks.global. Your personal data are collected for the purpose of providing better service within the scope of the activities of US Brainworks Inc. Your personal data can be processed in line with the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law on the Protection of Personal Data, in accordance with the basic principles prescribed by the Personal Data Protection Authority, as stated in this Clarification Text.

4. Purpose of Processing Personal Data

Personal data processed by US Brainworks Inc. (name, surname, email address, mobile phone number, company address, corporate phone number, application reason, job application reason) are processed in compliance with the fundamental principles determined by the legislation and the Personal Data Protection Authority. Our processing purposes for personal data are as follows:

• Sending e-bulletins about US Brainworks Inc. activities, events, announcements related to its activities,

• Collecting applications from different user types such as staff, employer, investor on the brainworks.global website,

• Allowing individuals with user types as staff, employer, investor to define their needs/problems through US Brainworks Inc. contact information on the brainworks.global website, uploading documents,

• Allowing all users to view the needs/problems entered through US Brainworks Inc.,

• Allowing individuals with user types as staff, employer, investor to enter solution input, document uploads for the needs/problems entered by another user,

• Allowing the user who defined the need/problem to view the solution proposal of the user who entered the solution input and accept the solution proposal,

• Matching the user who defined the need/problem with the user who entered the solution input via the contact information of US Brainworks Inc.,

• Communicating with users who filled out forms on the brainworks.global website verbally or in writing,

• Facilitating communication with users,

• Improving satisfaction and service quality,

• Collecting and compiling statistical information,

• Delivering documents and information resulting from our services,

• Offering suggestions/offers to our users by the institutions with which an agreement is reached,

• Informing our users about our services,

• Evaluating complaints and suggestions regarding our services.

5. Storage of Personal Data

Personal data shared with US Brainworks Inc. is under the supervision and control of US Brainworks Inc. Necessary precautions for the security of information and data obtained physically or virtually by US Brainworks Inc. are stored by the company or relevant organization in systems or internet infrastructure, with suitable technical and administrative methods, depending on the nature of the information and data, including technological capabilities and cost factors.

6. Sharing of Personal Data and Purposes of Sharing

In accordance with Articles 8 and 9 of the Law on the Protection of Personal Data, US Brainworks Inc. may share your personal data to ensure the realization of the personal data processing purposes specified in this Clarification Text concerning the activities carried out by US Brainworks Inc.

Your personal data (name, surname, email address, mobile phone number, company address, corporate phone number, application reason, membership type) can be transferred to the parties when a match is provided between the user who entered the need/problem definition and the user who proposed a solution via the communication provided by US Brainworks Inc.

US Brainworks Inc. can process your personal data within Turkey or in a foreign country where personal data will be transferred, provided that sufficient protection exists in the relevant foreign country; if there is not sufficient protection in the relevant foreign country, US Brainworks Inc. and the relevant foreign data controllers may process and store them on servers or other electronic platforms abroad, provided that they provide sufficient protection in writing and obtain the permission of the Board.

In addition, your data can be shared with our legal and administrative processes by our legal advisors, financial advisors, shareholders, business partners, domestic/foreign subsidiaries that we receive services from to carry out our banking activities, domestic/foreign organizations that we cooperate with, domestic/foreign banks, and customer/member workplaces with which we have agreements, to ensure the execution of the legal and administrative processes.

7. Deletion of Personal Data

When determining the storage periods of your personal data, US Brainworks Inc. makes determinations in consideration of the legislation in force and the purposes of the data subject. In accordance with the Law on the Protection of Personal Data, your personal data processed for the purposes stated in this Clarification Text will be deleted, destroyed, or anonymized by US Brainworks Inc. on its own initiative or upon request of the relevant person, when the purpose requiring the processing of the data disappears, and/or when all periods including the statute of limitations, for the data to be processed in accordance with the relevant legislation, expire.

8. Maintenance of Your Personal Data Accurate and Up-to-Date

Those who share their personal data with our company acknowledge and declare that they know the importance of keeping this information accurate and up-to-date in terms of both the rights they have on personal data in terms of Law No. 6698 on the Protection of Personal Data and other relevant legislation and that the responsibilities arising from incorrect information will belong entirely to themselves. You can make the necessary notifications about changes and/or updates in your personal data by sending them to the contact address or our company’s address via physical mail.

Exceptional Situations:

US Brainworks Inc. may disclose information about users to third parties in the limited cases listed below:

• To comply with laws, Decree Laws, Regulations, etc. issued and in force by the competent legal authority,

• To fulfill the requirements of the user agreement and other contracts with our company and to implement them,

• To request information about users in accordance with a properly conducted investigation or investigation carried out by the competent administrative and judicial authority,

• When it is necessary to provide information for the protection of the rights or security of users.

9. Data Subject’s Application Methods and Your Rights

Individuals whose personal data are processed have the following rights in accordance with Article 11 of the Law on the Protection of Personal Data:

• Learning whether personal data is processed,

• Requesting information if personal data has been processed,

• Learning the purpose of processing personal data and whether they are used in accordance with their purpose,

• Knowing the third parties to whom personal data is transferred domestically or abroad,

• Requesting the correction of personal data if it is incomplete or incorrectly processed and requesting notification of the transactions made within this scope to third parties to whom personal data has been transferred,

• Requesting the deletion or destruction of personal data in case the reasons requiring its processing disappear, even if it has been processed in accordance with the Law on the Protection of Personal Data and other relevant laws, and requesting notification of the transactions made within this scope to third parties to whom personal data has been transferred,

• Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

• Requesting the compensation of the damage in case of damage due to the unlawful processing of personal data.

You can send your requests regarding your rights mentioned above to the Data Controller. You can send your information and application requests via the contact information on our website or in writing to the address of US Brainworks Inc. at “Alsancak Mah. 1483 Sok. No: 39/B Konak, Izmir” or to the registered email address info@brainworks.global.

US Brainworks Inc. will respond to your requests regarding your rights listed above within the shortest time and at the latest within thirty (30) days free of charge, depending on the nature of the request. However, if the operation requires an additional cost, the fee in the tariff determined by us, which is prescribed by the Personal Data Protection Board, will be charged.

Data Controller’s Identity

US BRAINWORKS INC.

Website: www.brainworks.global

Phone Number: +90 (232) 502 02 04

Email Address: info@brainworks.global

Address: Alsancak Mah. 1483 Sok. No: 39/B Konak, Izmir.