ASAKUA

This is an English translation of the Turkish original. In case of any discrepancy, the Turkish version shall prevail.

PRIVACY POLICY

Notice on the Protection of Personal Data

As Asakua Aquaculture Construction Industry and Foreign Trade Ltd. Co. (“Asakua”), we attach great importance to the security of your personal data. In this regard, including the privacy of private life, we wish to inform you in the most transparent manner — as Data Controller — about the methods of collection, the purposes of processing, the legal grounds of processing and your rights, in accordance with the Turkish Personal Data Protection Law (KVKK), Law No. 6698, enacted to protect the fundamental rights and freedoms of all persons related to our company, including those who benefit from our products and services.

Brief definitions from the legislation:

Personal data: Any information relating to an identified or identifiable natural person.

Processing of personal data: Any operation performed on data — such as collection, recording, storage, retention, alteration, restructuring, disclosure, transfer, takeover, making available, classification or blocking of use — by fully or partially automated means or by non-automated means provided that it forms part of any data registry system.

Data processor: A natural or legal person who processes personal data on behalf of the Data Controller, based on the authorization granted by the Data Controller.

Data registry system: The registry system in which personal data is processed by being structured in accordance with specific criteria.

Data Controller: The natural or legal person who determines the purposes and means of processing personal data, and who is responsible for the establishment and management of the data registry system.

A. PURPOSE OF THE POLICY ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

As Asakua Aquaculture Construction Industry and Foreign Trade Ltd. Co. (“Asakua”), in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”), through this “Notice” prepared in our capacity as Data Controller, within the framework of KVKK Article 10 titled “Obligation of the Data Controller to Inform” and Article 11 titled “Rights of the Data Subject”, we explain to you:

  1. What types of personal data the Company processes and the purpose of processing such personal data;
  2. How this personal data is used;
  3. The methods and legal grounds of collecting your personal data;
  4. Your rights regarding the personal data processed by the Company and how you may exercise these rights.

As Data Controller, we process, record, transfer, share and store your personal data as explained below and within the limits prescribed by official legislation.

Our Company reserves the right to update this “Notice on the Protection of Personal Data” at any time within the framework of any changes that may be made to the applicable official legislation.

B. COLLECTION, PROCESSING AND PURPOSES OF PROCESSING OF PERSONAL DATA

Your personal data is collected and processed by our Company operating in the fields detailed in its articles of association, verbally, in writing or electronically, due to such activities, and as a result of the regulations of other relevant institutions and the agreements we have concluded. This personal data is used for the purpose of providing services related to our Company’s fields of activity and improving the quality of these services, carrying out our Company’s sales, marketing and other activities, and complying with our obligations of information retention, reporting and notification. Your personal data may also be used in the context of efforts such as improving the quality of the services we offer to you and our sales and marketing activities.

Your personal data will not be used outside the purposes stated above without your explicit consent, and will not be shared with or transferred to third parties except for legal obligations and official institutions/organizations.

Our Company may share such personal data only with our domestic or foreign affiliates and direct or indirect subsidiaries and joint ventures, or with public institutions or organizations authorized by legal obligation to request such data, and provided that adequate measures are taken, with domestic or foreign institutions, suppliers, authorized dealers/distributors/business partners with whom we have agreements as required by our activities — based on the explicit consent of customers or in other cases provided for in KVKK Article 5(2), particularly in the legislation we are subject to, for the purposes of providing value-added services, opportunities and benefits to our customers and improving service quality.

Although your personal data may vary depending on the services, products or commercial activities provided by our Company, it may be collected verbally, in writing or electronically through automated or non-automated methods, including offices, branches, dealers, call centers, the website, social media channels, mobile applications and similar means. As long as you benefit from our Company’s products and services, your personal data may be processed by being created and updated.

In addition, with the intent of using our Company’s services, your personal data may be processed:

  1. When you use our call center or website,
  2. When you visit our Company, our website or our social media channels/platforms,
  3. When you participate in trainings, seminars or organizations arranged by our Company.

Your personal data obtained with your consent or pursuant to other lawfulness grounds set forth in the laws of the Republic of Türkiye may be processed within the scope of the personal data processing conditions and purposes specified in KVKK Articles 5 and 6, by our Company and its affiliated companies/organizations and by other natural and/or legal persons specified under paragraph (C) below, for the following purposes:

  1. To enable our business units to carry out the work necessary to make you benefit from the products and services offered by our Company;
  2. To customize and recommend the products and services offered by our Company according to your preferences, usage habits and needs;
  3. To ensure the legal and commercial security of our Company and the persons who have business relations with our Company (administrative operations for communication carried out by our Company, ensuring the physical security and supervision of the locations belonging to the Company, evaluation processes of business partner/customer/supplier — authorized persons or employees, legal compliance process, financial affairs, etc.);
  4. To improve the quality of the services offered by our Company and to develop our quality policy;
  5. To inform you of and enable you to benefit from our Company’s general and special campaigns, promotions, advertisements, discounts and similar advantages;
  6. To provide you with information regarding the information, events and services you may request from our Company;
  7. To determine and implement our Company’s commercial and business strategies;
  8. To carry out our Company’s human resources policies; and
  9. To fulfill a legal obligation expressly stated in legislation or specified by legislation when required.

B.1. COOKIE POLICY

When you visit our website, the following cookies and analytics tools may be used:

  • Vercel Analytics: Collects page-view statistics anonymously; does not use cookies and does not contain personal data. Required for site operation and does not require your consent.
  • Vercel Speed Insights: Measures page load performance; does not use cookies and does not contain personal data. Required for site operation and does not require your consent.
  • Google Analytics 4: Used to collect detailed visit statistics. Activated only with your explicit consent; if you do not consent, no cookie is written and no data is collected. Your IP address is anonymized.
  • Cloudflare Turnstile: Used for bot protection on the contact form; required for site security and does not require your consent.

You may change your cookie preferences at any time via the “COOKIE SETTINGS” link at the bottom-right corner of the page.

C. METHOD AND LEGAL GROUNDS OF COLLECTING PERSONAL DATA

Your personal data is acquired in any verbal, written or electronic environment, in line with the purposes specified in the above paragraphs, so that our Company can offer its products and services within the prescribed legal framework and so that our Company can fulfill its contractual and statutory responsibilities completely and accurately.

The personal data collected on this legal basis is processed, recorded, transferred, shared and stored within the scope of the personal data processing conditions and purposes specified in KVKK Articles 5 and 6, for the purposes specified under paragraph (B) of this notice.

D. PROCESSING OF SPECIAL-CATEGORY DATA

Under the KVKK, data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership of an association, foundation or trade union, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data, are special-category personal data. In the processing of special-category personal data, our Company additionally takes the measures determined by the Personal Data Protection Authority at a sufficient level. In order to provide better services, our Company will only process the special category data of individuals by obtaining the consent of the relevant person and only to serve the purpose of collection.

E. TO WHOM AND FOR WHAT PURPOSE PROCESSED PERSONAL DATA MAY BE TRANSFERRED

Your collected personal data may be transferred to our shareholders, business partners, suppliers, legally authorized public institutions and private persons within the framework of the personal data processing conditions and purposes specified in KVKK Articles 8 and 9, in order to serve the purposes specified in paragraph (B).

F. TRANSFER OF PERSONAL DATA ABROAD

Within the conditions determined by the Personal Data Protection Authority under the KVKK, our Company is authorized to transfer personal data abroad in compliance with other conditions of the law and after obtaining the explicit consent of the person for that purpose.

G. RIGHTS OF THE DATA SUBJECT LISTED IN KVKK ARTICLE 11

Within the scope of the KVKK, we acknowledge that the data subject has the right to be informed and consent before personal data is processed, recorded, transferred, shared and stored, and that, after the data is processed, recorded, transferred, shared and stored, has the right to determine the fate of the data.

Within this framework, if you, as data subjects, submit your requests regarding your rights to our Company through the methods set out below in this “Notice on the Processing of Personal Data”, our Company shall conclude the request free of charge within thirty (30) days at the latest, depending on the nature of the request.

Pursuant to the Communiqué on Application Procedures and Principles to the Data Controller published by the Personal Data Protection Authority:

  1. If your application is to be answered in writing, no fee shall be charged for up to ten pages. A processing fee of 1.00 TRY may be charged for each page exceeding ten pages.
  2. If the response to the application is provided on a recording medium such as CD or flash memory, the fee that may be requested by our Company as Data Controller shall not exceed the cost of the recording medium.
  3. In this scope, data subjects have the right to:
    1. Learn whether their personal data is processed;
    2. Request information if their personal data has been processed;
    3. Learn the purpose of processing personal data and whether they are used in accordance with their purpose;
    4. Know the third parties to whom personal data is transferred domestically or abroad;
    5. Request the correction of personal data in case of incomplete or incorrect processing, and request that the action taken in this scope be notified to the third parties to whom the personal data has been transferred;
    6. Request the deletion, destruction or anonymization of personal data within the framework of the conditions provided for in KVKK Article 7, and request that the action taken in this scope be notified to the third parties to whom the personal data has been transferred;
    7. Object to the occurrence of a result against the person themselves through the analysis of the processed data exclusively by automated systems;
    8. Request compensation for damage in case of suffering due to unlawful processing of personal data. In contrast, individuals have no rights with respect to anonymized data within the Company. Our Company may share personal data with relevant institutions and organizations within the scope of business and contractual relationships, for the purpose of a judicial duty or the use of statutory powers by a state authority.

H.

If the purpose of processing personal data has expired and the retention periods specified by the relevant legislation have also ended, personal data may only be retained for the purpose of serving as evidence in possible legal disputes, asserting the relevant right tied to the personal data, or establishing a defense.

I. CASES IN WHICH OUR COMPANY MAY PROCESS YOUR PERSONAL DATA WITHOUT YOUR EXPLICIT CONSENT BY LAW

Pursuant to KVKK Article 5, in the following cases, our Company may process your personal data — obtained as stated above and in accordance with the law — without seeking your explicit consent:

  1. Cases expressly stipulated in laws; cases where it is mandatory to process the personal data of the data subject in order to protect the life or bodily integrity of yourself or another person, where the data subject is unable to express consent due to actual impossibility, or where consent is not legally valid;
  2. Where it is necessary to process personal data of the parties to a contract, provided that it is directly related to the establishment or performance of a contract concluded between our Company and its affiliated companies/organizations, or with other natural and/or legal persons specified in paragraph (C);
  3. Where it is mandatory for our Company to fulfill a legal obligation;
  4. Where the personal data has been made public by yourself;
  5. Where data processing is mandatory for the establishment, use or protection of a right;
  6. Provided that no harm is caused to your fundamental rights and freedoms;
  7. Where data processing is mandatory for the legitimate interests of our Company.

J. TO MAKE A REQUEST UNDER THE PERSONAL DATA PROTECTION LAW

Pursuant to KVKK Article 13, paragraph 1, you may submit your request regarding the exercise of the rights stated above to our Company by the method(s) determined or to be determined by the Personal Data Protection Authority.

Pursuant to the KVKK, you may also contact our Company in writing in connection with your data subject rights for detailed information and requests, through the contact information provided on our website.

To exercise the rights set forth in Article 11 of Law No. 6698, you may always contact us at info@asakua.com by sending an email.

For matters concerning your personal data, only the info@asakua.com email address must be used; requests and notifications received through channels other than this address will not be considered.

Rights regarding personal data may only be exercised in respect of data belonging to the persons themselves. Requests regarding the data of persons other than the person who fills out the form and whose attached official identification documents are included will not be taken into consideration.

Forms not accompanied by official identification documents will not be considered. Please note that even when data deletion requests are fulfilled, we are obliged to share data with official authorities if requested by them.

Last updated: 28 April 2026