GENERAL CLARIFICATION STATEMENT REGARDING THE PROCESSING, TRANSFER,

AND SHARING OF PERSONAL DATA

As …metauction…… (“…metauction…” or the “Intermediary”), in accordance with the

statutory legislation we hereby inform and enlighten you regarding our personal data

processing activities. This document has been prepared to ensure that data subjects are

informed about the lawful collection, acquisition, storage, transfer (both domestic and

international) and protection of personal data.

Data Controller and Its Representative

In accordance with to the statutory legislation, we, as … metauction …., acting as the data

controller, may process, record, store, classify, update, and, when necessary or limited to

the purpose of processing, disclose and/or transfer your personal data abroad and to third

parties, in compliance with legal and ethical principles. Additionally, since this platform

serves as a tender platform, your data may be shared with other members and

participants as required by the nature and necessity of the tendering process.

Purpose of Processing Personal Data

Your personal data are processed in accordance with the fundamental principles

stipulated by the statutory legislation for the following purposes: to manage our business

operations, tender processes, employment relationships, and human resources

processes; to respond to inquiries; to ensure the continuity of technical operations and

the commercial security of the platform; to conduct business operations; to carry out

advertising and marketing activities; to contact you; to manage customer and participant

relations; to ensure coordination and a secure environment among tender participants;

to store and share contact information when necessary and upon your approval; to

conduct market research and reporting; to manage legal and administrative processes;

to improve and expand our digital platforms; to provide evidence when necessary; to

verify identity information; and to ensure cybersecurity. Your personal data are stored

securely in physical or electronic media for an appropriate duration consistent with the

processing purposes. … metauction …. complies with all applicable obligations set forth

in the related legislation.

Detailed information about the purposes for which your personal data are processed by

our platform can be found in the Personal Data Protection and Privacy Policy available on

…… metauction ……………………….

Transfer of Your Personal Data

Within the scope of the information disclosed, your personal data may be shared, in

accordance with the related legislation and its core principles, with our business

partners, shareholders, authorized public institutions and organizations, private entities,

service providers from whom we procure support services for our operations, andindependent audit firms in compliance with legal obligations and limitations. Acceptance

of this statement shall be deemed as your explicit consent to such transfers.

The identity, contact, and payment information of users may be shared with domestic and

international payment institutions to ensure the secure and proper completion of sales

and payment processes related to tenders held on the platform. In the case of users

publishing tenders, names, contact details, and transaction data may be shared with

domestic and international tender participants and service providers to facilitate and

accelerate tender processes. Personal data collected for communication and notification

processes may be shared with service providers based domestically or internationally

that handle storage, server operations, information security, and other operational tasks.

Transfer of Personal Data Abroad and Sharing with Third Parties

Your personal data may be transferred by … metauction … in accordance with the

principles outlined in the related legislation and, without obtaining explicit consent, in

cases permitted by the related legislation or, when required, based on your explicit

consent. Such data may be transferred only to countries deemed to have adequate

protection by The competent authority appointed by the relevant law (“Board”) or, for

countries lacking such protection, only if both data controllers in Turkey and the recipient

country provide a written undertaking of adequate protection and “the Board” grants

authorization for the transfer.

As our website operates as a tender platform, communication and payment information,

as well as other personal data you share with us, may be transferred to other members,

and, when necessary, real and legal entities located abroad. By accepting this statement,

you consent to the sharing of your personal data with third parties in Turkey and abroad,

to the extent necessary for the proper conduct of tender processes.

Collected Personal Data

The platform collects various types of personal data from users through the following

methods depending on the services and features utilized by the users. These data

include, but are not limited to:

• Identity and Contact Information: Full name, mobile, home and business phone

numbers, address, email, billing details, national identity number, front side of ID

card.

• Authentication Information: Name, surname, date of birth, national ID number,

account details, passwords, usernames, user numbers, advertisement numbers,

front-side ID information, selfie videos, hologram verification videos, proof of

address documents.

• Transaction Security Information: Account details, contact and recovery data,

session and trusted device logs.• Transaction Data: Account details, name, surname, user ID, profile photo (if

provided), active and inactive listing information, participation in tenders, related

documents and certificates, saved card and bank information, billing/delivery

addresses.

• Payment Data: Invoice and payment details including name, surname, address,

ID number, tax number, issued invoices and payment receipts, invoice number,

amount, and date.

• Messages: Content, history, and timestamps of messages sent through the

platform.

Legal Basis and Method of Collecting Personal Data

Your personal data are collected by … metauction … through various channels and legal

bases mentioned above to operate our business, improve our services, manage tenders

securely, and continue commercial activities. Under the related legislation, your data

may be processed with or without your explicit consent depending on the legal

circumstances. The data collected may vary depending on the services used and include

information shared by users on our website or obtained through their activity on the

platform.

Links to Other Websites

This website contains links to other websites. We have no control over the data protection

practices of these third-party websites. The COMPANY is not responsible for the content

of linked sites (including those linked within them) and does not have the authority to

intervene in their content.

Amendments to This Statement

This “Data Privacy Statement and Information Notice Regarding the Processing and

Protection of Personal Data” may be amended as necessary to reflect changes in data

protection services, to introduce new services, or to comply with legal requirements.

Your Rights under the Related Legislation

As a data subject, you may submit your requests regarding your rights by completing the

form available at … …metauction.. and submitting it to ………metauction…………. The

platform shall respond to your request as soon as possible and within a maximum period

of thirty (30) days. If your request incurs a cost, the fee set by the Board may be charged.

Under Related Legislation, you are entitled to:

• Learn whether your personal data are being processed,

• Request information if your personal data have been processed,• Learn the purpose of processing and whether they are used appropriately,

• Know the third parties to whom your personal data are transferred within or outside

the country,

• Request the correction of any inaccurate or incomplete data,

• Request the deletion or destruction of personal data

• Request notification of corrections or deletions to third parties to whom your data

have been disclosed,

• Object to results produced solely through automated processing,

• Demand compensation if you su]er damage due to unlawful processing of

personal data.

☐ I have read and understood the above explanation, and I explicitly consent to the

processing, transfer, and sharing of my personal data, including with third parties and

international recipients, as necessary for the operation of this tender platform.

☐ I do not consent to the processing, transfer, or sharing of my personal data.

-! A confirmation checkbox will be added before each tender requiring participants to

a]irm: “I have read the statement regarding the processing, transfer, and sharing of

personal data at the link provided, and I hereby confirm my explicit consent.”