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Data Privacy Policy

ONVO ELEKTRONİK PERSONAL DATA PRIVACY POLICY

Dear Customers, Business Partners, Visitors, Employee Candidates, and Personnel; As ONVO ELEKTRONİK A.Ş. (“ONVO” or “Company”), we attach great importance to the protection of your personal data. In this context, pursuant to the Law No. 6698 on the Protection of Personal Data (“KVKK”), in our capacity as the “Data Controller”, we would like to inform you regarding your personal data and processing procedures.

This Policy aims to ensure the sustainability of the Company's "principle of conducting corporate activities in transparency". Within this framework, fundamental principles adopted regarding the compliance of Company data processing activities with the regulations in the Law No. 6698 on the Protection of Personal Data (“KVKK Law”) are determined, and practices executed by the Company are detailed.

This Policy applies to real persons whose personal data is processed by the Company through automated means or non-automated means provided that it forms part of any data filing system.

This Policy has been published on the website and made available to the public. In case of any conflict between active legislation—primarily the Law—and the provisions set forth in this Policy, the provisions of applicable statutory legislation shall prevail.

The Company reserves the right to amend this Policy in parallel with legal regulations.

WHAT IS YOUR PERSONAL DATA?

Personal data refers to any information that identifies you or makes your identity identifiable. Categories of your personal data that may be processed by ONVO Elektronik are specified below:

Identity Data: Refers to identity details of real persons who benefit from products and services offered by ONVO Elektronik.
Contact Data: Data group used to reach the individual (Phone number, postal address, e-mail address, fax number, IP address).
Special Categories of Personal Data: Refers to (i) health data obtained from personnel within the scope of personnel files and occupational safety, (ii) biometric data such as fingerprints and facial scans, and (iii) criminal conviction data such as judicial records.
Visual Data: Refers to photographs collected from personnel upon employment onboarding or video recordings captured by security cameras in ONVO Elektronik physical premises.
Audio Data: Refers to voice recordings of individuals captured during call center phone calls or security camera footage within ONVO Elektronik physical locations.
Personnel Record Data: Refers to identity, contact, professional, educational, and financial records compiled within legal employee files under employment contracts.
Purchased Product Data: Data processed into ONVO Elektronik databases regarding technical support, installation, manufacturer responsibility, and warranty obligations for purchased items.
Contractual Data: Refers to signatures, signature circulars, and sole proprietorship details processed into the database as a result of contractual bonds formed with business partners, suppliers, and outsourced service providers.
Location Data: Refers to location records of employees processed by ONVO Elektronik for internal auditing purposes.
Performance Data: All data processed internally for personnel auditing and operational efficiency, or externally for business partner performance evaluations.

DATA SUBJECT CATEGORIES

No	Category	Description
1	Customer	Real persons benefiting from products and services offered by the Company.
2	Prospective Customer	Real persons displaying interest in using products and services offered by the Company with potential to become customers.
3	Employee	Real persons performing services under an employment contract with the Company.
4	Visitor	Real persons visiting Company offices, stores, facilities, and websites.
5	Employee Candidate	Real persons applying for employment by submitting CVs or via other job application methods.
6	Third Parties	Real persons excluding the Data Subject categories specified above and Company employees.
7	Partners / Suppliers & Personnel	Parties (and their employees) with whom the Company establishes business partnerships or receives goods/services under contractual terms.

PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data may be processed in accordance with personal data protection legislation for the following purposes:

For Customers:

Executing procurement, sales, and post-sales support processes for goods and services,
Managing customer relationship workflows (CRM) and customer satisfaction activities,
Conducting marketing analytics, advertising, campaign, and promotional activities,
Ensuring physical venue security and processing online website orders,
Communicating regarding product/service promotions and fulfilling manufacturer warranty liabilities,
Resolving customer requests and complaints.

For Employees:

Fulfilling employment contracts, statutory obligations, employee benefits, and payroll operations,
Managing employee satisfaction, ethics, training, access permissions, and HR workflows,
Executing occupational health and safety (OHS) measures and financial/accounting processes,
Providing required notifications to official public authorities and ensuring physical operational security.

For Employee Candidates:

Executing selection, placement, and recruitment evaluation processes for candidates, interns, and students.

For Suppliers & Business Partners:

Establishing and executing commercial contracts, fulfilling legal obligations, and managing corporate accounting/finance processes,
Maintaining internal operations, physical space security, and system backups/data integrity.

For Visitors:

Ensuring physical security via CCTV footage and visitor logs, maintaining network security, and fulfilling legal access logs.

For Prospective Customers:

Managing inquiries, complaints, and trade fair interaction forms, and delivering personalized promotional offers based on explicit consent.

COLLECTION METHODS AND LEGAL GROUNDS

Your personal data is collected through all physical and electronic channels—such as website purchases, authorized service centers, dealers, call centers, job applications, and facility visits.

Based on the nature of data, processing relies on statutory grounds under Article 5/2 of the KVKK:

Explicitly stipulated in local or foreign laws,
Directly related to the establishment or performance of a contract,
Mandatory for ONVO Elektronik to fulfill its legal obligations,
Data made public by the Data Subject,
Mandatory for establishing, exercising, or defending legal claims,
Mandatory for the legitimate interests of ONVO Elektronik, provided it does not harm fundamental rights and freedoms.

In the absence of these legal grounds, data is processed based on your explicit consent.

TRANSFER OF PERSONAL DATA

ONVO may transfer your personal data to domestic recipient groups in accordance with KVKK provisions for specified purposes:

Suppliers, authorized service centers, and business partners providing product delivery and assembly services,
Banking institutions, financial entities, independent auditors, legal counsel, and consultants,
Legally authorized representatives, guardians, and proxies appointed by you,
Regulatory authorities, courts, execution offices, and legally empowered public/private entities,
Business partners associated with sales and communication management.

YOUR STATUTORY RIGHTS

Pursuant to Article 11 of the KVKK, you hold the right to apply to ONVO Elektronik to:

Learn whether your personal data is processed, and request information if processed,
Learn processing purposes and whether data is used accordingly,
Know third parties to whom data is transferred domestically or abroad,
Request correction of incomplete or inaccurate data,
Request deletion or destruction of data under statutory conditions, and request notification of such operations to third-party recipients,
Object to adverse results arising exclusively from automated analysis systems,
Claim compensation for damages incurred due to unlawful processing.

DATA SECURITY, CONFIDENTIALITY, AND DESTRUCTION

Data Security: The Company implements all necessary administrative and technical measures, establishes internal audit mechanisms, and acts in full compliance with KVKK requirements to prevent unauthorized disclosure, access, or security breaches.
Data Destruction: When legal grounds requiring processing cease to exist, personal data is deleted, destroyed, or anonymized ex officio or upon Data Subject request pursuant to our corporate Disposal Policy.

CONTACT INFORMATION

To exercise your statutory rights under the KVKK, you may submit your formal application accompanied by proof of identity via wet-signed letter to our postal address or via e-mail to kvkk@onvo.com.tr.

ONVO ELEKTRONİK A.Ş. (DATA CONTROLLER)

Address: Mimaroba Mah. Emirşah Sok. No: 8/1 Büyükçekmece, Istanbul / Türkiye
Phone: +90 850 886 66 86
MERSIS No: 0614092832500001
E-mail:kvkk@onvo.com.tr / info@onvo.com.tr
Website:[www.onvo.com](https://www.onvo.com).tr

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