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PURPOSE
With this policy, it is aimed to make statements about the personal data processing activities and systems adopted by MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş.. for the protection of personal data, and to ensure transparency by informing the persons whose personal data are processed by our company, especially our business partners, current and candidate employees, current and potential customers, company shareholders, visitors and third parties.

PRINCIPLES OF PROCESSING OF PERSONAL DATA
To ensure compliance with KVKK, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. Personal data will be processed in accordance with the general principles and provisions stipulated in the legislation. In this context, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. ; It acts in accordance with the principles listed below in the processing of personal data in accordance with international and national legislation regarding KVKK.

1. Engaging in Personal Data Processing Activities in Compliance with the Law and the Rules of Honesty

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING INC.; It is obliged to act in accordance with the law and the rules of honesty within the scope of processing personal data. In this context, proportionality requirements will be taken into account and personal data will not be used for purposes other than processing.

2. Ensuring Personal Data is Accurate and Up-to-Date Where Necessary

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. It is obliged to ensure that the personal data it processes are accurate and up-to-date, taking into account the fundamental rights of personal data owners and its own legitimate interests, and to establish the necessary systems to take the necessary measures in this regard.

3. Processing for Specific, Clear and Legitimate Purposes

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. It is obliged to determine the purposes for which personal data will be processed and to inform the data owners of these purposes before personal data is processed. Personal data will not be processed for purposes other than specified legitimate and lawful purposes.

4. Being Related to the Purpose for Processing, Being Limited and Proportionate

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. will process personal data in a manner suitable for achieving the specified purposes and will avoid the processing of personal data that is not relevant or needed to achieve the purpose.

5. Preservation for the Period Envisaged in the Relevant Legislation or Necessary for the Purpose for which they are Processed

MAKRO LIFE FRANCHISING GAYRİMENKUL SATIŞ VE MARKETING A.Ş.. In accordance with Article 138 of the Turkish Penal Code and Articles 4 and 7 of the KVK Law; will retain the personal data they process only for the period stipulated in the relevant legislation and laws or as required by the purpose of processing personal data. MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. First of all, it will determine whether the relevant legislation stipulates a period for storing personal data, if a period is determined, it will act in accordance with this period, and if a period is not determined, it will retain personal data for the period necessary for the purpose for which they are processed. If the period expires or the reasons requiring processing disappear, personal data will be deleted, destroyed or anonymized by MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş..

6. Carrying out Personal Data Processing Activities in Compliance with All the Basic Principles in Article 4 of the Law, Based on One or More of the Personal Data Processing Conditions Specified in Article 5 of the Law

As a rule, personal data will be processed in accordance with one or more of the conditions specified in Article 5 of the KVK Law. MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. It will be determined whether the personal data processing activities carried out by the Company's business units are carried out based on one or more of these conditions, and personal data processing activities that do not meet one or more of these conditions will not be included in the processes. In addition to ensuring that personal data processing activities are carried out based on one or more of the personal data processing conditions, all personal data processing activities are specified in Article 4 of the KVK Law and stated in Article III of the Policy. It will be ensured that all principles specified in the sections are complied with and include these principles. Personal data processing activities will be carried out by taking into account the special provisions stipulated in the Personal Data Protection Law regarding the processing of special personal data and their transfer to third parties and abroad; In addition to the above-mentioned issues, personal data processing activities will be carried out by fulfilling the special requirements required by the law in these cases.

CONDITIONS FOR PROCESSING PERSONAL DATA
1. Detection and Processing of Personal Data

In accordance with KVKK, personal data is defined as "Any information regarding an identified or identifiable natural person". The concept of personal data does not only consist of information that enables the recognition and identification of individuals such as name, surname, place of birth, date of birth, but also includes all physical, social, cultural, economic and psychological information of individuals.
In addition to the person's identity information, all information that makes the person specific or identifiable, such as citizenship number, tax number, passport number, social security number, driver's license number, vehicle license plate, home address, business address, e-mail address, telephone number, fax number, CV, photograph, video, genetic information, blood type, criminal history and criminal record information, is considered personal data and falls within the scope of protection of personal data.

In accordance with this definition, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş.. will determine whether all the data they collect, including third parties, especially their business partners, employees and customers, fall within the scope of personal data and will process these data in accordance with the rules of KVKK.
Processing of personal data; It covers all kinds of operations performed on data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, making available, classifying or preventing its use by fully or partially automatic or non-automatic means provided that it is part of any data recording system.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. In accordance with KVKK, personal data will only be processed with the explicit consent of the relevant persons. However, if any of the following conditions exist, it is possible to process personal data without explicit consent:

It is clearly stipulated in the law,
It is a mandatory situation for the protection of the life or physical integrity of themselves or someone else, who are unable to express their consent due to actual impossibility or whose consent is not given legal validity,
It is necessary to process personal data of the contracting parties, provided that it is directly related to the establishment or performance of a contract,
In cases where it is mandatory for the data controller to fulfill its legal obligation.
Publicization of personal data by the relevant person,
Data processing is mandatory for the establishment, exercise or protection of a right,
It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

2. Processing of Special Personal Data

Within the scope of the law, some personal data are considered as private data and MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. will not process such data without the express consent of the person concerned or without the exceptions set out in the third paragraph of Article 6 of the Law. Explicit consent; It means obtaining detailed consent after informing the person whose data will be collected for the purposes for which this data is collected.
KVKK; It considers data regarding a person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data as private data.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. will also take adequate measures determined by the Personal Data Protection Board in the processing of special personal data.

3. Transfer of Personal Data

C MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. will be able to transfer personal data to third parties with the explicit consent of the data owner, by taking the necessary security measures in line with the legal personal data processing purposes. However, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. Data that can be processed without explicit consent and data regarding health and sexual life may be transferred to third parties without explicit consent in accordance with the limitations set forth in the KVKK.

C MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. will take the necessary administrative and technical measures in order to transfer the data it transfers without explicit consent in accordance with the limitations in KVKK.

MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş.. may transfer personal data to foreign countries that have been declared to have adequate protection by the KVK Board, or, in the absence of sufficient protection, to foreign countries where the data controllers in Türkiye and the relevant foreign country have committed in writing to adequate protection and have the permission of the KVK Board.

4. Building Entrances and Personal Data Processing Activities and Network and Website Users

In order to ensure security by MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş., MAKRO LIFE FRANCHİSİNG PAZARLAMA VE DANIŞMANLIK HİZMETLERİ A.Ş. carries out security camera monitoring and personal data processing activities to track guest entries and exits in its buildings and facilities.

By using security cameras and recording guest entries and exits, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş.  Personal data processing activities are carried out by. In this context, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. It acts in accordance with the Constitution, KVK Law and other relevant legislation.

C MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  Video recordings of our visitors are taken through a camera monitoring system at the building, facility entrances and inside the facility.

C MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  Within the scope of surveillance activity with security cameras; To improve the quality of the service offered and to ensure its reliability, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. It aims to ensure the safety of customers and third parties and to protect the interests of customers regarding the service they receive.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  The company carries out camera monitoring activities for security purposes in accordance with the regulations in the KVK Law and the Law on Private Security Services and relevant legislation.

Only a limited number of MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş.  employee has access.
C MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. In accordance with Article 12 of the KVK Law, necessary technical and administrative measures are taken to ensure the security of personal data obtained as a result of camera monitoring activities.

Apart from recording with the camera mentioned above, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş.  by Ş.; To ensure security and for the purposes specified in this policy, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. Personal data processing activities are carried out to track guest entries and exits in its buildings and facilities.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  Internet access is provided to visitors who request it during their stay in the building and facilities, to ensure security and for the purposes specified in this policy. In this case, log records regarding internet access are recorded in accordance with Law No. 5651 and the mandatory provisions of the legislation issued in accordance with this Law; These records can only be obtained upon request by authorized public institutions and organizations or by MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. It is processed in order to fulfill the relevant legal obligations during the audit processes to be carried out. Only a limited number of employees have access to the log records obtained.

C MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. .on the websites it owns; To ensure that people visiting these sites carry out their visits on the sites in accordance with the purposes of their visit; Internet movements within the site are recorded by technical means in order to show them customized content and engage in online advertising activities.

5. Deletion, Destruction, Anonymization of Personal Data

Although it has been processed in accordance with the provisions of the relevant law, as regulated in Article 138 of the Turkish Penal Code and Article 7 of the KVK Law, if the reasons requiring processing are eliminated, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. Personal data is deleted, destroyed or anonymized based on its own decision or upon the request of the personal data owner.

In this context, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. It takes the necessary technical and administrative measures to fulfill its relevant obligations, develops the necessary operating mechanisms in this regard, trains and assigns the relevant business units to comply with these obligations and ensures their awareness.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  OBLIGATIONS
1. Obligation to Inform the Personal Data Owner

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. , will inform personal data owners about the following issues during the acquisition of personal data:
- Identity of the data controller and his representative, if any,
- For what purpose personal data will be processed,
- To whom and for what purpose personal data can be transferred,
- Method and legal reasons for collecting personal data,
- Personal data owner KVKK art. His rights under Art. 11.

In accordance with this obligation, MAKRO LIFE FRANCHİSİNG PAZARLAMA VE DANIŞMANLIK HİZMETLERİ A.Ş. publishes the information text they have prepared on their website and designs appropriate processes to enlighten the data owner during data collection activities.

2. Obligation to Respond to Applications of Personal Data Owners

Personal data owners may contact MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. in writing in accordance with the KVKK or by other methods determined by the KVK Board.  You can request information by applying with the attached application form or KEP address.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  It has established and implements procedures for responding to applications in accordance with Article 13 of the KVKK and other administrative and technical regulations in order to evaluate the rights of personal data owners and provide the necessary information to personal data owners.
Personal data owners;

- Learning whether your personal data is being processed or not,
- Requesting information if your personal data has been processed,
- Learning the purpose of processing your personal data and whether they are used for their intended purpose,
- Knowing the third parties to whom your personal data is transferred at home or abroad,
- Request correction of your personal data if it is incomplete or incorrectly processed,
- Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
- To request that the transactions made on your personal data in accordance with the relevant legislation be notified to third parties to whom your personal data has been transferred,
- Object to the emergence of a result against you by analyzing your processed data exclusively through automatic systems,
- If you suffer damage due to unlawful processing of your personal data, you have the right to request compensation for the damage.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. It only processes requests sent to registered e-mail addresses in writing or signed with a secure electronic signature. If the KVK Board determines other application methods, it will also accept applications through these methods.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  Depending on the nature of the request, it will respond to the request as soon as possible and within 30 (thirty) days at the latest. MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. It will accept the applications and carry out the necessary procedures or reject the applications with reasons.
In cases where the personal data owner's application is rejected, the answer given is insufficient, or the application is not answered, the personal data owner may file a complaint with the KVK Board within 30 (thirty) days from the date of learning the answer and in any case within 60 (sixty) days from the date of application.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  In order to prevent complaints, it will respond to personal data owners in a timely and justified manner as stipulated by KVKK.

 

3. Obligation to Ensure the Security of Personal Data

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. ensures that the necessary technical and administrative measures are taken to prevent the personal data they process from being processed unlawfully and from unlawful access to the data, and to ensure the appropriate level of security to ensure the preservation of the data.

The KVK Board may introduce detailed regulations regarding obligations regarding data security in the future. Therefore, MAKRO LIFE FRANCHISING GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. It will exercise due care in order to comply with the obligations within this scope and ensure the security of personal data.

MAKRO LIFE FRANCHISING GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. carries out the necessary inspections regarding the functioning of the measures in terms of the technical and administrative measures it will take and has established systems to have them carried out. The results of this audit will be examined by the units in charge within Makro Life Franchising Gayrimenkul Sales and Pazarlama A.S. and necessary precautions will be taken.

MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş is obliged to notify the personal data owner as soon as possible if the processed personal data is obtained by others through illegal means and to the KVK Board if required by the legislation. In this context, MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş.  Necessary mechanisms have been established within its structure.
MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  If situations that pose a security risk are detected by the company, it will take measures to eliminate the risk in question without delay.

3.1. Taking Technical and Administrative Measures to Ensure Lawful Data Processing

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. .analyzes all processes related to personal data processing activities carried out by its business units; All activities carried out by business units, from collection to deletion of data, are not audited for legal compliance.

C MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  Personal data processing activities carried out within the company are audited by the established technical systems.
The technical measures taken are reported regularly, and when a deficiency or illegality is detected, the relevant person is notified and the deficiency or illegality is corrected.

C MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  It informs and trains its employees about personal data protection law and the lawful processing of personal data.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. It includes provisions in the contracts and documents governing the legal relationship between . and its business partners, employees and customers that impose the obligation not to process, disclose or use personal data in violation of the regulations in the KVKK.

MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş, access to personal data is limited only to the relevant company employee in line with the purpose of processing.

Procedures to ensure that the activities of each business unit comply with the personal data processing conditions specified in the KVKK are determined specifically for each business unit and the activity it carries out. Implementation rules are determined for business units, necessary administrative measures are taken, procedures are created and training is provided to ensure the control of these rules and the continuity of the application.

3.2. Taking Technical and Administrative Measures to Prevent Unlawful Access to Personal Data

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  It takes the necessary administrative and technical measures, depending on the nature of the data to be protected, in order to prevent personal data from being unlawfully obtained, disclosed, displayed and transferred to third parties.
Technical measures are taken in accordance with technological developments and the measures taken are periodically updated and renewed.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. .designs and commissions access and authorization technical processes in accordance with legal compliance requirements. The technical measures taken are periodically reported to the relevant person and technological solutions are produced for issues with security risks.

Relevant software and systems are installed, including software and hardware that includes virus protection systems and firewalls.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş.  Its employees are trained on the technical measures taken and personnel knowledgeable in technical matters are employed.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. .takes a commitment that its employees will not disclose the personal data they have learned to anyone else in violation of the provisions of KVKK and will not use it for purposes other than processing. It is ensured that this commitment is valid even after the employees leave their jobs.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. Articles to protect personal data are added to the contracts made with the persons to whom personal data is transferred by .

3.3.Audit of Measures Taken for the Protection of Personal Data

MAKRO LIFE FRANCHISING GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş. carries out the necessary inspections regarding the functioning of the technical and administrative measures it will take and establishes the systems to have them carried out. The results of this audit are C MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş.  Within the scope of its internal operation, it is reported to the relevant department and the necessary activities are carried out to improve the measures taken.

3.3. Measures to be Taken in Case of Unauthorized Disclosure of Personal Data

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. If the processed personal data is obtained by others through illegal means, it is obliged to notify this situation to the relevant personal data owner and the KVK Board as soon as possible. In this context, the necessary internal structure is being created.
4. Obligation to Register in the Data Controllers Registry

C MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. Before starting data processing, it will be determined by the KVK Board and will be registered in the data controllers registry by submitting the application information and documents within the announced period. The documents to be submitted are as follows:

- Identity and address information of MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş., as the data controller, and its representative, if any,
- For what purpose personal data will be processed,
- Explanations about the data subject person group and groups and the data categories of these people
- Recipient or recipient groups to which personal data may be transferred,
- Personal data intended to be transferred to foreign countries,
- Measures taken regarding personal data security,
- Maximum period required for the purpose for which personal data are processed.

MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. ORGANIZATIONAL STRUCTURE
MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. In order to manage this policy and other policies related to this policy, a "Personal Data Protection Committee" or a person responsible for this matter has been appointed, responsible for carrying out the actions determined by the senior management for compliance.

In this context, the following minimum actions are taken by the Committee or the person to be appointed:

- To determine the basic policies regarding the processing and protection of personal data and what needs to be done to comply with the legislation,
- To submit the determined basic policies and action steps to the approval of the senior management; overseeing and coordinating its implementation,
- To decide how the policies regarding the processing and protection of personal data will be implemented and how the audit will be carried out, and to make the necessary assignments after receiving the approval of the senior management,
- To identify the risks that may occur in MAKRO LIFE FRANCHİSİNG GAYRİMENKUL SATIŞ VE PAZARLAMA A.Ş.'s personal data processing activities and to ensure that the necessary precautions are taken; Presenting improvement suggestions to senior management for approval,
- Ensuring that employees are trained on the protection of personal data and company policies,
- To decide on the applications of personal data owners at the highest level,
- MAKRO LIFE FRANCHISING REAL ESTATE SALES AND MARKETING A.Ş. To make the necessary arrangements within the company for the company to fulfill its obligations under KVKK,
- To follow developments in the protection of personal data; To make recommendations to senior management on what needs to be done within the scope of these developments,
Managing relations with the Institution and the Board.

 

ANNEX-1 DEFINITIONS
Explicit ConsentConsent regarding a specific issue, based on informed consent and expressed with free will.
AnonymizationIt is the alteration of personal data in such a way that it loses its nature as personal data and this situation cannot be reversed. Ex: Masking, aggregation, data corruption, etc. Making personal data unable to be associated with a natural person using techniques.
Employee CandidateReal persons who have applied for a job to our company by any means or have made their CV and relevant information available for review by our company.
Business PartnersReal persons working in institutions (such as, but not limited to, suppliers) with which our company has all kinds of business relations, including the shareholders and officials of these institutions
Processing of Personal DataAll kinds of operations performed on data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system.
Personal Data OwnerThe real person whose personal data is processed. For example; Customers and employees.
Personal DataAny information regarding an identified or identifiable natural person. Therefore, processing of information regarding legal entities is not within the scope of the Law. For example; name-surname, TR ID number, e-mail, address, date of birth, credit card number, bank account number, etc.
customerReal persons who use or have used the products and services offered by our Company, regardless of whether they have any contractual relationship with our Company
Special Personal DataData regarding race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, appearance, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data are special quality data.
Potential CustomerReal persons who have requested or are interested in using our products and services or who have been evaluated in accordance with commercial practices and rules of honesty as they may have this interest.
Company ShareholderShareholders of our company are real persons
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