Privacy Policy

PRIVACY STATEMENT SENKRON ENERGY DIGITAL SERVICES B.V.

1. WHO IS RESPONSIBLE FOR PROCESSING PERSONAL DATA?

This is the privacy statement of Senkron Energy Digital Services B.V. (hereinafter: SEDS) and Enerjisa Enerji Üretim AŞ (hereinafter: ESA). SEDS provides digital services in the energy sector, with a goal of empowering a sustainable future through innovative energy solutions. ESA is the shareholder, located

in Istanbul, and provides the IT infrastructure for SEDS.

SEDS and ESA attach great importance to privacy and the protection of personal data. This privacy statement describes how we handle personal data and the rights you, as a data subject, have.

All personal data is collected, processed, and secured in accordance with the General Data Protection Regulation ("GDPR"). SEDS is the controller for the processing operations listed below.

2. HOW CAN YOU CONTACT US?

For questions or comments about the processing of personal data by SEDS and ESA, the primary contact point is SEDS. You can contact us at [email protected].

3. FROM WHOM DO WE PROCESS PERSONAL DATA?

We process personal data of persons we directly or indirectly wish to contact, have contact with or have had contact with. Examples include our customers, prospective customers, their representatives, people associated with companies with which we have, have had, or wish to have a relationship, including suppliers, and anyone who expresses interest in our services.

4. WHAT PERSONAL DATA DO WE PROCESS?

Below is an overview of the categories of personal data we process:

Categories of personal data	Examples
Identifying data and contact details	First name and surname of the representative Telephone number E-mail address Country information Company information
Correspondence, conversation recordings and chat recordings	(E-mail) correspondence Messages you send us via social media Recordings of conversations
Data that says something about the use of our website, online user environment and social media	Activities on our website, online user environment and social media IP addresses Information collected by means of cookies (see also our Cookie Policy) Data that you actively provide or fill in in forms Information about the device with which you use our website or online user environment
Public messages about SEDS you leave on the internet	Messages on social media Reviews

5. WHERE DO WE GET YOUR PERSONAL DATA?

We receive most of the information because you provide it to us, for example when you create an account with us, because you enter your details on our website or because you communicate with us.

We also place cookies that allow us to collect information about your website visit. You can find more information about this in our Cookie Policy.

If you follow SEDS on social media or communicate with or about SEDS, we may have access to some of your public profile information. If you share information about SEDS via social media, your data may become visible on those social media. SEDS also follows social media channels and may access data about you on social media.

6 FOR WHAT PURPOSES ARE YOUR PERSONAL DATA PROCESSED AND ON WHAT BASIS?

Purpose & legal basis	Examples
To be able to enter into a relationship and an agreement with you Legal basis: necessary for the performance of the agreement	To register you as a (B2B) customer To create an account for the use of SEDS’ SaaS products To respond to the messages you send us To record the agreements made To process and record the data provided by you via our online user environment and, for example, via e-mail
In order to perform agreements and contracts Legal basis: necessary for the performance of the agreement	To maintain contact with you
For the development and improvement of products and services Legal basis: legitimate business interest	To have a good overview of our customers and their relations To conduct internal audits and investigations
For relationship management, promotional and marketing purposes Legal basis: legitimate business interest and consent	To inform you about a product that may be of interest to you, or a change to your existing product(s). The main purposes of using cookies on our website are listed below: To improve the functionality and performance of the website, enhancing the services provided to you. To enhance and personalize the website, our products and services, and offer new features through it according to your preferences. To ensure the legal and commercial security of our website, products, and services.
To combat fraud Legal basis: compliance with legal obligations	To comply with legal obligations, your personal data may also be passed on to third parties
To protect the position of SEDS and third parties Legal basis: legitimate business interest	To protect intellectual property rights
To ensure the security and stability of IT systems Legal basis: legitimate business interest	To monitor IT systems To carry out internal audits and investigations
To enter into agreements with suppliers and other partners Legal basis: necessary for the performance of the agreement	To maintain contact with you

7. TO WHOM DO WE PROVIDE PERSONAL DATA?

Insofar as personal data are exchanged between the companies within the Enerjisa Üretim Santralleri A.Ş. group, this is done on the basis of SEDS’s legitimate business interest in order to conduct an efficient and responsible business.

SEDS may use the services of third parties to process your data in accordance with this privacy statement. These parties act as processors for SEDS and SEDS will ensure that these parties provide adequate safeguards with respect to technical and organizational security measures. Third parties acting as processors for SEDS have entered into a processor agreement which includes that they will only process data on behalf of SEDS.

Your data will also be passed on to other parties outside SEDS if we are legally obliged to do so, such as supervisory authorities, because we have to perform an agreement with you or if this is necessary to fulfil the agreements with you. In addition, we will also provide your details to other parties we need as part of our services.

8. DO WE TRANSFER PERSONAL DATA TO OTHER COUNTRIES?

SEDS may use the services of third parties to process your data in accordance with this privacy statement. These parties may be located outside the European Economic Area (EEA).

Your personal data will only be stored or processed outside the EEA by us or by third parties engaged if this is in accordance with the applicable regulations for the transfer of personal data to countries outside the EEA. This means that we will only transfer your personal data outside the EEA if the European Commission has decided that the third country in question ensures an adequate level of protection, or if other appropriate safeguards are put in place.

9. HOW LONG DO WE RETAIN YOUR DATA?

Your data will not be retained longer than we need it for the purposes for which it is collected or processed. SEDS has different retention periods depending on the purpose and category of data.

If we no longer need the data for the purposes described above, we can still retain the data for archiving, legal proceedings, or research purposes.

10. WHAT HAPPENS IN THE EVENT OF TRANSFER OF THE BUSINESS?

In the future, one or more parts or assets of SEDS may be transferred to a third party or SEDS may merge with a third party. In that case, your personal information may be transferred to that third party. SEDS will notify you in advance in such a case.

11. WHAT ARE YOUR RIGHTS?

You have a number of rights with regard to the processing of your data (see below). If you would like more information about this or would like to exercise one of these rights, please send an e-mail to [email protected].

Right to withdraw your consent if we have requested your consent for a particular processing of your personal data;

Right of access;
Right of rectification if personal data is incorrect or incomplete;
Right of erasure if personal data is irrelevant to the purpose for which it was collected, if consent has been withdrawn, if you object to a processing of personal data based on a legitimate interest or if the processing of personal data is unlawful;
Right to restrict processing if you dispute the accuracy of personal data processed SEDS, or if you have objected to the processing of personal data by SEDS;
Right to data portability;
Right to object to processing or direct marketing. You have the right to object to the processing of your data within the framework of our legitimate interest. We will then make a new assessment to determine whether your data may no longer be used. You can also specifically object to the use of your data for direct marketing;
Right of objection and human intervention in case of automatic decisions;
Right to complain. This can be submitted to the SEDS via [email protected] or to the Personal Data Authority.

12. HOW DO WE PROTECT YOUR PERSONAL DATA?

We take appropriate measures to prevent abuse, loss, unauthorized access, unwanted disclosure and unauthorized alteration of personal data. Only persons who need access to your data in view of their function can access it. All of these persons have a duty of confidentiality.

13. CHANGES

We may change our privacy statement from time to time. This may, for example, if there are new data processing operations or in connection with changes in regulations or technological developments. If there are substantial changes to this privacy statement, we will notify you. If necessary, we will ask for

your permission for a modified or new processing.