PERSONAL DATA PROTECTION PRIVACY NOTICE

Effective Date: 02 July 2026 This Privacy Notice has been prepared in accordance with the Law No. 6698 on the Protection of Personal Data ("KVKK"), published in the Official Gazette dated 7 April 2016 and numbered 29677, and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform, published in the Official Gazette dated 10 March 2018 and numbered 30356. As the Data Controller, we provide this Privacy Notice to inform you about how your personal data is collected, processed, transferred, and protected.

1. Identity and Contact Information of the Data Controller

Within the scope of the Turkish Personal Data Protection Law (KVKK), the Data Controller is:

Data Controller	Pacem Teknoloji
Address	Tekeli Fevzi Çakmak, 10032. Sk. No:2, 35865 ITOB OSB, Menderes, İzmir, Türkiye
E-mail	info@pacemtech.com
Website	https://yeni.pacemtech.com

2. Categories of Personal Data Processed

Your personal data may include, but is not limited to, the following categories:

• Full name
• E-mail address
• Telephone number
• Address information (billing, delivery, residential)
• IP address, browser session information, and technical connection logs
• Device information, operating system, browser version, and screen resolution
• Curriculum Vitae (CV) and recruitment documents, including name, date of birth, educational background, work experience, references, photograph, and any supporting application documents

3. Purposes of Processing Personal Data

Your personal data may be processed for the following purposes:

• Ensuring the technical operation of the website, cybersecurity, and infrastructure management
• Responding to your inquiries, requests, complaints, and other communications
• Managing customer relations and after-sales services
• Preparing, negotiating, and performing contractual processes
• Recording communications, complaints, and requests for legal evidence where necessary
• Conducting statistical analysis, reporting, and improving service quality
• Managing finance, accounting, and auditing processes
• Complying with legal obligations and responding to requests from competent public authorities
• Planning and conducting recruitment processes, creating and managing candidate pools

4. Legal Grounds for Processing Personal Data

Your personal data is processed on one or more of the following legal bases under the KVKK:

• Article 5/2(a): Processing is expressly provided for by law.
• Article 5/2(c): Processing is necessary for the establishment or performance of a contract.
• Article 5/2(ç): Processing is necessary for the Data Controller to fulfill its legal obligations.
• Article 5/2(e): Processing is necessary for the establishment, exercise, or protection of a legal claim.
• Article 5/2(f): Processing is necessary for the legitimate interests of the Data Controller, provided that it does not violate the fundamental rights and freedoms of the data subject.
• Article 5/1: The explicit consent of the data subject (for cookies, marketing activities, and other processing activities requiring consent).

5. Parties to Whom Personal Data May Be Transferred

In accordance with Articles 8 and 9 of the KVKK, your personal data may be transferred to:

• Public authorities: Competent administrative and judicial authorities where required by applicable laws, court orders, or official requests.
• Suppliers and business partners: Providers of web hosting, cloud services, e-mail infrastructure, analytics services, payment systems, and other technical or operational services.
• Audit and consultancy firms: Authorized legal, financial, tax, and independent audit professionals.
• Relevant internal departments: Authorized personnel involved in recruitment and employment processes.

Where personal data is transferred abroad, such transfers shall be made only where the destination country provides an adequate level of protection or appropriate safeguards are established between the parties, in accordance with Article 9 of the KVKK.

6. Methods and Channels for Collecting Personal Data

Your personal data may be collected through the following channels:

• Website contact, membership, and application forms
• E-mail correspondence and telephone communications
• Cookies and similar tracking technologies (session, analytics, and marketing cookies)
• Online or physical application forms and career portals

7. Retention Periods of Personal Data

Personal data is retained only for the period necessary to fulfill the purposes for which it is processed. Upon expiry of the applicable retention period, personal data is deleted, destroyed, or anonymized in accordance with the Turkish Commercial Code, Tax Procedure Law, and other applicable legislation. Personal data relating to unsuccessful job applications may be retained in the candidate pool for a maximum period of two (2) years without the applicant's explicit consent.

8. Rights of the Data Subject (Article 11 of the KVKK)

Under Article 11 of the KVKK, you have the right to:

• Learn whether your personal data is being processed;
• Request information regarding such processing;
• Learn the purpose of processing and whether your data is used in accordance with that purpose;
• Know the third parties to whom your personal data has been transferred, whether domestically or abroad;
• Request correction of incomplete or inaccurate personal data;
• Request deletion or destruction of your personal data pursuant to Article 7 of the KVKK;
• Request notification of any correction or deletion made to third parties to whom the personal data has been transferred;
• Object to any adverse outcome resulting exclusively from automated processing;
• Request compensation for damages arising from unlawful processing of personal data.

9. Right to Apply and Application Procedure

You may submit your requests concerning the rights listed above through one of the following methods: (Application procedures have not yet been configured. Please configure them under the "KVKK → Application Methods" section.) Your application should include the following information:

• Full name
• Turkish Identification Number (or passport number for foreign nationals)
• Residential or correspondence address, or e-mail address
• A clear description of your request
• Supporting documents or information, if available

Your application will be responded to free of charge within thirty (30) days from the date it is received. Where the response requires additional costs, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.

10. Data Security

Appropriate technical and organizational measures are implemented in accordance with Article 12 of the KVKK and the decisions of the Turkish Personal Data Protection Board to ensure the security of your personal data. These measures include, but are not limited to:

• Access authorization and control mechanisms
• Encryption technologies
• Vulnerability assessments and security monitoring
• Personnel training and awareness programs

In the event of a personal data breach affecting your personal data, the breach shall be reported to the Turkish Personal Data Protection Authority within 72 hours, in accordance with Article 12/5 of the KVKK.