Clarification Text on the Processing of Personal Data

As Huawei Telekomünikasyon Dış Tic. Ltd. Şti. ("Huawei" or "Company"), we process your personal data as the data controller. This Clarification Text has been prepared to inform you about how we process personal data via WeFocus Platform ("Platform"). Through the platform, we provide services that help our customers measure and increase employee engagement and help our customers obtain information from their employees on the issues they have determined. In this context, we allow actions to be carried out through the Platform, including; - Creating surveys to obtain information from their employees; sending surveys to employees, - Filling out the questionnaires and checking the answers given, - Analyzing, visualizing, and reporting of survey responses, - Collecting employees’ feedback through social interaction areas on the Platform. We process your personal data in accordance with this clarification text in accordance with the transactions performed within the scope of the platform.

Purposes of Processing Personal Data and Legal Reasons

Your personal data are processed for the following purposes, based on the legal reason "data processing is mandatory to fulfill our legal obligations" specified in Article 5/2-ç of the Personal Data Protection Law ("Law")” - Fulfillment of our legal obligations in cases where authorized institutions or organizations request from our Company or we are required to notify these institutions (for example, sharing your information in case of a request from a public institution regarding a suspected unlawful transaction). Your personal data are processed for the following purposes, based on the legal reason "data processing is mandatory for the establishment, use or protection of a right" specified in Article 5/2-e of the Law: - Verifying your information for your use of the platform, creating your user account and providing the opportunity to login to your account, - Detection of suspicious / illegal transactions within the scope of accessing and using the platform; In this context, protecting the rights of our customers and our Company, - In the event of a possible legal dispute, the protection and use of our rights and the execution of legal processes. Your personal data are processed for the following purposes, based on the legal reason that "data processing is mandatory for our legitimate interests, provided that it does not harm the fundamental rights and freedoms of the relevant person" specified in Article 5/2-f of the Law: - Receiving and finalizing your questions, suggestions, requests and complaints, - Contacting you about our services and your account (for example, sending notifications about innovations and changes in the Platform), - Ensuring the use of the Platform within the scope of the services we offer to our customers (for example, recording the person information you want to send surveys to the Platform, using the analysis tools related to the surveys, creating reports on the filled surveys, sending action to the employees through the Platform), - Collecting, analyzing and reporting your responses to surveys , if you participate in surveys; providing our customers with analysis and evaluations regarding survey responses (for example, submitting survey responses regarding the work preferences of employees in a certain age range), - Making the action assignments determined by our customers through the platform, - Receiving your questions and feedback through the social interaction areas on the platform and forwarding them to our customers (your feedback is shared anonymously unless you choose to share your identity information), - Learning about how people use and interact with our Platform; In this way, improving and improving the user experience, Platform content and functioning, - Detecting and preventing problems / errors in the use of the platform, - Examination and supervision of our business activities. If you have given your express consent, your personal data will be processed in order to inform you about Huawei activities, opportunities and promotions in line with your communication consent preferences. This type of communication allows us to increase your loyalty and satisfaction with our services. Within the scope of the above-mentioned purposes and legal reasons, your identity, communication, transaction security, company-unit and legal transaction information are processed. If you participate in the surveys, your data obtained within the scope of the surveys are also processed. Your data obtained within the scope of the surveys (for example, your age, education status, profession, position) changes for each survey within the scope of the questions determined by our customer. Cookies are used to understand and analyze the trends, interests and preferences of the platform users. For information about cookies: Cookie Policy .

Sharing Personal Data with Third Parties

Your personal data is shared with the parties, business partners and Huawei group companies that we provide and receive services at home and abroad, based on the stated legal reasons, in order to fulfill the purposes under the heading "Purposes of Processing Personal Data and Legal Reasons". Your personal data will also be shared with authorized institutions and organizations in case of the need to provide information to authorized institutions and organizations (for example, to share with legal authorities due to a conflict). While sharing your personal data with third parties, compliance with the rules specified in Articles 8 and 9 of the Law is ensured.

Methods of Collecting Personal Data and Legal Reasons

Your personal data is collected on digital media by automatic and partially automatic methods. While processing your data, fulfillment of our legal obligations specified in Article 5 of the Law, establishment, use or protection of a right, and the fact that data processing is mandatory for our legitimate interests are acting on the basis of legal reasons. If at least one of the legal reasons specified in the Law is not available for the processing of your personal data, your explicit consent is required to process your data.

Related Person Rights

Article 11 of the Law on the Protection of Personal Data regulates the rights of data subjects. Under this article you have the following rights: - Learning whether your personal data is being processed, - Requesting information if your personal data has been processed, - Learning the purpose of processing your personal data and whether they are used appropriately for their purpose, - Knowing the third parties in the country or abroad to whom your personal data has been transferred, - To request correction of your personal data if it is incomplete or incorrectly processed, and to request notification of the transaction made within this scope to third parties to whom your personal data has been transferred, - To request the deletion or destruction of your personal data in the event that the reasons requiring its processing disappear, despite the fact that it has been processed in accordance with the provisions of the law and other relevant laws, and within this scope, and in case your personal data are processed incompletely or incorrectly, to request notification of the transactions made to third parties to whom your personal data has been transferred, - Objection to the emergence of a result against you by analyzing your processed data exclusively through automated systems, - To request the compensation of the damage if your personal data is damaged due to unlawful processing. To use your rights, Saray Mah. Ahmet Tevfik İleri Cad. Onur Ofis Park İş Merkezi Sit. A1 Blok Apt. You can send a mail with your requests to the address No.10 B / 1 Ümraniye / İstanbul. You can also apply to the Data Controller by using other methods specified in the Communiqué on Application Procedures and Principles.