Website Privacy Notice

1. Data Controller

Under Turkish Personal Data Protection Law No. 6698 (“KVKK”), the data controller is GENIA TURKEY ENERJİ YATIRIMLARI VE TURİZM A.Ş. (the “Company”). TechRight Turkey is a brand operating within Genia Investment. This notice explains personal-data processing carried out through techrightturkey.com and the TechRight Turkey website.

2. Categories of Personal Data

Depending on the nature of your relationship with the Company, the following categories may be processed:

• Identity data: first and last name
• Contact data: telephone number, email address, postal address and communication preference
• Customer-transaction data: records relating to enquiries, quotations, projects, contracts and services
• Security data: IP address, access time, traffic and security logs
• Legal-transaction data: disputes, applications and correspondence with competent authorities
• Enquiry content: explanations and attachments you provide through forms or other communication channels

3. Purposes of Processing

• Receiving, assessing and responding to enquiries
• Providing information about products and engineering, manufacturing, testing, inspection and consultancy services
• Managing quotations, projects, contracts, sales and after-sales processes
• Managing customer and business relationships and resolving requests or complaints
• Maintaining website security, continuity and technical operation
• Complying with legal and financial obligations and responding to competent authorities
• Establishing, exercising or protecting legal rights and managing disputes

4. Collection Methods and Legal Grounds

Personal data is collected through the website and contact form, email, telephone, face-to-face meetings, quotations, contracts and similar physical or electronic channels by automatic, partly automatic or non-automatic means forming part of a data filing system.

Processing relies on the legal grounds in Article 5 of KVKK: express provision by law; necessity for entering into or performing a contract; compliance with the Company’s legal obligations; establishment, exercise or protection of a right; and the Company’s legitimate interests, provided your fundamental rights are not harmed. Where a separate activity requires explicit consent, you will receive specific information and your consent will be requested separately.

5. Transfers of Personal Data

To the extent necessary for the purposes above, personal data may be disclosed to competent public bodies, courts and enforcement authorities, legal and financial advisers, independent auditors, business partners, and providers supplying hosting, IT, security, communications or technical support on the Company’s behalf.

Transfers are made in accordance with Articles 8 and 9 of KVKK and appropriate security safeguards. If infrastructure or a service provider located abroad is used, an applicable lawful cross-border transfer mechanism will be implemented.

6. Retention

Personal data is retained for the period necessary for the relevant purpose and for applicable statutory limitation and retention periods. When these periods expire and no other legal ground remains, data is deleted, destroyed or anonymised in accordance with applicable law.

7. Your Rights

Under Article 11 of KVKK, you may apply to the data controller to exercise the following rights:

• To learn whether your personal data is processed and request information if it is
• To learn the purpose of processing and whether data is used accordingly
• To know the third parties to whom data is transferred in Türkiye or abroad
• To request correction of incomplete or inaccurate data
• Where legal conditions are met, to request deletion or destruction and notification of these actions to recipients
• To object to an adverse result arising solely from automated analysis
• To claim compensation for damage caused by unlawful processing

8. How to Apply

You may send an application containing sufficient information to verify your identity and request to GENIA TURKEY ENERJİ YATIRIMLARI VE TURİZM A.Ş., Esentepe Mah. Oto Cad. Levent Loft 2 Residence No:4/3, Şişli / İstanbul, Türkiye in writing or by email to info@geniaturkey.com.

Applications should include your full name, signature for written requests, Turkish identity number or passport/identity number for foreign nationals, notification address, email and telephone number where available, and the subject of the request. Applications are answered free of charge as soon as possible and no later than thirty days; a statutory fee may apply where the response creates an additional cost.

9. Updates

This notice may be updated to reflect changes in law or the Company’s processing activities. The current version takes effect when published on the website.