Website Privacy and Cookie Policy Disclosure Statement

FOTONİKS Askeri Elektronik ve Elektro Optik Sis.San.Tic.A.Ş. (hereinafter referred to as the “Company” or “FOTONİKS Inc.”) places utmost importance on the processing of personal data of its website visitors in accordance with the Law on the Protection of Personal Data No. 6698 and other relevant legislation (“Data Protection Legislation”). We would like to inform you that we use cookies through our website.

The purpose of this Cookie Policy is to inform you about the types and purposes of cookies obtained during the visits of users/visitors (“Data Subjects”) to the website operated by us at www.fotoniks.com.tr (“Site”). By using the website, this Disclosure Statement shall be deemed to have been communicated to you.

FOTONİKS Inc. may update and amend the provisions of this Disclosure Statement at any time by publishing them in various locations. Any such updates and amendments made by FOTONİKS Inc. shall become effective as of the date of their publication.

1. DEFINITIONS AND ABBREVIATIONS
In this Disclosure Statement, the following terms shall have the meanings ascribed to them below:

FOTONİKS Inc.: The legal entity that is considered the data controller within the scope of the Law on the Protection of Personal Data No. 6698, responsible for determining the purposes and means of processing personal data, and for establishing and managing the data recording system.

Personal Data: Any information relating to an identified or identifiable natural person.

Processing of Personal Data: Any operation performed on personal data, whether fully or partially by automated means or by non-automated means provided that it is part of a data recording system, such as collection, recording, storage, retention, alteration, reorganization, disclosure, transfer, acquisition, making available, classification, or prevention of use.

Data Subject (Personal Data Owner): The natural person whose personal data is processed.

KVKK: The Law on the Protection of Personal Data No. 6698, which came into force upon its publication in the Official Gazette on April 7, 2016.

Cookie: Small text files stored on your device or network server through browsers by the websites you visit, enabling the identification of the respective device.

Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

2. PERSONAL DATA PROCESSED THROUGH COOKIES
Through cookies, your usage and visit habits on the Site, session information, past transactions, and browsing data are processed.

3. PURPOSE OF PROCESSING PERSONAL DATA IN THE INTERNET
Your personal data processed through cookies are handled in compliance with the Data Protection Legislation and limited to the purposes stated below:

• Your browsing data on the Site are processed and securely stored to provide better service to our visitors.
• Your past transactions are stored to create a summary of your preferences.
• Your browsing data and/or usage history on the Site may be monitored to improve the Site’s content according to your preferences and/or to determine your preferences.
• Functional and analytical cookies are used to analyze how the Site is used and to improve your user experience.
• Data are processed to manage information security processes and access authorizations.

4. METHOD AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
Your personal data processed through cookies are obtained by FOTONİKS Inc. during your visit to our website through channels such as:

• Website contact forms,
• Website visits,
• Log files, clear GIF files, and/or third-party sources.

Your personal data processed through cookies are collected electronically via cookies in accordance with the fundamental principles set forth in the Law on the Protection of Personal Data (KVKK) and processed based on the legal ground set out in Article 5(2)(f) of the KVKK:
“Processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”

FOTONİKS Inc. may match information collected through different online and offline methods or at different times on the Site and may use such information together with data obtained from other sources, such as third parties.

5. WHO HAS ACCESS TO THE INFORMATION OBTAINED THROUGH THE PROCESSING OF DATA IN THE INTERNET AND TO WHOM THIS INFORMATION IS TRANSFERRED
The records stored and maintained in the digital environment are accessible by authorized personnel of FOTONİKS Inc. Individuals with access to the records declare that they will maintain the confidentiality of the data they access through a confidentiality agreement.
The information stored and maintained in the digital environment may be shared with judicial authorities and legally authorized public institutions and organizations in accordance with the procedures and principles specified in the laws.
FOTONİKS Inc. will not disclose the personal data it obtains to third parties in a manner contrary to this disclosure statement, and will not use it for purposes other than processing.

TYPES OF COOKIES

Below you can find the different types and classifications of cookies we use on our website:

6.1. FIRST-PARTY COOKIES:
First-party cookies are sent only to the relevant site each time you request a page from the site on your computer.
The website can recognize you both during your visit and on subsequent visits. For this reason, it is practically impossible to make full use of the internet with first-party cookies disabled in a browser.

6.2. THIRD-PARTY COOKIES:
Third-party cookies are cookies sent to another website while you are viewing a website.
Third-party cookies are used for digital marketing purposes and can be utilized by ad servers to use your behavior data from one site for ads displayed on another site, as well as in website analytics.

6.3. COOKIES BASED ON STORAGE DURATION:

PERSISTENT COOKIES: Persistent cookies are used to enhance the functionality of the website and provide visitors with a faster and better service. These cookies are used to remember your preferences and are stored on your device via browsers. Some types of persistent cookies can be used to provide personalized suggestions based on factors such as your purpose of visiting the site.

SESSION COOKIES: These cookies are used to separate the user's visit into sessions and do not collect data from the user. The cookie is deleted when the user closes the webpage or remains inactive for a certain period. The main purpose of using session cookies is to ensure that the website functions correctly during your visit.

6.4. COOKIES BASED ON USAGE:

7. CONTROL AND BLOCKING OF COOKIE USAGE

Data owners have the right to personalize their cookie preferences by changing their browser settings. Depending on the browser used, users can change their cookie preferences through browser settings. Within the options provided by the browser, data owners have the ability to block the use of cookies, receive a warning before cookies are used, disable cookies, or delete them.
It is not mandatory to use cookies to access our site; you have the opportunity to personalize your cookie preferences by changing your browser settings.

Since changing and personalizing cookie settings may vary depending on the device used, it may be necessary to make separate cookie policy changes for each device accessed. Additionally, by clicking on the "Cookie Preferences" link on the Site, you can personalize your preferences for cookies, excluding Essential (Basic) Cookies.

To prevent the use of cookies, you will need to disable the "cookie usage feature" in your browser and delete any cookies associated with this website.

It is important to note that restricting the use of cookies will also restrict certain actions on our site. In particular, restricting the use of cookies known as "First-Party Cookies" will limit your access to certain sections of our site. The actions to restrict or block cookies can be performed by visitors at any time they desire.

8. SECURITY OF YOUR PERSONAL DATA

FOTONİKS Inc. takes appropriate measures, consistent with relevant privacy and data security laws and regulations, to protect your personal data. Depending on the state of technology, implementation costs, and the nature of the data to be protected, technical and organizational measures are implemented to prevent risks such as destruction, loss, alteration, unauthorized disclosure, or unauthorized access to your data.
The personal data subject to this disclosure statement is stored within FOTONİKS Inc. and is only accessible to a limited number of individuals. After the processing period, this personal data will be deleted, destroyed, or anonymized in accordance with FOTONİKS Inc.'s Personal Data Processing, Storage, and Destruction Policy.

9. YOUR RIGHTS AS A DATA SUBJECT
Under Article 11 of the Personal Data Protection Law (KVKK), you have the right to personally request, by proving your identity, the following:

• Learn whether your personal data is being processed, and if so, request information about it.
• Learn the purpose of processing your personal data and whether it is being used in accordance with the purpose.
• Learn whether your personal data is being transferred to other parties, domestically or abroad, and to whom it has been transferred.
• Request the correction of any incomplete or incorrect personal data, and request that these corrections be communicated to third parties to whom your personal data has been transferred.
• Request the destruction (deletion or erasure) of your personal data under the conditions specified in Article 7 of KVKK, and request that this action be communicated to third parties to whom your personal data has been transferred. However, your request for destruction will be evaluated by our Company, and the appropriate destruction method (deletion, erasure, or anonymization) will be determined based on the conditions of the specific case. You can also request information on why the chosen method of destruction was selected.
• Object to the result of an exclusively automated system analysis of your personal data, if it leads to a negative outcome for you.
• If you suffer damage due to the unlawful processing of your personal data, you can request compensation for the damage.

Your requests in your application will be resolved free of charge within a maximum of thirty (30) days, depending on the nature of the request. However, if the process incurs additional costs for the Company, a fee may be charged according to the tariff set by the Personal Data Protection Board in the "Principles and Procedures for Applying to the Data Controller" notice.

Regarding the processing of your personal data, you can submit your application by filling out all the information in the "Relevant Person Application Form" available on fotoniks.com.tr, or in accordance with Articles 11 and 13(1) of the Personal Data Protection Law (KVKK) and the "Principles and Procedures for Applying to the Data Controller" notice, using the following methods:

• In-Person Application: By personally visiting our company at Oğulbey Mah. Kumludere Cad. No:8 Gölbaşı / Ankara.
• KEP (Registered Electronic Mail): Via our registered electronic mail address fotoniks@hs01.kep.tr .
• Notary or Return-Receipt Mail: In writing, through a notary or via return-receipt mail to verify your identity and prevent giving information to the wrong person.
• Email: By using your previously registered email address in our system, secure electronic signature, or mobile signature, and sending an email to kvkk@fotoniks.com.tr .

Alternatively, you may use other methods in the future that may be determined by the Personal Data Protection Board.