As Arena Sanayi ve Ticaret A.Ş. (“We” or “Arena”), we attach utmost importance to the protection of your personal data, with the awareness of our role as a data controller. For this reason, we take the necessary measures to protect the privacy of all individuals whose data are processed and to ensure the security of their personal data.

Your personal data are processed under the supervision of our Personal Data Protection Committee and Personal Data Protection Officer, in accordance with the legal regulations and within the framework of Personal Data Protection Policies and Procedures put into effect by Arena.

The information in this data protection notice consists of the contents applicable to our company’s data processing activities overall and data protection notices specific to circumstances of a matter are separately submitted to data subjects, when necessary.

General Processing Activities

Personal data are processed by our company mainly to conduct the relevant activities for the functioning of our business and commercial activities, to protect our rights and interest, to comply with our legal obligations and to monitor and conclude the applications submitted to our company.

In parallel with these aims, personal data may be shared with our business partners, suppliers, group companies, and authorized public institutions and organizations.

Personal data are collected from physical and electronic mediums through automatic and non-automatic manners.

The legal ground for collecting personal data, as stated below, might change depending on the business activities but eventually is based on at least one ground set forth under the law (Article 5 and 6 of the Personal Data Protection Law).

Processing Activities based on Data Subject Types

Website Visitors

We collect the following information from the individuals that visit our website at “www.arena.com.tr” in an anonymized manner by way of utilizing aggregation techniques and other various measures:

• Information on how our website is used (e.g., pages visited, duration of visit, date and time, interactions with the website),

• Technical information regarding the visit (e.g., online identifiers such as IP address and cookie data, information on the device such as device ID, network connection type, browser, language and operating system),

• Non-precise location information, such as the city or country from where you have accessed the website (we infer this information from technical information such as IP address or language preference of the device).

This information is collected by automatic methods through cookies and similar technologies. Cookies are small text files that are saved on your device by the websites you have visited so that your preferences and some of your information could be remembered on your next visits. Cookies can be used to provide additional functions to websites, to allow websites to work more efficiently, or to transmit some information about your visit to the website or cookie owners.

We list below the cookies used on our website, their types, and their purpose of use:

You may configure your browser to block cookies for all or specific sites, to alert when cookies are set, to block third-party cookies, or to reset all cookies per session. In addition, you may delete cookies through your browser or view the list of cookies stored in your browser and the information they contain. You may find the necessary information to set your preferences about cookies in the help pages of your internet browser.

Candidates for Employment

The personal data of the candidates for employment at Arena or our group companies/subsidiaries are processed to evaluate the job applications and to manage the relevant human resources processes.

Personal data are obtained directly from you or third party employment platforms, through physical and electronic media, by automated and non-automatic means, by means of e-mail and phone calls, face-to-face interviews, or through the use of electronic systems and platforms.

The legal grounds for the collection of the personal data are to conclude an agreement within the scope of the application, for necessity arising from legitimate interests of Arena, and, in limited circumstances, your explicit.

The third parties that the personal data might be transferred to and the purposes for such transfers are provided below:

Suppliers, Consultants, and Business Partners

The personal data of our suppliers, consultants, business partners, and their employees and legal representatives include the data provided to us through various communication channels (e.g., email correspondences) and the data contained in agreements and accounting records, which are mainly identity and contact data.

Such personal data are processed to identify the data subjects, to communicate with them, to manage fee proposals, to make payments, to fulfil the tax and other legal liabilities, to record commercial activities, to plan procurements and provision of services, to carry out joint business operations and ensure process efficiency.

Personal data are mostly processed and collected through electronic mediums automatically, but there are also processing activities conducted in physical mediums through non-automatic manners. The legal grounds for collecting the personal data are the legitimate interests of Arena, to execute or fulfil the requirements of an agreement, to comply with our legal obligations, and to exercise our rights.

The third parties that the personal data might be transferred to and the purposes for such transfers are provided below:

Recipients of Products or Services

Personal data concerning recipients of products or services including our dealers as well as their employees and legal representatives are mainly identity, contact, marketing, customer transaction, finance, legal transaction, professional experience information and, in general, the information provided to us through various communication channels (e.g., email correspondences), data contained in agreements and accounting records, and information generated in platforms used for order processing.

Such information is processed to identify the relevant persons within the scope of business activities, to conduct contract management and sale of goods/services processes, to conduct after-sale support services for goods / services, organization and event management, to conduct processes for advertisements / campaigns / promotions, to conduct activities for customer satisfaction, to conduct marketing processes for products/ services, to conduct business activities and logistics activities and finance and accounting affairs, to record commercial activities, to plan procurement and provision of services, to carry out joint business operations and ensure process efficiency.

Personal data are mostly processed and collected through electronic mediums automatically, but there are also processing activities conducted in physical mediums through non-automatic manners. The legal grounds for collecting the personal data are the legitimate interests of Arena, to execute or fulfil the requirements of an agreement, to comply with our legal obligations, and to exercise our rights.

The third parties that the personal data might be transferred to and the purposes for such transfers are provided below:

Potential Recipients of Products or Services

Personal data concerning potential recipients of products or services including persons who applied to become our dealers as well as their employees and legal representatives are mainly identity, contact, marketing, customer transaction, finance, legal transaction, professional experience information and, in general, the information provided to us through various communication channels (e.g., email correspondences), data contained in agreements and accounting records, and information generated in platforms used for order processing.

Such information is processed to identify the relevant persons within the scope of business activities, to conduct contract management and sale of goods/services processes, to conduct processes for advertisements / campaigns / promotions, conducting activities for customer satisfaction, conducting marketing processes for products / services, to conduct business activities, to conduct finance and accounting affairs, to record commercial activities, to plan procurement and provision of services, to carry out joint business operations and ensure process efficiency.

Personal data are mostly processed and collected through electronic mediums automatically, but there are also processing activities conducted in physical mediums through non-automatic manners. The legal grounds for collecting the personal data are the legitimate interests of Arena, to execute or fulfil the requirements of an agreement, to comply with our legal obligations, and to exercise our rights.

The third parties that the personal data might be transferred to and the purposes for such transfers are provided below:

Your Rights Regarding Your Personal Data

Please send your requests concerning your rights regulated under article 11 of the Personal Data Protection Law to our company at Göktürk Merkez Mah. Göktürk Cad. No:4/1, Adres No: 2540206055, Eyüp, İstanbul, by adhering to the requirements set out under the Communiqué on Principles and Procedures for Application to Data Controllers.