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Personal Data Processing and Protection Policy

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Purpose

The purpose of this Policy is to ensure that Neo Menkul Değerler A.Ş. (“Neo Menkul” or the “Company”) complies with the Constitution of the Republic of Türkiye and the Personal Data Protection Law No. 6698 (the “Law”). In particular, it aims to protect individuals’ fundamental rights and freedoms, privacy and personal data, with particular regard to the confidentiality of private life; ensure compliance with obligations relating to the processing of personal data; establish strategies, internal controls and safeguards, operating procedures and responsibilities for the processing and security of personal data; and ensure transparency by informing individuals whose personal data is processed by the Company.

Scope

This Policy applies to investors, customers, employees, employees’ family members, job applicants, interns, shareholders, entrepreneurs, business partners, employees, shareholders and representatives of institutions with which the Company cooperates, visitors, and any other natural persons who establish a relationship with the Company in any capacity, where their personal data is processed by Neo Menkul wholly or partly by automated means or by non-automated means, provided that such processing forms part of a data recording system.

Responsibility

This Policy has been approved by the Board of Directors of Neo Menkul and has entered into force. All activities carried out and measures implemented within Neo Menkul under this Policy shall be governed by the relevant procedures. Senior Management of Neo Menkul is responsible for preparing, updating and implementing these procedures. All Neo Menkul employees are responsible for performing their duties in accordance with the Company’s policies, all relevant procedures and applicable legislation.

Neo Menkul Değerler A.Ş. regards the protection of personal data as a fundamental element of its corporate governance approach and takes all necessary administrative and technical measures to ensure full compliance with applicable legislation.

In accordance with the principles and provisions set out in this Policy, the Company aims to ensure that personal data is processed lawfully, securely and transparently, while taking the utmost care to protect data subjects’ rights.

This Policy may be reviewed and revised, where necessary, in response to changes in applicable legislation or updates required by the Company’s business processes. Neo Menkul undertakes to continually improve its compliance with personal data protection obligations and to maintain awareness of personal data protection across the organisation.