Privacy and Security Policy

TR90 AÇIKHAVA MEDYA TEKNOLOJİLERİ A.Ş.
DIGITAL PRIVACY POLICY

Last updated: 30 October 2026

This Privacy Policy lets you know how your personal information is collected, processed and used. Within this framework, TR90 Açıkhava Medya Teknolojileri A.Ş. protects your personal data by taking all technical and administrative measures. Under Law No. 6698 on the Protection of Personal Data (“KVKK”) and the relevant legislation, TR90 Açıkhava Medya Teknolojileri A.Ş., acting as the Data Controller, may process your personal data only within the framework described below and in accordance with the relevant legislation.

Processing of Your Personal Data and Its Scope

Pursuant to Law No. 6698 on the Protection of Personal Data (“KVKK”), the identity, contact, request and message data that you share with us through the contact form on our website (https://tr90.com.tr/) and through our official social media accounts (LinkedIn, Instagram, Facebook, etc.), together with the transaction security data generated on our website infrastructure, may be obtained wholly or partially by automatic means and processed by TR90 Açıkhava Medya Teknolojileri Anonim Şirketi (Joint Stock Company). Any operation performed on data within the scope of the KVKK is considered processing of personal data.

Purposes and Legal Grounds for Processing Your Personal Data

Your personal data shared through the contact form on our website (https://tr90.com.tr/) and through our official social media accounts, together with your transaction security data, are processed:

• To respond to the information, quotation, question and complaint requests conveyed to us regarding the services offered by TR90,
• To carry out customer communication activities,
• To provide after-sales support for goods and services, and to operationally carry out site survey, installation and technical service processes,
• To perform the requirements of the products and services offered by our company, the contract and the rules of commercial good faith in a proper manner,
• To provide information to courts, public prosecutors' offices, law enforcement and competent public authorities, as required by legislation or upon request, in matters of public security, administrative audits and legal disputes,
• To ensure information security processes and the security of servers and systems

for these purposes, on the legal grounds set out in Article 5(2) of the KVKK: “processing of personal data of the parties to a contract is necessary, provided that it is directly related to the conclusion or performance of that contract”, “processing is mandatory for the data controller to be able to fulfil its legal obligation” and “processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”.

Information on Third Parties or Organisations to Which Your Personal Data May Be Transferred

In line with the processing purposes stated above, the personal data you share through our website (https://tr90.com.tr/) and our official social media accounts may be transferred, within the framework of the conditions and purposes for processing personal data stated in Article 8 of the KVKK, to the persons, institutions and organisations listed below:

1. Technical infrastructure/software suppliers and hosting providers from which we receive services for the provision of information technology, server and database infrastructure and for carrying out the technical security and storage processes of the website,
2. Our business partners, subcontractors and field service suppliers, for the purposes of operationally carrying out in the field the requests, quotations or after-sales support processes you send through the contact form, and performing survey, installation and technical service,
3. Persons from whom we obtain consultancy so that our company's activities are carried out in compliance with legislation (for example, lawyers, tax advisors, auditors),
4. Judicial authorities or relevant law enforcement agencies, where requested under the relevant legislation or in order to resolve legal disputes.

Storage and Protection of Personal Data

In accordance with Article 12 of the KVKK, TR90 Açıkhava Medya Teknolojileri Anonim Şirketi takes the necessary technical and administrative measures, such as SSL encryption technologies, strong password/access management, transaction log records and firewalls, for the server systems and databases that hold the personal data collected through the website (https://tr90.com.tr/) and digital communication channels, in order to prevent the unlawful processing of personal data, to prevent unauthorised access and to ensure its secure retention.

If it is determined that processed personal data has been obtained by others through unlawful means (data leak/breach), our company will immediately notify the Personal Data Protection Board and the persons concerned, in accordance with the legislation in force.

Retention of Personal Data for the Period Stipulated in the Relevant Legislation or Required for the Purpose of Processing

TR90 Açıkhava Medya Teknolojileri Anonim Şirketi retains personal data for as long as is appropriate to the purpose. After the period required by the purpose of processing has ended, personal data is deleted or anonymised. In this case, it is also ensured that the third parties to whom the company has transferred personal data delete, destroy or anonymise the personal data.

Use of Cookies

No cookies that track or analyse visitors' movements within the site, or that collect personal data, are used on our website.

Rights of the Data Subject under Law No. 6698 on the Protection of Personal Data

To the extent that your data is processed by the Company and the Company processes your data as the data controller, you have the following rights regarding your personal data:

1. To learn whether any of your personal data is being processed;
2. To request information regarding the processing of your personal data;
3. To learn the purposes of processing your personal data and whether they are used in accordance with those purposes;
4. To learn the third parties, within the country or abroad, to whom personal data has been transferred;
5. To request the correction of personal data if it has been processed incompletely or incorrectly;
6. To request the deletion or destruction of personal data if the reasons requiring its processing no longer exist;
7. To request that the operations carried out pursuant to items (e) and (f) be notified to the third parties to whom the personal data has been transferred;
8. To object to a result against you arising from the analysis of personal data exclusively by automated systems;
9. To request compensation for the damage if you suffer damage due to the unlawful processing of your personal data.

Contact and Application Method

You may submit your requests under Article 11 of the Law, which regulates the rights of the data subject, in accordance with the “Communiqué on the Procedures and Principles of Applications to the Data Controller”, in writing to the address of TR90 Açıkhava Medya Teknolojileri Anonim Şirketi at 3S Kale Topaz Residence, Maltepe Mahallesi, Tayyareci Sami Sokak, No:1/1C Blok D:20 Zeytinburnu/İstanbul, or by e-mail to info@tr90.com.tr.