PRIVACY POLICY AND PERSONAL DATA PROTECTION CLARIFICATION TEXT

SUMMARY

Below is a summary of some key terms of this Privacy Policy and Personal Data Protection Clarification Text. This summary is for your reference only and does not form part of the Privacy Policy and Personal Data Protection Clarification Text.

This Privacy Policy and Personal Data Protection Clarification Text explains the following:

• how we collect your personal data;
• what personal data we collect;
• how we use your personal data;
• who we share your personal data with; and
• the rights and choices you have when it comes to your personal data.

In the light of the below, as Deepwall, we would like to inform you that; the personal data, of relevant persons whose data was provided by you as our partner and/or of our users, has been processed in accordance with the legislation applicable to such data, especially with the Personal Data Protection Law numbered 6698 (“PDPL”) applicable in Republic of Turkey and General Data Protection Regulation (“GDPR”) applicable in European Union and European Economic Area.

Privacy Policy and Personal Data Protection Clarification Text

Last modified: 03 March 2022

1. Who are we?

When we say “DeepWall” “our,” “we,” or “us,” we’re talking about Teknasyon Yazılım Sanayi ve Ticaret Anonim Şirketi. This Privacy Policy and Personal Data Protection Clarification Text (“Privacy and PDP Text”) applies to all of our apps, services, software and website (together, “Services”) unless specified otherwise.

This Privacy and PDP Text explains how we, as Deepwall, will use personal data about you and the steps we take to ensure your personal data is kept secure and confidential. It should be read together with our Terms of Service.

The entitiy which processes your personal data, that you have provided through Deepwall product, in accordance with the legislation, is Teknasyon Yazılım Sanayi ve Ticaret Anonim Şirketi registered before İstanbul Trade Registry with registry number of 943554 and, MERSİS number of 0836068918300001, whose headquarters are located in Maslak Mah. Büyükdere Cad. USO Center NTV Apt. No:245/27 Sarıyer, İstanbul.

2. How do we collect your personal data?

We may obtain personal data from you through the mobile applications, website or other similar devices, channels or applications operated by or on behalf of Deepwall.

3. Which personal data do we collect?

We collect personal data about you when you give this to us in the course of registering for and/or using our Services for example we may collect your name, address, e-mail address or telephone number.

Note that it is your responsibility to check and ensure that all data, content, material or data you provide us is correct, complete, accurate and not misleading.

Data that you may provide voluntarily

Certain parts of our Services may require you to provide personal data voluntarily. For example, we may request certain data permissions in order for you to register an account with us, subscribe or opt out of marketing communications fand/or to submit adminstratice or technical enquiries to us on our Contact Us and Demo Request pages, such as:

• Contact and correspondence data (such as full name, mobile phone number and email address);
• Company name;
• User name and password;
• User transaction records;
• Information on payments and payment methods, inoice information,
• Mobile application name, bundle ID, mobile application ID;
• User experience information
• In order for us to carry out a purchase activity on behalf of you you need to provide us one of these accoring to the platform: Shared Secret, Services JSON, App Secret; Details of products which are exposed for sale;
• Details of products which are exposed for sale;
• Profile data (such as profile photo and biography);
• Other data you choose to give us (such as data to identify a lost account).

When you use our Services, we may also ask you to share with us specific client data which we may use to deliver and/or optimise our Services, including the following;

• IDFA, GAID or OAID: Advertising identity for Apple, Google or Huawei;
• IP Address and mobile device identifiers such as device ID;
• Geographic location and language preferences.

The personal data that you are asked to provide and the reasons why you are asked to provide it, shall be disclosed to you at the point of any data or permission request.

Data that may be collected automatically

When you use our Services, we may also collect data automatically from you and/or your device which may be considered personal data under applicable data protection laws, such as:

• Data and analytics about your use of our Services;
• Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);
• Data about your device, such as device name and operating system, browser type and language;
• Data we collect with cookies and similar technologies;
• Broad geographic location based on your IP address;
• Precise geo-location data (GPS, with your consent); and
• Data about your use of our Services, such as in application interaction and usage metrics.

On Apple you can opt-out this by choosing “limit ad tracking” option from privacy settings. On Google Android you can opt-out by choosing “Opt-out of interest based ads” option from privacy settings. On Huawei, you can opt-out by choosing “disable personalized ads” option from privacy settings.

Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

Data about your device refers to data about your device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Some of this data may be collected using cookies and/or similar technologies (such as 'SDKs' or software development kits), as explained further below.

Data that we may obtain from third party sources

We may receive personal data about you from third party sources. For example, if you clicked on an advertisement to direct you to one of our Services we may be provided with data from which ad-network and advertising campaign the install originated from

You may choose to connect to our Services via your Google account. Exactly what data we receive from your social media will depend on your social media privacy settings, but it would typically include your basic public profile data such as:

• your username;
• profile picture;
• age range; and
• gender

The data that we may collect from our partners could include;

• Data we receive if you link a third-party tool with our Services (such as Facebook, Apple or Google);
• Demographic data (such as to determine the location of your IP address);
• Data to fight fraud (such as click fraud in advertising);
• Data from platforms that our Services run on (such as to verify payment); and
• Data for advertising and analytics purposes, so we can optimise the Services we deliver to you.

We do not request or intend to collect any special or sensitive categories of data such as any data on health, race, religion, political opinions, sexual preferences or orientation.

4. How do we use your personal data and process those for which reasons?

We may process and use your personal data:

1. to enable you to access and use the Services. For example;

• To perform signing-up process to DeepWall
• To create and manage user accounts and profiles;
• To verify your identification or device;
• To provide you with the correct versions of our applications; and
• To send you service related communications including confirmations, technical notices, updates, security alerts, and support or administrative messages.
• To verify invoice of purchase on your behalf through App Store, Google play and Hawei App Gallery

More specifically, we may use your personal data to enable our verification function that allows for the verification of a specific access request or ID authentication.

2. to personalise and improve aspects of our Services. For example;

• To respond to your customer support requests;
• To receive error messages about any issues you / your device encounters with our Services to enable us to fix bugs and interoperability issues;
• To detecting and preventing illegal activities;
• To conduct optional user feedback surveys, to receive and evaluate feedbacks for development of our services;
• To communicate with our users and manage user relationship;
• To remember you next time you visit one of our Services; and
• Communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by us.

3. to communicate with you, including some or all of the following:

• To provide you with promotional offers and rewards based on your interaction with our Services;
• To serve you with relevant targeted advertisements;
• To send you marketing communications and/or newsletters if you have subscribed for them about rewards and promotions.

4. for research, such as analysing market trends and customer demographics;

5. To comply with legal obligations, including to prevent and/or detect fraud or provide disclosure to the authorities when required by applicable law.

6. To carry out our activities in accordance with legislation, to eveluate and inspect our business activities, to carry out financial and accounting activities, to accrue invoice, to ensure the security of your transaction/,

7. To optimize the use for application users, analyzes to develop well, uses for customer-oriented use, to promote DeepWall; about marketing,

8. Contacting you with commercial electronic messages

5. Legal reasons and collection method of your personal data

We collect your personal data by automatic and non-automatic methods through the DeepWall panel (API) and website.

We will only collect and use your personal data (as described in section 4) in accordance with relevant data protection laws. Our legal grounds for processing your personal data are as follows:

1. Consent - Where necessary we will only collect and process your personal data if you have given your clear and affirmative consent for us to do so. In order to promote DeepWall and carry out marketing activities, your contact information is processed in order to contact you via e-mail if we have your express consent. You may withdraw your consent anytime without any reason by sending an e-mail to info@deepwall.com .

2. Legitimate Interests - We may use and process some of your personal data where we have sensible and legitimate business grounds for doing so. Under PDPL and European privacy laws there is a concept of “legitimate interests” as a legal justification for processing your personal data. Our legitimate interests for processing your personal data are for us to enable you access and use of our Services, to communicate with you about our Services and to improve our Services. In order to provide you with a better service, your User Transaction, Location, Transaction Security, advertising ID information is processed.

3. It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the Establishment or Performance of the Contract. - We may need to collect and use your personal information, as applicable, to establish agreement and perform our contractual obligations to you. DeepWall is a membership-based platform. During the completion of your membership, your Identity & Contact information, Transaction Security information and Location & Language information are processed. Your financial information is processed when payment is required on your behalf.

4. Processing of personal data in order to fulfill our legal obligations: Your name-surname and related billing information are processed during invoice creation.

6. Who do we share your personal data with?

When you use any of our Services, we may disclose your personal data to the following parties:

7. Which cookies do we use?

A cookie is a very small text file placed on your computer or device. We and our partners use cookies and similar technologies to provide and personalize our Services, analyze their use, target ads and prevent fraud. You can disable cookies in your browser settings, but in this case some parts of our Services may not work properly.

8. What ads do we show on our Services?

The advertisements you see displayed on our Services are provided on behalf of certain third-party advertising companies. No information that identifies you, such as your name, address, e-mail address or telephone number, is used to provide these advertisements. In order to display the advertisements that are most relevant to you, these third-party advertisers may place a cookie on your browser or use a cookie placed in this way. This cookie does not collect personal information about you or is not linked to personally identifiable information about you. By using our services, you consent to the use of such third-party cookies for these purposes.

9. What measures do we take to keep your personal data safe?

The security of your personal information is very important to us. That's why we use HTTPS where appropriate to help keep information about you secure. However, it cannot be guaranteed that information transmitted over the Internet is completely secure.

We do our best to keep the information you disclose to us secure. However, we cannot guarantee the security of the information you submit to us, and you do so at your own risk. By using our services, you accept the risks associated with providing information over the internet and you will not hold us responsible for any breach of security.

10. How long do we keep your personal information?

Unless a longer retention period is required or permitted by law, your personal information will only be provided for as long as it is reasonably necessary to fulfill the purposes set forth in this Privacy and PDP Text and for our legitimate interests such as complying with legal obligations, resolving disputes, and fulfilling our contracts. we will hold. For example, we will periodically disable credentials of unused accounts and review our datasets on a regular basis.

11. Do we transfer your personal information outside of your country of residence?

Our services are global in nature and your personal information may be transferred and processed in countries other than your country of residence in accordance with your express consent. These countries may have data protection laws that differ from the laws of your own country. We take all measures to provide adequate and appropriate measures to protect your data as described in the Privacy and PDP Text. Appropriate safeguards available to our business partners include standard contractual clauses approved by the EU Commission and Privacy Protection certification if transferred to the USA.

12. Your personal data rights and ways to contact us

You have certain rights under current data protection legislation, including the right to request a copy of the personal information we hold about you, if you request it from us in writing.

• Right of access: your right to request copies of your personal information from us;
• Right to rectification: your right to request that we correct your personal information if it is inaccurate or incomplete;
• Right to delete: your right to request the deletion and removal of your personal information from our systems;
• The right to restrict the use of your information: your right to request that we “block” our use of your personal information or limit the ways we use it;
• Right to data portability: your right to request that we move, copy or transfer your personal information;
• Right to object: your right to object to our use of your personal information, including where we use it for our legitimate interests.

Your Rights as a Relevant Person Pursuant to Article 11 of KVKK

Your requests, questions and complaints regarding your aforementioned rights, as personal data owners, in written form and with the documents identifying your identity, together with your written petition containing your explanations about the right you want to exercise, to our Company's Maslak Mah. Buyukdere Cad. Uso Center NTV Apt. No:245 Kat:7 Sarıyer/ İSTANBUL in person, via a notary public or by registered letter with return receipt or by sending an e-mail to info@deepwall.com or support@deepwall.com, your request will be evaluated by our Company and will be sent to the fastest way possible as stipulated within the scope of PDPL. will be finalized within 30 (thirty) days. Although it is essential not to charge any fee for the requests, our Company reserves the right to charge a fee based on the fee schedule determined by the Personal Data Protection Board.

Without prejudice to the cases stipulated in Article 28 of the PDPL titled 'Exceptions', by applying to our Company; learning whether it has been processed; request information about it if it has been processed; learning the purpose of processing and whether it is used in accordance with its purpose; knowing the third parties to whom it has been transferred in the country or abroad; requesting notification of transactions made by third parties to which it has been transferred; requesting their correction if they are incomplete or incorrectly processed; requesting its deletion or destruction in the event that the reasons requiring its processing disappear; requesting the notification of the transactions made to the third parties to whom your personal data has been transferred; Within the scope of PDPL, we inform you that you have the right to object to the emergence of a result against you by analyzing it exclusively through automatic systems and to demand the compensation of the damage in case you suffer damage due to the processing in violation of the PDPL, as a 'Data Controller'.

Changes to this Privacy and PDP Text

We reserve the right to amend or modify this Privacy and PDP Text at any time and any changes will be published on our Services. The date of the most recent revision will appear on this page. If we make significant changes to this policy, we may also notify you by other means such as sending an email. Where required by law we will obtain your consent to make these changes. If you do not agree with any changes, please do not continue to use our Services.

Exclusive rights to EEA and UK users

Individuals subject to European data protection laws may have data subject rights in relation to the personal data we hold on them. This in itself may be subject to limitations and/or restrictions. If you are in the EEA (European Economic Area), please contact us to exercise your rights.

Access to Data

If requested, we will confirm whether we are processing your personal data and, if so, we will provide you with a copy of this personal data along with other relevant information.

Restricting the processing of personal data

You can ask us to restrict or 'block' the processing of personal information in certain of your data, for example you may object to the accuracy or processing of the data. We will notify you before removing any restrictions on processing. If we share your personal data with others, we will notify them of the restriction where possible. If requested and if this is possible and legal, we will let you know with whom we share it or share your personal data so you can contact us directly if necessary.

Objections

Your rights:

• You can ask us to stop processing your personal data at any time. If we rely on a legitimate interest to process your personal data, there should be no problem as long as we demonstrate essential legitimate grounds for processing;
• You can object to the processing of your data for marketing purposes at any time. This can be done via 'unsubscribe' in our marketing emails; and
• refuse to receive service notifications via e-mail.
• You can opt out of giving us further access to your location data at any time by emailing info@deepwall.com or support@deepwall.com.

Withdrawal of approval

Although we rely on your consent to process your personal data, you have the right to withdraw this consent at any time. Please be aware that this does not change the way we process your data before we receive notification of your request to withdraw your consent.

Appearance and correction of data

You have the right to have incomplete or inaccurate personal data rectified or completed. If your personal data is shared with others, we will also notify them of the correction.

Deletion of data

You have the right to refuse to use our Website / product and in certain circumstances you may request that we delete or remove your personal data. If we share your data with others, we will again notify them of changes where possible. If requested, and wherever possible and legal, we will also inform you with whom we share your personal data so that you can contact them directly if necessary.

Data retention

We will retain your personal data until you decide to delete your account (on request) or as required by law or for legitimate business purposes (tax, legal, accounting, fraud or abuse prevention and/or other purposes). This data can be retained even after an account is deleted.

Upon expiration of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations. In some cases, we may anonymize your personal data so that it can no longer be associated with you. In this case, such data is no longer considered personal.

If you agree to receive marketing communications, we will retain your data until you unsubscribe; this is possible with the 'unsubscribe' button at the end of our marketing emails. Additional methods for unsubscribing may be added in the future.

Data portability

You have the right to receive from us your personal data that you have agreed to provide to us or that are necessary to us in connection with our contract with you. We will provide your personal data in a structured, commonly used and computer-readable format.

Making a complaint to the data protection authority

Please contact us if you have questions about our privacy practices, including our personal data processing practice or our privacy practices. Note that we may need to ask you for more information to verify your identity before responding to any request.

Exclusive rights of users resident in California

If you are a valid California resident, the California Consumer Privacy Act ('CCPA') gives you specific rights regarding our collection and use of your personal information. You have the following rights under the CCPA:

• The right to request clarification regarding certain information about our collection and use of your personal information in the last 12 months.
• List of categories of personal information collected and disclosed about consumers “What personal information do we collect?” In the section 'Who do we share your personal information with?'
• Please contact us to request data portability.
• You have the right to request the deletion of the personal information we collect from you.

In addition, at any time you wish your rights listed above; As personal data owners, with your written petition containing your explanations about the right you want to use, together with the documents identifying your identity, to our Company's Maslak Mah. Buyukdere Cad. Uso Center NTV Apt. No:245 Kat:7 Sarıyer/ İSTANBUL in person, via a notary public or by registered letter with return receipt or by sending an e-mail to info@deepwall.com or support@deepwall.com.

Please note that these rights may be limited in certain circumstances provided by applicable law.

Please note that these rights may be limited in certain circumstances provided by applicable law.