Personal Data Policy (KVKK Supplement)

1. Introduction

1.1. Purpose and Scope

This policy describes the principles applied by MACHEX LTD (the "Company"), owner and operator of the Machex brand, when Turkish Personal Data Protection Law No. 6698 ("KVKK" or the "Law") applies. The Law entered into force on 7 April 2016. This supplement is read together with the Privacy Policy; it does not replace applicable GDPR rights or obligations.

This policy covers visitors, individual and corporate members, buyers, sellers and service providers using the Machex marine marketplace.

1.2. Effective Date and Amendments

This text has been updated for the Machex marine platform. Last updated: 6 September 2026.

The Company may amend this policy in line with changes in legislation. The current version is available at https://machex.com/legal/data-policy.

2. Legal Framework, Grounds and Principles

Where KVKK applies, the Company observes applicable obligations under that Law and related legislation, including relevant regulatory decisions. For processing subject to GDPR, the Privacy Policy describes the applicable framework.

The Company monitors legislative changes and informs members, managers, staff and visitors where necessary.

Personal data is processed in accordance with these principles:

Lawfulness and fairness.

Accuracy and, where necessary, keeping data up to date.

Specific, explicit and legitimate purposes.

Relevance, limitation and proportionality to the purposes of processing.

Retention only for the period required by applicable legislation or the processing purpose.

Under Article 5 of KVKK, explicit consent is required unless a statutory exception applies. Such exceptions include:

Processing expressly provided for by law.

Processing data of the parties where directly necessary to conclude or perform a contract.

Processing necessary for the controller to fulfil a legal obligation.

Data made public by the data subject, within the applicable limits.

Processing necessary to establish, exercise or protect a right.

Where the applicable conditions are met, these grounds permit processing without explicit consent.

3. Purposes of Processing

Depending on the platform features you use, personal data may be processed for the following purposes under the conditions in the Law and applicable legislation:

4. Categories of Personal Data

The following categories may be processed in accordance with the conditions laid down by the Law and applicable legislation:

Data is collected electronically through registration and profile forms, listings, verification requests, messaging and offer workflows, payment records, support requests and technical records generated during platform use, and physically through written requests submitted to the Company.

5. Transfers of Personal Data

To the extent necessary for the service, personal data may be shared with hosting, authentication, communication and payment providers, the other party to your requested transaction, legal and financial advisers and competent authorities, for the relevant purpose and under Article 8 of KVKK where applicable. Information you choose to publish in listings may be visible to other visitors.

Transfers subject to Article 9 of KVKK are assessed under that provision. The relevant processing condition must be met together with an adequacy decision or, in its absence, appropriate safeguards prescribed by law. These may include standard contracts, approved binding corporate rules or undertakings subject to Board approval. Without adequacy or appropriate safeguards, only legally permitted occasional-transfer exceptions may apply; ongoing service use cannot rely on an occasional-transfer exception. GDPR transfer requirements also apply where relevant.

6. Your Rights

Where KVKK applies, you may contact the Company to exercise the following rights:

Learn whether your personal data is being processed.

Request information about processing of your personal data.

Learn the purposes of processing and whether data is used consistently with those purposes.

Learn the third parties to whom data is transferred domestically or abroad.

Request correction of incomplete or inaccurate personal data.

Request deletion or destruction under the conditions in Article 7 of the Law.

Request that recipients be notified of correction, deletion or destruction.

Object to an adverse result produced exclusively by automated analysis of your data.

Seek compensation for damage caused by unlawful processing.

These rights are subject to the applicable statutory conditions. GDPR rights remain available where applicable.

You may use the form at https://machex.com/legal/data-request. KVKK requests are answered as soon as possible and within thirty days, normally free of charge; a fee may be charged only where permitted under the applicable Board tariff. GDPR requests follow the GDPR procedure described in the form and Privacy Policy.

For requests submitted under the KVKK procedure, the required particulars include:

First name, surname and a signature for written requests; the applicable electronic or mobile signature for the relevant electronic submission method.

For Turkish citizens, the required national identity number; for other nationals, nationality and passport number or identity number where applicable. Provide only information necessary for the relevant procedure and identity check.

A residential or business address for correspondence.

An email address and telephone number for notification.

The subject of the request.

These particulars are required where the relevant statutory procedure applies; they do not impose additional formalities on GDPR requests.

Relevant supporting information and documents should be included. For written requests under KVKK, the application date is the date complete documents are delivered to the Company; for other methods, it is the date the complete request reaches the Company, subject to the applicable legal procedure.

The Company verifies that the applicant is the person entitled to exercise the rights. It may request proportionate additional information to clarify the request or confirm identity where necessary.

Replies are provided in writing or electronically. If a request is rejected, the reasons will be explained.

7. Deletion, Destruction and Anonymisation

Under Article 7 of KVKK, where the grounds for processing no longer exist and no lawful longer retention period applies, personal data is deleted, destroyed or anonymised on the Company's initiative or at the data subject's request, in accordance with applicable guidance, disposal procedures, the data inventory and the request.

Data is retained only for the applicable statutory period or as needed for the processing purpose. Account and transaction relationships, statutory retention duties and the protection of rights determine the period. Data is deleted, destroyed or anonymised when retention is no longer necessary.