Personal Data Protection and Disclosure Notice

# PERSONAL DATA PROTECTION AND DISCLOSURE NOTICE **Last Updated:** August 22, 2026 At Newstones, we attach great importance to the privacy and security of your personal data. This Personal Data Protection and Disclosure Notice has been prepared to inform you, within the scope of Turkish Personal Data Protection Law No. 6698 (“KVKK”), about how your personal data is processed, the purposes for which it is processed, the legal grounds for processing, the parties to whom it may be transferred, the methods through which it is collected, and your rights as a data subject. ## 1. Data Controller Within the scope of Law No. 6698 on the Protection of Personal Data (“KVKK”), your personal data is processed by **Newstones**, acting as the data controller. Newstones aims to process personal data in accordance with the principles set forth under KVKK and applicable legislation and to take the necessary measures to ensure the security of personal data. ## 2. Personal Data Processed Depending on your communication with Newstones, requests for information about our products or services, quotation requests, or use of our website, the following personal data may be processed: ### Identity Information * Name * Surname * Position or title within the company ### Contact Information * Telephone number * Email address * Address information ### Customer Transaction Information * Product and service requests * Quotation requests * Order information * Request and application records * Communication history ### Transaction Security Information * IP address * Website access records * Log records * Browser information * Device information ### Cookie and Usage Data * Website usage information * Pages visited * Technical connection information * Information obtained through cookies and similar technologies Your personal data is processed only to the extent necessary for the relevant processing activity. ## 3. Purposes of Processing Personal Data Your personal data may be processed for the following purposes: * Responding to product and service requests, * Providing information about our products, * Evaluating quotation requests and preparing quotations, * Managing customer and prospective customer relationships, * Managing order and sales processes, * Responding to communication requests, * Evaluating requests and complaints, * Managing contractual and commercial processes, * Conducting invoicing and accounting processes, * Managing business activities and operational processes, * Ensuring website security, * Managing information technologies and technical infrastructure, * Fulfilling legal obligations, * Responding to requests from authorized public institutions and organizations, * Improving service quality and customer experience, * Sending commercial electronic communications where the necessary consent has been obtained. ## 4. Methods of Collecting Personal Data Your personal data may be collected automatically or by non-automated means through: * Contact forms available on the Newstones website, * Quotation and information request forms, * Email, * Telephone, * Physical or electronic contracts, * Orders and commercial documents, * Communications with customers and business partners, * Cookies and similar technologies used on the website. ## 5. Legal Grounds for Processing Personal Data Your personal data is processed based on one or more of the legal grounds specified under Article 5 of KVKK, depending on the nature of the relevant processing activity. Accordingly, your personal data may be processed based on the following legal grounds: * Being directly related to the establishment or performance of a contract, * Being necessary for the data controller to fulfill a legal obligation, * Being necessary for the establishment, exercise, or protection of a legal right, * Being necessary for the legitimate interests of the data controller, provided that such processing does not prejudice the fundamental rights and freedoms of the data subject, * Being expressly provided for by law, * The explicit consent of the data subject where required. The applicable legal ground is assessed separately for each personal data processing activity according to the nature of the relevant process. ## 6. Transfer of Personal Data Your personal data may be transferred, only to the extent necessary for the relevant processing purpose and in accordance with KVKK, to the following categories of recipients: * Authorized public institutions and organizations, * Judicial and administrative authorities, * Financial advisory and accounting service providers, * Legal and financial consultants, * Website, hosting, software, and IT service providers, * Cargo and logistics service providers, * Business partners and service providers, * Legally authorized persons and organizations. Your personal data is transferred only within the scope and for the purposes required by the relevant processing activity. ## 7. International Transfer of Personal Data If your personal data needs to be transferred outside Türkiye, such transfers are carried out in accordance with the conditions stipulated under KVKK and applicable legislation. Where an international transfer takes place, the relevant legal requirements and necessary security measures are assessed and implemented. ## 8. Retention of Personal Data Your personal data is retained for the period required by the purposes of processing and in accordance with the statutory retention periods stipulated under applicable legislation. When the processing purpose ceases to exist or the applicable legal retention period expires, your personal data is deleted, destroyed, or anonymized in accordance with applicable legislation. ## 9. Cookies The Newstones website may use cookies and similar technologies to ensure the proper functioning of the website, improve security, enhance user experience, and perform necessary analyses. Essential cookies may be used to provide the basic functions of the website. For analytical, performance, or marketing cookies, user preferences and/or explicit consent mechanisms are implemented where required by applicable legislation. You may change your cookie preferences through your internet browser settings. ## 10. Rights of Data Subjects under KVKK Under Article 11 of KVKK, you have the following rights as a data subject: 1. To learn whether your personal data is being processed, 2. To request information regarding the processing of your personal data, 3. To learn the purpose of processing your personal data and whether it is used in accordance with that purpose, 4. To know the third parties to whom your personal data has been transferred domestically or internationally, 5. To request the correction of incomplete or inaccurately processed personal data, 6. To request the deletion or destruction of your personal data under the conditions stipulated by KVKK, 7. To request that the correction, deletion, or destruction of your personal data be notified to third parties to whom your personal data has been transferred, 8. To object to a result arising against you as a result of the analysis of processed data exclusively through automated systems, 9. To request compensation for damages arising from the unlawful processing of your personal data. ## 11. How to Exercise Your Rights You may submit an application to Newstones in order to exercise your rights under KVKK. Your application should include the following information: * Name and surname, * Turkish ID number; for foreign nationals, passport number or identification number, * Residential or business address for notification purposes, * Email address, telephone number, or fax number, where applicable, * Subject of the request, * Explanation regarding your request. Applications are evaluated and concluded within the statutory period in accordance with the procedures and principles stipulated under KVKK and applicable legislation. If responding to an application requires an additional cost, the relevant fees stipulated under applicable legislation may apply. ## 12. Explicit Consent For personal data processing activities that require explicit consent under KVKK, the explicit consent of the relevant data subject is obtained separately. The obligation to provide information and the process of obtaining explicit consent are separate processes. Therefore, where explicit consent is required, a separate explicit consent text is provided to the relevant data subject. ## 13. Updates Newstones reserves the right to update this Personal Data Protection and Disclosure Notice in accordance with changes in legislation, technological developments, or changes to its personal data processing activities. The updated version becomes effective as of the date it is published on the website. ## 14. Contact For questions regarding your rights under KVKK, the processing of your personal data, or this Disclosure Notice, you may contact Newstones through the communication channels provided on its website. **Newstones** **Website:** Newstones official website **Email:** Contact email address provided on the website **Telephone:** Contact telephone number provided on the website