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We, Santa Farma İlaç Sanayii A.Ş. (“Santa Farma” or the “Company”), provide this privacy notice as the Data Controller pursuant to article 10 “Disclosure Obligation of Data Controller” of the Personal Data Protection Act no. 6698 (“PDPA”) which was promulgated in the Official Gazette no. 29677 on April 7, 2016 with a view to protecting the fundamental rights and freedoms of individuals in relation to processing of personal data, including especially the right to privacy, and determining the obligations of real and legal persons acting as data processors.

Santa Farma optimizes its system infrastructure and online presentations in order to protect the personal data obtained from its Customers and/or representatives of Customers.

PERSONAL DATA TO BE PROCESSED Santa Farma will process the following personal data about you under its relationship with you:

(i) Identity Details

(ii) Contact Information

(iii) Data about your Education, Business and Professional Career

(iv) Financial Data

(v) Data Related to the Security of the Corporate Premises and your Visual and Audio Data

(vii) Legal Action Data

(viii) Client Transaction Data

(ix) Cyber Security Data

(x) Special Categories of Personal Data: Association, foundation, labour union membership; personal health data; conviction and security measure data; fingerprint data

PURPOSE OF PROCESSING PERSONAL DATA Santa Farma processes, stores and transfers personal data, to the extent permitted in the law, which are deemed to be required for providing the services and products in the best manner possible in addition to the mandatory data for its employees, customers, representatives of customers and healthcare professionals.

In that respect, personal data are processed for:

performance of employment contract and fulfilment of legal obligations for corporate staff.

presenting corporate products and services and fulfilling necessary activities in that respect, monitoring and recording adverse impacts and reactions of products, communicating with the parties in relation to products and services in case of explicit consent, communicating with the parties in order to minimize potential reactions of medications, conducting marketing activities, performing customer acquisition activities and sharing offers about our products and services in that respect, and preparing reports and conducting reviews required for corporate activities for customers, suppliers and solution partners.

presenting corporate products and services and fulfilling necessary activities in that respect, monitoring and recording adverse impacts and reactions of products, communicating with the parties in relation to products and services in case of explicit consent, communicating with the parties in order to minimize potential reactions of medications, creating trainer participant lists, preparing accommodation and travel plans for congresses, completing value transfer forms and submitting notifications to the Ministry, fulfilling other legal obligations provided in the relevant regulations, and preparing mandatory reports and reviews which are required for corporate activities for healthcare professionals.

COLLECTION OF PERSONAL DATA AND LEGAL MOTIVE Santa Farma shall obtain the personal data of its employees, Customers and/or representatives of Customers, suppliers, solution partners and healthcare professionals by means of all kinds of written, verbal and electronic media, third persons and competent authorities in order to fulfil the objectives and provide the services in line with the principles provided in articles 5/1, 5/2/a, 5/2/c, 5/2/ç, 5/2/e, 5/2/f , 6/2, 6/3 and 8 of the Act.

TRANSFER OF PROCESSED PERSONAL DATA Santa Farma may disclose the personal data with the domestic or foreign third parties offering services for provision of products and services or performance of contracts, foreign affiliates of Santa Farma, persons and entities providing services and/or consulting provided that Santa Farma shall have discretion to execute a non-disclosure agreement, business partners working on contracts, and third parties involved in joint projects.

Santa Farma shall be obliged to store the records and documentation related to the processes conducted with its customers for a certain period of time indicated in the law. In that respect, any request for deletion, destruction or anonymization of personal data shall be fulfilled by Santa Farma only after the conclusion of the legal period whereas Santa Farma shall refrain from processing your personal data and disclosing the personal data to third parties apart from mandatory conditions arising from national and international laws, regulations and agreements during the relevant period.

DATA SUBJECT RIGHTS As of October 7, 2016, the Customers themselves, if they are real persons, or the real person representatives of the Customers that are legal persons may contact Santa Farma under the provisions of PDPA in order to:

· learn whether or not their personal data have been processed,

· request information about the processing, if any,

· request information about the processing purpose and whether or not the use of the data is fit for the purpose,

· Yurt içinde veya yurt dışında kişisel verilerin aktarıldığı üçüncü kişileri bilme,

· receive information about the recipient domestic/foreign third parties,

· ask for correction in case of incomplete or incorrect processing of the personal data,

· ask for deletion or destruction of personal data,

· request for provision of information to recipient third parties in case of correction, deletion or destruction of personal data,

· object to any unfavourable result arising from analysis of processed data with automated systems exclusively,

· demand indemnification against losses, if any, incurred as a result of processing activities in violation of the law.

Santa Farma shall respond to all such requests within maximum thirty days free of charge. Nevertheless, please note that our company shall charge the fee provided in the applicable tariff if the Personal Data Protection Committee provides for any fee for the relevant request.

CONTACT DETAILS FOR YOUR REQUESTS If you wish to communicate with us to give feedback or ask questions under the Act no. 6698, please deliver your request to Santa Farma İlaç San. A.Ş Okmeydanı, Boru Çiçeği Sok. No:20 Şişli, Istanbul in person, via notary or santafarmaas@hs01.kep.tr through safe electronic signature along with your letter of request as well as documentation meant to prove your identity.

The Company shall accept the written request following the verification of identity and give feedback to the relevant parties within the legal period.

Version: 01072020

Date: 21.07.2020

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Santa Farma İlaç San. A.Ş.