This Privacy Policy regulates the policy regarding the confidentiality of the information and documents shared by Digital Risk Management Platforms Limited ("Polipilot") operating at 239-241 Kennington Lane London SE11 5QU United Kingdom and the parties who have accepted the Insurance and Risk Management System User Agreement ("Company") during the use of the Insurance and Risk Management System ("Platform") offered by Polipilot. Polipilot has adopted the principle of protecting the confidentiality of Platform users as a principle, and as Polipilot, it is our first priority to protect the information provided by the Company, Company officials or employees before and during the use of the Platform and to ensure their confidentiality.

In this context, as Polipilot, we take all necessary measures and actions to comply with the provisions of the Personal Data Protection Law No. 6698 ("Law"), the decisions of the Personal Data Protection Board ("Board") and, to the extent appropriate, the provisions of the European Union Data Protection Regulation ("GDPR") for the lawful processing of personal data.

This Privacy Policy applies exclusively to data collected through the Platform. There may be additional personal (and other) information that we have or collect about you or your company pursuant to other relationships subject to other contracts and rules. In this context, this Privacy Policy has been prepared to inform you about what kind of information about users is processed by Polipilot and how it is used, and to provide information on how you can exercise your rights as a data owner.

Collection, use and processing of personal data

Polipilot collects, uses and discloses Personal Information about you (including persons associated with you, all of whom will be referred to in this Privacy Policy as "you") in the ordinary course of business for the purposes set out below:

• Communicating with you and maintaining communications;
• In cases where you request a service from Polipilot, to assist you in completing your application, evaluating the suitability of the requested service, providing and maintaining the service and renewing this service;
• Respond to your requests for information about applications, accounts and other services;
• Make recommendations for future service needs;
• Allow our affiliates and subsidiaries to notify you of certain products or services offered by them;
• Processing transactions through service providers;
• To share with these associations for customers/participants who obtain insurance coverage by becoming a member of the relevant association;
• Share with financial institutions and other organizations with which we have joint marketing agreements;
• Ensure legal, security, processing and regulatory requirements;
• Providing protection against fraud, suspicious or other illegal activities; and
• Generate statistics to be used for analyzing the platform and our business.

What Information Do We Collect?

Information you volunteered, When using the Platform as a registered user, the data received from you as your employer or employee may include, but not limited to, the following information, which may vary depending on the scope of the Platform and may be needed for the use of the services provided through the Platform by your employer and you:

• Information you provide in applications or other forms, which may include your name, address, e-mail address, age, personal identification numbers, credit card numbers, credit records, banking information, payment records, medical and health information, employment and income information;
• information we obtain from and/or make available to other persons (such as government agencies, industry associations, auditors, surveyors, your insurer and your employer) to verify your identity and the accuracy of the information you provide;
• Information received from Polipilot's affiliates, insurers, other intermediaries, third party providers and other parties for underwriting or claims purposes (such as previous insurance and claims history); and
• Information we receive from consumer reporting agencies.

All Personal Information you submit to us will be used for the purposes set out in the Platform, the Clarification Text or this Privacy Policy.

With Whom Do We Share Your Data?

We will not disclose, share, sell or otherwise use your Personal Information without your consent, except to the extent required by law, in accordance with your instructions or as set out in this Privacy Policy. Polipilot may transfer the personal data transferred within the scope of the Polipilot Usage Agreement to Polipliot's affiliates, representatives and service providers, suppliers, legally authorized public institutions and organizations, authorized resellers, Amazon Web Service servers where the Platform is kept and abroad within this scope.

Affiliates: In the ordinary course of business, which includes servicing our Customers, your Personal Information may be shared between Polipilot and its affiliates for research and statistical purposes, systems administration and crime prevention or detection purposes. This may require accessing or moving Personal Information in a different country from where the Personal Information was collected. When you provide us with information containing Personal Information of third parties (for example, names, addresses or other information about living persons), we will retain and use that Personal Information to provide general insurance and other services to you on the understanding that the persons to whom that Personal Information relates have been informed of the reasons for obtaining that Confidential Information, that such Confidential Information may be disclosed to third parties, and have consented to such disclosures and use.

Agents and Service Providers: We sometimes contract with other companies and individuals at home and abroad to perform functions or services for or on behalf of Polipilot, such as hosting this Platform, sending email messages and making phone calls. They may have access to Personal Information such as addresses needed to perform their functions, but they are contractually restricted from using this information for purposes other than providing services to Polipilot or on our behalf.

Business Transfers: As we continue to develop our business, we may sell or buy assets. In such transactions, user information is often one of the transferred business assets. Also, if Polipilot itself or any of Polipilot's assets were acquired (including in bankruptcy proceedings), your Personal Information may be one of the transferred assets.

Legal Considerations: Polipilot has the right to retain and disclose any information about you or your use of this platform without your prior consent if Polipilot has a good faith belief that such action is necessary to:

(a) the rights, property or safety of Polipilot or its affiliates, other users of this platform or the public;

(b) enforce the terms and conditions applicable to the use of this platform;

(c) responding to claims that any content violates the rights of third parties;

(d) respond to allegations of suspected or actual illegal activity;

(e) respond to an audit or investigate a complaint or security threat; or

(f) comply with applicable laws, regulations, legal proceedings or governmental authorities.

What Steps Do We Take to Protect Your Information?

We take physical, electronic and procedural security measures appropriate to the sensitivity of the information we hold about you. The security measures will vary depending on the sensitivity, format, location, quantity, distribution and storage of Personal Information. These security measures include physical, technical and administrative measures to protect Personal Information from unauthorized access. These security measures include encryption of communications via SSL, encryption of information while it is stored, firewalls, access controls, segregation of duties and similar security protocols. However, due to the nature of the Internet and related technologies, we cannot absolutely guarantee the security of Personal Information and Polipilot expressly disclaims this obligation.

Polipilot may change this Privacy Policy at any time by notifying via the Platform or via e-mail. The provisions of the Privacy Policy amended by Polipilot take effect on the date of notification. You can send your questions regarding the issues regulated in this Privacy Policy to Polipilot by sending an e-mail to privacy@polipilot.com.