TERMS OF USE & PRIVACY POLICY

Users accessing our website at www.refsan.com.tr (hereinafter referred to as the “Site”) must carefully read these Terms of Use & Privacy Policy (hereinafter referred to as the “Policy”) before using the Site. If any of the conditions specified in this Policy are unacceptable to you, please do not use the Site.

REFSAN ENDÜSTRİYEL MAKİNA SAN. TİC. A.Ş., the owner of the Site (hereinafter referred to as “REFSAN”, “our Company”, or “we”), reserves the right to unilaterally modify the general and specific conditions outlined below at any time. We recommend reviewing this page upon each visit to stay informed of any changes to our terms of use and privacy conditions.

In this Policy, users who access the Site without registering are referred to as “Visitors,” and those who use the Site by registering are referred to as “Members.”

Terms of Use and Security Rules

In the following cases, Refsan management may restrict a Visitor's or Member's use of the Site and reserves its legal rights against the person or persons involved in the following activities:

• 1.a. Recording incorrect, irregular, incomplete, or misleading information, expressions contrary to general moral rules, or information that does not comply with the laws of the Republic of Turkey on the Site,
• 1.b. Copying the works and content on the Site, in whole or in part, to use or attempt to use them for different purposes,
• 1.c. Sharing user credentials, such as usernames and passwords, provided to or determined by the Member, with third parties or organizations. The Member is directly responsible for any malicious use of their password by others. Similarly, the Member cannot use another person's IP address, e-mail address, username, or other personal information on the internet, nor can they access or use other users' private information without permission. The Member bears all administrative, legal, and penal liabilities arising from such unauthorized use.
• 1.d. Using software or engaging in activities that threaten the general security of the Site, disrupt the operation of the Site and its software, or obtaining, deleting, or altering information,
• 1.e. Taking advantage of any vulnerability (technical, etc.) of the Site's campaigns, membership, sales, or product delivery systems to harm Refsan and/or the Site, gaining unfair advantage, making repetitive automated requests, or exploiting the systems despite not meeting the required conditions. If Refsan detects such abuse, our Company reserves the right to cancel the relevant transactions, terminate the Member's account, and unilaterally and immediately terminate any loyalty program agreement in place, alongside all other legal rights.
• 1.f. Refsan is not liable for any direct or indirect damages arising from breach of contract or tort due to accessing the Site or using the information, data, or programs on the Site, provided there is no explicit fault on Refsan's part. Refsan accepts no responsibility for transaction interruptions, errors, negligence, deletions, losses, communication delays, computer viruses, communication errors, theft, destruction, or unauthorized access, modification, or use of records.
• 1.g. Refsan reserves the right to unilaterally change, reorganize, or suspend any service, product, contract, and information offered on this Site without prior notice. Changes take effect the moment they are published on the Site. Accessing or using the Site constitutes acceptance of these changes. These conditions also apply to other external web pages linked from the Site.
• 1.h. The Site may contain links or references to other websites not under Refsan's control. Refsan is not responsible for the content of these sites or any other links they contain.

Use of Content

• 2.a. All rights to the texts, graphics, photos, videos, animations, sounds, and software codes on the Site are reserved. Unless otherwise stated, they cannot be used for commercial or personal purposes without permission and proper attribution. Publishing any element of this Site on another medium, website, or application, or linking to it without Refsan's permission, is strictly prohibited.
• 2.b. Copying or using the software utilized in the design and database creation of the Site pages, all rights of which belong to our Company, is strictly prohibited.
• 2.c. Refsan and the Site welcome all kinds of feedback and criticism. All feedback submitted to the Site becomes the property of Refsan and may be used for marketing purposes after being anonymized.

Responsibilities

• 3.a. Information regarding Visitors and Members (visit duration, time, viewed pages, and any other activities) is tracked to provide better service. This information, strictly adhering to our privacy principles, is shared with our advertising and cooperation partners solely to enrich and improve our content. Our goal is to ensure the Site meets your expectations and continues to develop.
• 3.b. While utilizing the Site and its services, Visitors and Members agree to comply with the Turkish Penal Code, Turkish Commercial Code, Law on Intellectual and Artistic Works, Industrial Property Law, Turkish Code of Obligations, other relevant legislation, and any announcements or notices published by Refsan regarding its services. All legal, penal, and financial responsibilities arising from use contrary to these notices and laws belong to the respective Visitor or Member.
• 3.c. Refsan may temporarily or permanently suspend a Member's access to the Site and/or cancel their membership for failing to comply with the obligations stated in this Policy or the general rules published on the Site.
• 3.d. Visitors or Members cannot engage in actions that prevent or hinder others from using the Site, nor can they overload, lock servers or databases, or attempt fraudulent activities. Otherwise, their membership or usage rights will be terminated, and they accept all resulting administrative, legal, and penal responsibilities.
• 3.e. It is the individual's responsibility to back up messages sent through the Site, a practice highly recommended by Refsan. Refsan cannot be held responsible for the loss, deletion, or damage of messages due to a lack of backups.
• 3.f. Visitors and Members cannot delete or remove any Copyright, Trademark, or Intellectual and Artistic Works Law notices from any material copied or printed from the Site.
• 3.g. Risks associated with links provided on the Site for informational and convenience purposes (links redirecting to different websites) belong entirely to the Visitor/Member.
• 3.h. Different section-specific rules and obligations may be specified in certain parts of the Site. Individuals and organizations using these sections are deemed to have accepted these rules in advance.
• 3.i. To learn about our principles and practices regarding the protection of the privacy of personal data belonging to our Site Visitors and Members, please visit our "Privacy and Protection of Personal Data" page.

Rights and Obligations of Refsan

• 4.a. Refsan agrees and undertakes that the Visitor/Member will benefit from the services subject to this Policy, excluding technical malfunctions, and that personal information shared by the Visitor/Member will not be shared with third parties or organizations, except as stated in the "Privacy and Protection of Personal Data" regulations and clarification texts. If it is determined that a Visitor/Member has caused electronic sabotage or attacks intended to hinder the Site's operation or manipulate earnings, or if an official criminal complaint or investigation request is received from official authorities regarding the user, Refsan has the right to investigate and disclose the identity information of the relevant Visitor/Member.
• 4.b. Refsan may make unilateral changes to this Policy without prior notice to ensure the continuity of its promised services. Refsan reserves the right to permanently or temporarily suspend the service provided by the Site, change its content, or cancel it entirely, at any time and without giving any reason. The Visitor/Member accepts this provision in advance. Our Company will publish the updated Policy on the Site under the same link with a new date, and if deemed necessary, notify the Visitor/Member via email. The updated Policy becomes effective the moment it is published, and the use of the Site or its services will be subject to the updated Policy from that point forward.

Our Privacy Principles

Under the "Our Privacy Principles" heading of this Policy, the general privacy rules and conditions of the Site are outlined. The principles adopted by Refsan within the framework of personal data protection legislation are detailed in the "General Policy on the Processing and Protection of Personal Data," accessible via the "Privacy and Protection of Personal Data" link. We kindly ask you to read and review these documents carefully. Additionally, in areas where personal data is collected by the Site, a Clarification Text regarding the collection, processing, and sharing of the Member's personal data is provided. Checkboxes are presented to obtain explicit consent regarding whether they wish to receive commercial communications and, if so, through which channels.

5.a. In General

The Site is equipped with an SSL Security Certificate.

You can forward any questions or inquiries regarding the Site's privacy practices to our Company via the communication channels listed at the bottom of this Policy.

5.b. Site Membership

To use the Site, you must fill out the registration form by creating a username and password. During registration, you are required to provide your contact information (e.g., your email address). Refsan uses this information to contact you regarding the services you indicated interest in on our Site. Furthermore, by checking the provided consent box, you agree to receive SMS and/or emails about Refsan's campaigns and services. The Member always has the right to withdraw these permissions via the "Edit Information" page.

5.c. Information That May Be Collected by the Site

Refsan may collect your information via cookies during your use of the Site. For more detailed information about cookies and how to opt-out by rejecting them, we recommend reading the Refsan Cookie Policy.

The following principles apply to matters regarding members' Site membership, the confidentiality and protection of the information they provide, and registrations and campaigns conducted through the Site:

• Information entered by our members on our Site for membership, product purchases, and updating details cannot be viewed by other internet users.
• Information belonging to our members may be disclosed to authorized/relevant institutions within the framework of our responsibilities stipulated by legal regulations.
• In cases where the Site links to other internet-web sites/applications, the privacy-security policies and terms of use of those respective sites/applications apply to all uses and transactions. Our Company is not responsible for any direct or indirect damages, losses, or disputes that may arise due to the use of information from other websites accessed for advertising, banners, content viewing, or any other purpose, nor for the ethical principles, privacy-security principles, service quality, and other practices of those sites.
• Please note that this Policy applies exclusively to online information collection and dissemination practices related to the Site and does not apply to any of our offline practices.

5.d. Security

Refsan will take all necessary measures, including physical, electronic, and other security criteria, to protect your personal information against loss, destruction, and/or malicious uses such as unauthorized access, misuse, alteration, or disclosure. In this context, we kindly ask you to carefully read the principles and measures detailed in the "Policy on the Processing and Protection of Personal Data," accessible via the "Privacy and Protection of Personal Data" link.

Refsan bears no responsibility for any damages arising from information disclosures caused by unwanted and/or unforeseen reasons, or due to the Visitor's/Member's own fault (intent/negligence).

Other Provisions

• 6.a. From the moment a Visitor accesses the Site, or a Member completes their registration by approving this Policy, they declare, accept, and undertake that they have read, understood, and agreed to all the articles contained herein.
• 6.b. The Visitor/Member shall compensate Refsan for any damages incurred due to their actions contrary to the obligations undertaken in this Policy. Refsan reserves the right of recourse against the Visitor/Member for any compensation and/or administrative/judicial fines it may have to pay to public institutions and/or third parties due to the Visitor's/Member's non-compliant behavior.
• 6.c. In the event of any dispute arising from the interpretation and application of this Policy, Refsan agrees and undertakes to refer the matter to the authorities competent to handle the dispute and/or complaint. All Refsan personnel accept and declare that they are aware of this Policy and are obliged to comply with it. Refsan agrees and undertakes to evaluate any complaints regarding violations of the Policy and to initiate necessary actions if a violation is detected.
• 6.d. If any provision of this Policy is deemed invalid by a competent court, the Visitor/Member and Refsan agree that the effective provision that best reflects the intent of the invalidated provision and the true intention of the parties will apply, and this situation will not affect the validity and enforceability of the remaining provisions of this Policy.
• 6.e. The Policy is made available to the public by being published on the Site.
• 6.f. The Company reserves the right to make unilateral changes to the Policy in line with legal regulations.
• 6.g. The current version of the Policy can be accessed on the Site.

If you have any questions, complaints, or other inquiries regarding this Policy, please contact us using one of the communication channels listed below.