GDPR Privacy Policy

Gizlilik Politikası (GDPR) · Tradonymus™ · Ben Tek Bilişim Sistemleri ve Danışmanlık Hizmetleri Ltd. Şti.

Yapay Zekâ Tabanlı B2B Ticaret İşletim Sistemi • AI-native B2B Trading OS

PRIVACY POLICY

for individuals in the European Union / EEA

Issued under Regulation (EU) 2016/679 (GDPR)

Document Control

1. Introduction and Scope

This Privacy Policy explains how Ben Tek Bilişim Sistemleri ve Danışmanlık Hizmetleri Limited Şirketi (“Tradonymus”, the “Company”, “we”, “us”) processes the personal data of individuals located in the European Union and the European Economic Area (“EU/EEA”) when they visit the www.tradonymus.com website and use the Tradonymus platform (the “Platform”), in accordance with Regulation (EU) 2016/679 (the “GDPR”).

Tradonymus is a business-to-business (B2B) export marketplace serving four user types: Suppliers, Buyers, Deal Makers and Service Providers. The Platform is aimed at organisations; however, where it processes data relating to the natural persons who represent or contact those organisations, that data is personal data under the GDPR and this policy applies.

2. Controller and Contact Details

3. Categories of Personal Data We Process

We do not seek to process special categories of personal data (Article 9 GDPR). Where uploaded documents incidentally contain such data, we process it only where a lawful condition under Article 9 applies.

4. How We Collect Personal Data

• Directly from you — registration forms, listings, offers, messages, document uploads and communications;

• Automatically — through cookies and similar technologies (see the Cookie Policy);

• From the organisation you represent or from publicly available business sources, where relevant.

5. Purposes and Legal Bases (Article 6 GDPR)

Where we rely on legitimate interests, we balance those interests against your rights and freedoms; you may object as described below. Where we rely on consent, you may withdraw it at any time without affecting prior processing.

6. Disclosure and Recipients

We may share personal data, only as necessary, with: other Platform users where you choose to transact or communicate; our processors (hosting/cloud, payment service providers, e-mail and analytics providers, professional advisers); and competent authorities where required by law. Processors act on our documented instructions under a data processing agreement (Article 28 GDPR).

7. International Transfers (Chapter V GDPR)

Because Tradonymus is established in Türkiye and certain processing or access occurs outside the EU/EEA, personal data may be transferred outside the EU/EEA, including to Türkiye. Türkiye is not, at present, the subject of an EU adequacy decision.

Accordingly, transfers outside the EU/EEA are made on the basis of an appropriate safeguard under Article 46 GDPR — primarily the European Commission’s Standard Contractual Clauses (SCCs), supplemented by additional measures where required — or, where applicable, a derogation under Article 49. You may request information about the safeguards applied via info@tradonymus.com.

8. Retention

We retain personal data only for as long as necessary for the purposes set out above and to meet legal, accounting and record-keeping obligations and limitation periods. When data is no longer required, it is deleted, anonymised or securely destroyed.

9. Your Rights (Articles 15–22 GDPR)

Subject to the conditions in the GDPR, you have the right to:

• Access — obtain confirmation and a copy of your personal data (Art. 15);

• Rectification — correct inaccurate or incomplete data (Art. 16);

• Erasure — request deletion in certain circumstances (Art. 17);

• Restriction — limit processing in certain circumstances (Art. 18);

• Data portability — receive/transfer data in a structured, machine-readable format (Art. 20);

• Object — to processing based on legitimate interests and to direct marketing (Art. 21);

• Withdraw consent — at any time, where processing is based on consent (Art. 7(3));

• Not be subject to a solely automated decision producing legal/similarly significant effects (Art. 22);

• Lodge a complaint — with a supervisory authority (see section 12).

10. How to Exercise Your Rights

To exercise any of these rights, contact us at info@tradonymus.com. We respond without undue delay and within one month of receipt, which may be extended by two further months for complex or numerous requests (we will inform you). Exercising these rights is free of charge unless requests are manifestly unfounded or excessive.

11. Automated Decision-Making and Profiling

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing. Where we use analytics or ranking to operate the Platform, this does not constitute such automated decision-making; if this changes, we will update this policy and provide the required information.

12. Complaints and Supervisory Authority

If you believe our processing infringes the GDPR, you have the right to lodge a complaint with the supervisory authority in your EU/EEA country of habitual residence, place of work or place of the alleged infringement. We would, however, appreciate the chance to address your concerns first via info@tradonymus.com.

13. Cookies

We use cookies and similar technologies as described in our Cookie Policy. Non-essential cookies are used only with your consent, in line with the GDPR and applicable ePrivacy rules.

14. Data Security (Article 32 GDPR)

We implement appropriate technical and organisational measures to protect personal data, including access controls, encryption of sensitive fields, logging, and measures against unauthorised access, taking into account the state of the art, the costs of implementation and the risks to data subjects.

15. Children

The Platform is a B2B service and is not directed at children under 16. We do not knowingly process children’s personal data.

16. Changes to this Policy

We may update this policy to reflect legal or operational changes. The current version, with its effective date, is published on the Platform; material changes will be notified as appropriate.

17. Contact

For any privacy request or question under the GDPR, contact us at info@tradonymus.com.