Togg User Rights and Terms

Privacy Notice

Data Controller

Türkiye’nin Otomobili Girişim Grubu Sanayi ve Ticaret Anonim Şirketi (‘‘Togg’’)

Address

Muallimköy Mah. Deniz Cad. Bilişim Vadisi T.G.B. Sitesi 1.3.A Blok No:143/9 İç Kapı No:105 Gebze/Kocaeli

Introduction

A. Create Membership/Account

Your personal data regarding identity information (name, surname) and contact information (e-mail address) will be collected via electronic forms located in the account creation screen. Your personal data will be processed limitedly for the purposes of conducting membership/account creation and verification of contact information, conducting customer relationship management processes, conducting contract processes, conducting business/product/service commitment processes, and conducting communication activities, according to the ‘‘Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract’’ and ‘‘Processing of data is obligatory for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject’’ legal basis regulated in Article 5 (2) of the KVKK.

Your personal data, which we process on the account creation screen, may be transferred to our suppliers residing in Turkey by taking the necessary technical and administrative measures within the scope of the above-mentioned purposes in accordance with Article 8 of the KVKK. In addition, if necessary, your personal data may be transferred to authorized public institutions under legal regulations in order to fulfill our legal obligations.

B. Creating Personalized Togg Smart Device (Configurator) and Calculators

Your personal data regarding customer transactions (vehicle configuration information, savings amount, annual fuel consumption, charging time calculation information) will be collected via information logged in by you on the personalized Togg smart device creation configurator, charging time and savings calculator screens. Your personal data will be processed limitedly for the purposes of conducting products/services marketing processes, conducting contract processes, conducting marketing analysis activities, conducting customer satisfaction activities, conducting customer relationship management processes, and conducting business/product/service commitment processes, according to the ‘‘Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract’’ and ‘‘Processing of data is obligatory for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject’’ legal basis regulated in Article 5 (2) of the KVKK.

Your personal data, which we process on the personalized Togg smart device creation configurator, charging time and, savings calculator screens, may be transferred to our suppliers residing in Turkey by taking the necessary technical and administrative measures within the scope of the above-mentioned purposes in accordance with Article 8 of the KVKK. In addition, if necessary, your personal data may be transferred to authorized public institutions under legal regulations in order to fulfill our legal obligations.

C. Pre-Order

Your personal data regarding customer transactions (invoice information, smart device order information) and contact information (address) will be collected via electronic forms and screens during the pre-order creation process. Your personal data will be processed limitedly for the purposes of conducting pre-order creation processes, conducting contract processes, conducting goods/services sales processes, and informing authorized institutions according to the ‘‘Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract’’ and ‘‘It is obligatory for compliance with a legal obligation to which the data controller is subject’’ legal basis regulated in Article 5 (2) of the KVKK.

Your personal data, which we process for the pre-order creation process, may be transferred to authorized public institutions under legal regulations in order to fulfill our legal obligations by taking the necessary technical and administrative measures in accordance with Article 8 of the KVKK.

Ç. Togg Wallet

Your personal data regarding identity information (name, surname, nationality, T.C. ID number, birthday), contact information (phone number), and customer transactions (information on balance amount and balance filling sources; spending, cancellation and refund amounts; payments and payment methods/preferences) will be collected via electronic forms and screens during the Togg Wallet creation process. Your personal data will be processed limitedly for the purposes of conducting identity verification procedures, conducting finance and accounting transactions, conducting activities in compliance with legislation, conducting contract processes, conducting payment services processes, conducting goods/services sales processes, and informing authorized institutions according to the ‘‘Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract’’ and ‘‘It is obligatory for compliance with a legal obligation to which the data controller is subject’’ legal basis regulated in Article 5 (2) of the KVKK. Your personal data (identity and customer transaction information) that you shared within the scope of Togg Wallet creation process will be transferred to Turkcell Ödeme ve Elektronik Para Hizmetleri A.Ş. with your explicit consent, which is governed by the Law on Payment and Securities Settlement Systems, Payment Services, and Electronic Money Institutions No. 6493. Besides, your financial information (credit/debit card information), which you input during payment transactions will not be stored in Togg's databases.

D. ToggCare

Your personal data regarding identity information (name, surname), contact information (e-mail address, phone number), customer transactions (request, suggestion and complaint information, message content), and visual & audio record information (call center voice recordings) will be collected via contact us form and call center conversations within the scope of ToggCare user call center request management and solution services. Your personal data will be processed limitedly for the purposes of conducting communication activities, following up on requests/complaints, conducting research/investigation activities necessary to carry out support services on the subject of the request, providing information and support services, conducting customer relationship management processes, receiving and assessing recommendations for business process improvement, conducting customer satisfaction activities, and using them as evidence of future disputes, according to the ‘‘Processing of data is obligatory for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject’’ and ''Data processing is obligatory for the establishment, exercise or protection of any right'' legal basis regulated in Article 5 (2) of the KVKK.

Your personal data may be transferred to our suppliers residing in Turkey by taking the necessary technical and administrative measures within the scope of the above-mentioned purposes in accordance with Article 8 of the KVKK. In addition, if necessary, your personal data may be transferred to authorized public institutions under legal regulations in order to fulfill our legal obligations.

E. Website Support, Development and Information Security

Your data regarding transaction security information (IP address, website input-output information, computer screen records) will be collected via information security systems and electronic devices within the scope of carrying out support/development activities and conducting information security processes within the services provided on the Togg Website. Your personal data will be processed limitedly for the purposes of conducting information security processes, conducting access authorisations, conducting audits and ethical activities, conducting storage and archive activities, securing data controller operations, providing information to authorized institutions, and conducting activities in compliance with legislation, according to the ''It is expressly provided for by the laws'', ''It is obligatory for compliance with a legal obligation to which the data controller is subject'', and ''Processing of data is obligatory for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject" legal basis regulated in Article 5 (2) of the KVKK.

Your personal data may be transferred to our suppliers residing in Turkey by taking the necessary technical and administrative measures within the scope of the above-mentioned purposes in accordance with Article 8 of the KVKK. In addition, if necessary, your personal data may be transferred to authorized public institutions under legal regulations in order to fulfill our legal obligations.

F. Legal Processes

In the event of legal processes, your personal data, which is collected during the provision of various services on the Togg Website, will be processed limitedly for the purposes of conducting activities in compliance with legislation, following up and conducting legal transactions, and informing authorized institutions, according to the ''It is obligatory for compliance with a legal obligation to which the data controller is subject'' and ''Data processing is obligatory for the establishment, exercise or protection of any right'' legal basis regulated in Article 5 (2) of the KVKK.

Your personal data may be transferred to authorized public institutions under legal regulations in order to fulfill our legal obligations.

Your Rights and Application Methods of Your Personal Data

You have the rights to request regulated in Article 11 of the KVKK:

● to learn whether your personal data are processed or not,
● to demand for information as to if your personal data have been processed,
● to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
● to know the third parties to whom your personal data are transferred in country or abroad,
● to request the rectification of the incomplete or inaccurate data, if any,
● to request the erasure or destruction of your data under the conditions referred to in KVKK,
● to request reporting of the operations carried out to third parties to whom your personal data have been transferred,
● to object to the occurrence of a result against yourself by analyzing the data processed solely through automated systems,
● to claim compensation for the damage arising from the unlawful processing of your personal data.

Regarding your processed personal data, you can send your requests and applications, to togg.kvkk@togg.com.tr by your registered e-mail address in our systems; to turkiyeninotomobili@hs01.kep.tr registered e-mail address (KEP) by your registered e-mail address (KEP) and secure e-signature or mobile signature; or you can send your application in written to Muallimköy Mah. Deniz Cad. Bilişim Vadisi T.G.B. Sitesi 1.3.A Blok No:143/9 İç Kapı No:105 Gebze/Kocaeli address. Also, you can decide on other methods to send requests and applications provided from Communique On The Principles And Procedures For The Request To Data Controller.

Your request for your rights regulated under Article 11 of the KVKK will be concluded as soon as possible regarding the nature of the request and thirty days at the latest, free of charge. However, if the transaction also requires an additional cost, you may be charged based on the tariff determined by the Personal Data Protection Board.

Privacy Notice Updates

The Privacy Notice will be updated according to the services and conditions that change within the Togg Website, and regulatory developments. Notifications for the update of the Privacy Notice will be published by Togg on the website.

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TÜRKİYE’NİN OTOMOBİLİ GİRİŞİM GRUBU SANAYİ VE TİCARET ANONİM ŞİRKETİ COOKIE POLICY

This text has been prepared by Türkiye’nin Otomobili Girişim Grubu Sanayi ve Ticaret Anonim Şirketi (“Togg”) as data controller within the scope of Article 10 of the "Law No. 6698 on the Protection of Personal Data" ("Law") and "Communique On Principles And Procedures To Be Followed In Fulfillment Of The Obligation To Inform".

As Togg, we use first party and third party cookies in some areas of the https://www.togg.com.trwebsite (“Website”). This Cookie Policy (“Policy”) is valid for the Website managed by Togg, and cookies will be used as described in the Policy.

The purpose of this Policy is to inform you about the processing of personal data obtained automatically through the placing of cookies used on our Website on your device; for which purposes, what type of cookies we use and how you can manage these cookies. Except for the necessary cookies, explicit consent of the users is obtained and the opportunity of changing their consent any time is provided.

Through the cookie management panel, users can see the types of cookies used on our Website and can set their preferences with the “on” or “off” options for all cookies other than necessary cookies. Users can always change their preferences through this panel.

What Does Cookie Mean?

Cookies are small text files created on your device by a website and contain data in name-value format. Cookies enable the website you visit to store information on your device and use this information during your next visits. Cookies created by a website are stored by the internet browser you use to access the site, and cookies do not contain personal data about visitors such as name, gender or address. The information contained in the cookies can only be accessed by the website domain name https://www.togg.com.tr that created the relevant cookie and can only be accessed if you use the same internet browser.

Cookies have become an important part of internet technologies today, and their main functions are to remember the preferences of the online visitor and to recognize the device during connection, and almost every website uses cookies.

Who Sends Cookies and How?

Cookies are sent through the communication established between your internet browser (such as Chrome, Firefox, Safari, Edge, etc.) on your device during your browsing and the website servers of Togg.

What are the Types of Cookies? :

● According to their ownership:
‍
    ○ First Party Cookies It is placed on the device directly by the website visited or by Togg.
    ○ Third Party Cookies These are cookielists placed on the device by a third party, such as an advertiser or analytical system, in cooperation with Togg.

● According to time that they are active:
‍
    ○ Session Cookies It provides data that can be stored until the user closes the browser or the session expires. They are short-term cookies.
    ○ Persistent Cookies These are cookies that stay on the drive until the cookie is deleted by the user or until the specific expiration date for the cookie. Persistent cookies have a written expiration date of variable duration in their code.

● According to their intended use:
‍
    ○ Necessary Cookies These are cookies that are necessary to navigate the website and use features such as accessing secure areas of the site.
    ○ Functionality Cookies It allows the website to remember the past choices (username information, password information, which language is preferred, etc.). Preference cookies that provide automatic access to the website are also called functionality cookies.
    ○ Statistical Cookies also known as performance cookies, are cookies that provide anonymous, statistical data about the use of the website. By using statistical cookies, data on how the user uses the website, the pages the user visits, the links the user clicks can be stored. Anonymized statistical cookies are not used to identify the website user. The purpose of these cookies is to make the website more functional.
    ○ Marketing Cookies These are cookies that can be used by companies operating to create a profile of your interests and show relevant advertisements on other sites.

For What Purposes and on What Legal Grounds Will Your Personal Data Be Processed?

Necessary cookies are used to fulfill an information society service you have requested (logging in, filling out forms and remembering privacy preferences). Your personal data collected through these cookies are processed within the scope of clause (c) "Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the 2 contract." or clause (f) "Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject." of paragraph 2 of Article 5 of the Law.

Advertisement and Marketing cookies are used by our business partners to profile your interests and show you relevant advertisements. Your personal data collected through these cookies are processed based on the legal reason of explicit consent within the scope of paragraph 1 of Article 5 of the Law.

Performance/Analytical cookies are cookies that allow statistical measurement to analyze the behavior of users on websites. These cookies are frequently used to improve the site, including measuring the impact of advertisements on data subjects. They are used by website owners to estimate the number of unique visitors, identify the most important search engine keywords that lead to a website, or monitor website browsing. Your personal data collected through these cookies are processed based on the legal reason of explicit consent within the scope of paragraph 1 of Article 5 of the Law.

Functionality cookies are used to make our website more functional and personalize it (with the exception of your privacy preferences, ensuring that your other preferences are remembered when you re-enter the site). Your personal data collected through these cookies are processed based on the legal reason of explicit consent within the scope of paragraph 1 of Article 5 of the Law.

Information About Cookies Used on Our Website

Information about cookies on our website is given in the table below:

Information about cookies on our website is given in the table on web version

Transfer of Personal Data Processed Through Cookies

Within the scope of our activities carried out with cookies, your personal data is transferred to our suppliers for the purpose of customizing the services of Togg, carrying out marketing activities, execution and examination of business activities, and execution of goods and service purchase operations.

In addition, if you give your consent for the statistical and marketing cookies specified in the table above; your personal data will be processed on servers abroad through third-party infrastructure providers Google and Facebook for a limited purpose of storage and archiving activities. In this context, your personal data will be processed by service providers whose servers are located abroad, based on your explicit consent, by taking the necessary technical and administrative measures.

Management of Cookies

The use of cookies is not mandatory to use our website, but if you set your browser not to accept cookies, the quality of your user experience may decrease and various functions of our sites may be impaired. In particular technical cookies enable the website to perform its basic functions. Since technical cookies enable the website to work technically, if you turn them off, some functions on the website may not work properly.

You can turn the buttons on or off according to your preference, click the “Accept Selected” button, and refresh the page to activate your settings.

You can configure your browser to block cookies for all or specific sites, to alert when cookies are created, to block third-party cookies, or to count all cookies as session cookies. In addition, you can delete cookies through your browser or view the list and values of cookies stored in your browser. For detailed information about the cookie management functions of your browser, please click on the relevant link below and get information from your browser's website

In addition;

● Click to turn off Cookies managed by Google Analytics.
● Click to manage the personalized advertising experience provided by Google.
● Preferences in terms of cookies used by many companies for advertising activities can be managed through Your Online Choices.

For more detailed information about cookies, you can visit https://www.aboutcookies.org or https://www.youronlinechoices.eu/ or use the "Privacy Badger” application (https://www.eff.org/tr/privacybadger).

Data Subject’s Requests

For your rights under the 11th article of the Law and detailed information, you can review the Privacy Notice. Togg reserves the right to change the terms of use regarding cookies and the Cookie Policy.

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INFORMATION SECURITY POLICY

Document Number : TPOIT001

Revision Number : A0

Publish Date : 30.05.2022

As Togg, we are developing electric and connected new generation cars, and creating a mobility ecosystem around these cars, on the way we set out with the aim of creating an automobile brand that Turkey owns the intellectual property rights to compete on a global scale. By means of this ecosystem, we aim to make life easier for the masses and to contribute to a clean future by zeroing harmful emissions. Information security is of critical importance for us by strategically and operationally means, to protect Togg's technology, know-how and company reputation, as well as to sustain our business activities. Information assets owned or used by our company are essential elements for the creation and improvement of our business activities, products, and services. In this context, within the framework of legal compliance, access controls are given in accordance with the principle of "need to know" and security measures are taken in accordance with the developing technology. The Information Security Management System, which provides an appropriate balance between risks and precautions for the organization's information assets and services, is implemented by taking information security threats into consideration. In this context, our fundamental principles in Information Security are:
• Togg information assets can only be accessed by authorized persons, ensuring that the accessed data is accurate and accessible within the expected timeframes.
• Information security and business standardization are provided in the management of information systems that are used to achieve Togg's business processes and goals.
• Information security awareness of employees, stakeholders and third parties are ensured.
• The Information Security Management System established within Togg is operated with a risk-based perspective and continuous improvement is ensured.
• Information security requirements arising from the national or international regulations which are Togg is subjected to, the legal and relevant legislation requirements, the obligations arising from the agreements, and corporate responsibilities towards internal and external stakeholders are met and ensured.
• The personal data we process is processed, stored, transferred in accordance with the European and Turkish Personal Data Protection legislation (GDPR and KVK Law), and the process is operated in accordance with the legislation in case of termination of legal commitment with the relevant persons.
• It is ensured that core and supporting business activities within Togg are available with acceptable downtimes.
• At Togg, efforts are made to minimize the possibility of information security violations, and actions are taken to minimize the impact of our stakeholders (employees, consumers, shareholders, etc.) in case of violations.

In line with this policy; we commit that we will realize our information security principles and ensure the establishment, operation and maintenance of the information security management system in accordance with the TS ISO / IEC 27001 standard, and that we will allocate the necessary resources for this, that we will evaluate the effectiveness of our Information Security Management System and that we will continuously improve it and that this point of view will be announced to all relevant parties.

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USER AGREEMENT (TERMS AND CONDITIONS)

Thank you for preferring the Trumore Mobile App and Togg Website (hereinafter referred to as ‘‘Trumore’’). Before using the Trumore, please read these terms and conditions carefully.

This User Agreement (“Agreement”) is signed between the individual user of the Trumore (“You” or “User”) and Türkiye’nin Otomobili Girişim Grubu Sanayi ve Ticaret Anonim Şirketi (“Togg” or “Company”) which is located at Muallimköy Mah. Deniz Cad. Bilişim Vadisi T.G.B. Sitesi 1.3.A Blok No:143/9 İç Kapı No:105 Gebze/Kocaeli to regulate the terms and conditions regarding access and use of the services (“Services”), which are detailed below, provided through the Trumore.

Before you start using the Services, you must have read this Agreement on the sign-up screen during your sign-up to the Trumore, and if you complete the sign-up process, you will be deemed to have read and accepted this Agreement.

Togg may change the services provided in the Trumore and the terms of the Agreement partially or completely. These changes will be updated first in the Trumore, then sent to your registered e-mail address on the system and/or sent to you via push notifications. You are deemed to have accepted these changes by continuing to benefit from the services after the change notifications we have sent to you. The changes will take effect on the date specified in the notification, or within 7 (seven) days of the notification being published in the Trumore.

GENERAL PROVISIONS

Trumore is a platform that allows Users, who download the application or visit the website, to use the services listed below partially or completely without being required to own a Togg Smart Device. Trumore works in tandem with the Togg Smart Device to transform it into a new generation smart mobility device.

Togg will request some information during sign-up that may be needed to provide services in the Trumore. Without prejudice to the Togg Wallet services, we do not apply any confirmation procedure regarding the accuracy of this information, except for the phone number and e-mail address. In this respect, you are responsible for the accuracy and up-to-dateness of the information you provide while signing up for the Trumore. After filling in the information requested during sign-up, if you click the "Create Account" button, your membership will be completed, assuming that you have accepted the terms and conditions set forth in the Agreement.

It is your responsibility to protect the confidentiality of the password you have registered with the system during your membership, and Togg does not accept liability in any way if the password is shared with others or organizations.

By completing the required verification, you have the opportunity to change your personal information from the "Profile" tab, and your password information from the "Account Settings" tab at any time within the Trumore.

Unless otherwise stated, Togg provides the Services included in the Trumore free of charge for the purpose of transforming the Togg Smart Device into a new generation smart mobility device, and does not make any commitment that the Services will meet your expectations.

If you want your account, which was created as a result of your membership defined in the Trumore, to be deleted, you can click the "Delete My Account" button in the "Profile" tab.

The results generated through the calculators on the "Discover" screen of the Trumore may vary, as the battery specifications of the Togg Smart Device are calculated based on the average use of fuel and electricity prices from official sources. Togg has no responsibility in this regard.

Togg takes all necessary measures in its systems to protect the Trumore from viruses and similar software. Accordingly, Togg does not accept any responsibility for errors that may arise from the User's software and operating systems and their direct or indirect consequences.

Togg does not accept any liability for User comments and shared messages made within the Trumore. If the Trumore is used in violating moral rules, disrupting public order, violating the personal rights of others, infringing on the intellectual property rights of Togg and/or others, Togg may suspend the account of the User who engages in such actions or cancel its membership by terminating the contract.

SERVICES

1. Tru ID

Tru ID is a unique identification number that will be provided free of charge during membership in the Trumore, through the Trumore, or with the screen to be located in the Togg Smart Device, given to the User in order to benefit from the services provided under the terms of the Agreement, and if any, can be matched with the Togg Smart Device.

Through Tru ID, Togg aims to recognize the User’s mobility experiences, empathize with the User, and develop proposals in accordance with the User’s needs. Togg acts in compliance with the conditions set out in the "Protection of Personal Data" clause below and the Law on the Protection of Personal Data No. 6698 (''KVKK'') within the scope of this Service, which it offers to improve mobility.

In case that the User owns a Togg Smart Device, he/she will be able to integrate the Tru ID with the Togg Smart Device and benefit from additional services provided by Togg, including after-sales support services.

2. Togg Wallet

Togg Wallet is a tab within the Trumore, that contains the Digital Asset Wallet and Togg Digital Wallet.

The Tru ID owner/User can begin exploring the NFT Offering Platform with its Digital Asset Wallet without logging into a new platform, and places bids on digital artifacts with Avax in the Digital Asset Wallet. The User will be able to store the NFT's purchased with Avax in the Digital Asset Wallet or share them with anyone they want.

Togg Digital Asset Wallet does not perform any crypto asset sales activities. The User will be able to transfer Avax to the Digital Asset Wallet via any stock exchange or wallet.

While creating the Digital Asset Wallet, an authentication process will be conducted via the information obtained from the form to be filled out by the User at the first stage through the NVI Identity Sharing Platform, pursuant to the Know Your Customer Principles, within the scope of Article 6 and 6 (a) of the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism, and General Communiqué of The Financial Crimes Investigation Board (Serial No. 19). After this process is completed, the artificial intelligence-assisted authentication process will need to be completed through the useruploaded T.C. ID card photo and a selfie. Following successful validation processes, the User will be able to access the Digital Asset Wallet.

You can conduct your payment transactions for other services within the Trumore by transferring the balance via the Togg Digital Wallet.

Togg operates with Turkcell Ödeme ve Elektronik Para Hizmetleri A.Ş. (“Paycell”), which is governed by the Law on Payment and Securities Settlement Systems, Payment Services, and Electronic Money Institutions No. 6493 in order to provide Togg Wallet services. Paycell is responsible for providing payment services and carrying out payment service processes in accordance with the applicable legislation.

The User must be at least 18 (eighteen) years old to benefit from the Togg Wallet services. In this context, Togg will conduct the authentication process remotely within the scope of Article 6 and 6 (a) of the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism, and General Communiqué of The Financial Crimes Investigation Board (Serial No. 19).

3. Create Your Own Device and Pre-Order

You can design your Togg Smart Device in accordance with your needs and tastes in terms of colour, interior equipment, exterior equipment, etc. via the "Create Your Own Device" tab on the Trumore and you can create your pre-order for Togg Smart Device from the "Pre-Order" tab through the Togg Wallet. Price differences for your Togg Smart Device, which is designed in accordance with your choices, will be reflected in the recommended turnkey price, and the turnkey price may differ on the delivery date. You can review the Pre-Order Agreement for more detailed information regarding pre-order.

4. ToggCare

Togg provides its users with the ToggCare service for the solution of any questions or problems related to the Togg Smart Device and/or Trumore via the Trumore. Within the scope of ToggCare, the User will convey the questions or problems to Togg via the form in the "Contact Us" tab, and then the Togg call center employees will contact the User. The User will also be able to reach the ToggCare service through the "Chatbot" tab.

Togg will try to resolve the inconvenience reported by the User within a reasonable time period. However, Togg does not commit an absolute solution to the User within the ToggCare service.

5. Trumore-go

Togg aims to provide road and map information support to the User through Trumore-go. The User will be able to access their favorite locations more easily by recording the addresses they frequently visit, such as home and workplace.

The navigation service provides the route information you request based on the images taken from the satellite, Togg does not make any commitment regarding the road and map information it offers on these platforms. The User will not be able to use Navigation to create other content, products, or services that may violate the obligations in this Agreement.

In order to benefit from the Navigation service, the User must allow the location information to be accessed by the Trumore. However, the User can change the preference for accessibility to location information at any time via device settings.

The User has the right to win magnets in each of the 81 provinces where he/she travels at least 10 km. The magnet gain can be turned off by the User from the “Account Settings” tab of the Trumore. However, by turning off the magnet gain, the previously acquired magnets will not be deleted directly, and the User must delete the magnets he/she has acquired one by one.

INTELLECTUAL PROPERTY RIGHTS

Economic rights, such as the right of adaptation, reproduction, distribution, and communication to the public by devices enabling the transmission of signs, sounds, and/or images, which are regulated under Articles 21 to 25, and moral rights, such as the right to disclose the work to the public, the right to designate the name, the prohibition of modification, and the right of the author against persons who own or possess a work, which are regulated under Articles 14 to 17 of the Law on Intellectual and Artistic Works No. 5486, within the scope of the software and design of the Trumore, belong to Togg.

Unauthorized use of trademarks, designs, patents, and content (information, pictures, logos, brands, and icons) displayed in the Trumore and protected by Togg, is prohibited in accordance with the Industrial Property Law and the Law on Intellectual and Artistic Works.

PROTECTION OF PERSONAL DATA

Togg acts in accordance with the KVKK in the processing and transferring of your personal data, gives great significance to the security of your personal data, and takes technical and administrative measures that are compatible with current technological developments in accordance with Article 12 of the KVKK.

The personal data we collect through the Trumore will be processed by Togg within the scope of the contractual relationship and the provision and development of the Services provided in the Trumore, limited to the purposes of monitoring user movements through the Trumore, conducting marketing and analysis activities, conducting customized user satisfaction activities, improving the user experience, profiling, creating a personalized user experience, making promotional suggestions, and recommending Togg's products and devices according to the tastes, usage habits, and needs of the Users.

You can review our Privacy Notice to learn about the personal data you have provided within the scope of membership, the purposes of processing and transferring this personal data, your rights as a data subject regulated in Article 11 of the KVKK, and the details of the application methods to Togg. In addition, you always have the opportunity to update your personal data, which you provided when you signed up for Trumore, from the "Profile" screen.

THIRD PARTY APPLICATIONS

Togg may link to some third-party applications and/or websites within the Trumore to facilitate accessibility. Togg does not make any commitment that the third-party applications and/or websites will operate continuously and flawlessly. The links are provided to you solely to facilitate accessibility, and Togg does not accept any liability in any way regarding the services promised to be provided, privacy, or security on third-party applications and websites.

RESOLUTION OF DISPUTES

In case of any dispute arising from the implementation or interpretation of the Agreement, Turkish Law applies to the resolution, and the Gebze Courts and Executive Offices will be authorized.

Complaints and objection procedures stipulated by KVKK in requests regarding personal data are reserved.

OTHER PROVISIONS

This Agreement shall remain in effect until the User unsubscribes from the Trumore ''Account'' screen or the User’s membership is revoked under the terms set forth by Togg in the Agreement.

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In-Vehicle Emergency Call System (eCall) Privacy Notice

Data Controller

Türkiye’nin Otomobili Girişim Grubu Sanayi ve Ticaret Anonim Şirketi (‘‘Togg’’)

Address

Muallimköy Mah. Deniz Cad. Bilişim Vadisi T.G.B. Sitesi 1.3.A Blok No:143/9 İç Kapı No:105 Gebze/Kocaeli

As Togg, we highly value the processing and protection of your personal data. This Privacy Notice is prepared in order to ensure that our users are informed about the personal data processing and transfer during the provision and development of various services within the Togg Website, in accordance with Article 10 of the Personal Data Protection Law NoAs Togg, we have prepared this Privacy Notice in order to ensure that you are informed about the personal data processing, storage, and transfer of your personal data that we collect in accordance with Personal Data Protection Law No. 6698 (“KVKK”), The Regulation Type-Approval Requirements for the Deployment of the eCall In-Vehicle System Based on the 112 Service ("Regulation"), and the relevant legislation.

In the in-vehicle emergency call system (''eCall'') processes carried out by Togg, your vehicle will send the following information and the legally required minimum amount of data when eCall is activated manually or automatically, and a voice call will be made to the emergency call center:

● The data is limited to the last three positions of the vehicle, as it is necessary to determine the current position and direction of travel at the time of the incident,
● Vehicle identification number,
● Vehicle type, brand, model, age and color information,
● The number of passengers,
● Type of triggering of the emergency call system (manual/automatic) and timestamp,
● Type of vehicle's tractive power storage.

Your personal data will be processed and transferred to the emergency call center limitedly for the purposes of conducting emergency management processes, conducting activities in compliance with legislation, conducting communication activities, conducting goods / service after-sales support process, according to the “It is necessary for compliance with a legal obligation to which the data controller is subject” legal basis regulated in Article 5 (2) of the KVKK. Your processed personal data will only be used within the scope of the eCall service.

If a period of time is specified in the law or relevant legislation for storage of your personal data, the data in question must be kept for at least this period. If a period of time is not stipulated in the law or relevant legislation; it is stored for reasonable periods of time determined in connection with the purposes of processing, provided that it is limited and measured. In this regard, your collected data will be kept for 2 hours after the emergency call for various investigations. After the end of this period, your data will be automatically deleted from the system.Your personal data may be transferred to authorized public institutions under legal regulations in order to fulfill our legal obligations.The eCall system is active by default and cannot be deactivated. However, there is no constant and continuous screening by means of the system. All transactions related to eCall are carried out in line with the principles of individual fundamental rights and freedoms.You have the rights regarding your personal data;
● to learn whether your personal data are processed or not,
● to demand for information as to if your personal data have been processed,
● to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
● to know the third parties to whom your personal data are transferred in country or abroad,
● to request the rectification of the incomplete or inaccurate data, if any,
● to request the erasure or destruction of your data under the conditions referred to in KVKK,
● If you request correction of missing or incorrect data and deletion or destruction of your personal data, to request that this situation be notified to the third parties to whom we transfer your personal data,
● to claim compensation for the damage arising from the unlawful processing of your personal data.
You can forward your applications and requests regarding your personal data to Togg using the following methods:
‍
● By sending an electronic mail message to togg.kvkk@togg.com.tr address,
● By filing an application personally with a valid identity card,
● By sending a wet-signed application accompanied by a photocopy of your identity card, to the address of Muallimköy Mah. Deniz Cad. Bilişim Vadisi T.G.B. Sitesi 1.3.A Blok No:143/9 İç Kapı No:105 Gebze/Kocaeli,
● By sending an e-mail message with mobile signature or secure electronic signature to togg.kvkk@togg.com.tr address,
● By your registered e-mail address in our systems; to turkiyeninotomobili@hs01.kep.tr registered e-mail address (KEP) by your registered e-mail address (KEP) and secure e-signature or mobile signature;
forward Togg.

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Togg Integrated Management System Policy

On the way we set out to create an automobile brand that will compete on a global scale and whose intellectual property right is owned by Turkiye, we are crea ng connected and electrified new genera on cars and establishing a mobility ecosystem around them.

We believe that sustainable and persistent success will be achieved by implemen ng systems for quality, environment, occupa onal health and safety and energy managements in a con nuous improvement mindset.

In this context, we undertake:

• To take precau ons by managing risks within the scope of quality, environment, occupa onal health and safety and energy as from the project stage by using new or improved technologies related to our products, services, and ac vi es in the Togg mobility ecosystem,
• To reduce our environmental impacts and prevent environmental pollu on by controlling the consump on of raw materials, energy, and natural resources,
• To use energy efficiently by increasing the renewable energy rate and applying innova ve solu ons in our facili es,
• In line with our zero-accident policy, to create a Togg Occupa onal Safety Culture in which the employees take an ac ve role with the awareness of permanence of health and establish a working environment where everyone is safe and well,
• To increase company performance and efficiency of all processes,
• To ensure the par cipa on and coopera on of all our stakeholders in our policy by crea ng an open communica on environment on quality, environment, occupa onal health and safety and energy,
• To comply with the legisla on and other applicable requirements from relevant par es in all processes,
• To ensure the sa sfac on of all our users by providing “mobility solu ons that are fully compliant with the highest quality standards in their field and relevant legisla on” in the Togg mobility ecosystem,
• To support and develop our business partners.

Within the scope of this policy, we are coming to implement all the necessary action plans and to provide all the necessary information and resources to realize above-mentioned engagements.

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Çevre Yönetim Sistemi Kapsamı

Togg Entegre Yönetim Sistemi, “Elektrikli araç tasarım, geliştirme ve üretim” faaliyetlerini kapsamaktadır. Bu kapsamın bir parçası olan Çevre Yönetim Sistemi; Togg Teknoloji Kampüsü bünyesindeki tüm çalışanları, yüklenicileri, stajyerleri, misafirleri ve görevlendirme gereği Togg Teknoloji Kampüsü dışında bulunan kişileri içermektedir.
Togg Çevre Yönetim Sistemi, tüm değer zinciri boyunca hammadde tedariği, tasarım, üretim, lojistik süreçleri ve ürünlerin nihai bertarafına kadar uzanan tüm faaliyetleri kapsamaktadır. Bu sistem, Truzero stratejisi çerçevesinde iklim değişikliği ile mücadele, düşük karbon ekonomisine geçiş ve sürdürülebilir mobiliteyi yeniden tanımlama hedefleri doğrultusunda yapılandırılmıştır.

Trutek Kalite Politikası

Trutek olarak; “Türkiye'nin lider yenilikçi mobilite teknolojileri odaklı mühendislik şirketi olmak” vizyonumuz çerçevesinde, kullanıcı odaklı yaklaşım ile müşterilerimizin beklentilerini aşan kaliteli ve güvenilir ürünleri geliştirir, ISO 9001 Kalite Yönetim Sisteminin gerekliliklerini sağlar, gerekli kaynakları temin ederek sürekli iyileştirmeyi taahhüt ederiz. Bu doğrultuda;

Yüksek katma değerli teknolojik ürün ve hizmetlerimizin müşteri şartlarına uygunluğu ve müşteri memnuniyetinin artırılması amacıyla şirketimizde ve ülkemizde fikri ve sınai mülkiyet haklarının (FSMH) oluşturulması ve stratejik öneme sahip ürünlerin yerlileştirilmesi,

Ülkemizin ithalat oranının azaltılarak, yurt içi sirkülasyona katkı sağlama ve teknoloji tabanlı ihracatı artırma hedefi kapsamında, toplam kalite felsefesini esas alarak, takım ruhu ile şirket ve birim hedeflerine ulaşılması, yenilikçi ve yaratıcı yaklaşımların cesaretlendirilmesi,

Nitelikli mühendislerin yetiştirilmesi, bilgi birikiminin şirketimizde ve ülkemizde tutulması ve yetkinliklerin geliştirilerek yüksek katma değerli ürün standartlarının oluşturularak ulusal ve uluslararası standartlara ve yasal mevzuatlara tam uyumun sağlanması,

Özellikle üniversiteler, yerli sanayi kuruluşları ve diğer özel/kamu araştırma kurumları ile iş birliğinin artırılması, yenilikçi bakış açısıyla risk ve fırsatları değerlendirip iş süreçlerimizi gözden geçirerek performansımızı geliştirecek yaklaşımların uygulanması,

Sürekli iyileştirme yaklaşımı doğrultusunda, veri yönetimi ile dijital araç ve çözümleri de kullanarak iş süreçlerimizdeki verimliliğin uluslararası düzeyde rekabet edebilecek seviyeye yükseltilmesi,

Tüm bu kapsamda, çalışanlarımızın ve paydaşlarımızın kalite bilincinin artırılması yönündeki ilke ve faaliyetlerimizi bütünleşik bir şekilde yöneterek, sektörümüzde lider bir kuruluş olmak için tüm gücümüzle çalışırız.

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Purpose and Scope

The philosophy of Togg has been developed over a solid purpose: To redefine sustainable mobility with a user-centric and open ecosystem. We gather all processes we implement with a focus on sustainability under Togg's Truzero sustainability strategy.This policy has been published to define core principles to be followed in all our decisions and actions throughout the entire value chain from product design to business partner management after-sales processes; as well as to inform our stakeholders in this regard. Togg Climate and Environment Policy is binding for "Togg - Türkiye'nin Otomobili Girişim Grubu Sanayi ve Ticaret A.Ş." and its subsidiaries, their respective executives, and associates as well as for its business partners, contractors, and stakeholders.Environment and climate-related issues are prioritized as integral parts of our Truzero strategy and operations. We recognize the urgency of addressing these challenges and have incorporated them into our SMAP, decision-making processes, resource allocation, and long-term planning. Through dedicated initiatives, we strive to minimize our environmental footprint, mitigate climate impact, and promote sustainability across our three business pillars: Smart Mobility Devices, Digital Experience Platform Trumore, and Clean EnergySolutions. We prioritize environmentally friendly practices and continuously seek opportunities for improvement. Our commitment to environmental stewardship extends beyond compliance requirements, driving us to proactively pursue user-centric and innovative solutions and partnerships that contribute to a healthier planet for future generations.

Core Principles

Redefine sustainable mobility with and open and user-centric mobility ecosystem

GHG Emissions
Promote carbon neutrality for all stakeholders and become an industry leader in CO2 emission reduction.

Material use, Waste & Circularity
‍Reduce, reuse, and recycle material waste and ensure recyclability and reusability.

Labor Practices
Create a safe working environment that is fair, just, and open, for employees to work in - become the best employer.

Diversity, Equity & Inclusion
Practices and culture promoting diversity, equity, accessibility, and inclusion, inside the company and beyond.

User Safety and Engagement
Ensure zero-defect products and high-quality aftersales services.

Cyber Security & Digital Privacy
Ensure data protection processes are regularly analyzed, up to date and further developed.

Governance Foundation
Develop a comprehensive corporate governance structure, and standardize sound system of clear responsibilities.

Business Partner Relationships
Ensure responsible sourcing which will become industry best practices internationally.

1. Protecting the climate and the environment is a core responsibility of each Togg associate regardless of their position. We carry out environmental and climate management with a division of responsibility extending from Cockpit to the operational units, and with governance bodies established at strategic and operational level.
2. We comply with all relevant laws and regulations on climate and environmental management to which we are subject, including legal frameworks regarding environmental and climate protection and impact management during direct operations, provision of products and end-of-lifecycle. We adopt a proactive approach for monitoring compliance.
3. We closely follow the international agenda on environmental and climate-related issues; support public, civil society, or industrial initiatives at international or local level. We support startups and women entrepreneurs within the scope of our agile collaboration approach.
4. Every Togg associate is included in an online orientation process before starting their job. This orientation covers topics such as sustainability, our working principles, and company culture.
5. Every Togg visitor in production facilities take HSE training during their visit. They have the right to question an actual behavior which they think that may pose an instant environmental hazard.
6. We adopt internationally accepted, proven, relevant and reliable system standards and frameworks in our environmental and climate management processes and systems such as;
> ISO14001 Environmental Management System Standard,
> ISO 9001 Quality Management System Certificate
> ISO 50001 Energy Management System Standard
> ISO 45001 Occupational Health and Safety Management System Certificate
> ISO 27001 Information Security Certificate
7. We assess and monitor environmental and climate-related risks and opportunities inline with our corporate risk management system. We employ appropriate analysis tools and use their outcome in our strategy setting processes.
8. Our world is calling for sustainable solutions and we're more than listening, we fight for sustainability. Powered by ingenuity and electricity, we're engineering a sustainable ecosystem designed to connect more people to more opportunities that protect the places where we work, live, and explore.
9. Born-electric, born-digital, born-clean, we ensure our product and technology development are the most valuable leverages to minimize environmental and climate-related impacts of our products and processes. Hence, we allocate required resources for these studies.
10. We map and analyze our environmental and climate related impacts such as energy usage, GHG and air emissions, water, materials, and chemicals consumption, wastes and biodiversity, maintain records of them.
11. We consider climate change factors and environmental impacts including impacts on biodiversity of our physical investments starting from planning and designing processes and conducting impact assessments. We monitor the conduct during the implementation processes.
12. The future is "renewable". We use green energy resources in our operations as much as possible and promote its wider use through our mobility ecosystem products and services.
13. We aim to reduce our energy intensity constantly. To this end, we develop reliable and efficient energy systems, conduct periodical and productive maintenance, track energy losses, ensure energy continuity and take emergency precautions for energy shortages.
14. We periodically calculate significant direct and indirect greenhouse gas emissions that occur in our value chain and conduct studies to reduce emission intensity in our operations with an aim to reach "carbon neutral by 2035" status.
15. In pursuit of reaching our goal of carbon neutrality by 2035, we are actively undertaking initiatives to transition towards a low-carbon economy. This involves promoting circularity within our operations, we aim to minimize waste and maximize resource efficiency. Additionally, we are actively participating in voluntary carbon projects to offset our carbon emissions and contribute to global efforts in combating climate change.
16. We consider water as a vital resource for all; hence we consume responsibly. We aim to reduce water intensity of operations and to maximize recycling. We seriously monitor quality of wastewater discharges and impact on receiving environment.
17. We develop waste management plans for the entire life cycle of our products. We reduce and sort wastes at source and maximize recycling, reuse, and recovery.
18. We support circular economy. We explore opportunities for maximizing the usage of materials with reduced environmental impacts such as recycled or reused materials.
19. We aim to minimize the usage of hazardous chemicals and treat them safely.
20. In the management of environment and climate-related issues, we evaluate our performance against OKRs we set. We implement internal control and/or independent audit practices to ensure reliability of our systems and accuracy of our findings.
21. We aim to work with business partners that share similar values and policies with us. We apply environment and climate-related principles during procurement processes as decision criteria for choosing products or business partners to work with. We monitor their business conduct and support their development for a carbon-neutral ecosystem. We maintain open communication with them and support their training and technology transformations where needed.
22. We conduct training activities for raising awareness and improving skill sets of our associates and promote culture related to environmental, climate and social issues.
23. We incentivize environmental and climate friendly behaviors, improvement ideas, projects and performance achievements of our Togg ecosystem.
24. Togg's supervision on sustainability and climate change is the responsibility of the Cockpit. Togg's every Work Stream is responsible for the management of sustainability and climate change issues. There is a sustainability committee called Truzero Owners to support these responsibilities.

Definitions

Truzero: is Togg's sustainability strategy which outlines the approach and actions that an Togg plans to take to address environmental, social, and economic issues in a way that promotes sustainability. This strategy typically involves setting goals and targets related to sustainability, identifying key areas of impact and opportunity, and implementing initiatives to achieve 2035 carbon neutrality goal.

Sustainability: is ability to meet the needs of the present without compromising the ability of future generations to meet their own needs. It involves balancing economic, environmental, and social considerations to ensure long-term well-being and resilience for both people and the planet. Sustainable practices aim to minimize negative impacts on the environment, promote social equity, and support economic prosperity in a way that is viable and equitable for current and future generations.

Business Partner (BP): is a person, company, or organization that provides goods or services to Togg. Business Partners play a crucial role in the ecosystem by supplying the necessary materials, components, or services required for the production or operation of a product or service. They can range from raw material BP to service providers, and their performance and reliability can significantly impact the success and efficiency of Togg.

Cockpit: At Togg, the Cockpit is the strategic decision-making body representing the company's top leadership team. It consists of C-level executives such as the CEO, CFO, COO, and CMO. The Cockpit is the leadership team that defines Togg's vision, mission, and strategic goals. It manages critical decisions in the company's core business areas, ensures the implementation of corporate objectives, and guides all operational processes.

Truzero Owner: refers to business owners at Togg who implement the company's sustainability strategy, develop innovative solutions to reduce environmental impacts, and take responsibility for achieving corporate ESG goals. This team consists of leaders and team members playing a critical role in executing all projects that support Togg's Truzero goal of becoming carbon neutral by 2035.

Reporting

We periodically report our practices, achievements and future goals on environment and climate-related issues to the Cockpit and other relevant governance bodies through OKRs, internal reports, to the public authorities through regulatory reports and to a broad range of external stakeholders through annual sustainability reports.

Communication

All our stakeholders can submit their suggestions, information requests or their grievances regarding Togg Climate and Environmental Policy to us by e-mail to Truzero@togg.com.tr

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