Personal Data Processing Clarification Notice

1. Identity of the Data Controller

In accordance with Law No. 6698 on the Protection of Personal Data ("GDPR"), your personal data may be processed by Gazla OÜ ("Company") as the data controller within the scope explained below.

• Data Controller: Gazla OÜ
• Address: Harju maakond, Tallinn, Lasnamäe linnaosa, Sepapaja tn 6, 15551, Estonia
• Email: info@gazla.co
• Website: https://gazla.co

2. For What Purpose Personal Data Will Be Processed

Your personal data may be processed for the following purposes in order to provide and improve the services offered by the gazla.co platform:

• Performing and managing platform membership operations
• Providing entrepreneur-investor matching services
• Creating and managing user accounts
• Ensuring platform security and preventing fraud
• Conducting communication activities
• Improving and personalizing user experience
• Conducting statistical analyses and reporting
• Fulfilling legal and regulatory requirements
• Determining and implementing commercial and business strategies
• Conducting marketing, promotion, and information activities for platform services
• Managing financial transactions and payment processes
• Increasing customer satisfaction and service quality

3. Personal Data Categories Processed

Personal data categories processed on our platform are as follows:

3.1. Identity Information

• Name, surname
• ID number (when necessary)
• Date of birth
• Gender
• Profile photo

3.2. Contact Information

• Email address
• Phone number
• Address information
• Social media account information

3.3. Customer Transaction Information

• Username and password
• Platform usage history
• Preferences and interests
• Interaction records
• Search and viewing history

3.4. Transaction Security Information

• IP address
• Cookie records
• Device information (operating system, browser type, etc.)
• Session and log records
• Security verification information

3.5. Professional Experience Information

• Education information
• Work history
• Areas of expertise
• References and recommendations

3.6. Financial Information

• Bank account information (if any)
• Payment and invoice information
• Investment preferences and budget information
• Tax number (when necessary)

3.7. Marketing Information

• Communication preferences
• Campaign and promotion participation information
• Survey and feedback responses

4. Collection Method and Legal Basis of Personal Data

4.1. Collection Method

Your personal data is collected through the following methods:

• Creating an account and filling out a profile on the platform
• Contacting via contact forms and email
• Automatic collection during platform usage (cookies, log records)
• Mobile application usage
• Logging in via social media accounts
• Communication via phone, email, or live support
• Participation in surveys, competitions, and events

4.2. Legal Basis

Your personal data is processed based on the following legal bases specified in Articles 5 and 6 of the GDPR:

• Your explicit consent
• Necessity for the establishment or performance of a contract
• Fulfillment of legal obligations
• Being made public by the data subject
• Necessity for the establishment, exercise, or protection of a right
• Necessity for data processing for our legitimate interests

5. To Whom and For What Purpose Personal Data May Be Transferred

Your personal data may be transferred to the following persons and institutions within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the GDPR in order to realize the above-mentioned purposes:

5.1. Domestic Transfer

• Our business partners: Entrepreneurs, investors, and other users we collaborate with to provide platform services
• Service providers: Third-party companies providing cloud services, infrastructure, analytics, payment, customer support services
• Consultants: Legal, financial, and technical advisors
• Audit firms: Independent audit organizations
• Public institutions and organizations: Authorized public institutions and organizations within the scope of legal obligations
• Social media: Product information, images, descriptions, and other content you share on the Platform may be used on gazla.co's official social media accounts (X/Twitter, LinkedIn, Instagram, etc.) for promotional and marketing purposes

5.2. International Transfer

Your personal data may be transferred abroad in the following cases in accordance with Article 9 of the GDPR:

• Transfer to countries with adequate protection
• Your explicit consent or the existence of other conditions stipulated in the GDPR in case of insufficient protection
• Use of international service providers (cloud storage, analytical tools, etc.)

6. Rights of the Data Subject Listed in Article 11 of the GDPR

In accordance with Article 11 of the GDPR, you have the following rights as data subjects:

• Learning whether your personal data is processed
• Requesting information about it if your personal data has been processed
• Learning the purpose of processing personal data and whether they are used in accordance with their purpose
• Knowing the third parties to whom personal data is transferred domestically or abroad
• Requesting correction if personal data is incomplete or incorrectly processed
• Requesting deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the GDPR
• Requesting notification of operations related to correction, deletion, and destruction to third parties to whom personal data has been transferred
• Objecting to a result emerging against you through the analysis of processed data solely through automated systems
• Requesting compensation for damage if you suffer damage due to the unlawful processing of personal data

Application Method

You can apply through the following methods to exercise the rights mentioned above:

• Email: By sending an email with the subject "GDPR Application" to info@gazla.co
• Written application: By applying to our company address in writing with your identity verification information
• Through the platform: You can directly exercise some of your rights from the account settings section

Your applications will be concluded free of charge as soon as possible and at the latest within 30 (thirty) days depending on the nature of your request. However, if the transaction requires an additional cost, the fee in the tariff to be determined by the Personal Data Protection Board may be charged.

7. Personal Data Retention Period

Your personal data will be stored for the period required by the processing purpose and for the periods stipulated in the relevant legislation:

• While account is active: Data is actively processed and stored
• After account is closed: Required period for legal storage obligations (usually 2-3 years)
• Log and security records: 1 year
• Financial records: In accordance with tax legislation and relevant regulations (usually 10 years)
• Communication records: 3 years
• Marketing permissions: As long as permission is valid or until canceled

When retention periods expire, your personal data is deleted, destroyed, or anonymized.

8. Data Security

Our company takes necessary technical and administrative measures to ensure an appropriate level of security in order to prevent unlawful processing and access to personal data and to ensure the preservation of personal data:

• SSL/TLS encryption protocols
• Secure data centers and backup systems
• Access control and authorization mechanisms
• Regular security tests and audits
• Personnel training and confidentiality commitments
• Incident response and breach notification processes

9. Contact

For questions about this Clarification Text or the processing of your personal data:

• Email: info@gazla.co
• Website: https://gazla.co

10. Update of the Clarification Text

This Clarification Text may be revised from time to time due to changes in legal regulations or updates in company practices. The updated text will be published on our website and users will be informed about important changes.

Effective Date:

Effective Date: 25 Aralık 2025