Privacy Policy

Per 07.03.2025

PRIVACY STATEMENT ENERJISA COMMODITIES B.V.

1. WHO IS RESPONSIBLE FOR PROCESSING PERSONAL DATA?

This is the privacy statement of Enerjisa Commodities B.V. (hereinafter: Enerjisa Commodities). Enerjisa Commodities is headquartered in Amsterdam and Istanbul-based commodity trading house, mainly active in power, gas, and environmental commodities. Enerjisa Commodities trades various energy products on a B2B basis.

For the processing of personal of personal data for this website and related IT services, Enerjisa Commodities is jointly responsible with Enerjisa Enerji Üretim AŞ (hereinafter: ESA). ESA is the shareholder, located in Istanbul, and provides the IT infrastructure for Enerjisa Commodities.

For the processing of personal data for trading purposes, in the case of a B2B relationship, Enerjisa Commodities is jointly responsible with Enerjisa Elektrik Enerjisi Toptan Satış AŞ. (hereinafter: ETS). ETS is headquartered in Istanbul is a commodity trading house, mainly active in power, gas, and

environmental commodities and renewable energy certificates.

Enerjisa Commodities, ESA, and ETS attach great importance to privacy and the protection of personal data. This privacy statement describes how we handle personal data and the rights you, as a data subject, have.

All personal data is collected, processed and secured in accordance with the General Data Protection Regulation ("GDPR").

2. HOW CAN YOU CONTACT US?

For questions or comments about the processing of personal data by Enerjisa Commodities, ESA, and ETS, the primary contact point is Enerjisa Commodities. You can contact us at [email protected].

3. FROM WHOM DO WE PROCESS PERSONAL DATA?

We process personal data of persons we directly or indirectly wish to contact, have contact with or have had contact with. Examples include our B2B customers, prospective B2B customers, their representatives, people associated with companies with which we have, have had or wish to have a relationship, including suppliers, and anyone who expresses interest in our services.

4. WHAT PERSONAL DATA DO WE PROCESS?

Below is an overview of the categories of personal data we process.

For the provision of the website and IT services, Enerjisa Commodities and ESA process the following personal data:

Categories of personal data	Examples
Correspondence	(E-mail) correspondence Messages you send us via social media
Data that says something about the use of our website	Activities on our website IP addresses Information collected by means of cookies (see also our Cookie Statement) Information about the device with which you use our website or online user environment
Public messages about Enerjisa Commodities you leave on the internet	Messages on social media Reviews

For the processing of personal data for trading purposes, Enerjisa Commodities and ETS process the following personal data:

Categories of personal data	Examples
Identifying data and contact details	First name and surname of the representative Telephone number E-mail address Function Copy of passport or other means of identification
Correspondence related to the B2B relationship	(E-mail) correspondence Messages you send us via social media
Data that says something about the use of our online user environments for our products and services	Activities on our website, online user environment and social media IP addresses Information about the device with which you use our website or online user environment

5. WHERE DO WE GET YOUR PERSONAL DATA?

We receive most of the information because you provide it to us, for example when you create an account with us, because you enter your details on our website or because you communicate with us.

We also place cookies that allow us to collect information about your website visit. You can find more information about this in our Cookie Statement.

If you follow Enerjisa Commodities on social media or communicate with or about Enerjisa Commodities, we may have access to some of your public profile information. If you share information about Enerjisa Commodities via social media, your data may become visible on those social media. Enerjisa Commodities also follows social media channels and may access data about you on social media.

6 FOR WHAT PURPOSES ARE YOUR PERSONAL DATA PROCESSED AND ON WHAT BASIS?

Below we provide information on the purposes for which we process your personal data and the legal basis we rely on. These purposes and legal bases apply to both the processing activities for the use of the website and those for trading purposes. When this is not the case, this is specified in the table.

Purpose & legal basis	Examples
To be able to enter into a relationship and an agreement with you for trading purposes Legal basis: necessary for the performance of the agreement Controllers: Enerjisa Commodities and ETS	To register you as a (B2B) customer To respond to the messages you send us To record the agreements made To process and record the data provided by you via our online user environment and, for example, via e-mail
In order to perform agreements and contracts Legal basis: necessary for the performance of the agreement Controllers: Enerjisa Commodities and ETS	To maintain contact with you
For the development and improvement of products and services Legal basis: legitimate business interest Controllers: Enerjisa Commodities and ETS	To have a good overview of our customers and their relations To conduct internal audits and investigations
For relationship management, promotional and marketing purposes Legal basis: legitimate business interest and consent Controllers: Enerjisa Commodities and ETS	To inform you about a product that may be of interest to you, or a change to your existing product(s)
To combat fraud Legal basis: compliance with legal obligations Controllers: Enerjisa Commodities and ESA	To comply with legal obligations, your personal data may also be passed on to third parties
To protect the position of Enerjisa Commodities and third parties Legal basis: legitimate business interest Controllers: Enerjisa Commodities and ETS	To protect intellectual property rights
To ensure the security and stability of IT systems egal basis: legitimate business interest Controllers: Enerjisa Commodities and ESA	To monitor IT systems To carry out internal audits and investigations
To enter into agreements with suppliers and other partners Legal basis: necessary for the performance of the agreement Controllers: Enerjisa Commodities and ETS	To maintain contact with you

7. TO WHOM DO WE PROVIDE PERSONAL DATA?

Insofar as personal data are exchanged between the companies within the Enerjisa Üretim Santralleri A.Ş. group, this is done on the basis of Enerjisa Commodities, ESA and ETS’s legitimate business interest in order to conduct an efficient and responsible business.

Enerjisa Commodities, ESA, and ETS may use the services of third parties to process your data in accordance with this privacy statement. These parties act as processors for Enerjisa Commodities and/or ESA/ETS and we will ensure that these parties provide adequate safeguards with respect to technical and organisational security measures. Third parties acting as processors for Enerjisa Commodities and/or ESA/ETS have entered into a processor agreement which includes that they will only process data on behalf of Enerjisa Commodities and/or ESA/ETS.

Your data will also be passed on to other parties outside Enerjisa Commodities and/or ESA/ETS if we are legally obliged to do so, such as supervisory authorities, because we have to perform an agreement with you or if this is necessary to fulfil the agreements with you. In addition, we will also provide your

details to other parties we need as part of our services.

8. DO WE TRANSFER PERSONAL DATA TO OTHER COUNTRIES?

Enerjisa Commodities, ESA, and ETS may use the services of third parties to process your data in accordance with this privacy statement. These parties may be located outside the European Economic Area (EEA).

Your personal data will only be stored or processed outside the EEA by us or by third parties engaged if this is in accordance with the applicable regulations for the transfer of personal data to countries outside the EEA. This means that we will only transfer your personal data outside the EEA if the European Commission has decided that the third country in question ensures an adequate level of protection, or if other appropriate safeguards are put in place.

9. HOW LONG DO WE RETAIN YOUR DATA?

Your data will not be retained longer than we need it for the purposes for which it is collected or processed. Enerjisa Commodities, ESA, and ETS have different retention periods depending on the purpose and category of data.

If we no longer need the data for the purposes described above, we can still retain the data for archiving, legal proceedings or research purposes.

10. WHAT HAPPENS IN THE EVENT OF TRANSFER OF THE BUSINESS?

In the future, one or more parts or assets of Enerjisa Commodities may be transferred to a third party or Enerjisa Commodities may merge with a third party. In that case, your personal information may be transferred to that third party. Enerjisa Commodities will notify you in advance in such a case.

11. WHAT ARE YOUR RIGHTS?

You have a number of rights with regard to the processing of your data (see below). If you would like more information about this or would like to exercise one of these rights, please send an e-mail to [email protected].

Right to withdraw your consent if we have requested your consent for a particular processing of your personal data;

Right of access;
Right of rectification if personal data is incorrect or incomplete;
Right of erasure if personal data is irrelevant to the purpose for which it was collected, if consent has been withdrawn, if you object to a processing of personal data based on a legitimate interest or if the processing of personal data is unlawful;
Right to restrict processing if you dispute the accuracy of personal data processed Enerjisa Commodities, or if you have objected to the processing of personal data by Enerjisa Commodities;
Right to data portability;
Right to object to processing or direct marketing. You have the right to object to the processing of your data within the framework of our legitimate interest. We will then make a new assessment to determine whether your data may no longer be used. You can also specifically object to the use of your data for direct marketing;
Right of objection and human intervention in case of automatic decisions;
Right to complain. This can be submitted to the Enerjisa Commodities via [email protected] or to the Dutch Data Protection Authority.

12. HOW DO WE PROTECT YOUR PERSONAL DATA?

We take appropriate measures to prevent abuse, loss, unauthorised access, unwanted disclosure and unauthorised alteration of personal data. Only persons who need access to your data in view of their function can access it. All of these persons have a duty of confidentiality.

13. CHANGES

We may change our privacy statement from time to time. This may, for example, if there are new data processing operations or in connection with changes in regulations or technological developments. If there are substantial changes to this privacy statement, we will notify you. If necessary, we will ask for your permission for a modified or new processing.