Effective Date: August 15, 2023

ATP Aviation MRO Services («ATP», «we», «us», or «our») is committed to safeguarding the privacy and security of the personal information we collect, use, and disclose in association with our maintenance, repair, and overhaul (MRO) services for the aviation industry. This Privacy Policy («Policy») explains how we collect, use, and disclose personal information, as well as the rights and choices you have regarding your personal information. By utilizing our services, accessing our website, or otherwise providing us with your personal information, you acknowledge and agree to the terms and conditions of this Policy.

Personal Information We Collect

We may collect the following categories of personal information:

• 1.1 Identifiers, such as name, address, email address, phone number, company name, job title, and other contact information.
• 1.2 Professional or employment-related information, such as employer, job title, department, work contact information, and other professional information.
• 1.3 Inferences drawn from personal information, such as preferences, characteristics, predispositions, behavior, or attitudes.
• 1.4 Device and usage information, including Internet Protocol (IP) address, browser type, device type, operating system, pages visited, and other data collected through cookies, pixel tags, or similar technologies.
• 1.5 Other information you provide to us, such as feedback, questions, or information provided in connection with support inquiries.

How We Collect Personal Information

We collect personal information through various means, including:

• 2.1 Directly from you, when you provide it to us by filling out forms, contacting us, or otherwise voluntarily submitting information.
• 2.2 Automatically, as you navigate through our website or use our services, using technologies such as cookies, pixel tags, or other tracking technologies.
• 2.3 From third parties, such as vendors, suppliers, partners, or others, who provide services on our behalf or assist us in operating our business.

How We Use Personal Information

We use the personal information we collect for various purposes, including to:

• 3.1 Provide, maintain, and improve our MRO services and related offerings.
• 3.2 Communicate with you, respond to your inquiries, and provide customer support.
• 3.3 Personalize and enhance your experience with our services and website.
• 3.4 Monitor and analyze usage and trends to improve our services, website, and marketing efforts.
• 3.5 Protect the security and integrity of our services, website, and information systems.
• 3.6 Comply with legal and regulatory requirements, enforce our contractual rights, and resolve disputes.
• 3.7 Carry out any other purpose for which the information was collected, as described at the time of collection or as otherwise permitted by law.

How We Disclose Personal Information

We may disclose your personal information to third parties in certain circumstances, including:

• 4.1 To our vendors, suppliers, and partners, who provide services or perform functions on our behalf, such as data hosting, analytics, customer support, or marketing services.
• 4.2 To comply with legal or regulatory requirements, such as responding to subpoenas, court orders, or other lawful requests for information.
• 4.3 To protect our rights and property, the safety and security of our services, website, or users, or to enforce our terms of service or other agreements.
• 4.4 In connection with a merger, acquisition, reorganization, or sale of substantially all of our assets, in which case your personal information may be transferred to the acquiring entity.
• 4.5 With your consent or at your direction.

Your Rights and Choices

Depending on your jurisdiction, you may have certain rights concerning your personal information, including the right to:

• 5.1 Access your personal information held by us, including obtaining a copy of the personal information we have collected about you.
• 5.2 Request that we correct, update, or delete any inaccurate or outdated personal information.
• 5.3 Object to our use of your personal information for certain purposes or request that we restrict the processing of your personal information in certain circumstances.
• 5.4 Withdraw your consent to our processing of your personal information, where we rely on your consent as the basis for processing.
• 5.5 Complain with a supervisory authority if you believe that our processing of your personal information violates applicable law.

To exercise any of these rights, please contact us using the contact information provided in Section 8 below. We may require you to provide additional information to verify your identity before we can respond to your request. We will process your request in accordance with applicable law.

Data Retention and Security

We take reasonable precautions, including administrative, technical, and physical measures, to safeguard your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure, so we cannot guarantee the absolute security of your personal information.

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Policy, or as required or permitted by applicable law.

International Data Transfers

We may transfer your personal information to countries outside of your country of residence, including to the United States, where our headquarters is located. These countries may have data protection laws that differ from those of your country of residence. By using our services or providing us with your personal information, you acknowledge and agree to such transfers.

Contact Information

If you have any questions or concerns about this Policy, our privacy practices, or your rights with respect to your personal information, please contact us at:

ATP Aviation MRO Services

HAMI‌DI‌YE MAH. CENDERE CAD. NO: 103 /2 I‌Ç KAPI OFIS: 26, 34398 KAG‌ITHANE/I‌STANBUL

+90 501 063 3090

info@atp.com

We will make every effort to respond to your inquiry promptly.

Changes to This Policy

We reserve the right to update or modify this Policy at any time and from time to time. If we make material changes to this Policy, we will notify you by posting the revised Policy on our website or by other means, as required by applicable law. Your continued use of our services or website following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically review this Policy to stay informed about our privacy practices.

Applicable Law

This Policy and our privacy practices are subject to the laws of the jurisdiction in which you reside, to the extent not preempted by applicable federal or international law. In the event of a conflict between the terms of this Policy and applicable law, the requirements of applicable law will control.