Privacy Policy

Last Updated: August 2026

Solidus Makina Anonim Şirketi (“SolidTrack”, “we”, “us”, or “our”) collects data from your use of SolidTrack field telemetry units, the SolidTrack Platform, App, and API to help you optimize your heavy machinery operations, fleet management, and everyday business.

We fully understand that you value your privacy. We believe privacy is about being able to decide for yourself how your data is used and by whom. This Privacy Policy outlines our principles, the data we collect, and how we handle it.

OUR PRIVACY PRINCIPLES

• Transparency: We will always keep you fully informed about your data. We make sure you understand which data from or about you (and your workforce) we use, why we use it, how long we use it, and who can access it.

• Your Control: We consider the data from or about you to be yours. We only use it for the purposes for which you have given it to us, or for which we collected it from you.

• Our Role: SolidTrack is the Data Processor and you (the Customer) are the Data Controller in accordance with the Turkish Personal Data Protection Law (KVKK) and the General Data Protection Regulation (GDPR) in the EU. SolidTrack shall act only on instructions from you.

• Security: We implement appropriate technical and organizational security measures to protect data against accidental or unlawful destruction, loss, or alteration, and against unauthorized disclosure.

• Data Minimization: We keep as little of your data as possible, and only for as long as we need it. When we no longer need data, we destroy it or irreversibly anonymize it.

DEFINITIONS

• Personal Data: Any information relating to an identified or identifiable natural person (‘Data subject’ or ‘user’), such as your fleet operators, site managers, or company administrators.

• Processing: Any operation performed upon Personal Data, such as collection, recording, storage, adaptation, retrieval, use, disclosure, or destruction.

LEGAL COMPLIANCE AND DATA PROCESSING

As we are headquartered in Turkey and operate globally, we comply with both the Turkish Personal Data Protection Law (KVKK) and the General Data Protection Regulation (GDPR). SolidTrack will process Personal Data only if: a) The user or Customer has unambiguously given consent; or b) Processing is necessary for the performance of a contract to which the Customer is a party; or c) Processing is necessary for compliance with a legal obligation.

We process data on your behalf. You can at any time access, correct, or have your data deleted from our system. The employees at SolidTrack who have access to your data do so solely to assist you in support queries and to collect aggregated statistical data for further improvement of our platform.

In cases where Personal Data is transferred or processed outside Turkey or the European Economic Area (EEA), SolidTrack will ensure adequate safeguards with respect to the protection of privacy and fundamental rights by applying appropriate contractual clauses or legally binding instruments.

DATA WE COLLECT

What data we exactly collect depends on what services and hardware you use. In general, we collect three categories of data:

Data You Provide

This is the data you or your administrators enter into the SolidTrack Platform. This includes account details (name, email, phone number), geofence locations (addresses, site coordinates), and workforce information (operator names, shift schedules, certification statuses, and health/safety logs used in the Team Management module).

Data Collected by Sensors (Telemetry)

Our field telemetry units are equipped with multiple sensors designed for heavy machinery and hydraulic breakers. When active, these units automatically collect:

• GPS positions and relocation data

• Running hours and asset utilization metrics

• Environmental and physical data (e.g., temperature, impact force, shock levels, vibration, blank firing incidents)

• Battery levels and GSM cell information This data, in combination with your asset registry, is sent to SolidTrack to provide real-time dashboards and predictive maintenance alerts.

Metadata

This refers to any data automatically generated while you use SolidTrack platforms. It includes user interface events, IP addresses, unique device identifiers, cookies, and system activity logs.

DATA ANONYMIZATION AND STATISTICS

SolidTrack shall refrain from selling or disclosing raw personal or fleet data unless according to a written agreement with the rightful owner or a court order. However, SolidTrack reserves the right to analyze, aggregate, and disclose market statistics (e.g., average hydraulic breaker lifespan) which are based strictly on anonymous operating data from SolidTrack telemetry devices. Once data is aggregated and anonymized, it is no longer possible to identify the Customer or the end-user.

YOUR SOLIDTRACK ACCOUNT

We use your SolidTrack account to grant you access to our SaaS platform, dashboards, reports, and Secure Share links. We will use your email address occasionally to send system-critical information, maintenance alerts, or software updates.

We will not share your SolidTrack account details with third parties, unless they work under our direct responsibility according to our instructions, or when explicitly and lawfully ordered to do so by legal authorities.

YOUR RIGHTS AND CONTACT INFORMATION

As a data subject, you have the right to request access to, rectification of, or erasure of your Personal Data. You also have the right to restrict processing, object to processing, and request data portability via our API.

If you have any questions about how we use your data, or if you wish to exercise your rights or delete your SolidTrack account, please contact our Data Protection Officer at: Email: info@solidtrack.io

If you are not satisfied with our handling of your requests, you have the right to lodge a complaint with the relevant supervisory authority, such as the Turkish Personal Data Protection Authority (KVKK) or your local EU Data Protection Authority.

Company Information: Solidus Makina Anonim Şirketi Dudullu OSB Mahallesi, İmes Sanayi sitesi C306 Sk. No:2, 34775 Ümraniye İstanbul/Türkiye

GOVERNING LANGUAGE

This Privacy Policy is published in Turkish and in English. In the event of any discrepancy between the two texts, the Turkish text prevails.