Personal Data Protection and Processing Policy

Anasayfa
Personal Data Protection and Processing Policy

24 GAYRİMENKUL VE GİRİŞİM SERMAYESİ PORTFÖY YÖNETİMİ A.Ş.

PERSONAL DATA PROTECTION AND PROCESSING POLICY

a) Data Controller
24 Real Estate and Venture Capital Portfolio Management A.Sh. as a legal entity, we take the necessary measures in accordance with the KVKK during the processing and transfer of personal data of employees and officials of legal entities who purchase our products in the capacity of data controller within the scope of the Personal Data Protection Law No. 6698 (“KVKK”) and other relevant legislation.

b) The Purpose for Which the Personal Data will be Processed and the Legal Reasons
As the Data Controller, we collect the personal data belonging to our customers from the customers themselves and/or their authorities, authorized institutions and organizations by all kinds of oral, written, electronic and physical methods in visual format, both automatically and non-automatically by the employees of our company or through our website. These data that we collect are KVKK m.in accordance with Article 4, we process and store in a measured and limited manner, in accordance with the principles and depending on the reasons of compliance with the law and the purposes listed below.

c) The Method and Legal Reason of Collecting Personal Data

Personal data is collected by e-mail, using our existing current records, by face-to-face meetings and business card sharing, by telephone calls, by concluding contracts in order to fulfill the above purposes.

Legal Reason		Purpose of Processing
Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data belonging to the parties to the contract		Fulfillment of obligations and responsibilities related to products and services within the field of activity of our company Execution of contract processes, Conducting advertising, campaign and promotion processes related to our products and services and contacting you for these purposes, Product sales, newsletter delivery and making informations, Execution of marketing activities Execution of customer relations, Execution of product and service purchase processes, Improving the quality of products and services, For the purpose of conducting investment processes,
Provided that it does not harm your fundamental rights and freedoms, if data processing is mandatory for the legitimate interests of the data controller;		Execution of all products and services that we provide within the framework of the Capital Market Law and related legal regulations by its subsidiaries and business partners, Conducting analysis and reporting studies that are deemed necessary to be performed related to portfolio management and investment consulting activities, For the purpose of carrying out strategic planning activities
In order to fulfill our legal obligation and/or for our legitimate interest, the processing of your data is mandatory and is clearly stipulated in the laws		Identification and confirmation of your identity and address information, Verification of customer information and ensuring that it is up-to-date, Conducting a risk analysis, Execution of risk management and information security processes, Conducting Internal Audit / Investigation / Intelligence activities, conducting analysis, reporting studies and conducting reviews that are considered mandatory to be performed within the scope of Portfolio Management and Investment consulting activities, Execution and supervision of business activities, Execution of storage and archive activities, Execution of finance and accounting works
		In order to store and report the information requested by the public institutions that we are obliged to provide information in accordance with the BRSA, CBRT, MASAK, GIB, CMB and TBB and to meet the information and document requests of these institutions
In the event that data processing is mandatory for the establishment, use or protection of a right;		In possible cases, Follow-up of legal affairs, For the purpose of tracking requests and complaints
In the presence of explicit consent		For the purpose of conducting analysis and modeling studies that are deemed necessary to be carried out within the scope of the company's activities and conducting investigations

d) To Whom and for What Purpose the Processed Personal Data May be Transferred

It is our priority that personal data is not disclosed and not transferred. However, in order to be able to fulfill our obligations related to the provisions of the legislation to which we are subject, in a limited and measured manner related to the fulfillment of the following processing purposes,

To the institutions and organizations authorized to receive information by law (e.g. BRSA, CMB, TSPB, CBRT, MASAK, SGK, IYS, Banks Association of Turkey), for the purpose of conducting risk management and monitoring activities and legal reporting, conducting regulatory and audit activities, conducting complaints and legal processes,
In order to be able to provide support services to the suppliers, independent audit companies from which we receive external services, to the company,
Apart from these cases, data transfer is transferred to real and legal persons who are obliged to do so within the scope of compliance with the law reasons.

11 of the KVKK. Your Rights Under the Article

11 of the KVKK. within the scope of article 11 of the KVKK, you have rights as a data owner and your requests related to these rights. with article 13. article 1. in accordance with the paragraph and the Communiqué on the Procedures and Principles of Applying to the Data Controller “info@24portfoy.com.tr ” you can use it by applying to the address.

Employee Candidate Lighting Text

a) Data Controller

24 As Portföy, we process the personal data of persons applying for a job with us in the capacity of data controller within the scope of the Personal Data Protection Law No. 6698 (“KVKK”) and other relevant legislation.

b) The Purpose for Which the Personal Data will be Processed and the Legal Reasons

Personal data of employee candidates:

We operate limited to the Execution of Employee Candidate Selection and Placement Processes, the Execution of Activities in Accordance with the Legislation, their purposes.

c) The Method and Legal Reason of Collecting Personal Data

Personal data is collected by e-mail, face-to-face interviews and by hand delivery of job application forms and resumes to us in order to fulfill the above purposes.

Legal Reason		Purpose of Processing
Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data belonging to the parties to the contract		Execution of Employee Candidate Selection and Placement Processes
Clearly stipulated in the laws		Conducting Activities in Accordance with the Legislation

d) To Whom and for What Purposes the Processed Personal Data Can be Transferred, the personal data of employee candidates are not transferred to third parties.

a) 11 of the KVKK. Your Rights Under the Article