Your Personal Data is Under Protection!

Dear Customer,

We respect your private life and privacy.

For that reason, in order to ensure that your fundamental rights are protected, we would like to inform you about how your data is utilized and protected further to the Personal Data Protection Act Law No:6698 (the Act).

The Overall Scope of the Act

In the Act, we are identified as a “Data Controller”. The Act defines data processing as: any operation which is performed on personal data, wholly or partially by automated means or non-automated means which provided  that form part of a data filing system, such as collection, recording, storage, protection, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, sharing with third parties categorization, preventing the use thereof.

The Reasons For Processing Your Personal Data

As per the products and services you may acquire from our organization, we process yours personal data further to the 5th article of the Act:

• Explicit envision by the laws as set out by the article 5/2 (a),
• Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract which you may have signed with us as set out by the article 5/2 (c),
• It is necessary for us to be in compliance with a legal obligation to which the data controller is subject as set out by the article 5/2 (ç),
• Data processing is necessary for the establishment, exercise or protection of any right as set out by the article 5/2 (e)
• Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject as set out by the article 5/2 (f)
• Your’s explicit consent as per your’s Special categories of personal data as set out by the article 6/2.

Why and What For Are We Using Your Personal Data? The Reasons For Processing Your Personal Data*

• To provide investment services and relative auxiliary services via all distribution channels such as digital banking and investment channels, especially for our brokerage, investment consultancy, clearing and custodian services, credited transactions, and generic investment advise,
• Saving your identity, address, and other necessary information used in yours transactions,
• To communicate your’s important contact informations which we need to share with you,
• Production of all necessary records and documents, including the processing of your location information, in order to be able to carry out your transactions on paper and verbal media and in electronic banking (internet banking and investment channels, mobile banking and investment channels ATM, telephone) of our institution or our Transmitter of Orders,
• To inform or report to public authorities which we have a legal duty to share information with, such as BDDK, TCMB, MASAK, GİB, SPK,TSBP, SPL, Borsa İstanbul, Takasbank, Yatırımcı Tazmin Merkezi ve TBB Risk Center,
• If you have permission, to use in the provision of our products and services, which are within the scope of the Act and which are out of your purpose of being a customer of our Institution, to plan and implement special product, service, offer activities for you, to perform product, service, working model offers, profiling and segmentation, creating an internal target, scoring and risk analysis, managing customer relations, using in-house performance monitoring and analysis studies, designing statistical studies and financial service delivery models, conducting market research,
• To record camera footages in our branches, regional directorates and headquarters buildings due to workplace security practices,
• Planning, controlling and implementing our corporate sustainability, corporate management, strategic planning and information security processes,
• To fulfill our administrative and legal obligations and the contracts we have signed with you.

With Whom and For What Purposes Do We Share Your Personal Data?

If necessary, we will only share your personal data with individuals and organizations permitted by the Act. These people and institutions are listed as follows: In order to carry out financial activities, the persons permitted by the Capital Markets Law and legislation, institutions, institutions considered as financial institutions and other third parties, due to the legal reporting required to be made, such as BDDK, CBRT, MASAK, GİB, SPK, SPL. Public institutions such as TSBP, Borsa İstanbul, Takasbank and Investor Compensation Center and TBB Risk Center, our main shareholder, other persons in the same group of companies as our main shareholder, third parties we intermediate, our subsidiaries and affiliates (For example, T.Garanti Bank A.Ş.., Garanti Portföy Yönetimi A.Ş., Garanti Yatırım Ortaklığı A.Ş.) are program partner organizations, domestic and foreign banks, and other financial institutions with which we receive or cooperate to carry out our capital market activities.

Where Can We Access Your Personal Data?

Your personal data The channels such as the Head Office, Branches, kiosks, ATMs, Customer Communication Center, Garanti BBVA Mobile and Internet Branch, which are available for you to make transactions at our institution and brokerage firms, order platforms, websites, public institutions and organizations. It can be collected in verbal, written or electronic media through system integrations (such as Identity Sharing System) shared with.

What Are Your Rights Under the Act?

By applying to our Institution at any time:

• You can learn whether it is processed, whether it is used according to its purpose and purpose, and if it is processed, ask for information about it,
• You can learn the third parties that your information is shared in Turkey and abroad in accordance with the law,
• If you think your information is incomplete or incorrectly processed, you can request that it be corrected,
• You can request that your information be deleted or destroyed within the framework of the conditions stipulated in Article 7 of the Act,
• You may request that your requests specified in articles (c) and (d) be notified to third parties to whom your information has been transferred and to perform the same transactions,
• You may object to the emergence of a result against you due to the analysis of your information with automated systems, or if you think that it has been recorded or used against the law and if you have been harmed for this reason, you may claim damages,for your personal data,

If your application for these purposes requires an additional cost, you may need to pay the fee amount in the tariff to be determined by the Personal Data Protection Board. Your requests in your application will be finalized as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request.

In order to exercise your rights under the Act, you can send your applications in writing via your registered electronic mail (REM) address, secure electronic signature, mobile signature or your e-mail address, which you have previously notified to our Institution and registered in our institution's system. You can visit the web page of Personal Data Protection Authority for more information.

* Our organization will update this information in case of any change in the personal data inventory study.

In the event that there is a discrepancy between the Turkish and English versions, the Turkish version shall prevail.

I have read, understood, been informed about, and accepted the explanations given hereinabove.

Privacy and confidentiality are as important for us as they are for you.

In keeping with its approach to its service philosophy focused on customer satisfaction and security and furthermore as a requirement of the business of securities, Garanti Yatırım Menkul Kıymetler A.Ş. complies with the following essential principles in order to protect the privacy of any information that you may provide to the Garanti BBVA Securities corporate website ( hereinafter referred to as “the website” ):

• Only information having to do with product/service transactions or to update existing information may be submitted through the website.
• Necessary precautions have been taken to maintain the highest possible level of bank system and internet infrastructure security as these apply to the confidentiality of the information submitted to the website. None of the product/service transaction or update information submitted by our customers to the website can be displayed by other internet users. This information will not be used for communicating with our customers by e-mail or SMS. Unauthorized access to information that our customers give to us is restricted to everyone, including but not limited to Garanti Yatırım Menkul Kıymetler A.Ş. personnel.
• Garanti Yatırım Menkul Kıymetler A.Ş. will not divulge such information to any other individual, agency, or organization without the customer’s consent or unless it is required by law to do so.
• Garanti Yatırım Menkul Kıymetler A.Ş. may not divulge such information in any way whatsoever except within the framework of specified authorizations and the requirements of law. If any regulatory, lawmaking, or enforcement agency or authority to which Garanti Yatırım Menkul Kıymetler A.Ş. is responsible requires such information to be divulged, Garanti Yatırım Menkul Kıymetler A.Ş. will do so only within the framework of authorized requirements.
• In addition to its own internal links, our website may contain links to other websites. Our Privacy Policy and the promises that it makes apply only to our own website and in no way extend to any other website. If you transfer to another website from our website by means of a link, the privacy and security terms and conditions of that other website will apply and not those of our website. Garanti Yatırım Menkul Kıymetler A.Ş. cannot be held in any way responsible for any material or moral losses or damages that may be sustained due to the use of information, ethical principles, confidentiality principles, or the quality or nature of service of any other website that you may visit because of any advertisement, banner, content, or other reason contained on our website.
• Garanti Yatırım Menkul Kıymetler A.Ş. may obtain support services from outside organizations with which it works. In such cases, Garanti Yatırım AŞ will ensure that such organizations comply with Garanti Yatırım Menkul Kıymetler A.Ş.’s own privacy standards and conditions.
• With the exception of such information and materials as are clearly indicated as belonging to other parties, all of the information and materials contained on our website and the rights applicable to them and to their arrangements are the sole property of Garanti Yatırım Menkul Kıymetler A.Ş. These rights include but are not limited to copyrights, trademarks, patents, intellectual property, and all other rights of ownership, all of which are retained by Garanti Yatırım Menkul Kıymetler A.Ş.
• Necessary precautions have been taken to maintain the highest possible level of bank system and internet infrastructure security as these apply to the confidentiality of our customers’ personal information. Please do not hesitate to contact us if you need any additional information regarding the matters discussed here.

Very truly yours,

Garanti Yatırım Menkul Kıymetler A.Ş.

INFORMATION ABOUT PROTECTION OF PERSONAL DATA

Pursuant to the provisions of the Law on Protection of Personal Data no. 6698 (“KVKK”), we, as Garanti Yatırım Menkul Kıymetler A.Ş., as and in the capacity of Data Responsible, may record, store, keep, update, if and to the extent permitted by the applicable laws and regulations, disclose or transfer or assign to third parties, classify and process as enumerated in the Law on Protection of Personal Data all and any of your personal data.

Purposes of processing of personal data and legal reasons and causes thereof: To use in all kinds of products and services, also including those products and services which may be offered by us as an agency in accordance with the Banking Law and other applicable laws and regulations, and to record identity, address and other required information for the purpose of identification of transaction owner, and to regulate all transaction-based records and documents electronically or on paper, and to comply with information keeping, non-disclosure, reporting and provision obligations arising out of the applicable laws or instructed by BRSA, TCB or other official authorities, and to be able to offer demanded / other products / services of our Bank, and to take the necessary actions signed by you.

Persons /entities to whom personal data may be transferred for the purposes set forth hereinabove: Persons and entities permitted by the Banking Law and other applicable laws and regulations, including, but not limited to, financial institutions and other third parties enumerated in article 73/4 of the Banking Law no. 5411, and public legal entities such as BRSA (Banking Regulation and Supervision Authority), CMB (Capital Markets Board) and TCB (Turkish Central Bank), and our main shareholder, and program partners and other third parties from whom we receive services or with whom we enter into cooperation for our intermediary services and activities.

Personal data collection method: Your personal data may be collected verbally, in writing or electronically through such channels as Head Offices, Branch Offices, E-Trader and call center.