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. personal.
- 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
Your Personal Data are Under Protection!
Dear customers,
We, as Garanti Yatırım Menkul Kıymetler A.Ş., have respect for security of your personal data and for your right of privacy, and make account of confidentiality and protection of your personal data. Now, we are hereby presenting to your attention this public disclosure text prepared in order to inform you about your rights regarding processing, transfer, storage and destruction of your personal data shared by you with our Company at any time in the course of trading brokerage services, investment consultancy, clearing and custodian services, credited transactions and generic investment advice and all other investment services and relevant side services within the scope of Capital Markets Law and other applicable law, offered by Garanti Yatırım Menkul Kıymetler A.Ş. to you, and regarding use and protection of your personal data under the Personal Data Protection Law no. 6698 (“KVKK” or “Law”).
As will be described in this Public Disclosure Text, your personal data and sensitive personal data may be recorded, archived, updated, transferred, classified and processed pursuant to and under KVKK and other applicable laws and regulations appertaining thereto.
Data Supervisor
This public disclosure text is published by Garanti Yatırım Menkul Kıymetler A.Ş., as and in the capacity of data supervisor. As per the Law, “Data Processing” refers to all kinds of transactions effected on personal data, such as acquisition, recording, storage, updating and classification of personal data, fully or partially, by automatic means and ways or by non-automatic means and ways, providing that it is a part of any data registration system, and sharing of data with third parties or transfer to them to the extent permitted by the applicable laws and regulations.
We, as data supervisor, are keeping and safeguarding all kinds of personal data, shared by you with us, in strict compliance with the applicable laws and regulations, and by taking all kinds of the technical and administrative actions and measures required for protection of your personal data under an appropriate security level.
Personal Data Collected by Us
Personal data, varying according to the type, nature and past of the relations between our Company and the related person and depending on the method of acquisition of data and the following purposes, to be collected in the course of relations to be established by us with you in tandem with the products and services you are going to receive from our Company, and to be processed in compliance with the principles set down in the Law and in our Company’s Personal Data Processing and Protection Policy, are generally as listed below, without however being limited thereto:
Identity Data and Information: Name, surname, T.R. identity number, passport number, place of birth, date of birth, sex, marital status, information on spouse/children, status of citizenship, nationality, and civil registry information
Visual Records: Photograph
Communication Data: Together with such communication data as address, electronic mail, registered electronic mail address, mobile phone, fixed phone and facsimile number, all and any communication records relating to phone conversations, video conversations and electronic mail correspondences, and other audio and video data
Transaction Security Data: Customer information, IP addresses, codes and passwords needed for entry to electronic channels, and positioning data processed for such purposes as security applications used in said channels and as performance of legal obligations, and biometric data processed in reliance upon consent received from the related persons
Marketing Data: Data on past shopping activities, public surveys, cookie records, and data obtained through campaigns, in line with a consent to be received from our customers, prospective customers and other natural persons who may be related thereto
Data on Commercial Life: Data on natural persons in such documents regarding legal entities as tax chart, trade registry gazette, certificate of authorization, trade registry documents, certificates of competency, signature circular and certificates of activity, and various other demographic information introducing data subject, such as tax liability status and other personal information
Brokerage and Finance Data: Pricing, account reconciliation and customer information, and uniform numbers relating to products and services bought by the customer directly or via our Company , and reference numbers, account numbers, IBAN, and all kinds of detailed financial data regarding collection and payment activities, as generated by our Company
Data About Your Education, Business and Professional Life: Profession, job title, past work experience, education level, and curriculum vitae information
Legal Information: Information contained in correspondences with juridical authorities, information contained in case files, and information kept in the course of proceedings relating to alternative dispute resolution ways, acquired by our Company due to the legal disputes involved in by our Company, and data contained in writs and subpoenas of any kind relating to administrative and juridical authorities sent and delivered to our Company,
Camera and Entrance – Exit Records: Such data as entrance and exit records and camera views relating to employees and visitors, kept for the sake of physical security in premises and offices of our Company and its affiliates
III. Personal Data Collection Method
Your personal data are acquired during the services provided by Garanti Yatırım Menkul Kıymetler A.Ş. to you, and may be collected either during face-to-face interviews, or via call centre, internet website, e-mail, digital messaging platforms and social media channels. Your personal data may be stored in verbal, written or electronic media through Head Offices, Branch Offices, kiosks placed in branch offices for your transactions, ATMs, Customer Communication Centre, Garanti BBVA Mobile and Internet Branch, transaction platforms, websites and similar other channels of our Company and our transmission broker, as well as through system integrations (like Identity Sharing System) shared via public entities and authorities.
Personal Data Processing Purposes and Legal Reasons
Your personal data acquired by Garanti Yatırım Menkul Kıymetler A.Ş. are basically processed for the following purposes and legal reasons, particularly provision of safe, effective and top quality services to you:
Our Processing Purposes
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Legal Reasons
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Know-your-customer processes, customer identity determination and confirmation, and recording the identity, address and other required information of our customers for the transactions to be executed by our customers
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It is a legal requirement for performance by our Company of its legal liabilities.
It is clearly stipulated in the applicable laws.
Data processing is required for establishment, use or protection of a right.
In case of receipt of an explicit consent thereinfor.
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For provision of trading brokerage services, investment consultancy, clearing and custodian services, credited transactions and generic investment advice and all other investment services and relevant side services within the scope of Capital Markets Law and other applicable law, and for performance, execution and development of the transactions related thereto, and for conduct of operational processes, and for compliance with internal systems, and risk monitoring and information obligations, and for performance of our obligations arising out of the agreement/agreements signed by you with our Company .
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Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement.
Data processing is required for legitimate interests of our Company , providing that the fundamental rights and freedoms of the related person are protected.
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For performance of our obligations arising out of the Capital Markets Law the Law on Prevention of Laundering of Crime Revenues, and other applicable laws and regulations appertaining thereto
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It is clearly stipulated in the applicable laws.
It is a legal requirement for performance by our Company of its legal liabilities.
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For analysis and further development of our Company’s systems, and conduct of information security processes, and installation, management and application of infrastructures for information systems
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It is a legal requirement for performance by our Company of its legal liabilities.
Data processing is required for legitimate interests of our Company , providing that the fundamental rights and freedoms of the related person are protected.
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For building our Company’s business processes and activities, and for planning and conduct of operational processes and purchasing operations
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Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement.
Data processing is required for legitimate interests of our Company , providing that the fundamental rights and freedoms of the related person are protected.
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For management of relations established with support service providers, business partners or suppliers, and for provision of support services after sales of services
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Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement.
Data processing is required for legitimate interests of our Company , providing that the fundamental rights and freedoms of the related person are protected.
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For protection of reputation of our Company, and development of its business relations, and determination of its strategies, and planning and performance of its business activities and operational processes, and management of its corporate communication activities
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It is a legal requirement for performance by our Company of its legal liabilities.
Data processing is required for legitimate interests of our Company , providing that the fundamental rights and freedoms of the related person are protected.
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For management of legal and execution proceedings, and follow-up and handling of other legal processes involved in by our Company
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It is a legal requirement for performance by our Company of its legal liabilities.
It is clearly stipulated in the applicable laws.
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For handling and management of relations and business affairs of our Company with T.Garanti Bankası A.Ş. and BBVA S.A. and its domestic and foreign branches and subsidiaries
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It is a legal requirement for performance by our Company of its legal liabilities.
Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement.
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For protection of transaction security in the course of use of electronic channels, and for protection of our customers, Company and systems as a whole against fraud, swindling and other attacks that may be incurred by our customers in all types of physical or electronic media and environments, and for keeping the logs in the case of use of internet access
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It is a legal requirement for performance by our Company of its legal liabilities.
Data processing is required for legitimate interests of our Company , providing that the fundamental rights and freedoms of the related person are protected.
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For storage and safeguarding of information requested by juridical and administrative authorities like the Banking Regulation and Supervision Authority, the Central Bank of the Republic of Turkey, the Financial Crimes Investigation Board, the Turkish Revenue Administration, the Capital Markets Board, Capital Markets Licensing Registry and Training Agency, Turkish Capital Markets Association, Borsa İstanbul, ISE Settlement and Custody Bank, Central Securities Depository, Investor Compensation Centre and the Risk Centre of the Banks Association of Turkey to which we are obliged to give information, and for reporting and information to these authorities
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It is a legal requirement for performance by our Company of its legal liabilities.
It is clearly stipulated in the applicable laws
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To offer through all available channels, also including electronic channels, all our products and services, especially trading brokerage services, investment consultancy, clearing and custodian services, credited transactions and generic investment advice and all other investment services and relevant side services pursuant to and under the Capital Markets Law and all other applicable laws and regulations pertaining thereto
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It is a legal requirement for performance by our Company of its legal liabilities.
Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement.
It is clearly stipulated in the applicable laws.
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To keep all of the required records, documents and certificates, also including the processing of positioning information, for the sake of completion of transactions on paper and via verbal environments and electronic media belonging to our Company and our transmission broker (internet banking, I-Trader, E-Trader, GarantiFX Trader mobile banking and investment platforms, ATM and telephone).
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It is a legal requirement for performance by our Company of its legal liabilities.
Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement.
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For planning and implementation of product, service and offering activities -which are within the scope of applicable law and which are out of your purpose being a customer of our Company- specifically for our customers, and for preparation of product, service and business model offers, and for the associated profiling and segmentation works and activities, creating and internal target, scoring, managing customer relations, using in-house performance monitoring and analysis studies, designing statistical studies and financial delivery models, conducting market research for the sake of improvement and updating of products and services and renewal of them with the developed and advanced technologies
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In case of receipt of an explicit consent thereinfor.
Data processing is required for legitimate interests of our Company , providing that the fundamental rights and freedoms of the related person are protected.
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For the sake of legal and physical security, and as a proof for the transactions executed by using the services, and as a requirement of our legal obligations, recording of camera views and photographs in our Company’s headquarters building and additional service units, ATMs and branch offices, and processing of your biometric photographs on your T.R. identity cards for security and identification purposes
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It is clearly stipulated in the applicable laws.
It is a legal requirement for performance by our Company of its legal liabilities.
Data processing is required for legitimate interests of our Company , providing that the fundamental rights and freedoms of the related person are protected.
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Conducting audit, control, risk analysis and applicable audit activities
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It is clearly stipulated in the applicable law.
Data processing is required for legitimate interests of our Company, providing that the fundamental rights and freedoms of the related person are protected.
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For planning, supervision and implementation of our corporate sustainability, corporate governance, strategic planning and information security processes
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It is clearly stipulated in the applicable laws.
It is a legal requirement for performance by our Company of its legal liabilities.
Data processing is required for legitimate interests of our Company , providing that the fundamental rights and freedoms of the related person are protected.
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Your personal data are collected and acquired in all types of verbal, written, visual and electronic media for the purposes tabulated hereinabove and for provision of the services provided by our Company within the legal framework specified herein and for full, complete and smooth performance by Garanti Yatırım Menkul Kıymetler A.Ş. of all of its legal and contractual obligations. Legal reasons underlying the collection of your personal data are KVKK (Personal Data Protection Law) and other applicable laws and regulations appertaining thereto. Your personal data are processed by Garanti Yatırım Menkul Kıymetler A.Ş. by automatic and non-automatic methods and ways in case of receipt of your explicit consent pursuant to article 5/1 of KVKK or alternatively in reliance upon certain legal motives pursuant to and under article 5/2 of KVKK.
Your sensitive personal data may be processed only in case of receipt of your explicit consent pursuant to article 6/1 of KVKK. Garanti Yatırım Menkul Kıymetler A.Ş. may process your sensitive personal data only with your prior explicit consent. And as per article 6/3 of KVKK, personal data relating to health and sexual life may be processed by authorized institutions and entities or by persons under secrecy obligations for the sake of protection of public health, and for preventive medicine, medical diagnosis, treatment and care services, and for planning and management of healthcare services and their financing, without an explicit consent of the data subject. Accordingly, in accordance with article 6/3 of KVKK, in cases or events stipulated in the applicable laws, personal data not related to health and sexual life may be processed without an explicit consent of the data subject. This means to say that in cases or events stipulated in the applicable laws, your personal data not related to health and sexual life may be processed by Garanti Yatırım Menkul Kıymetler A.Ş. without an explicit consent of you.
Furthermore, as per article 6/3 of KVKK, your personal data relating to health and sexual life may be processed for the sake of protection of public health, and for preventive medicine, medical diagnosis, treatment and care services, and for planning and management of healthcare services and their financing.
Transfer of Personal Data
Where required by the applicable laws and regulations or where permitted by you, your personal data may be shared with third party persons or entities for the purposes and motives set forth in Section III of this Public Disclosure Text by taking all kinds of technical and administrative actions and measures required for establishment of an appropriate level of security pursuant to KVKK and other applicable laws and regulations. These persons or entities may vary depending on the probable changes in pertinent laws, but are nevertheless the following parties in general.
Your personal data are transferred to the following parties for the following purposes and legal reasons:
Transferees
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Our Purposes of Transfer
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Public entities and authorities and juridical authorities who are legally authorized to get information
Persons, entities, entities regarded as financial institutions and other third parties permitted under Capital Markets Law and applicable law
Banking Regulation and Supervision Authority, the Central Bank of the Republic of Turkey, the Financial Crimes Investigation Board, the Turkish Revenue Administration, the Capital Markets Board, Capital Markets Licensing Registry and Training Agency, Turkish Capital Markets Association, Borsa İstanbul, ISE Settlement and Custody Bank, Investor Compensation Centre and the Risk Centre of the Banks Association of Turkey and such public legal entities
Our controlling shareholder, BBVA S.A, other companies within the same group of companies with our controlling shareholder, affiliates and subsidiaries (For example: Türkiye Garanti Bankası A.Ş. Garanti Emeklilik ve Hayat A.Ş., Eureko Sigorta A.Ş., Garanti Konut Finansmanı Danışmanlık Hizmetleri A.Ş., Garanti Faktoring A.Ş., Garanti Finansal Kiralama A.Ş., Garanti Ödeme Sistemleri A.Ş., Garanti Bilişim Teknolojisi ve Ticaret T.A.Ş. and Garanti Portföy Yönetimi)
Overseas program and solution partner entities, regulators, governing bodies, legal authorities, banks, exchanges, financial institutions and third parties that we get services or collaborate for conducting our intermediation and brokerage services
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For legal reporting purposes, regulation, supervision and financial activities, management of complaint and legal processes, fulfillment of legal requirements
Conducting activities in collaboration with supporting parties and affiliates in order for the continuation of services provided
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VI. Your Rights Relating to Protection of Personal Data
Whenever you like, you may apply to our Company, and:
1. May ask whether your personal data are processed or not, and if so, for which purposes, and whether your personal data are used for the intended purposes or not, and if processed, may request detailed information thereabout; and
2. May learn the identity of third parties with whom your personal data are shared within Turkey or abroad in accordance with the laws; and
3. If you think your personal data are processed incompletely or inaccurately, may request completion or correction of them, as the case may be; and
4. May request deletion or destruction of your personal data within the frame of conditions stipulated in article 7 of the Law; and
5. May request the transmission of your requests stated in subparagraphs (3) and (4) hereinabove to third parties to whom your personal data are transferred, so that such third parties also take the same actions in connection therewith; and
6. May raise an opposition against any consequences in your disfavor due to analysis of your personal data by automatic systems, or if you think that your personal data are recorded or used unlawfully, and if you have actually incurred damages due to that reason, may claim indemnification of your damages.
If and when you use any one of your rights to learn whether your personal data are processed or not, and if your personal data are processed, to request information thereabout, and to access to and request your personal data, and to learn the purpose of processing of your personal data and whether your personal data are used for the intended purposes or not, and to learn the identity of third parties to whom your personal data are transferred in Turkey or abroad, then and in this case, the information requested by you will be given to you in writing via electronic media or by using the communication data designated by you.
VII. Data Security and Application Rights
Your personal data are carefully protected within the reach of available technical and administrative means, and the required security actions and measures are taken at a level appropriate for the probable risks by also considering the technological opportunities.
You may transmit your requests under KVKK:
• By delivering the same in writing and by hand to our Head Offices or Branch Offices, or
• By sending via a notary public, or
• By delivering the same with secure electronic or mobile signature to our Registered Electronic Mail address* of [garantibbvayatirim@hs03.kep.tr] , by using your registered electronic mail address or your electronic e-mail address registered in our systems.
If any application filed by you for the aforementioned purposes requires an additional cost, you may need to pay a fee as specified in the tariff to be designated by the Personal Data Protection Board. Your requests in your application will be responded as soon as possible and in any case within no later than 30 (thirty) days, depending on the kind of your request.
In case of any change in the personal data inventory, our Company is going to update this information text.
*Registered Electronic Mail system is a closed system; meaning you can send mails to our Registered Electronic Mail address only from another Registered Electronic Mail address.
Garanti Yatırım Menkul Kıymetler A.Ş.