Privacy Notice

DISCLOSURE TEXT ON THE PROTECTION OF PERSONAL DATA

‍‍Your personal data are processed by us, Anatolia Gayrimenkul ve Girişim Sermayesi Portföy Yönetimi A.Ş. (“Anatolia” or “Company”), in accordance with the current legislation under the Law on the Protection of Personal Data no. 6698 (“KVKK Law”), and high importance is given to ensuring the security of your data. With this disclosure text, we wish to inform you about the methods of obtaining your processed personal data, the legal grounds for data processing, the parties to whom it will be transferred, and the purposes of the transfer.

‍Method of Collecting Personal Data

‍Anatolia may obtain your personal data for the purposes stated in this Disclosure Text and within the framework of the conditions specified in the KVKK Law, through information and documents provided verbally, physically, or electronically during face-to-face or digital meetings, communications, or telephone calls with you, via various financial institutions, call centers, websites, mobile applications, and similar electronic environments, or through contracted institutions and organizations and other publicly available channels. 

‍Our Purposes for Processing Your Personal Data

‍Your personal data may be processed by Anatolia for the purposes stated below and may be retained for the period required by these purposes:

Establishment and management of real estate investment funds and venture capital investment funds, execution of portfolio management processes,

Fulfillment of legal and administrative obligations arising from capital market legislation and other legal regulations, providing information to authorized institutions and organizations,

Execution of customer relationship management processes, Tracking and finalizing requests/complaints, Ensuring the security of electronic and physical environments,

Execution of communication, survey, promotion, and marketing processes.

‍Your Personal Data We Process

‍As Anatolia, we need to process some of your personal data for the purposes listed under title (2) of this Disclosure Text, primarily including the establishment of real estate investment funds and venture capital investment funds, the management of the funds we establish, the conclusion of fund issuance agreements, and the provision of services such as portfolio management. You can find, without limitation, the personal data we obtain and process through the collection methods specified in title (1) of this Disclosure Text below:

Identity: name, surname, mother's-father's name, mother's maiden name, gender, date of birth, place of birth, marital status, identity card serial number, citizenship, nationality information, passport, and all kinds of information on the identity card including the Turkish ID number.

Contact Information: address, e-mail address, contact address, registered electronic mail address (KEP), telephone number.

Customer Transaction: call center records, request information. Transaction Data: Data obtained based on transactions made for services received from our Company.

Transaction Security Information: IP address information, device ID, website entry/exit information, password and passcode information, connection device information, log records, browser and time zone information, traffic information.

Financial: Professional investor information, financial performance information, credit and risk information, investment information, annual income, asset information, portfolio information, credit and debit card numbers, account number and IBAN information.

Professional Experience: Education and work information such as diploma information, employment information, occupation, title-position, in-service training information, certificates. Marketing: Survey, cookie records, information obtained through campaign work.

Visual and Audio Records: Information regarding your visual and audio records, including camera and video call recordings, and your call center voice recordings.

Other Information: Data contained in correspondence with public institutions and judicial authorities, information contained in lawsuit or enforcement files.

‍Legal Grounds for Processing Your Personal Data

‍Your personal data may be processed by our Company based on the following legal grounds: Your identity, contact, financial, profession, education, marketing, and customer transaction data may be processed based on your **explicit consent** for the purpose of promoting special offers or campaigns, conducting marketing communication activities, and sending commercial electronic messages.

We may process your personal data in **cases stipulated by relevant laws**, primarily the Capital Markets Law No. 6362 and secondary regulations, Borsa Istanbul regulations, and legislation on the prevention of money laundering. We may process your personal data for the **establishment of necessary contracts and the fulfillment of obligations under these contracts** within the scope of providing fund establishment, fund management, individual portfolio management, and investment advisory services to you under the contracts signed with you.

Your personal data may be shared with these institutions to the **extent necessary to fulfill our legal obligation** upon the request of official authorities and courts and other relevant institutions and organizations within the framework of legislation.

Your personal data may be processed based on the reason that **data processing is mandatory for the establishment, exercise, or protection of a right** for the purposes of filing a lawsuit or defending against an opened lawsuit.

Your transaction security data may be processed for our **legitimate interest** in ensuring the security of our electronic systems, provided that your fundamental rights and freedoms are not harmed. 

‍Transfer of Personal Data

‍Your personal data may be transferred in compliance with the general principles listed in Article 4 and the conditions stipulated in Articles 8 and 9 of the KVKK Law, provided that necessary security measures are taken. In this context, your personal data may be transferred;

To the Company's direct or indirect shareholders, affiliates, and subsidiaries for the purposes of providing various rights and benefits to you, securing the protection and execution of your rights, and conducting management activities,

To the Financial Crimes Investigation Board, Capital Markets Board, Central Bank of the Republic of Turkey, Turkish Capital Markets Association, Capital Markets Licensing Registry and Training Agency Inc., Borsa Istanbul Inc., Central Registry Agency, independent audit firms, and other authorized persons and organizations within Turkey and/or abroad, as well as public legal entities and regulatory authorities as required by legislation, and to our business partners, suppliers, or subcontractors for the performance of the contract and other purposes listed under title (2) of this Disclosure Text.

‍Your Rights as the Data Subject

‍Pursuant to Article 11 of the KVKK Law, as the data subject, you have the right to:

Learn whether your personal data is processed,

Request information if your personal data has been processed,

Learn the purpose of processing your personal data and whether they are used appropriately for their purpose,

Know the third parties to whom your personal data is transferred domestically or abroad, Request the rectification of your personal data if it is incomplete or incorrectly processed,

Request the erasure or destruction of your personal data if the reasons requiring their processing cease to exist,

Request that the rectification and erasure operations be notified to third parties to whom your personal data has been transferred,

Object to the emergence of a result against you by analyzing the processed data exclusively through automated systems,

Request compensation for damages in case you suffer damage due to unlawful processing of your personal data,

Obtain a copy of the Standard Contract signed with the data recipient residing abroad, if a Standard Contract exists regarding the transfer of your personal data abroad for the purposes explained under title (5) of the Disclosure Text.

If you wish to exercise any of your rights mentioned above, you can submit this request, along with sufficient information and explanation about your identity and the right you wish to exercise, by applying in person or via a notary to the address *Maslak Mah. Taşyoncası Sk. Maslak 1453 Sitesi T4 Blok No: 1u İç Kapı No: B224 Sarıyer / İstanbul*, or via registered electronic mail (KEP) to our registered e-mail address [[email protected]], or by using secure electronic signature, mobile signature, or your electronic mail address previously notified to us and registered in our system to the e-mail address [[email protected]].

You will be informed about the result of the evaluation within 30 days after your request reaches us. As a rule, your requests will be fulfilled free of charge, but if the process requires an additional cost, the fee determined by the Personal Data Protection Board may be requested from you.