Policies

WEBSITE CLARIFICATION TEXT

As FUZUL HOLDİNG ANONİM ŞİRKETİ (“Fuzul Holding”), we attach great importance to the protection of your personal data. Therefore, we show all necessary effort and care to process and preserve your personal data in accordance with the Personal Data Protection Law No. 6698 (“KVKK”).

1. PURPOSE AND SCOPE

This Clarification Text (“Clarification Text”) has been prepared in accordance with Article 10 of the KVKK, titled “Clarification Obligation of the Data Controller”, to fulfill the obligation to inform you about the identity of the data controller, the method and legal grounds for collecting your personal data, the purposes for which this data will be processed, to whom and for what purpose it can be transferred, and what your rights are as listed under Article 11 of the KVKK. Fuzul Holding acts as a data controller under the KVKK regarding the processing of personal data. Personal Data is processed and stored by Fuzul Holding in accordance with the KVKK and the legislation on the protection of personal data.

2. IDENTITY OF THE DATA CONTROLLER

The data controller is FUZUL HOLDİNG A.Ş. The contact information of our Company is as follows:

• Address: Başakşehir Mah. Cahit Zarifoğlu Cd. 423. Sokak Olimpa Rezidans Kat 1 Başakşehir/İstanbul
• Phone: 444 63 13
• Email Address: kvkk@FuzulHolding.com
• Registered Email (KEP) Address: fuzultasarruf@hs01.kep.tr

3. WHICH PERSONAL DATA DO WE PROCESS, AND FOR WHAT PURPOSES?

When you reach Fuzul Holding through digital channels such as the e-Branch or the website, we process your personal data including First name, last name, gender, phone number, province-district, e-mail, profession, IP address, advertising medium, call center interview records, and e-Branch customer correspondence for the following purposes:

• Execution of Advertising / Campaign / Promotion Processes,
• Execution of Marketing Processes of Products / Services,
• Execution of Customer Relations Management Processes,
• Execution of Marketing Analysis Studies,
• Execution of Storage and Archive Activities,
• Tracking of Requests/Complaints,
• Execution of Communication Activities,
• Execution of Activities for Customer Satisfaction.

Even if you do not purchase any services, you can continue to receive SMS or e-mails regarding our campaigns and opportunities by giving consent to Fuzul Holding to send electronic commercial messages.

If you have physically visited Fuzul Holding branches, we collect your personal data including First name, last name, gender, phone number, province-district, e-mail, profession through the customer representative, and if you have held a phone meeting with the call center, your call records, and we process them for the purposes listed above.

Security camera footage obtained through security cameras located in our branches are processed for the purposes of:

• Ensuring Physical Space Security,
• Carrying out Activities in Accordance with the Legislation,
• Ensuring the Security of Data Controller Operations.

If you connected to the Wi-Fi during your visit to our branches, your IMEI number and internet log data of your connected device are processed for the purpose of:

• Carrying out Activities in Accordance with the Legislation.

If you decide to benefit from the products or services offered by Fuzul Holding, your personal data specified above is forwarded to the Operations and Sales Departments, and during this process, a copy of your ID, bank account information, and photograph details are also requested. Since you will sign a contract, your Signature data is processed, and customer records identifying you are created within Fuzul Holding. In this process, if there are cases where your spouse's consent is required, personal data such as the spouse's name, surname, and signature may be processed. These data are processed for the purposes of:

• Carrying out Activities in Accordance with the Legislation,
• Execution of Commitment Processes to Firm / Product / Services,
• Execution of Communication Activities,
• Execution / Audit of Business Activities,
• Execution of Business Continuity Ensuring Activities,
• Execution of Goods / Services After-Sales Support Services,
• Execution of Goods / Services Sales Processes,
• Execution of Goods / Services Sales and Operations Processes,
• Execution of Customer Relations Management Processes,
• Execution of Activities for Customer Satisfaction,
• Execution of Storage and Archive Activities,
• Execution of Contract Processes,
• Tracking of Requests / Complaints,
• Ensuring the Security of Data Controller Operations,
• Providing Information to Authorized Persons, Institutions, and Organizations.

In order to provide you with the requested products or services in the best possible way, your required identity, communication, and financial information from among the personal data mentioned above are transferred to our Delivery department. Processing of personal data such as Findex report, payroll, land registry information, mortgage document, tax plate, and written approval statement of the guarantor's spouse may also be carried out by this department for the following purposes:

• Execution of Goods / Services After-Sales Support Services,
• Execution of Goods / Services Delivery Processes,
• Carrying out Activities in Accordance with the Legislation,
• Execution of Risk Management Processes.

Your personal data consisting of name, surname, T.R. Identity Number, address, phone number, bank account details, payment amounts, invoices, and signature are processed by our Accounting and Finance departments for the purposes of:

• Execution of Finance and Accounting Affairs,
• Carrying out Activities in Accordance with the Legislation,
• Execution / Audit of Business Activities,
• Execution of Storage and Archive Activities,
• Ensuring the Security of Data Controller Operations,
• Providing Information to Authorized Persons, Institutions, and Organizations.

If you benefit from the "Online Transactions" service where you can carry out your processes related to Fuzul Holding via the internet, your e-mail and password personal data are processed to determine your identity and to ensure your transaction security. Since options such as debt viewing, making payments, and viewing status are available within the scope of the "Online Transactions" service, your personal data related to these are processed. Fuzul Holding utilizes outsourced services for payments made through "Online Transactions" and does not process the credit card information of its customers.

In the event of any legal dispute, your personal data regarding the dispute is transferred to our Legal department. In our legal department, this data and your legal transaction data such as court information, file information, execution info, etc. related to the dispute are processed for the purposes of:

• Tracking and Execution of Legal Affairs,
• Execution of Storage and Archive Activities,
• Providing Information to Authorized Persons, Institutions, and Organizations.

No matter how you reach Fuzul Holding, whether you receive service or not, your personal data processed in the digital environment may be processed by our Information Technology (IT) department for the purposes of:

• Execution of Information Security Processes,
• Ensuring the Security of Data Controller Operations,
• Ensuring the Security of Data Processing Activities,
• Execution of Risk Management Processes.

4. TRANSFER OF YOUR PERSONAL DATA

Your personal data may be shared with the units within Fuzul Holding, as explained above, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law. Provided that you have given your explicit consent, your personal data may be transferred to group companies, including Fuzul Holding, and other companies in which these companies are shareholders, for the purpose of promoting their own products and services and announcing campaigns; these companies will be able to contact you limited to the purposes stated herein.

Personal Data may be shared with institutions, call centers, auditors, consultants, and other third parties from whom services are received, contracted advertising agencies, business partners, audit firms, lawyers, or public institutions or organizations authorized to request this data due to a legal obligation, and other relevant authorities, without being limited to these, in order to fulfill the purposes of the contract established between you and Fuzul Holding or due to the activities of Fuzul Holding.

While transferring your personal data to units within Fuzul Holding or to the third parties listed above, all necessary technical and administrative measures are taken by Fuzul Holding.

5. METHODS AND LEGAL REASONS FOR COLLECTING YOUR PERSONAL DATA

5.1. Method of Collecting Your Personal Data:

Fuzul Holding collects your personal data through various methods, whether physical, verbal, written, or electronic, online or offline.

If you physically visit our company premises, your images are automatically processed through the cameras we have placed in the workplace buildings, in accordance with our legal obligation to ensure workplace safety and our legitimate interest. If you establish a Wi-Fi connection during your visit, your data regarding the IMEI number of your connected device and internet log records are automatically processed in an electronic environment.

5.2. Legal Grounds for Collecting Personal Data:

Your personal data is collected, stored, and transferred based on one or more of the following reasons:

• Your explicit consent,
• Explicitly provided for in laws,
• The necessity of processing personal data for the establishment or performance of your contract with Fuzul Holding,
• It is mandatory for Fuzul Holding to fulfill its legal obligation,
• Data processing is mandatory for the legitimate interests of Fuzul Holding, provided that it does not harm your fundamental rights and freedoms.

6. RIGHTS OF THE DATA SUBJECT

As personal data owners, if you submit your requests regarding your rights specified below to Fuzul Holding, your requests will be evaluated and finalized by Fuzul Holding as soon as possible and in any case within 30 (thirty) days at the latest.

Pursuant to Article 11 of the Law, you have the following rights as a personal data owner:

• Learning whether your personal data is processed,
• If your personal data has been processed, requesting information about it,
• Learning the purpose of processing your personal data and whether they are used in accordance with their purpose,
• Knowing the third parties to whom your personal data is transferred at home or abroad,
• Requesting correction of your personal data if it is incomplete or incorrectly processed,
• Requesting the deletion or destruction of your data,
• Requesting notification of the operations carried out as per the correction, deletion, or destruction of data to third parties to whom your personal data has been transferred,
• Objecting to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
• Requesting compensation for damages in case you incur damages due to unlawful processing of personal data.

To exercise your rights mentioned above, you can fill out the application form on our website and deliver it in person with the necessary information identifying your identity and supporting documents, send it via a notary public or other methods determined by the Personal Data Protection Board to “Başakşehir Mah. Cahit Zarifoğlu Cad. Olimpa Rezidans No:8 Kat:1 Başakşehir – İstanbul”, or forward it to fuzulgayrimenkul@hs01.kep.tr with a secure electronic signature.

KVKK REQUEST FORM

GENERAL EXPLANATIONS

Personal data owners defined as data subjects (hereinafter referred to as the "Applicant") in the Personal Data Protection Law No. 6698 ("KVK Law") have been granted the right to make certain requests regarding the processing of their personal data in Article 11 of the KVK Law.

Pursuant to Article 13/I of the KVKK Law, applications regarding these rights to our Company, which is the data controller, must be submitted to us in writing or by other methods determined by the Personal Data Protection Board (“Board”).

It is important that the personal data we hold about you is accurate and up-to-date. Therefore, please notify us when there is a change in your personal data. In accordance with the KVK Law and relevant legislation, regarding yourself;

• You can learn whether personal data is processed,
• You can request details regarding the information we collect,
• You can learn for what purpose this information was collected and how it is used, and the third parties to whom personal data is transferred at home or abroad, or
• In case it is incomplete or incorrectly processed, you can request them to be corrected, updated, or deleted if the reasons requiring their processing have disappeared, including the notifications to be made to the third parties to whom the transfer was made.

In this framework, applications to be made to our Company in "writing" can be delivered to us by taking a printout of this form and writing "Personal Data Protection Law Information Request" on the envelope or on the subject line:

• By the applicant's personal application,
• Via notary public or registered mail,
• By sending it to our Company's registered electronic mail (KEP) address.

Contact:

FUZUL GAYRİMENKUL YATIRIM A.Ş.

• Address: Akşemsettin Mahallesi Adnan Menderes Bulvarı (Vatan Caddesi) No:28/A Fatih/İstanbul
• Phone: 444 63 13 | Mail address: kvkk@FuzulHolding.com | KEP address: fuzulgayrimenkul@hs01.kep.tr

Data Subject Application Form

1. Data Subject Information

Please fill out the fields below so that we can contact you and verify your identity.

2. Your Relationship with Our Institution

3. Subject of Request

4. Choose the Method of Notification of the Response to You

In line with the requests I have stated above, I request that my application to your Institution be evaluated in accordance with Article 13 of the Law and that I be informed.

I declare and undertake that the information and documents I have provided to you in this application are accurate and up-to-date, that your Institution may request additional information in order to finalize my application, and that I have been informed that I may need to pay the fee determined by the Personal Data Protection Board if it requires an additional cost.

Applicant Data Subject

• Name Surname:
• Application Date:
• Signature:

IMPORTANT NOTE: Applications must belong to the person himself/herself. Applications cannot be made on behalf of spouses, relatives, children, etc. FUZUL GAYRİMENKUL YATIRIM A.Ş. may request additional verification information from the applicant if there is any doubt regarding identity. In the event that the information regarding your requests submitted within the scope of the form is incorrect, outdated, or if an unauthorized application is made, our Company does not accept any liability for requests arising from such incorrect information or unauthorized application.

7. GENERAL DISCLAIMER TEXT FOR EMAIL FOOTER

This e-mail and its attachments are private and confidential to the person/persons specified to be sent in the e-mail; it may contain personal data within the scope of the Personal Data Protection Law No. 6698 and the European Union General Data Protection Regulation (“GDPR”) dated May 25, 2018. It is a necessity in accordance with the aforementioned regulations to use this e-mail and its attachments proportionally with the purpose of sending it to you. Confidential Information and Personal Data contained in the e-mail should not be used outside the purpose of sending, should not be reproduced, archived, or transferred to third parties without the consent of the relevant person and our company. Confidential Information and Personal Data must be destroyed when the purposes of sending are fulfilled. The responsibility for ensuring the security of Confidential Information and Personal Data belongs to you, and our company has no liability in case of any violation. If this e-mail has reached you although you are not the addressee of it, please contact the sender of this e-mail immediately without copying the content of this e-mail or disclosing it to other persons.