Information About The Law On The Protection Of Data

As Ak Yatırım Menkul Değerler A.Ş. ("Ak Yatırım"), we are taking the necessary measures in the capacity of data controller for the storage, processing and transfer of your personal data according to the legislation and in conformity with the Law No. 6698 on the Protection of Personal Data ("KVKK") and the principle of right to privacy and protection of fundamental rights and liberties of individuals. We would like to inform you about these issues.

COLLECTION OF PERSONAL DATA

As Ak Yatırım and with the capacity of data controller, we are collecting the personal data of our customers / prospective customers / third persons from themselves and/or their officials (e.g., proxies, representatives, guardians) in all kinds of written, verbal and visual formats and automated and non-automated electronic and physical methods through our own channels (Headquarters, Akbank and Ak Yatırım Branches, Website, Internet Branch, Social Media channels, Mobile Phone) and Akbank T.A.Ş. (“Akbank”) of which we are their subsidiary’s that operates tranmissions of orders and via organizations and institutions which we acquire support services from or which we are business partners with. We are processing, storing and securing your personal data collected by our Company as per the principles stipulated in Article 4 of the KVKK in a measurable and constrained manner and in accordance with the below purposes and reasons for compliance with laws for such purposes.

PROCESSING PURPOSES AND REASONS FOR COMPLIANCE WITH THE LAWS

For the purposes of fulfilling our obligations and responsibilities as Ak Yatırım through all channels, including electronic channels, in relation to the investment services and operations and peripheral services that we execute, providing analysis, reports, listings which regards the public requests within the framework of the Law No. 6362 on Capital Markets ("SPKn") and relevant regulations, we are processing the personal data that are required to provide the best services and products that we aim to offer as well as such information that we are obligated to collect from our customers and our customers' officials as per the legal reasons stated below.

Thus, by our Company;

In case it is obligated or explicitly stipulated in the law that your personal data is to be processed for the purposes fulfilling our legal obligations and/or legitimate interests:

• Determination and verification of your identity and address information,
• Verification of customer information and ensuring the currency of the same,
• Carrying out risk analysis,
• Execution of the risk management and data security processes,
• Execution of the Internal Audit / Investigation / Intelligence operations,
• Carrying out the analysis and reporting works that need to be carried out, and performing examinations,
• Execution and audit of business activities,
• Execution of storage and archiving activities,
• Execution of finance and accounting works,
• Storing, reporting and meeting the information and document needs for the data requested by the organizations that we are obligated to inform such as the Capital Markets Board (SPK), Turkish Capital Markets Association (TSPB), Borsa Istanbul A.Ş. (BIST), Istanbul Takas ve Saklama Bankası A.Ş. (Takasbank) and Merkezi Kayıt Kuruluşu A.Ş. (MKK), Banking Regulation and Supervision Agency (BDDK), Republic of Turkey Central Bank (TCMB), Ministry of Commerce, Financial Crimes Investigation Board (MASAK), Turkish Revenue Administration (GIB), the Union of Chambers and Commodity Exchanges of Turkey (TOBB), the Banks Association of Turkey (TBB) Risk Center and others,
• For the purposes of performing all activities according to the legislation,

In case it is directly related to the establishment or performance of an agreement between our Company and you, and in case it is mandatory for us to fulfill our legal obligations:

• Performance of our obligations and responsibilities in relation to the investment services and operations and peripheral services that we execute within the framework our Company's area of activity, and execution of our agreement processes,
• Execution of the advertisement, campaign and promotion processes regarding the products and services of our Company, and communicating with you regarding the same purposes,
• Sale of and informing about products/services, and carrying out marketing activities,
• Carrying out works in relation to customer satisfaction, and sharing the offers regarding the services,
• Performance of customer relationship management processes,
• Performance of product and service purchase processes and support services regarding the same,
• Increasing the quality of products and services,
• For the purposes of executing the investment processes,

In case it is mandatory to the process data for the legitimate interests of the data controller, provided that the same does not harm the fundamental rights and liberties:

• The necessity to share with the parent company and joint ventures certain information that have been acquired within the scope of the investment services and operations and peripheral services that we execute within the framework of the SPKn and relevant regulations,
• Being able to carry out improvements regarding the needs of the customers and the industry,
• Execution of the other analysis and reporting works and performance of examinations that are deemed to be necessary within the scope of the investment services and operations and peripheral services,
• Execution of strategic planning activities,
• Execution of social responsibility and civil society activities,
• For the purposes of taking suggestions regarding the improvement of business processes, and evaluating the same,

In case processing data is mandatory for establishing, using or protecting a right:

• Monitoring of legal affairs,
• For the purposes of tracking requests and complaints

If there is express consent:

• Provision of the personalized investment services and operations and peripheral services that are provided by our Company, carrying out the marketing analyses and modelling for the same, and contacting you within the same scope,
• Sharing the personal offers regarding our products and services,
• Carrying out activities regarding the cross-sale of the products and services,
• Carrying out customer acquisition works,
• Carrying out the necessary analysis and modelling works and examinations that are deemed to be necessary within the scope of our Company's activities,
• In relation to the purpose of carrying out activities regarding the customer satisfaction.

TRANSFER OF THE PROCESSED DATA

For the purposes of conducting investment services and operations and peripheral services and as per our obligations regarding the provisions of the SPKn and the legislation that we are subject to, your data is transferred in a measurable and constrained manner in relation to the abovementioned processing purposes to the authorized organizations and institutions (e.g., SPK, BDDK, TCMB, Ministry of Commerce, MASAK, BIST, Takasbank, MKK, TOBB, TBB), to our domestic and/or foreign shareholders, to our business partners (e.g., program partner institutions, banks, financial institutions), to domestic and foreign third parties that we receive external services from, especially Akbank which provides brokerage services in transferring orders, to independent audit companies, including but not limited to real and legal entities to which transferring data is mandatory within the scope of reasons for compliance with the law.

RIGHTS OF THE RELEVANT PERSON WHOSE DATA HAS BEEN PROCESSEDI

As per the provisions of the KVKK, you may exercise your following rights by applying to our Company:

• Learning whether your personal data is processed,
• If the personal data is processed, requesting information regarding the same,
• Learning the purpose of processing the personal data and whether such processing is used according to the relevant purposes,
• Knowing the domestic or overseas third persons to which the personal data is transferred,
• If the personal data is processed insufficiently or erroneously, requesting the correction of the same,
• Requesting the deletion or destruction of the personal data,
• In case the personal data is corrected, deleted or destroyed, requesting the conveyance of such operations to the third persons to which the personal data has been transferred,
• Objecting to an outcome that is to the detriment of the person due to the analysis of the processed personal data exclusively via automated systems,
• If the person suffers damages due to the wrongful processing of the personal data, requesting the indemnification of such damages.

The request conveyed within such scope shall be finalized without any charges and within 30 days at the latest by Ak Yatırım. However, if the Law on the Protection of Personal Data stipulates any fees, our Company shall collect such fee under the established schedule. The customer may need to complete certain identity verification requests by our Company in order to finalize the application.

IF YOU WOULD LIKE TO CONTACT US FOR YOUR REQUESTS

If you would like to contact us, provide feedback or ask questions within the scope of the KVKK, with the documents that authenticate your identity and by filling out the Data Subject Request Form under the Law on the Protection of Personal Data:

• You can sign the form during your application and apply in person to the Ak Yatırım Headquarters, Ak Yatırım Branches or Akbank Branches with documents that authenticate your identity (identity card, driver's license, etc.), or
• You can send the form with documents that authenticate your identity (identity card, driver's license, etc.) through a notary public to the address of Ak Yatırım Menkul Değerler A.Ş. Sabancı Center 4. Levent, 34330 ISTANBUL, or
• You can submit the form with documents that authenticate your identity (identity card, driver's license, etc.) to akyatirim@hs03.kep.tr via the Registered Electronic Mail (KEP) of the data subject.

Within this scope, we would like to remind you that your written applications regarding the above matters shall be accepted after the identity verification is carried out by us.

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