Protection Of Personal Data

SİNPAŞ GYO
CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA

This Information and Clarification Form is produced in relation to the processing and transferring of the Personal Data of natural persons stipulated by the Personal Data Protection Law no 6698 ("PDP Law"). Pursuant to the Law no 6698, your any current personal information you have shared with our company shall be considered "Personal Data". The safety of your personal data is of greatest concern for us, and your personal data shall be retained in accordance with the conditions provided by the legislation and in the safest manner possible and for a period required by legal obligations. 

a) Data Controller and Its Representative  

In accordance with the Personal Data Protection Law No 6698 ("PDP Law"), your personal data may be processed by Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş. (in short Sinpaş GYO), in the capacity of "Data Controller" under the following provisions.  

b) The Purposes of Processing your Personal Data i 

Your personal data may be processed under the conditions and for purposes of personal data processing as stipulated in Articles 5 and 6 of the Law No 6698, to perform of the obligations of our company and of the natural and legal persons having a business relationship with our company, to be able to inform the updates, to establish and execute the contracts to be entered into with you, to remind and fulfill any legal obligations, to engage in various advertising and marketing activities, to carry out and follow up financial, accounting and legal affairs, to follow-up your requests and complaints - to follow up contractual process and/or legal request, to obtain your opinion through survey and voting within the scope of planning and execution of the customer satisfaction activities, to identify suitable products, projects and services for you, to customize and develop them for you, to provide effective customer service, to notify the changes in legislation and company policies that concern you or to make other related notifications, to celebrate birthdays, to invite to lotteries and competitions, to give gifts and to carry out other similar activities, promotions and campaigns in your favor, to inform you by electronic mail, SMS and fax, to notify you about campaigns, to send you printed bulletins, magazines and campaign letters, to define our visitor profiles, to evaluate the requests, demands and complaints, to conduct the human resources policies of our company and to respond to your requests and questions. 

c) To Whom and For What Purpose the Processed Personal Data Can Be Transferred  

Your collected personal data shall be processed in accordance with the law and good faith, proper, updated if necessary, defined, clear and legitimate purposes, retained for a limited and constrained period of time linked to the purpose for which they are processed, limited and proportionate and as stipulated in the relevant legislation or as required for the purpose of processing. Furthermore, the personal data may be shared with our direct/indirect local/foreign affiliates or subsidiaries, local/foreign/international public/private institutions and organizations, companies and other 3rd parties from whom our company receives services/support/consulting services or is in cooperation with or project/program/financing partnership, our company's subsidiaries, consultants, shareholders or other group companies as solution partners, Central Registry Agency and other authorized institutions and organizations, suppliers and subcontractors provided however that the conditions set forth in Articles 8 and 9 of the PDP Law are observed, and the necessary security measures are adopted and limited to the purposes listed under Article (b) of this clarification text and in accordance with the terms and purposes of personal data processing set forth in Articles 8 and 9 of Law No. 6698. SİNPAŞ GYO may process and store your personal data on the servers located abroad or other electronic environments, provided that it adopts required security measures, that sufficient level of protection is ensured in Turkey or in the foreign country to which personal data shall be transferred if no adequate level of protection is ensured in the relevant foreign country, then on the condition that Sinpaş GYO and the data controllers in the relevant foreign country undertakes to provide adequate level of protection in writing, and with the permission of the Board. 

ç) The Methods and the Legal Grounds for Collecting of Your Personal Data  

Personal data may be collected by our Company through various channels (with your participation in trainings, conferences and similar settings to be held by SİNPAŞ GYO through its headquarters, branches, agencies, sales offices or other subcontractors or business partners and the offices and other physical settings, call centers, websites, mobile applications and similar platforms of electronic operation, social media and other public channels from where you can be contacted, as well as by means of investigation method, through other group companies or other persons and entities with whom they are contracted, in written and oral or audio or video recording or in other physical or electronic settings, etc.). Your personal data may be collected, processed, transferred and retained for the purposes set out in Articles (b) and (c) herein within the data processing conditions and purposes set forth in Articles 5 and 6 of the PDP Law. Your personal data are retained for a period of time as required by legal obligations or as permitted by legislation and under the conditions to the extent permitted by legislation.  

d) Your Rights as a Personal Data Subject

If you, as a Personal Data Subject, forward your claims as to your rights to our Company pursuant to the below-described method, our Company shall bring your claim to a conclusion at no charge as soon as possible, depending on the nature of your claim but no later than thirty days. However, if any fee is stipulated by the Personal Data Protection Council, a fee in the tariff determined by our Company shall be charged. In this context, personal data subjects shall have the right to; 

• Learn whether or not her personal data has been processed,

• Request related information if the personal data has been processed,

• Know the purpose of processing the personal data and whether the data has been used for the intended purpose,

• Know the third parties to whom his personal data is transferred at home or abroad,

• Request the correction of any incomplete or incorrect processing of the personal data and request that third parties to whom your personal data were transferred be notified of such action,

• Even if your personal data are processed in compliance with the PDP Law and provisions of the other applicable laws, if the reasons requiring data processing are no longer valid, to request erasure or destruction of your personal data, and, accordingly, to request that the third parties to whom your personal data were transferred, be notified of such action,

• Even if your personal data are processed in compliance with the PDP Law and provisions of the other applicable laws, if the reasons requiring data processing are no longer valid, to request erasure or destruction of your personal data, and, accordingly, to request that the third parties to whom your personal data were transferred, be notified of such action,

• Object to the occurrence of any result that is to the detriment of the person concerned by means of the analysis of personal data exclusively through automated systems,

• Request compensation for the damage arising from the illegal processing of his personal data.

In accordance with Paragraph 1 of Article 13 of the PDP Law, you may submit your request in writing to our Company to exercise your rights listed above. You may present your request including a description of the rights you hereby wish to enjoy, which are set out in Article 11 of the PDP Law, by  

filling in the form, you can find at www.sinpas.com.tr, accompanying with the wet signed copy of the form and the documents proving your identity, in person or send it through notary public to “Dikilitaş Mah. Yenidoğan Sok. Sinpaş Plaza No:36 Dikilitaş-Beşiktaş/İSTANBUL” addressed to SİNPAŞ GYO Customer Relations Department.

Our Company reserves its right to make any amendments in this clarification text due to any possible amendments to the PDP Law and the methods to be defined by the Personal Data Protection Council.