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.

Information about Commercial Communication Permit

As per the Law no. 6563 on Electronic Commerce Regulation and the Law no. 6698 on Personal Data Protection, this permit means that you allow your personal data to be stored, used and transferred to contracted service providers so as to ensure that we may be able to inform you about various products and services, offer and provide various advantages regarding these products and services, and contact via short message service (SMS), multimedia message (MMS), electronic mail, mail, telephone, call centre, automatic call, Whatsapp and similar other methods in order to convey special promotions, advertisements, sales, marketing, questionnaires and similar other electronic communication. This information will only be shared with contracted third parties who ensure the same data security sensitivity with us and comply with legal regulations and in order to offer flawless services, deliver your packages and send timely notifications through telephone, SMS and/or e-mail.

Mersis No: 0-7710-3054-3200013
Tel No:2123102700
Address: Dikilitas mah. Yenidogan sok. No:36
34349 Besiktas, Istanbul, Turkey

You can text KIZILBUK and send it to 3172 as a free-of-charge SMS, send an e-mail to info@sinpas.com.tr or call 4441974

“We wish to have you as a member of the Big Sinpas Family addressing value to your life, offer new projects and convey the opportunities and campaigns tailored for you. Therefore, we undertake to use your personal data only for marketing and communication purpose of Sinpas Holding and the group companies and to protect as per the Law no. 6698 on Personal Data Protection. As long as we continue our commercial activities as Sinpas Holding, we may store your personal data under such law at secure data centres in Turkey or abroad and share personal data with business partners who signed or will sign confidentiality agreement with the company. If you decide to change your data sharing preferences, you can contact a data expert and cancel your membership by sending an e-mail to info@sinpas.com.tr or dialling 4441974.

SINPAS GYO
CLARIFICATION TEXT ON PERSONAL DATA PROTECTION


This Clarification Text has been issued as regards to the processing and transfer of the “Personal Data” of natural persons who are covered by the Law no. 6698 on Personal Data Protection (“PDP Law”). As per the Law no. 6698, any and all updated information which you share with the company will be called “Personal Data”.

The security of your personal data is of great importance for us. Therefore, your personal data will be stored according to legal conditions with the highest possible level of security, in compliance with the prescriptions of the regulations and as long as necessary due to legal liabilities.


a) Data Controller and Representative
As per the Law no. 6698 on Personal Data Protection (“the PDP Law”), your personal data may be processed by Sinpas Gayrimenkul Yatirim Ortakligi A.S. (Shortly “Sinpas GYO”) as the “Data Controller” according to the following conditions.

b) The Purpose of Personal Data Processing
Your personal data may be processed according to the personal data processing conditions specified under articles 5 and 6 of the Law no. 6698 in order to ensure the performance of liabilities by the company or real and legal contracted partners, make notifications as regards to updates, sign and perform the contracts with you and remind the liabilities thereunder, engage in various advertisement and marketing activities, monitor and carry out financial, accounting and legal procedures, monitor requests and complaints, monitor contractual processes and/or legal requests, plan customer satisfaction activities and receive feedback with surveys and votes, determine the products, projects and services tailored for you, customize and develop these according to your preferences, offer an efficient customer service, provide information as regards to relevant amendments in regulations and in-house policies and convey other relevant amendments, celebrate your birthday, include you in draws or contests, give presents, carry out other activities, promotions and campaigns to your benefit, keep you updated via electronic mail, SMS or fax, inform you about campaigns, send printed bulletins, periodicals and campaigns, determine visitor profiles, evaluate request and complaints, perform the human resources policies of the company and reply to your requests and questions.


c) Personal Data Transferees and the Purpose of Transfer
Your personal data are processed according to legal and good faith rules, for updated, definite, explicit and legitimate purposes and as long as processing is relevant, limited, legally permitted and necessary. Furthermore, your personal data may be shared with direct and/or indirect subsidiaries and affiliates in Turkey and/or abroad; national and/or international public and/or private persons, companies and/or third parties who provide service, support and/or consultancy to the company and/or are collaborated and/or partnered by the company as regards to projects, programs and/or finance; the company’s affiliates, advisors, shareholders, solution partners and/or other group companies; Central Registry Agency of Turkey and other authorized bodies; and suppliers and subcontractors according to articles 8 and 9 of the Law no. 6698 provided that the company takes necessary measures for personal data security and that personal data transfer is limited to the conditions specified under paragraph (b). SINPAS GYO may store and process your personal data using servers and other electronic media abroad provided that sufficient level of data security is ensured by SINPAS GYO in Turkey and transferee countries or that, if the transferee country cannot provide sufficient level of security, SINPAS GYO and the data controllers in a relevant foreign country undertake to provide the sufficient level of data security in written and that the Board grants a permit thereto.

d)The Methods and Legal Grounds for Personal Data Collection
Your personal data may be collected by the company in written or audio or video recording or other physical or electronic methods using various channels (such as SINPAS GYO head office, branches, agencies, sales offices, call centres, websites, mobile applications, other electronic platforms, social media and other public platforms, trainings, conferences and similar other events, questionnaires, other group companies or their contracted business partners or other offices and physical spaces where you can contact sub-contractors and business partners). Your personal data can be collected, processed, transferred and stored according to the paragraphs (b) and (c) and in conformance with the personal data processing purposes and conditions specified under articles 5 and 6 of the PDP Law.

Your personal data are stored as long as necessary due to legal liabilities or for a certain period of time prescribed by the relevant regulation.

e) The Rights of Personal Data Owners
As personal data owners, you can submit your requests concerning your rights to the company by one of the following methods. In this case, the company will reply to your request free-of-charge and as soon as possible or within thirty days at the latest. However, the company may apply a charge according to a predefined tariff if the Personal Data Protection Board deems it necessary. In this sense, personal data owners may apply to;

  • Learn whether their personal data are processed,
  • Request information about the procedure if personal data are processed,
  • Learn the purpose of personal data processing and whether processing is carried out according to such purposes,
  • Learn the national and international third party transferees,
  • Request correction if personal data are incompletely or inaccurately processed and request third party transferees to be informed about the procedure carried out thereto,
  • Request the deletion or removal of personal data when the legal ground for processing does not apply anymore and request transferee third parties to be informed about the procedure carried out thereto even though personal data may be processed in compliance with the PDP Law and the provisions of other relevant laws,
  • Request the deletion or removal of personal data when the legal ground for processing does not apply anymore and request transferee third parties to be informed about the procedure carried out thereto even though personal data may be processed in compliance with the PDP Law and the provisions of other relevant laws,
  • Raise an objection in case a condition arises to the detriment of a relevant person due to the analysis of processed data only by automatic systems, and Request indemnity in case damage is incurred due to illegal processing of personal data.

As per paragraph 1, article 13 of the PDP Law, you can submit your application in written so as to execute the foregoing rights. In case you wish to execute your rights specified under article 11 of the PDP Law, you can fill in the form at www.sinpasgyo.com.tr or deliver by hand or through a notary office an originally signed copy of it together with your ID information to “Dikilitas Mah. Yenidogan Sok. Sinpas Plaza No:36 Dikilitas-Besiktas/Istanbul, Turkey”.

The company reserves the right to amend this clarification text due to the possible amendments to the PDP Law and the procedures to be determined by the Personal Data Protection Board.