In order to carry out transactions before ED CAPITAL PORTFOLIO MANAGEMENT INC. (“ED Capital Portfolio”), we process your personal data specified below. Within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data (“KVKK”) and relevant legislation, we would like to inform you about the use and protection of your personal data and your rights in this regard.
Data Controller: ED CAPITAL PORTFOLIO MANAGEMENT INC. (“ED Capital Portfolio”)
This Disclosure Notice aims to inform you on the following matters:
• Which of your personal data are collected,
• For what purposes your personal data are used,
• With whom your personal data are shared,
• Whether your personal data are transferred abroad,
• How your personal data are protected,
• Whether ED Capital Portfolio uses automated decision-making methods regarding your personal data,
• Your rights regarding your personal data.
• Processed Personal Data, Processing Purposes and Legal Grounds for Processing
(a) Processing Based on Legal Compliance Grounds
Your personal data specified below are processed based on the legal grounds set out in Article 5/2 of the KVKK.
ED Capital Portfolio processes your personal data listed in the table below for the specified purposes, through the specified departments and limited to the specified retention periods. Your personal data will be processed primarily in accordance with capital markets regulations and legislation, the Banking Law, the Law on the Prevention of Laundering of Proceeds of Crime, the Law on the Prevention of the Financing of Terrorism, the Turkish Code of Obligations and the Income Tax Law, within the scope of compliance with applicable legislation and the service agreement, pursuant to KVKK Article 5/2 (a) for fulfilling legal obligations, Article 5/2 (c) for the necessity of establishing and performing a contract, Article 5/2 (ç) for fulfilling ED Capital Portfolio’s legal obligations, and Article 5/2 (e) for the necessity of establishing, exercising or protecting a right. Accordingly, the processing of such data is not subject to your explicit consent. We inform you that you do not have the right to request the deletion of your personal data until the end of the retention periods required by law and business necessity.
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Veri İşleyen |
Kişisel Veri |
İşleme Amacı |
Saklama Süresi |
|
Accounting and Operations Department |
Personal information of real persons contained in documents related to legal entities, such as identity information on national ID cards, passports or identity cards (e.g., name, surname, Turkish ID number), tax certificates, trade registry gazettes, authorization documents, qualification certificates, signature circulars, and activity certificates. |
For the purpose of fulfilling legal obligations within the scope of the service relationship and in compliance with legislation, primarily including Capital Markets regulations and related laws. |
It is retained until the end of the 10 (ten)-year retention period starting from the date the service relationship ends. |
|
Accounting and Operations Department |
Address information, email address, phone number, income information, profession, employment details (employer name, title, duration of employment), information on investment products and activities, work information, education, communication records including phone calls and email correspondence, and your signature. |
Limited to the purpose of the service agreement (e.g., performance of the contract, fulfillment of requests, execution of deliveries and payments, etc.), for ensuring communication, supporting group companies in carrying out corporate and partnership law transactions, safeguarding the legal and commercial security of the Company and individuals engaged in business relations with the Company, and in compliance with legislation, primarily including Capital Markets regulations and related laws. |
It is retained until the end of the 10 (ten)-year retention period from the date the service relationship ends. |
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Accounting and Operations Department |
Bank account number, and, if you are a qualified investor, your bank account balance. |
Limited to the purpose of the service agreement, for executing payments and verifying the balances of qualified investors, and in compliance with legislation, primarily including Capital Markets regulations and related laws. | It is retained until the end of the 10 (ten)-year retention period starting from the date the service relationship ends. |
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- Açık Rızaya Dayalı İşleme
Aşağıdaki verileriniz açık onayınız olduğu sürece ürün ve hizmetlerin geliştirilebilmesi, yatırımcı memnuniyeti ve ihtiyaçları doğrultusunda yeni ürün ve hizmetlerin sunulabilmesi için sizlerle ticari iletişim kurmak amacıyla işlenmektedir.
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Veri İşleyen |
Kişisel Veri |
İşleme Amacı |
Saklama Süresi |
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Accounting and Operations Department and/or Sales and Marketing Department |
Name, surname, email address, phone number, address information, information on investment products and activities, qualified investor information, and communication records including phone calls and email correspondence. |
For the purpose of conducting commercial activities, in order to improve the services provided, offer new services in line with investor satisfaction and needs, and for marketing purposes, as well as for the determination and implementation of the Company's commercial and business strategies. |
It is retained until the end of the 10 (ten)-year retention period from the date the service relationship ends. |
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Accounting and Operations Department and/or Sales and Marketing Department |
Video and audio (biometric) recordings of meetings conducted via Zoom. |
Retention of meeting recordings and use in case of disputes. |
It is retained until the end of the 10 (ten)-year retention period starting from the date the service relationship ends. |
Personal data other than Zoom meeting recordings are processed based on your explicit consent pursuant to Article 5/1 of the KVKK. The recording of meetings held via Zoom is based on your explicit consent pursuant to Article 6/2 of the KVKK.
In Zoom meetings, participants are asked whether they allow recording at the moment the meeting recording starts. Participation in the meeting takes place only if the participants give consent to the recording. Meeting recordings are protected by Zoom with Advanced Encryption Standard 256 (AES-256). The meeting recordings are stored in ED Capital Portfolio’s computer systems and are not transferred to the cloud.
You have the right to withdraw your consent, which is the legal basis for the processing of your personal data, at any time and without providing any justification, regarding the processing of your personal data by ED Capital Portfolio and/or its suppliers for these purposes. Following the notification of your declaration of withdrawal of consent to ED Capital Portfolio, ED Capital Portfolio and/or its suppliers will immediately cease processing your data for these purposes.
Withdrawal of your consent will not affect the lawfulness of the processing carried out based on your consent prior to such withdrawal. ED Capital Portfolio will continue to retain the information obtained prior to the withdrawal of consent as long as permitted or required by applicable laws.
Method of Collection of Personal Data
The personal data listed herein are collected directly from the data subject through the relevant department specified in the “Data Processor” column in the tables, via e-mail, forms, websites, business cards, telephone, and contracts and their annexes. Personal data are stored on servers located in Türkiye belonging to third parties from whom ED Capital Portfolio receives services.
Automated decision-making systems are not used.
Retention Period
Your personal data will be retained for the period specified under the heading “Retention Period” in the table above. Pursuant to Article 7 of the KVKK, your personal data will be deleted, destroyed, or anonymized at the first disposal period following the expiration of this period.
Transfer or Disclosure to Third Parties
ED Capital Portfolio may, without requiring your consent, transfer or disclose your personal data specified above in cases where it is necessary to comply with legal obligations and/or to fulfill its responsibilities under the service agreement and/or to perform its legal obligations, limited to the service received for the fulfillment of obligations and proportionate to this purpose, to:
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Relevant units within ED Capital Portfolio, banks, audit firms, lawyers, law offices, certified public accountants, suppliers, and other third parties as required by the nature of the work and/or from whom services are obtained;
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Public institutions and organizations, including but not limited to law enforcement units, the Capital Markets Board, and the Financial Crimes Investigation Board, relevant ministries and directorates, and public institutions and legal entities, including the Social Security Institution, assigned pursuant to labor and social security legislation, as well as other public institutions authorized by law.
The transfer of data within Türkiye shall be limited to cases where it is required by law pursuant to Article 8/2(a) of the KVKK, namely pursuant to Article 5/2 (a) due to legal obligation, (c) due to the necessity for the establishment and/or performance of a contract, (ç) due to the fulfillment of a legal obligation, and (e) due to the necessity of establishing, exercising, or protecting a right.
In addition, ED Capital Portfolio may share your name, surname, e-mail address, telephone number, and address information with its suppliers within the scope of the KVKK, provided that you have given your explicit consent, for the purposes of sending commercial communications to you and carrying out activities related to the processing of personal data for commercial purposes. This transfer is based on your explicit consent pursuant to Article 8/1 of the KVKK.
Information regarding third parties and/or categories of third parties to whom your data are disclosed in Türkiye is always open to your information and review.
Transfer of Personal Data Abroad
ED Capital Portfolio does not transfer your personal data abroad.
Your Rights
As a data subject, pursuant to the applicable legislation, you have the right to:
(a) request information as to whether your personal data are processed and how they are processed (Art. 11/(a), (b));
(b) learn the purpose of processing and whether they are used in accordance with this purpose (Art. 11/(c));
(c) know the third parties to whom personal data are transferred (Art. 11/(ç));
(d) request correction of your personal data (Art. 11/(d));
(e) request the deletion of your personal data in the event that the reasons requiring processing cease to exist (Art. 7, Art. 11/(e));
(f) request notification of correction and deletion operations to third parties to whom your personal data have been transferred (Art. 11/(f));
(g) object to the results obtained as a result of analysis of your personal data (Art. 11/(g));
(h) request restriction of processing (Art. 7);
(i) request compensation for damages in case you suffer damage due to unlawful processing of your personal data (Art. 11/(ğ)).
The above-mentioned rights are limited by law and may only be provided by us under certain conditions. (Please review Articles 10 and 13 of the KVKK in particular.)
You may submit your requests listed above to musteri.iletisim@edcapital.com.tr. ED Capital Portfolio will conclude your request as soon as possible and no later than 30 (thirty) days following receipt of the relevant documents.
Data Controller: ED CAPITAL PORTFOLIO MANAGEMENT INC.
MERSIS No: 0324116395100001
Address: İşçi Blokları Mah. Muhsin Yazıcıoğlu Cad. No: 61/223, Çankaya / Ankara
E-mail: musteri.iletisim@edcapital.com.tr
Upon your request, ED Capital Portfolio may always update your personal data and this disclosure notice. You may access the current disclosure notice at www.edcapital.com.tr.
Right to Lodge a Complaint with the Personal Data Protection Board
To exercise your right to lodge a complaint (KVKK Articles 13, 14, 15):
Authority: Personal Data Protection Board
Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4, 06520 Balgat-Çankaya / Ankara
Telephone: +90 312 216 5000
Website: http://www.kvkk.gov.tr/