Personal Data Protection Disclosure Notice
1) Introduction
The purpose of this disclosure text regarding the protection and processing of personal data is to fulfill the obligation to inform under Article 10 of the Personal Data Protection Law No. 6698 (KVKK) and to transparently inform users regarding the use of personal data obtained through the contact forms filled out by users during the use of the website and mobile application (V Info) managed by İSRA Gayrimenkul ve Girişim Sermayesi Portföy Yönetimi Anonim Şirketi (“İSRA”), acting as the data controller.
2) Information on the Data Controller
İSRA Gayrimenkul ve Girişim Sermayesi Portföy Yönetimi Anonim Şirketi
• Address: Oruçreis Mah. Tekstilkent Cad. B Blok No:12/A 341-342 Esenler / İstanbul
• Tax Office:: Atışalanı Vergi Dairesi
• Tax Identification No: 4811358663
• Trade Registry No: 460135-5
• MERSİS No: 0481 1358 6630 0001
• Website: www.israportfoy.com.tr
• Contact Channel: info@israportfoy.com.tr
3) Personal Data Processed
Your personal data that may be subject to processing are as follows:
Identity Information: name and surname, Turkish Republic identity number, tax identification number, identity type, identity serial number, mother’s and father’s name, date of birth, place of birth, age, nationality, passport number, identity document, signature
Contact Information: address, phone number, e-mail address, fax number, business address, certificate of residence
Customer Information: customer number, account information, tax certificate, certificate of activity, trade registry gazette, document showing tax residency status (if the investor is a taxpayer abroad), account balance information, money transfer information, customer title, address, trade registry number, tax certificate, IBAN information
Financial Information: account number, financial status, credit debt and mortgage information, if any
Visual and Audio Records: photograph
Professional Experience: educational background, occupation, commercial activity, experience
Company Information: company title, tax identification number, financial information of the company
4) Purposes of Processing
These personal data are processed for the following purposes within the framework of the principles stipulated by the KVKK:
Purposes That Do Not Require Explicit Consent;
- Establishment and Performance of Contracts,
- Conducting Activities in Compliance with Legislation,
- Conducting Investment Processes,
- Conducting Finance and Accounting Transactions,
- Conducting Storage and Archiving Activities,
- Conducting Internal Audit, Investigation, and Intelligence Activities,
Purposes Based on Explicit Consent;
- Conducting Communication Activities,
- Managing Customer Relationship Management Processes,
- Conducting Advertising, Campaign, and Promotion Processes,
- Conducting Marketing Processes for Products and Services,
- Conducting Marketing Analysis Activities,
- Conducting Marketing Processes for Products / Services,
- Conducting Advertising / Campaign / Promotion Processes,
- Conducting Sales Processes for Goods / Services,
- Conducting Production and Operation Processes for Goods / Services,
- Conducting Customer Relationship Management Processes,
İSRA takes all necessary technical and administrative measures to ensure that personal data are collected, stored, and shared in compliance with the law and to protect their confidentiality.
5) Legal Grounds for Collection and Processing of Personal Data
Your personal data are collected, by automatic or non-automatic means, verbally, in writing, or electronically through written or digital applications submitted to our Company, the use of our website, telephone calls, e-mail, SMS, social media, and other communication channels.
a) Where it is expressly provided for by law,
b) Where it is necessary to process personal data belonging to the parties of a contract, provided that such processing is directly related to the establishment or performance of the contract,
c) Where it is mandatory for the data controller to fulfill its legal obligation,
ç) Where data processing is mandatory for the establishment, exercise, or protection of a right,
d) Where data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
Personal data processing activities carried out within the scope of marketing, promotion, campaign, and customer relations processes, other than the cases stated above, are conducted solely based on your explicit consent. Your personal data may be shared with relevant institutions or organizations only for the fulfillment of legal obligations or upon the requests of authorized authorities.
6) Transfer of Personal Data
Your collected personal data may be transferred, limited to the processing purposes stated above, to business partners and public institutions and organizations to which there is a legal obligation, within the framework of the personal data processing conditions and purposes specified in Article 8 of the KVKK.
7) Retention and Deletion of Personal Data
Our Company retains the personal data it processes for the periods stipulated by the applicable legislation. Where no specific retention period is prescribed by the legislation, personal data are retained for the period required for the purposes of processing, depending on the services provided by our Company in relation to such data, in accordance with our Company’s practices and the customs of commercial life. After this period, they are retained only for the periods deemed necessary in practice for the purpose of serving as evidence in possible legal disputes.
Following the expiry of the specified periods, such personal data are deleted, destroyed, or anonymized on the first destruction date in accordance with Article 7 of the KVKK.
8) Your Rights as a Data Subject
You may submit the following requests to our Company by applying within the framework of Article 11 of the Personal Data Protection Law:
a) To learn whether personal data are being processed,
b) To request information if personal data have been processed,
c) To learn the purpose of processing personal data and whether they are used in accordance with such purpose,
ç) To know the third parties to whom personal data are transferred domestically or abroad,
d) To request the correction of personal data if they have been processed incompletely or inaccurately,
e) To request the deletion or destruction of personal data within the framework of the conditions set forth in Article 7,
f) To request that the transactions carried out pursuant to subparagraphs (d) and (e) be notified to third parties to whom the personal data have been transferred,
g) To object to the occurrence of a result against the person by means of analyzing the processed data exclusively through automated systems,
h) To request compensation for damages in the event of suffering damage due to the unlawful processing of personal data.
You may exercise your rights stated above in accordance with the KVKK, the provisions of the Communiqué on the Procedures and Principles of Application to the Data Controller published on 10.03.2018, and the relevant current legislation, by using the “KVKK Application Form” available at www.israportfoy.com.tr;
- You may deliver it in person/by hand to Oruçreis Mahallesi, Tekstilkent Caddesi, Koza Plaza B Blok, No:12/A İç Kapı No: 341 Esenler / ISTANBUL, or send it through a notary public,
- You may submit it to info@israportfoy.com.tr with a secure electronic or mobile signature, through your registered electronic mail address, or through the e-mail address registered in our system.
In order for a person other than the data subject to submit a request, there must be a notarized special power of attorney issued by the data subject in favor of the person who will make the application.
Within this scope, your requests submitted to our Company in due form shall be finalized within thirty days at the latest. If the fulfillment of such requests requires an additional cost, our Company shall charge the applicant the fee specified in the tariff determined by the Personal Data Protection Authority (“Authority”). If our Company responds to your application through a recording medium such as a CD or flash drive, a fee not exceeding the cost of the recording medium may be requested.
Our Company may request information from the applicant in order to determine whether the applicant is the personal data subject, and may ask the data subject questions regarding the application in order to clarify the matters stated in the application.
Pursuant to Article 14 of the KVKK, in cases where the application is rejected, the response given is found insufficient, or no response is provided within the prescribed period, the personal data subject may file a complaint with the Authority within thirty days from the date on which they learn of our Company’s response, and in any case within sixty days from the date of application.
Respectfully,