The security and/or protection of your personal data is among the top priorities of Dagi Yatırım Holding Joint Stock Company (“Company/Our Company”). With this awareness, our Company attaches great importance to the processing and safeguarding of all kinds of personal data belonging to all individuals associated with the Company, including those who benefit from our products and services, in accordance with the Law on the Protection of Personal Data No. 6698 (“Law” or “Turkish Data Protection Law – KVKK”).
In this context, acting in the capacity of “Data Controller” as defined in the Law, and in line with Article 10 of the Law and the Communiqué on Principles and Procedures to be Followed in Fulfillment of the Obligation to Inform, published in the Official Gazette dated March 10, 2018 and numbered 30356 (“Communiqué”), this Information Notice is hereby presented to data subjects to fulfill our obligation to inform regarding the identity of our Company, the purposes for which personal data will be processed, to whom and for what purposes processed personal data may be transferred, the method and legal grounds for collecting personal data, as well as the rights of data subjects under Article 11 of the Law.
Unless expressly stated otherwise, the terms “we” and “our” used in this Information Notice refer to Dagi Yatırım Holding A.Ş.
Definition of Personal Data
Under Article 3/I(d) of the Law, “personal data” refers to any information relating to an identified or identifiable natural person. In this context, personal data means any information relating to a specific or identifiable person. Examples include: your name, surname, Turkish ID number, address, telephone number, e-mail address, date of birth, IP number accessed, transaction details, etc.
In addition, according to the Law, data concerning individuals’ race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, association/foundation/trade union membership, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, are considered as special categories of personal data. In line with our Company’s Policy, anonymous information, anonymized data, and other information that cannot be associated with a specific individual are not considered personal data.
Processing of Personal Data
Under Article 3/I(e) of the Law, the processing of personal data means any operation performed on personal data, whether fully or partially by automated means or otherwise, provided that it is part of any data recording system. This includes obtaining, recording, storing, preserving, altering, reorganizing, disclosing, transferring, taking over, making available, classifying, or preventing the use of such data.
Identity of the Data Controller
Pursuant to the Law, the “Data Controller” refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system. Accordingly, the corporate identity information of Dagi Yatırım Holding Joint Stock Company, acting as the Data Controller, is as follows:
Trade Registry No: 317461-0
MERSIS No: 0815006963200011
Tax Office: Şişli Tax Office
Tax Number: 8150069632
Registered Address: Birahane Sok. Koç Plaza No.3, Floor 4/5, Şişli/İstanbul
Telephone: +90 212 346 15 15
Fax: +90 212 346 15 17
Website: www.terafinansalyatirimlar.com
E-mail: info@dagiholding.com
Collection, Processing and Purposes of Processing Personal Data
Your personal data may vary depending on the services, products, or commercial activities provided by our Company and may be collected verbally, in writing, or electronically through automatic or non-automatic means, including but not limited to offices, branches, dealers, call centers, website, social media platforms, and mobile applications.
In accordance with Articles 5.2 and 6.3 of the Law, your personal data may be processed without your explicit consent where necessary to fulfill our legal obligations, for the establishment or performance of a contract, for the exercise or protection of a right, or to protect our legitimate interests provided that it does not harm your fundamental rights and freedoms. Additionally, with your explicit consent, your personal data may also be processed in accordance with Articles 5.1 and 6.2 of the Law for the purposes specified in this Information Notice.
Collected personal data are processed for purposes such as enabling you to benefit from the products and services offered by our Company, customizing these products and services according to your preferences, usage habits, and needs, ensuring the legal and commercial security of our Company and persons in business relations with our Company (administrative operations related to communication, ensuring the physical security and supervision of Company premises, business partner/customer/supplier (authorized personnel or employees) evaluation processes, legal compliance processes, finance, etc.), determining and implementing our Company’s commercial and business strategies, and executing our human resources policies, in compliance with Articles 5 and 6 of the Law and other applicable legislation.
Transfer of Processed Personal Data Domestically and/or Abroad
Your collected personal data may be transferred to legally authorized administrative and official authorities, relevant persons and institutions where required by legislation and legal obligations, independent audit firms, tax advisors, external professional consultants, lawyers, insurance companies, partners, domestic and international third parties from whom services are received or to be received, our shareholders, business partners, suppliers, authorized public institutions, and private persons. Such transfers are carried out within the framework of the personal data processing conditions and purposes set out in Articles 8 and 9 of the Law and other applicable legislation.
Your personal data may be transferred to foreign countries declared by the Board to have adequate protection (“Countries with Adequate Protection”) or, in cases where adequate protection is not provided, to foreign countries where data controllers in Turkey and the relevant foreign country provide a written undertaking for adequate protection and have obtained the Board’s permission (“Countries Where the Data Controller Undertakes Adequate Protection”). Our Company acts and will continue to act in compliance with Article 9 of the Law and other applicable legislation in this regard.
Method and Legal Basis of Collecting Personal Data
Your personal data are obtained through our audit and consultancy services, written/digital applications made to our employees, our website, our telephone lines, social media channels, SMS, and other oral, written, or electronic media, through automated or non-automated methods, and through other channels by which our Company communicates or may communicate with you. These data are collected to carry out our activities and fulfill our contractual and legal obligations with you, and they are retained for the legally required periods in accordance with the relevant legislation.
Rights of the Data Subject under Article 11 of the Law
As data subjects, you may submit your requests regarding your rights to our Company in accordance with the methods set out in this Information Notice. Our Company will conclude such requests free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if a fee is prescribed by the Personal Data Protection Board, the tariff determined by our Company will be charged. Within this scope, data subjects have the following rights under Article 11 of the Law:
To learn whether their personal data are processed,
To request information if their personal data have been processed,
To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
To know the third parties to whom personal data are transferred domestically or abroad,
To request correction if personal data are incomplete or incorrectly processed,
To request the deletion or destruction of personal data under the conditions prescribed in the Law,
To request that third parties to whom personal data are transferred be notified of such corrections, deletions, or destructions,
To object to the occurrence of a result against themselves by analyzing the processed data exclusively through automated systems,
To demand compensation for damages in case of unlawful processing of personal data.
In accordance with Article 13/1 of the Law, you must submit your requests concerning the exercise of the above rights in writing or through other methods determined by the Personal Data Protection Board. Since no other method has yet been determined by the Board, applications must be submitted to our Company in writing under the Law. Within this scope, for applications to be made to our Company under Article 11 of the Law, you may fill in the form available at www.dagiholding.com and deliver a signed copy along with identity-verifying documents by hand to Birahane Sok. Koç Plaza No.3, Floor 4/5, Şişli/İstanbul, or send it via notary or other methods stipulated in the Law.