NOTICE ON PERSONAL DATA PROTECTION

This notice has been prepared on the processing and transfer of the “Personal Data” of natural persons as stated in the Personal Data Protection Law no. 6698 (“PDP Law”). According to the PDP Law, any up-to-date information you share with our company is considered “Personal Data”.

The security of your personal data is of huge importance to us. It will be stored in line with the conditions set forth in the legislation, as securely as possible, and for as long as the law requires. The personal data we collect will be handled with integrity in accordance with the rules of the law, will be correct and where necessary up to date, will be used for specific, clear and legitimate purposes, will be related to the purpose of processing, will be limited and measured, and will be stored for as long as the legislation requires or in line with the principles of storing data for the entire time it is needed for the required purpose.

a) Data Controller

As the PDP” Law requires, your personal data will be processed as outlined in the statements below by the “Data Controller”, TİMUR GAYRİMENKUL GELİŞTİRME YAPI VE YATIRIM A.Ş (“NEF”).

b) Purposes for processing your personal data

The personal data we collect will be finitely processed, so that natural and legal persons from our company, or those who are connected with the company, can execute their obligations, in order to carry out updates and briefings; to draw up and execute contracts with you; to send reminders of legal obligations and ensure they are carried out; to appear in various advertisements and marketing activities; to collect your views in surveys and polls; to determine appropriate products, projects and services, and to personalise and develop such products, projects and services; to deliver effective customer service; to inform you about relevant changes to legislation, company politics, or other relevant issues; for birthday celebrations; to include you in prize draws and competitions; for giving gifts and for other activities, promotions, and special offers beneficial to you; to send you emails, text messages, and fax messages; to inform you of special offers; to send bulletins, magazines, and articles on special offers; to determine our visitor profile; to assess requests, demands and complaints; to exercise human resource politics; and to reply to demands and questions from you.

c) For what purpose and to Whom your personal data may be transferred

Taking in to account the conditions and required security measures set forth in Article 8 and Article 9 of the PDP Law, processed personal data can be transferred for the purposes as listed under section (b) of this notice, indirectly/directly to our domestic/international affiliates or subsidiaries, to domestic/international, public/private institutes and organisations, companies or third-party individuals or organisations we collaborate with or who are project/programme/financial partners, or to those who receive services/support/advice from our company, partner companies, consultants, shareholders, or other types of solution partners, to the Central Securities Depository and other competent bodies or organisations, and to suppliers or subcontractors. NEF can process and store your personal information in line with the required security measures on servers within or outside of Turkey, or in other electronic environments.

ç) Methods and legal reasons for collecting your personal data

Your personal data may be obtained by our company through various channels (NEF’s head office, branches, agents and sales offices, the offices or physical environments of other subcontractors or partners with whom you are in contact with, call centres, internet sites, mobile applications and other electronic processing platforms, social media or other platforms that are open to the public, through your participation in training, conferences and other similar events, from other group companies, individuals or companies that they have agreements with in written or spoken form, in sound or image recordings or in other physical and electronic environments, etc.). Your personal data will be collected and processed as outlined in sections (b) and (c) of this notice, and on the condition that it is related directly to a contract as stated in section (c) of the second clause in Article 5 of the PDP Law and that the processing of personal data of the parties is necessary, also in line with legal responsibilities of the data controller in section (ç) of the same clause, and as stated in part (e), in order for rights to be established, used and protected, the data processing must be mandatory and on the condition that the data subject’s fundamental rights and freedoms as stated in section (f) are not harmed, for NEF’s legitimate interests or for legal reasons with your expressed consent.

Your personal data will be stored as required by the conditions in the legislation for as long as is legally required, or for as long as the legislation permits.

d) Rights of the data subject

As the natural person whose data is being processed, your lawful demands, when communicated to our company as outlined below, will be met by our company, free of charge, in the shortest time possible and at the most within 30 days. If a fee is requested by the Personal Data Protection Commission, the amount stated will be taken from our company. Within this context, the data subjects can:

• Learn whether or not her/his personal data has been processed;
• Request information on processing if her/his data has been processed;
• Learn the purpose of the processing of personal data and whether the data is being used in accordance with its purpose;
• Learn which third parties within the country or abroad to whom personal data has been transferred;
• Request rectification in the case that personal data is processed incompletely or inaccurately and that third parties who have been transferred this data are informed of the changes within this context;
• Request the deletion or destruction of personal data that has been processed in line with the PDP Law and the requirements of other legislation, but which is no longer required for the original purpose, and to request that third parties to whom this data has been transferred are informed;
• Object to the occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems;
• Request compensation for damages in cases where the person incurs damages due to the unlawful processing of personal data.

As required by the first clause of Article 13 of the PDP Law, demands related to your rights stated above can be communicated to our company. In order to exercise your rights outlined in Article 11 of the PDP Law, you must complete the form at www.nef.com.tr with an explanation of which rights you wish to exercise, and deliver a signed copy of the form together with your personal ID documents either by hand or through a public notary to the NEF Customer Relations Department at the following address: “Esentepe Mahallesi Ali Kaya Sokak No:3 Apa Nef Plaza K:5 Şişli-İstanbul”.