PERSONAL DATA PROTECTION
DISCLOSURE STATEMENT

As Deniz Finansal kiralama A.Ş. (“Deniz Leasing”), we act with the title of data supervisor and wish to inform you on ways of obtaining your Personal Data, purposes of processing, legal reasons and your  rights in line with the security of our valuable customers, confidentiality of personal life, principle on protecting basic rights and freedoms of persons and in as per Article 10 of Law on Protection of Personal Data numbered 6698, regarding the identity, communication, legal proceeding, customer proceeding, location, CCTV footage, risk management information, financial, visual and auditory records, demographical information, job, education level, and income level, legal data, biometrical data including your biometrical photograph, all kinds of personal data including your health data and/or data with personal quality, corporate, commercial and other data, information and documents (“Personal Data”) which you have submitted to our institution or which are acquired through te methods determined under the heading the Collection Method of Your Personal Date.

PROCESSING PURPOSES REGARDING YOUR PERSONAL DATA
for the purpose of providing factoring,  financial leasing and the services within the scope of activities listed in the financing companies law including financial leasing services, insurance and other agency services, fulfilling, performing, developing the correspondent actions, carrying out operational processes, complying with internal systems, risk monitoring and informing requirements; sharing them with the related authorities when required; performing audit and fulfilling the related activities concerning its sustainability and continuity,

Realizing liabilities stated in the Law 6361 on Prevention of  Laundering Proceeds of Crime  and legislation that our institution is subject to; complying with prevention of Money Laundering legislation and with domestic and international legislation; using the system that allows electronic messages to be taken, right to reject to be used and complaint processes to be managed (“İYS System”) as per the Law on Arrangement of Electronic Commerce numbered 6563 and its foundation, Commercial Communication & Commercial Electronic Messages Regulation,

Ensuring that data is kept up to date and accurately; contacting customer on services and products subject to financial leasing activities, presenting proposalsi planning and realizing promotion, marketing and campaign activities;

Fulfilling the requirements of the contracts you have entered into and/or we have entered into; recording information such as occupation, income status, purpose of the transaction including identification and address detection in order to fulfill the know your customer requirements as per the legislations that our Company is subject to; performing intelligence, information researches and credibility assessments, planning and statistics,

Analyzing and developing the Financial Leasing systems, maintaining application management operations, executing/planning information processes, establishing infrastructures for information systems, managing, auditing and implementing them;
Quality standards, security, prevention of fraud, resolution of conflicts, recording and auditing correspondence, communication and proceedings;

designing the business processes and business activities, planning operational processes and purchasing operations, ensuring their execution and security; management of relations with support service providers, business partners or suppliers, executing support services upon service sale,

Executing customer relations; customer satisfaction activities, developing appropriate services and products for the customer, and ensuring that they are offered continuously, carrying out market searches, profiling, segmentation, scoring, risk analysis, customer relations management, recording notifications such as complaints, objections, requests, and suggestions and assessing requests and complaints communicated through social media, generating solutions for them;

Arranging all records and documents in an electronic format (online, Head Office Units,  call center and similar channels) or on paper which will constitute a base for the proceedings;

Being used for the products and services to be offered  in an agency capacity; planning and realizing the requirements with support services,

Boosting the reputation of  Deniz Leasing and business relations and identifying strategies, planning and performing business activities and operational processes; realizing corporate communication activities,

Performing the follow up of litigations and execution  followup to which Deniz Lasing is a party to and following up and performing other legal processes;

Recording camera footage and images in the head office and additional service units, recording biometrical photograph on your national identity card with security and identity detection purposes in order to ensure legal and physical security and constitute a basis for the proceeding that is carried out in a secure manner and also to ensure that those are in line with legal liabilities;
Executing and managing the affairs carried out by Deniz Leasing with its main shareholder and domestic, overseas branches and subsidiaries,  for the consolidated financial table preparation studies of main shareholders, risk management and assessments,
Keeping logs in case of use of internet access;

Planning and executing corporate sustainability, corporate management, strategical planning and information security processes; sustaining them without interruption for a better and more reliable service,

Fulfilling the information keeping, reporting, informing obligations laid out by the Banking Regulation and Supervision Agency, Financial Institutions Union, Capital Market Institution, Central Bank of Republic of Turkey, MASAK, The Banks Association of Turkey, KOSGEB, Revenue Administration, Undersecretariat of Treasury, Social Security Institute, Merkezi Kayıt Kuruluşu A.Ş, Ministry of Finance, Credit Bureau and other authorities,

Fulfilling all administrative, legal liabilities and liabilities arising from all of our contracts including product and service contracts that we have signed and the administrative, legal liabilities of Deniz Leasing,

Determine, monitor, report and control the risk group to be a part of for the identification of the loan limits to be disbursed based on a risk group,
METHOD OF COLLECTING YOUR PERSONAL DATA

Your personal data may be collected through the  head office units of our Company, branches, its website, call center and other phone channels, contracts, electronic mail, application forms, written and verbal communication channels carried out with our Company, public institutions and agencies as well as dealers and sale offices, unions and associations such as commerce and artisan chambers, by the method of recording CCTV footage at branches in our regional offices and head office buildings for reasons of security practices, parties, contracted institutions and support service and external service institutions which our company receives services from which act as the complementary to or an extension of the activities of our company such as SMS, email, cookies, and similar tracing technologies, facsimile, mail, cargo or carrier services, and databases, service contracts of similar establishments and institutions to the extent allowed by the legislation and contracts, via the system integrations between our company and public institutions and agencies within the national and international authorities/institution legal legislation limits (ID Sharing System, Address Exchange System, Trade Registration Gazette, Deed and Land Registration System, Risk Center, Credit Bureau, electronic pledge etc), through any kind of notifications,   submitted to our Company such as media, social media, registered electronic mail, electronic notification, email, mail, facsimile, text message, applications, interviews and various similar channels fully or partially automatic or non-automatic manners in a written, verbal or electronic media.

LEGAL REASONS FOR THE COLLECTION METHODS OF YOUR PERSONAL DATA

 As per the Law on  Personal Data Protection,

Your Personal Data can be processed based on the legal reasons stated above.
PERSONS/INSTITUTIONS THAT YOUR PERSONAL DATA MAY BE TRANSFERRED TO DUE TO THE PURPOSES STATED ABOVE

Your data on account numbers, ID information, address, scope of activity and all accounts, transactions and data can be transferred to and  be processed by U.S Internal Revenue Service (IRS), European Capital Market Authority (ESMA) and/or all other US and/or EU institutions in scope of laws and regulations of United States of America (USA) Dodd Frank (Dodd Frank Wall Street Reform and Consumer Protection Act) and FATCA (Foreign Account Tax Compliance Act), ISDA (International Swaps and Derivatives Association) and European Union (EU) EMIR (European Market Infrastructure Regulation) and CRS (Common Reporting Standard) in case you are a US and/or EU real person or legal entity or you trade in US and/or EU markets or you are subject to the tax laws of US and/or EU or due to various legal requirements,

Your data may be transferred to our Company’s domestic and overseas direct and indirect subsidiaries, Principal Shareholders and other shareholders, their subsidiaries, employees, company officers, legal, financial and tax consultants, auditors and it may be processed for creating consolidated financial tables, risk management and assessment activities for the parent company in line with data processing terms and purposes of central information system in our Principal Shareholder and as per the terms and purposes stated in article 8 of the Law on Protection of Personal Data regarding transfer of personal data and article 9 regarding transferring personal data abroad.

YOUR RIGHTS IN LINE WITH ARTICLE 11 OF THE LAW

By applying to our Company, you are entitled to a) learn if your personal data has been processed, b) request information if your personal data has been processed c) learn the purpose of your personal data being processed and learn if it is used in line with purpose, ç) know domestic and overseas third parties that your personal data has been transferred to, d) request it to be fixed if your personal data has been incorrectly processed, ,e) request that your personal data be deleted or destroyed as per the terms stated in article 7 of the Law, f) request that third parties that your personal data is transferred to state proceedings carried out in line with sub-paragraphs (d) and (e), g) object to a result against you which stems from your personal data’s being analyzed exclusively by automatic systems and ğ) request that restitution is made for the  damage arising from unlawful processing of your personal data. It is possible for your rights to be exercised as of 07.10.2016 which is the effective date of the regulation whereas our right is reserved to claim  the expenses to be incurred by our Company to make sure that your requests are fulfilled from you as per the tariff set out in the article 13 titled “Application to the data officer” of the Personal Data Protection Law

CASES THAT DO NOT REQUIRE CONSENT

As per the paragraph 2 of the article 5 of the Law on Protection of Personal Data numbered 6698, provided that it is clearly set forth in the laws, it is directly relevant through establishing or executing an agreement, Deniz Leasing has the right to process personal data without obtaining an express consent in case processing personal data regarding the parties to the agreement is necessary, it is obligatory for Deniz Finansal Kiralama AŞ. to fulfill its legal obligation in the capacity of Data Officer, it is made public by the related person, data processing is obligatory to establish, exercise or maintain a right, data processing is obligatory for the legitimate interests of the Company which is the data officer, the Company has the right to process personal data without obtaining an express consent and, Personal Data which is obligatory to be disclosed for public information  in accordance with the provisions in the official registrations or balance sheets and annual reports and in the laws as per the principle of clarity published or made public or laid out in the laws and Personal Data disclosure, use and transfers to be performed in order for the Company to fulfill its legal obligations resulting from the legislation which the Company is subject to and/or legal obligations and/or fulfill the Data transfer obligation to persons who may request the secrets in the laws to fulfill the Data transfer obligation and and for these Data, Deniz Leasing is authorized to disclose, give, process and transfer the related Data to related persons without the requirement of obtaining an express consent.

LEGAL LIABILITY ON RETENTION
It is a legal requirement for our company to retain your information and documentation for a period of ten years as per the legal and financial legislation that our Company is subject to. In the event that you request the deletion or destruction of your personal data, your request can be fulfilled at the end of the said 10-year period. Even in case the mentioned periods expire; your data might be anonymized  in order to improve the services and make them more secure for the purposes of the risk analysis and other assessment of your data. Your personal data which does not fall within the above-mentioned scope shall be deleted upon your request.
SHOULD YOU WISH TO CONTACT US FOR YOUR REQUESTS
Should you wish to contact us in line with the Law on the Protection of Personal Data, give feedback or ask questions, you may send out your petition that involves your identity documents and request to our branches, to Büyükdere Cad. No:141 34394 Esentepe-İSTANBUL address or you can send us via notary public or submit to info@denizleasing.com address.

Visit www.denizleasing.com to view confidentiality policy regarding the protection of personal data and terms of implementation principles and disclosure form on protection of personal data.

Click for Personal Data Protection, Retention and Destruction Policy