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This Clarification Text regarding the processing of your personal data (“Clarification Text”) by Deniz Faktoring A.Ş. (“Deniz Factoring”) was drafted in accordance with Turkish Law No. 6698 on the Protection of Personal Data (the “Kişisel Verilerin Korunması Kanunu” or “KVKK”). The purpose of this document is to inform you about the personal data processed by Deniz Factoring in relation to its activities, products, and services. It outlines the methods used for obtaining your personal data, the legal grounds and objectives for processing this data, and the entities to whom your data may be disclosed, including the reasons for such disclosure. Additionally, this text aims to inform any natural persons whose personal data is processed about their rights under the KVKK. Deniz Factoring acts in the capacity of Data Controller pursuant to the KVKK and takes the necessary measures when processing and storing your personal data.

You can find out more about our company in the table below. - Title
Deniz Faktoring A.Ş. - Address
Esentepe Mahallesi, Büyükdere Caddesi, No: 141, Kat:16 Şişli / İstanbul - MERSIS (Turkish Central Trade Registry System) No./Trade Registration No.
0291 0141 6680 0019 / 398 630-346 212 -

1. Personal data that is processed

The types of personal data* processed by Deniz Factoring are listed by category in the table below. - Identity Information
Name, surname, mother and father’s name, date of birth, place of birth, marital status, identity card serial number, Turkish ID number, etc. - Contact Information
Address, email address, contact address, registered electronic mail address (KEP), telephone number, etc. - Location
Information about your current location, etc. - Legal History
Information in correspondence files with judicial authorities, information in case files, etc. - Customer Transactions
Call center records, promissory notes, check and invoice information, valuations, collateral, credit information and other related transaction information, compliance and relevance test results, orders, transaction request information, etc. - Risk Management
Information processed for the management of commercial, technical, and administrative risks, etc. (e.g. asset/income information, demographic information, data obtained from the Turkish Risk Center, TCMB—the Central Bank of the Republic of Turkey, GIB—the Turkish Revenue Administration, KKB—the Turkish Credit Bureau, KPS—Turkish Identity Sharing System, APS—Address Registration System, information on debt owed to the Turkish Credit Bureau, score information, information on fraud and money laundering controls) - Professional Experience
Occupation, title, employment history, educational status, etc. - Transaction Security
IP addresses, login and logout information, device types, passwords, etc. - Financial Information
Balance sheets, financial performance information, credit and risk information, asset information, etc. - Visual and Audio Recordings
Call center recordings, audio-visual recordings, etc. - Physical Space Security Information
Physical space (workplace, building) entry and exit records, camera recordings, etc. - *If you intend to submit any signature circulars or other documents related to representation and authorization during the contract processes that contain sensitive personal data, such as information related to religion and blood group, we kindly request that you remove or redact such sensitive data from the documents before submitting them to us.

2. Methods of obtaining your personal data

Deniz Factoring collects and processes your personal data across several categories. These include identity information, contact information, legal history, customer transactions, risk management, financial information, professional experience, and visual and audio recordings. This data collection is part of the process when you send a request, fill out a form, or submit information or images of documents. It enables you to benefit from our products or services, become a customer, or contact us in any way, often through automated means. You may be involved in a collateral transaction with our clients and/or Deniz Factoring, either as a guarantor, pledge debtor, or in other roles such as spouse, where consent is required by law. If you are an authorized representative acting on behalf of our client, such as a company official, proxy, guardian, or trustee, we may also collect your data. Data is collected through various channels. These can be physical (e.g. our head office, branches, mail, cargo, fax, or printed forms) or digital (including mobile apps, websites, customer contact centers, electronic mail, and telephone). We gather this information directly from you or from our legal entity or real person merchant customers.
You may also have provided us with your personal data through various methods, including messages, requests, interviews, and channels such as social media, email, mail, fax, and text messages.
If you download the “Deniz'e Çek Gönder” mobile app or use any of Deniz Factoring’s digital service channels, we will take steps to ensure the security of your transactions. As part of this process, we may collect certain information. This includes the IP address of your device, your website login and logout details (traffic), and the type of device you use. We gather this data where necessary based on your requests and the nature of the products and services we offer you. Additionally, we may collect information about your operating system, password details, and information on how you access and use these services. We may, with your consent, process your location information in order to personalize branch information according to your current location.
We may collect your personal data through various methods across the following categories: identity information, contact information, legal history, customer transaction history, risk management, financial information, visual and audio recordings, and physical space security information:
We collect your personal data in ways that are permitted by relevant legislation and agreements. This includes obtaining information from systems shared by various institutions and organizations. Data may also come from our controlling shareholder, Denizbank A.Ş., and from companies within the DenizBank Financial Services Group that provide support or services under service agreements. Additionally, we gather information through system integrations with public institutions for intelligence activities, such as the KPS (Turkish Identity Sharing System), APS (Address Registration System), Risk Center of the TBB (Banks Association of Turkey), and the Association of Financial Institutions, and from parties from whom our company receives services that complement or extend our company’s activities, which mediate the establishment of a contractual relationship with our company. Our data sources also include service providers and business partners, such as correspondent factoring companies, dealers, and sales offices. Publicly available sources such as news in the media, online records, or directories are also used. Furthermore, we collect data through messages, requests, visits, and interviews, either entirely or partially through automated means;
We may also collect such data through non-automated means, including data recording systems, from individuals authorized to represent you, businesses under your ownership or affiliation (such as investment companies, partnerships, or joint ventures), as well as directors, partners, agents, representatives, trustees, officers, or attorneys of such businesses. We may also obtain it from judicial authorities or public authorities as part of legal and enforcement proceedings.
(*For information regarding the group of companies with which Deniz Factoring is associated, including our main shareholder, subsidiaries, and affiliates, please visit https://www.denizbank.com/hakkimizda/denizbankin-iliskili-kuruluslari .)

3. Legal grounds behind and purposes for the processing of your personal data

We engage in various activities for different legal purposes. The table below outlines these legal reasons and the purposes of processing your data. We process your personal data in a controlled, restricted, and carefully measured manner for the following purposes. - PERSONAL DATA CATEGORIES
Identity information, contact information, customer transaction history, legal history, risk management, financial information, professional experience, visual and audio recordings, and transaction security information
WHY WE PROCESS YOUR PERSONAL DATA
To maintain thorough records of factoring transactions and the full range of products and services we offer, which may also encompass services provided as agents; to fulfill, execute, and revoke risk management transactions related to the customer/loan/service; to manage invoice transactions efficiently and accurately; to offer a comprehensive spectrum of products and services, including those that may be performed in accordance with the relevant legislation as stipulated in the factoring agreement; to fulfill our obligations and responsibilities in relation to these, establish contracts, execute our contractual and operational processes, and ensure compliance with internal systems, risk monitoring, and information obligations; to provide other services determined by the BDDK (Turkish Banking Regulation and Supervision Agency), receive requests for these services, conduct and execute the contracts and transactions concluded, and improve processes in compliance with Turkish Law No. 6361 on Financial Leasing, Factoring, Financing, and Savings Financing Companies (Law No. 6361), as well as other applicable regulations;
To establish our debt collection structuring policy, to conduct risk monitoring and analysis processes, create and implement surety or guarantee agreements when needed to secure legal relationships between our company and merchant customers (whether legal entities or individuals), and to determine the values of movable or immovable properties used as collateral for asset valuation;
LEGAL GROUNDS
In accordance with the provisions outlined in subparagraph (a) of paragraph 5/2 of the KVKK, where processing of personal data is expressly mandated by the law; in accordance with subparagraph (c), when it is essential to process personal data of contractual parties directly associated with the initiation or execution of a contract; and in accordance with subparagraph (ç), when the data controller is obliged by the law to fulfill its legal obligations; - PERSONAL DATA CATEGORIES
Identity information, contact information, customer transaction history, financial information, visual and audio recordings
WHY WE PROCESS YOUR PERSONAL DATA
To get in touch with you regarding our products or services, or for matters related to regulatory compliance and service provision purposes;
LEGAL GROUNDS
In accordance with the provisions outlined in subparagraph (a) of paragraph 5/2 of the KVKK, where processing of personal data is expressly mandated by the law; in accordance with subparagraph (c), when it is essential to process personal data of contractual parties directly associated with the initiation or execution of a contract; and in accordance with subparagraph (ç), when the data controller is obliged by the law to fulfill its legal obligations; - PERSONAL DATA CATEGORIES
Identity information, contact information, customer transaction history, legal history, risk management, financial information, professional experience, transaction and physical space security information
WHY WE PROCESS YOUR PERSONAL DATA
To examine the credit history of various parties involved, including natural person customers, owners, managers, shareholders, partners, representatives, or real beneficiaries of legal entity customers, as well as guarantors, assignment debtors, or those related to the factoring transaction, such as the drawer or endorser of a submitted check, as well as determining creditworthiness and collateral viability; to conduct intelligence and information research, manage risks, prevent fraudulent activities, and execute credit sales, allocation, disbursement, monitoring, and follow-up processes within the context of evaluating requests for factoring transactions;
To monitor and record all visits in order to maintain the physical security of Deniz Factoring’s facilities, including head office, branches, and other premises, to share them with relevant authorities when required, and manage emergency situations effectively;
LEGAL GROUNDS
In accordance with the legal requirements stipulated under Article 5/2 subparagraph (ç) of the KVKK which mandates that “it is necessary for the data controller to fulfill its legal obligations,” and subparagraph (f) which asserts that “data processing is obligatory for the legitimate interests of the data controller, as long as it does not infringe upon the fundamental rights and freedoms of the data subject”; - PERSONAL DATA CATEGORIES
Identity information, contact information, customer transaction history, legal history, risk management, financial information, professional experience, and transaction security information
WHY WE PROCESS YOUR PERSONAL DATA
In compliance with the relevant legislation, particularly Turkish Law No. 6361 and Turkish Banking Law No. 5411, to fulfill our legal obligations and cooperate with regulatory bodies and law enforcement agencies; to verify and update customer identity and contact information, keep data up-to-date, conduct risk analysis and management, and maintain information security processes; to conduct internal auditing, investigations, intelligence, and ethics audits; to conduct finance and accounting processes;
To adhere to the information storage, archiving, reporting, and disclosure obligations mandated by various authoritative bodies including the BDDK (Turkish Banking Regulation and Supervision Agency), SPK (Turkish Capital Markets Board), TCMB (Central Bank of the Republic of Turkey), the Turkish Ministry of Treasury and Finance, MASAK (Turkish Financial Crimes Investigation Board), TBB (Banks Association of Turkey), GIB (Turkish Revenue Administration), SGK (the Turkish Social Security Institution), KKB (Turkish Credit Bureau), KVK Kurumu (Turkish Personal Data Protection Authority), BTK (Turkish Information and Communication Technologies Authority), MMK (Turkish Central Registry Agency), KGF (Turkish Credit Guarantee Fund), and FKB (Turkish Association of Financial Institutions); to fulfill the information retention, archiving, reporting, and disclosure obligations specified by these entities and respond to information and document requests from these authorities in compliance with legislation aimed at preventing the laundering of the proceeds of crime and terrorism financing;
To obtain approval for commercial electronic messages pursuant to Turkish Law No. 6563 on the Regulation of Electronic Commerce and its subsequent regulations and utilize the system instrumental in enabling the management of the right of refusal and complaint processes (“İYS System”); to fulfill our obligations related to identity verification and access management in line with the Communiqué on the Management and Audit of Information Systems of Financial Leasing, Factoring, and Financing Companies;
LEGAL GROUNDS
Data processing activities are carried out on firm legal grounds, as expressly stipulated in Article 5/2, subparagraph (a) of the KVKK which mandates that “these actions are justified as they are explicitly mandated by law” and pursuant to subparagraph (ç) of the same article which adds “if it is compulsory for the data controller to fulfill its legal obligations”; - PERSONAL DATA CATEGORIES
Identity information, contact information, customer transaction history, transaction security information, financial information, and risk management
WHY WE PROCESS YOUR PERSONAL DATA
To ensure the effective implementation of DenizBank Financial Services Group’s compliance program across the financial group in strict accordance with Article 5 of the Turkish Regulation on the Compliance Program for Obligations Regarding the Prevention of the Laundering of the Proceeds of Crime and the Financing of Terrorism; to ensure customers can be recognized, enable the intra-group sharing of account and transaction information, and ensure that information on customers is accurate and up to date;
LEGAL GROUNDS
Data processing activities are carried out on firm legal grounds, as expressly stipulated in Article 5/2, subparagraph (a) of the KVKK which mandates that “these actions are justified as they are explicitly mandated by law” and pursuant to subparagraph (ç) of the same article which adds “if it is compulsory for the data controller to fulfill its legal obligations”; - PERSONAL DATA CATEGORIES
Identity information, contact information, customer transaction history, legal history, financial information, visual and audio recordings
WHY WE PROCESS YOUR PERSONAL DATA
To manage all requests and complaints, including those relating to customer relations, experience, satisfaction, complaints, objections, requests, and suggestions; to follow up on and implement all legal, enforcement, and legal follow-up and litigation processes before judicial and/or administrative authorities;
To prepare the consolidated financial statements of the parent companies within the framework of the Turkish Banking Law, to plan or execute relationships with parent companies, and to manage and assess risks; to provide risk, audit, and operational services together with subsidiaries within the framework of the Turkish Banking Law and relevant legislation; to provide risk, audit, and operational services in order to comply with the Capital Markets Board legislation;
LEGAL GROUNDS
Based on the legal grounds of “being necessary for the data controller to fulfill its legal obligations” under Article 5/2(ç) of the KVKK and “being necessary for the establishment, exercise, or protection of a right” under Article 5/2(e); - PERSONAL DATA CATEGORIES
Identity information, financial information, contact information, customer transaction history, and transaction security information
WHY WE PROCESS YOUR PERSONAL DATA
To manage, plan, and execute relationships and processes with our service providers, partners, or suppliers, and to fulfill our legal and commercial obligations under contracts with third parties with whom we have business relationships;
LEGAL GROUNDS
Pursuant to subparagraphs (c) and (ç) of Article 5/2 of the KVKK; - PERSONAL DATA CATEGORIES
Identity information, contact information, customer transaction history, and financial information
WHY WE PROCESS YOUR PERSONAL DATA
To carry out advertising, marketing, and promotional activities for our products and services, including surveys and statistical studies; to execute campaign processes and to communicate with you for these purposes, to offer you proposals, and to provide marketing-related commercial electronic message sending services
LEGAL GROUNDS
with your explicit consent under Article 5/1 of the KVKK. -

4. To whom and for what purpose your personal data may be transferred

Kişisel Verileriniz; Your personal data may be shared with the following parties on a limited and proportionate basis, in order to fulfill our obligations under Turkish Law No. 6361, the Banking Law, and other relevant legislation to which we are subject, and to achieve the purposes listed below:

• Your personal data may be shared with the following parties on a limited and proportionate basis, in order to fulfill our obligations under Turkish Law No. 6361, the Banking Law, and other relevant legislation to which we are subject, and to achieve the purposes listed below:
• Third parties that we use to provide our services, such as service providers, individuals, institutions, and organizations with whom we collaborate; service providers such as dealers, sales offices, etc. offering services in matters such as consultancy, valuation, infrastructure or acting as intermediaries in establishing a contractual relationship with Deniz Factoring; partner organizations with whom we collaborate, subcontractors, and companies/organizations operating as brokers/agencies, mobile service providers authorized by the Information and Communication Technologies Authority (BTK); financial institutions, including banks, factoring companies, and insurance companies, located in Turkey and/or abroad to carry out factoring activities, provide products and services related to your request, fulfill our legal obligations such as providing, storing, and reporting information, and execute payment/collection and insurance processes,
• Authorities operating system integrations (KPS—Turkish Identity Sharing System, APS—Address Registration System, etc.) shared through public institutions and organizations, to enable us to process your requests correctly and make inquiries within systems for your security within the framework of customer identification obligations,
• Affiliated companies and subsidiaries within the Denizbank Financial Services Group, our shareholders, our direct/indirect domestic/foreign subsidiaries, companies for whom we act as agents, and persons, institutions, and/or organizations that are authorized to receive information under the provisions of the relevant law and other legislation in accordance with the provisions of Arti·cle 73 of the Turkish Banking Law, the activity expansion permits of the BDDK (Turkish Banking Regulation and Supervision Agency), and Turkish legislation on the Prevention of Money Laundering and the Financing of Terrorism,
• Courts, law firms, asset management companies, and independent audit companies for the purpose of auditing the compliance of activities with legislation for the purposes of following up and carrying out legal follow-up and litigation processes before all judicial and/or administrative authorities,
• Your personal data may be shared with other third parties, with your explicit consent, for the purposes specified in Articles 8 and 9 of the KVKK.

5. Your rights

According to Article 11 of the KVKK, you have the following rights regarding your personal data:

a) To find out whether your personal data has been processed,
b) To request information if your personal data has been processed,
c) To find out why your personal data has been processed and whether it has been used for the intended purpose,
d) To know the names of the third parties to whom your personal data has been transferred domestically or abroad,
e) To request correction of personal data if it is incomplete or improperly processed and to request that third parties be informed of the actions taken,
f) To request the deletion or destruction of personal data in the event that the reasons for the processing of such data no longer exist, despite the fact that it has been processed in accordance with the provisions of Turkish Law No. 6698 and other relevant laws, and to request that third parties be informed of the actions taken,
g) To object to a decision made against you as the result of your data being analyzed exclusively through automated means,
h) To request compensation in the event you face damages due to the illegal processing of your personal data.

Under the scope of the rights provided in Article 11 of Turkish Personal Data Protection Law No. 6698, you may submit any requests for information in compliance with the “Turkish Communiqué on Procedures and Principles for Requesting Information from the Data Controller.” These requests should be made in writing, with an original signature, accompanied by documents verifying your identity, and can be sent to the following address: Büyükdere Cad. No: 141, 34394 Esentepe, Istanbul, Turkey. Alternatively, you have the option to send your requests via a notary or using a registered electronic mail (KEP) address by emailing denizfaktoring@hs09.kep.tr .

Click to view the Personal Data Protection, Retention, and Disposal Policy.

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