FREEDOM YATIRIM MENKUL DEĞERLER ANONİM ŞİRKETİ (“Company” or “Freedom Yatırım”), acting as data controller under the Turkish Personal Data Protection Law No. 6698 (“KVKK”), processes your personal data within the scope described below. This notice is prepared in accordance with Article 10 of the KVKK and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform.
1. Data Controller
Title: FREEDOM YATIRIM MENKUL DEĞERLER ANONİM ŞİRKETİ
MERSIS No: 0388191061400001
Address: İstanbul Finans Merkezi, Finanskent Mahallesi Finans Caddesi No: 46/3 İç Kapı No:76 K3 Blok Kat:13 Ümraniye/İstanbul
Email: [email protected]
2. Personal Data Processed
When you visit our website, fill in the contact form or become our client, the following categories of personal data may be processed:
- Identity data: name, surname, national ID number, date of birth (at account opening).
- Contact data: phone number, email address, postal address.
- Client transaction data: account details, order and trade records, balance information.
- Financial data: income, asset and risk profile information, suitability/appropriateness test results.
- Transaction security data: IP address, browser and device information, cookie data, log records.
- Audio records: telephone calls recorded as required by regulation.
- Marketing data: preferences and interests, subject to your explicit consent.
3. Purposes of Processing
- Responding to requests submitted via the contact form and contacting you,
- Carrying out account opening, know-your-customer (KYC) and identity verification processes,
- Fulfilling obligations arising from the Capital Markets Law No. 6362, the Law No. 5549 on Prevention of Laundering Proceeds of Crime and related secondary legislation,
- Providing investment services and activities, transmitting and executing orders,
- Fulfilling reporting obligations towards the CMB, Borsa İstanbul, MKK, Takasbank, MASAK and other competent authorities,
- Ensuring information security, preventing fraud and operating the website securely,
- Informing you about our products and services via SMS and email, subject to your explicit consent,
- Managing legal processes and responding to requests.
4. Transfer of Personal Data
In accordance with Articles 8 and 9 of the KVKK, your personal data may be transferred to the CMB, Borsa İstanbul, MKK, Takasbank, MASAK, courts and other competent public authorities within the scope of our legal obligations; to IT, custody, audit and consultancy providers from whom we receive services; and to our group company Freedom Holding Corp. and its affiliates (subject to the conditions of Article 9 of the KVKK in case of cross-border transfer).
5. Collection Method and Legal Grounds
Your personal data is collected electronically or physically through our website, contact form, email, telephone, trading platforms, branches and business partners. Data is processed on the legal grounds set out in Article 5 of the KVKK: being expressly stipulated by law, being necessary for the conclusion or performance of a contract, fulfilment of our legal obligations, establishment, exercise or protection of a right, and our legitimate interests; where none of these apply, on the basis of your explicit consent.
6. Retention Period
Your personal data is retained for as long as required by the purpose of processing and, in any case, for the statutory retention periods under capital markets legislation, MASAK legislation and the Turkish Commercial Code (minimum 10 years); at the end of this period it is deleted, destroyed or anonymised.
7. Your Rights as a Data Subject
Under Article 11 of the KVKK you have the right to:
- Learn whether your personal data is processed,
- Request information if it has been processed,
- Learn the purpose of processing and whether it is used in accordance with that purpose,
- Know the third parties to whom it is transferred domestically or abroad,
- Request correction if it is incomplete or inaccurate,
- Request deletion or destruction under the conditions of Article 7 of the KVKK,
- Request that correction, deletion and destruction be notified to third parties to whom data was transferred,
- Object to a result against you arising from analysis exclusively by automated systems,
- Claim compensation for damages arising from unlawful processing.
8. How to Apply
You may submit your requests, together with documents verifying your identity, in writing to our address above, via registered electronic mail (KEP), with secure electronic signature, or from your email address registered in our system to [email protected], in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. Your application will be concluded free of charge within 30 days at the latest.