1. Definition

This Privacy Policy aims to provide information regarding the privacy and security measures adopted for the personal information of visitors and members. The Policy explains the methods for processing, collecting, storing, and using the personal information of visitors and members.

2. Purpose

The purpose of this Privacy Policy is to explain which personal data of Başkent's visitors and members are collected, for what purposes and by which methods such data are processed, the legal basis for such processing, the methods of collection, and the purposes for which such data may be shared with third parties.

3. Information Collected and Methods of Collection

Başkent processes the personal data of website visitors and members in accordance with Articles 5 and 6 of the Personal Data Protection Law No. 6698, the applicable legislation, and the decisions of the Personal Data Protection Board. During website visits, certain general information, such as the user's location and the referring website, may be collected automatically; however, such information is not used for identification purposes.

In addition to automatically collected data, identity, contact, and professional information, as well as photographs and video recordings contained in the shared content, may also be collected. Furthermore, records of interviews conducted with Başkent employees, messages, comments, and opinions are among the data that may be collected. Where necessary and in compliance with the applicable legislation, special categories of personal data may also be processed.

3.1 What Is Personal Data?

Personal data means any information relating to an identified or identifiable natural person. As the data controller, Başkent may record, store, process, disclose, and transfer your personal data in accordance with the Law.

3.2 Methods and Legal Basis for the Collection of Personal Data

Personal data may be collected verbally, in writing, or electronically, through automated or non-automated methods, via contact and membership forms on the website, shared content, authorized natural or legal persons acting as data processors, e-mail, telephone, the website, various agreements, paper forms, and official records.

3.3 General Principles Regarding the Processing of Personal Data
Any operation performed on personal data, including collection, recording, storage, preservation, alteration, reorganization, disclosure, transfer, classification, and prevention of use, falls within the scope of “data processing.”
Your personal data collected may be processed for the following purposes:
Fulfilling notification obligations
Managing information security processes
Conducting audit, compliance, and ethics activities
Managing outsourced services and supplier processes
Managing finance and accounting operations
Managing legal processes and dispute resolution
Conducting internal audit, internal control, and risk management activities
Ensuring business continuity
Providing information to legally authorized persons and institutions
Managing customer relations and customer satisfaction
Conducting know-your-customer, identity verification, and beneficial ownership identification processes
Carrying out retention and archiving activities
Providing investment services and ancillary services within the scope of capital markets legislation
Establishing and performing contracts
Planning products and services tailored to individuals and carrying out marketing activities
Managing requests and complaints
Managing sales and after-sales support processes
Types of Data That May Be Processed Sample Content
Identity and Identification Information Name, surname, profession, job title, employer, education and employment history, gender, marital status, citizenship status, and tax residency status.
Identity Document Data Date of birth, place of birth, identity number, blood type, religion, and photograph.
Contact Information Home, business, or temporary residence address, telephone number, e-mail address, and fax number.
Financial and Investment Information Investment objectives, risk and return preferences, markets and products traded, transaction frequency, and transaction volume.
Communication Records Telephone conversations, e-mail correspondence, and other audio/visual records.
Digital Footprint and Technical Data IP address, device ID, unique identifier, device type, log records, traffic information, referral URL, and location information.

Types of Data That May Be Processed	Sample Content
Identity and Identification Information	Name, surname, profession, job title, employer, education and employment history, gender, marital status, citizenship status, and tax residency status.
Identity Document Data	Date of birth, place of birth, identity number, blood type, religion, and photograph.
Contact Information	Home, business, or temporary residence address, telephone number, e-mail address, and fax number.
Financial and Investment Information	Investment objectives, risk and return preferences, markets and products traded, transaction frequency, and transaction volume.
Communication Records	Telephone conversations, e-mail correspondence, and other audio/visual records.
Digital Footprint and Technical Data	IP address, device ID, unique identifier, device type, log records, traffic information, referral URL, and location information.

3.4 To Whom and For What Purposes Are Personal Data Transferred?

The personal data collected may be shared with third parties where necessary and in accordance with the conditions set forth in Articles 8 and 9 of the Law.

Recipient of the Transfer	Purpose of the Transfer
Third parties providing services, support, or consultancy	Electronic commerce, campaign and commercial electronic communication processes, financial consultancy, independent audit, legal services, archiving, information technology, and agency services.
Public institutions and organizations and judicial authorities	To fulfill legal obligations and to establish and protect legal rights.

3.5 Rights of the Personal Data Subject Under the Law

To learn whether personal data are processed
To request information if personal data have been processed
To learn the purpose of processing and whether the data are used in accordance with such purpose
To know the third parties to whom personal data are transferred, whether domestically or abroad
To request the correction of incomplete or inaccurate personal data
To request the deletion or destruction of personal data under the conditions set forth in the Law
To object to any adverse outcome resulting from the analysis of personal data exclusively through automated systems
To request compensation for damages arising from unlawful processing of personal data

You may submit your requests in writing to the Company's address or to denetim@baskentmenkul.com.tr via registered electronic mail (KEP), secure electronic signature, mobile signature, or the e-mail address registered in our systems.

4. Security and Confidentiality

Başkent exercises reasonable care to ensure the security and confidentiality of personal data. However, no absolute guarantee of security can be provided against third parties seeking to circumvent security measures or interfere with data over the internet.

5. Sharing Personal Data Belonging to Third Parties

Personal data relating to third parties shared with Başkent through the website shall also be processed in accordance with this Privacy Policy. Where personal data of third parties are shared, it is deemed that the person sharing such data has fulfilled the obligations imposed by the applicable legislation.

6. Notices and Amendments

Any amendments to this Privacy Policy shall be announced on the website. The most current version shall be published on the website in a manner accessible to everyone and shall enter into force as of the date of publication.

7. Contact

You may contact Başkent using the contact information available on the website.