PERSONAL DATA PROTECTION



KIZILAY REAL ESTATE AND PRIVATE EQUITY ASSET MANAGEMENT INC.
 DISCLAIMER IN ACCORDANCE WITH PERSONAL DATA PROTECTION LAW

The disclaimer has been prepared for the purpose of informing you in accordance with the Law on Protection of Personal Data No. 6698.

Your personal data, which you provide to our Company (Kızılay Real Estate and Private Equity Asset Management Inc.) for mutual fund purchase and portfolio management services or which are obtained by our Company through various channels, are processed by us as of Data Officer within the scope of the Law on Protection of Personal Data. Your personal data shall be processed for mutual fund trading, portfolio management and other capital market activities, in accordance with the personal data processing conditions and purposes specified in Law No. 6698, with the purposes of carrying out the necessary work by our business units to benefit you from the products and services offered by our company; for customizing the products and services according to your taste, usage habits and needs before recommending them to you; for establishing communication with you about the products and services you receive; for using them related to marketing activities if your permission is given previously; for executing product/service offer, modeling, intelligence, reporting, scoring, risk monitoring activities; for determining and implementing of our company's commercial and business strategies; for working for existing and new products of our company and our subsidiaries and for identifying potential customers.

Your personal data will be transferred to the administrative and official authorities, to the direct and indirect shareholders of our Company and to their affiliates, to our business partners, our suppliers and to the persons related to the intermediary activities, to independent auditing companies where permitted by the legislation, to the institutions that information transfer are allowed in accordance with the Capital Market Law, to the electronic media and platforms used for Capital Market activities, to legal entities such as CMB, BIST, TSPB, MKK, within the limits of legal obligations and framework of legal restrictions. For the purposes mentioned before, your personal data are processed related to investment services and activities, tax, money laundry (MASAK), social security (SGK) legislations and other regulations that are related to the Capital Market Law.

Your personel data are collected through channels in which our company communicates with its customers or may communicate in the future, such as applications made to our Headquarter, customer interviews, SMS and e-mail channels, applications made to web sites.  Then, they are kept within statutory periods in accordance with the relevant legislation.

Keeping all related exceptions reserved, especially those defined in Article 28, according to Article 11 of the Law on the Protection of Personal Data; you have the right to learn whether your personal data has been processed, request information about your personal data if it has been processed, learn the purpose of processing your personal data and whether it is used accordingly, know the third parties to whom personal data has been transferred at home and abroad, request correction of personal data if it has been processed incorrectly, to request the deletion or destruction of personal data in the event that the reasons for the processing of personal data disappear, to request the notification of the correction or deletion to the third parties to whom the personal data has been transferred, to object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems, to request compensation if you suffer damage due to unlawful processing of personal data.