Informative Text on the Protection and Processing of Personal Data

This document was prepared by AlternatifbankA.Ş. ("Our Bank") in the capacity of Data Controller within the scope of our obligation to inform data subjects, whose personal data is processed, in accordance with article 10 of the Law no. 6698 on Protection of Personal Data ("LPPD").

Within the framework explained below, your personal data can be recorded, stored, updated, disclosed to third parties, transferred, categorized and processed by Our Bank as permitted by the legislation, using methods listed in the LPPD.

Purposes of and legal grounds for processing your personal data; Your personal data is processed to be used in any and all banking, capital market, insurance agency and other product and services including deposit, credit, and transfer transactions which may involve those that can be offered by Our Bank in the capacity of intermediary and agency;  to determine identity, address and other required information of the transacting party; to perform transactions on electronic (SWIFT, online / mobile banking, etc.) or paper media;  to comply with data retention, reporting, information obligations stipulated by applicable legislation, the Banking Regulation and Supervision Agency (BRSA), the Ministry of Customs and Trade, the Central Bank of the Republic of Turkey, the Banks Association of Turkey and other competent authorities; to offer requested / other Banking products and services; and to enter into and execute agreements, to which Our Bank is a party, within the scope of the Law no. 4358 on Generalization of the Use of Tax Identification Numbers, Banking Law no. 5411, Law no. 5549 on Prevention of Laundering Proceeds of Crime, Insurance Law no. 5684, Turkish Commercial Code no. 6102, Capital Markets Law no. 6362, inferior regulations dependent on these laws, and provisions of other laws applicable to the activities of Our Bank. Subject to your permission, your personal data can be processed and used by Our Bank also for the purpose of offering and introducing our products and services within the scope of the legislation, which are beyond your purpose for becoming a client of our Bank; planning and implementing custom products, services and offers; developing product and service operating model proposals; utilization in profiling, segmentation, setting objectives within the bank, scoring, risk analysis, customer relationship management, intra-bank performance monitoring and analysis studies; conducting statistical studies, market research, client satisfaction surveys.

You can be recorded by camera in our branches, electronic tellers (ATM), regional directorates, general directorate, and buildings used by Our Bank within the scope of workplace security applications and legitimate interests of Our Bank.

Information on Data Processing of Parties Subject to Risk Groups: Where you, your spouse or your children are board members or the general manager of, or the aforementioned are together with a legal entity or on their own, members of an unlimited partnership which they are in direct or indirect control, a qualified shareholder, board member, general manager of a bank, surety, guarantee and other similar relationships with real or legal persons where the aforementioned are in partnerships collectively or solely, which they are in direct or indirect control or are board members or the general manager of and where one is unable to repay their debts will cause the other member(s) unability to repay the debts constitute a “risk group”.  Persons identified within the risk group are determined by the Banking Regulation and Supervision Agency (“BRSA”) and even if you are not a client of our Bank, your personal data may be processed by our bank in order to fulfill our legal obligations at the foremost under banking regulations, the identification of risk groups, the determination of the total amount of loans to be made available to persons within the same risk group, to determine your risk group and the loan limitations to certain risk groups under banking regulations, monitoring, reporting, control, credibility evaluations and the management of legal and financial risks by our Bank.

Entities and organizations to which your personal data can be transferred for abovementioned purposes; Entities and organizations permitted by the Banking Law and other legislative provisions; including but not limited to financial institutions and other third parties listed in article 73/4 of the Banking Law no. 5411; public entities such as BRSA, Capital Markets Board, Financial Crimes Investigation Board (FCIB), Ministry of Finance of the Republic of Turkey, CBRT; our main shareholder The Commercial Bank (P.S.Q.C.) and direct / indirect domestic / foreign subsidiaries of our bank including AlternatifFinansalKiralamaA.Ş. and AlternatifMenkulDeğerlerA.Ş.; domestic and foreign banks and clearing houses that mediate / provide custodian services for transfers involving domestic and foreign money and security transfers and security deposit requests; relevant insurance companies, Risk Center of the Banks Association of Turkey; and organizations, domestic / foreign banks and financial institutions, and other third parties from which we receive services, with which we cooperate and act as program partners to conduct banking activities.

Method of and legal grounds for collection of your personal data; Your personal data is collected for the purpose of fulfilling all legal and contractual obligations of Our Bank, by means of all agreements / information forms and other documents issued upon your approval and/or with your signature pursuant to the Banking Law no. 5411 and other applicable legislation mentioned above; notifications that you will make with your electronic approval and/or signature; channels such as our General Directorate, Branches, ATMs, Online Banking, Call Center; verbally, in writing or on electronic media using various methods that are fully or partially automated or not automated as part of any data recording system; various methods of collection including our domestic / foreign subsidiaries, institutions and organizations with which we cooperate, public authorities, domestic / foreign Banks and other third parties.

Pursuant to article 11 of the LPPD, your rights as a client are;  to make an application concerning your personal data to Our Bank;

a) to find out whether your personal data was processed,

b) to request pertinent information if your personal data was processed,

c) to find out the purpose of processing and whether your personal data was purposefully used, 

d) to find out local and foreign third parties to whom your personal data was transferred,

e) to request correction if your personal data was incompletely / incorrectly processed,

f) to request deletion / destruction of your personal data pursuant to the terms stipulated in article 7 of the LPPD,

g) f) to request notification of actions, taken in accordance with clauses (d) and (e) above, to third parties,

h) to object to an outcome against you due to the analysis of your personal data exclusively by means of automated systems,

i) to request compensation if you incur losses due to unlawful processing of your personal data.