1. Data Controller

TEB Yatırım Menkul Değerler A.Ş. (“TEB Yatırım” or “the Company”), in accordance with the Personal Data Protection Law No. 6698 (“the Law”), processes your personal data as a data controller within the scope of the investment transactions you carry out as our customer through the TEB Yatırım PRIME Application and the TEB Yatırım PRIME Web Platform (both collectively referred to as the “Platform”) available at https://prime.tebyatirim.com.tr/ and through discussions with the customer representative.

This Privacy Notice has been prepared to inform you about the personal data we process. We kindly request that you read this Privacy Notice carefully. Our specialised explanatory texts for the channels you use are also provided to you on the relevant channels.

2. Your Processed Personal Data, the Purpose of Processing Your Data, and the Legal Basis

Articles 5 and 6 of the Law list the legal grounds for processing personal data. Below, we have outlined which personal data we process, for what purposes, and on what legal grounds within the scope of those purposes:

 

Processed Personal Data Purposes of Processing Legal Grounds
  • Identity (Name, surname, date of birth, place of birth, nationality, Turkish ID number, mother's name, father's name, age)
  • Contact (Address, Telephone number, email address)
  • Customer Transactions (suitability and appropriateness test responses)
  • Finance (International Bank Account Number)
  • Professional Experience  (Information about the job and profession, educational background)  
  • Other (Signature, details regarding the suspicious transaction)
  • TEB Yatırım fulfilling its obligations under the Law within the scope of its investment services (for example, identity verification in accordance with Law No. 5549 on the Prevention of Money Laundering of Criminal Proceeds (“Law No. 5549”) and related legislation for the purpose of registering your customer account, Conducting suitability and appropriateness tests within the scope of the Circular on the Establishment and Operating Principles of Investment Institutions No. III-39.1 and the Investment Services Circular, Obtaining and verifying identity information within the scope of suspicious transaction reports under Law No. 5549 and related legislation, Notification of information misuse or market fraud offences in accordance with the Notification Obligation on Information Misuse or Market Fraud Offences No. V-102.1)
Article 5/2(a) of the Law

It is expressly provided for by the laws.

  • Identity (Name, surname, date of birth, place of birth, nationality, Turkish ID number, mother's name, father's name, age, gender, ID card expiry date, driving licence photocopy, ID card photocopy )
  • Contact (Address, Telephone number, email address)
  • Customer Transactions (Customer account number, credit/debit balance information, credit information, block information, request/complaint/suggestion information, Central Registry Agency registration number, suitability and appropriateness test responses, risk profile score during the account opening process, collateral deposit/withdrawal request information, order/instruction information, number of transactions)
  • Finance (IBAN number, customer bank account number, credit and debit balance, blocked information, income information, interest information, current balance information)
  • Transaction Security (User log records, IP address information, website/mobile application entry and exit information, device ID information)
  • Visual and Audio Recordings (Telephone call recording)
  • Other (signature)
  • Verifying the accuracy and currency of the information you have provided to us in the context of carrying out brokerage activities for your investment transactions,
  • Preparation of contracts relating to investment processes,
  • The creation of your customer record,
  • The opening of your investment account,
  • Getting your investment account ready for trading,
  • The implementation of risk controls during the opening of your investment accounts and periodically at specific intervals,
  • Ensuring that you can carry out your money transfer and withdrawal transactions,
  • The execution of the derivative purchase/sale transactions you have submitted, 
  • Conducting maturity date checks on your positions,
  • The execution of withholding tax procedures relating to your earnings,
  • Making correction entries for errors occurring in daily transactions,
  • The implementation of our periodic internal control activities,
  • The assessment and finalization of your limit requests,
  • Ensuring that you can view your investment portfolio,
  • Processing requests to reactivate accounts that have been inactive for a long period of time or blocked due to insufficient information, and carrying out the procedures to reactivate the account.
  • Conducting credit and collateral assessments, carrying out monitoring and follow-up processes,
  • Granting credit to customers whose credit applications for share purchases have been approved,
  • Should you apply for credit, receiving and processing your application requests.
  • Processing the transfer of portfolios to TEB Yatırım for customers wishing to do so,
  • The execution of account reconciliation procedures,
  • Transferring dividend payments to your accounts,
  • The appointment of an Investment Advisor,
  • Ensuring that your investment transactions are carried out with your Investment Advisor,
  • Processing your account closure requests.
Article 5/2(c) of the Law

Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract.

  • Identity (Name, surname, date of birth, place of birth, nationality, Turkish ID number, mother's name, father's name, age, gender, ID card expiry date, driving licence photocopy, ID card photocopy )
  • Contact (Address, Telephone number, email address)
  • Customer Transactions (Customer account number, credit/debit balance information, credit information, block information, request/complaint/suggestion information, Central Registry Agency registration number, suitability and appropriateness test responses, risk profile score during the account opening process, collateral deposit/withdrawal request information, order/instruction information, number of transactions)
  • Finance (IBAN number, customer bank account number, credit and debit balance, blocked information, income information, interest information, current balance information)
  • Transaction Security (User log records, IP address information, website/mobile application entry and exit information, device ID information)
     
  • Conducting communication activities
  • Receiving and resolving your requests, complaints and suggestions,
  • In the event of an error arising from TEB Yatırım, paying compensation for damages,
  • Conducting reporting activities,
  • Monitoring your equity levels and closing orders that fall below the equity level,
  • Being notified if your margin level falls below a certain level and you are required to top up your margin,
  • Closing of transactions with insufficient margin amounts for customers who fail to meet margin calls as a result of margin calls.
  • In exceptional circumstances (systemic problems), authorized employees opening a backup terminal to manually enter your transactions into the systems,
  • Preparation and submission of the visa and inheritance documents requested by you,
  • Sending monthly account statements to you,
  • Identifying customers who have not conducted any transactions other than automated transactions for a period of ten years,
  • Conducting internal control/audit activities,
  • Identifying customers who have defaulted,
  • The examination and auditing of our business activities,
  • Conducting work aimed at developing and improving your experience with our services
Article 5/2(f) of the Law
Processing of data is necessary for the legitimate interests pursued by
the 
data 
controler, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.
  • Identity (Name, surname, date of birth, place of birth, nationality, Turkish ID number, mother's name, father's name, age, gender, ID card expiry date, driving licence photocopy, ID card photocopy )
  • Contact (Address, Telephone number, email address)
  • Customer Transactions (Customer account number, credit/debit balance information, credit information, block information, request/complaint/suggestion information, Central Registry Agency registration number, suitability and appropriateness test responses, risk profile score during the account opening process, collateral deposit/withdrawal request information, order/instruction information, number of transactions)
  • Finance (IBAN number, customer bank account number, credit and debit balance, blocked information, income information, interest information)
  • Transaction Security (User log records, IP address information, website/mobile application entry and exit information, device ID information)
  • Visual and Audio Recordings (Telephone call recording)
  • Professional Experience (Information about the job and profession, educational background)
  • Other (Signature, details regarding the suspicious transaction)
  • Legal Proceedings (Information contained in the lawsuit/enforcement file in the event of a potential dispute, correspondence with the authorized institutions or organizations )
  • Where authorized institutions or organizations (Capital Markets Board (“CMB”), the Investor Compensation Centre (“ICC”), the Turkish Capital Markets Association (“TCMA”), Borsa Istanbul A.Ş. (“BIST”), Istanbul Takas ve Saklama Bankası A.Ş. (“Takasbank”) and the Merkezi Kayıt Kuruluşu A.Ş. (“MKK”), The Banking Regulation and Supervision Agency (“BRSA”), The Central Bank of the Republic of Turkey (“CBRT”), The Ministry of Trade, The Financial Crimes Investigation Board (“MASAK”), The Revenue Administration (“GİB”), The Union of Chambers and Commodity Exchanges of Turkey (“TOBB”)) request information from our Company or where we are required to notify such institutions, fulfilling our legal obligations (e.g. reporting suspicious transactions to MASAK, reporting suspicious transactions related to information abuse or market fraud to the Capital Markets Board),)
Article 5/2(ç) of the Law

It is necessary for compliance with a legal obligation to which the data controller is subject.

  • The protection and exercise of our rights and the conduct of legal proceedings in the event of a potential dispute
Article 5/2(e) of the Law

Data processing is necessary for the establishment, exercise or protection of any right.

 

3. Transfer of Your Personal Data to Third Parties and Purposes of Transfer

Your personal data is transferred to third parties in compliance with Articles 8 and 9 of Law No. 6698. All necessary technical and administrative measures are taken when transferring data to third parties.

The table below lists the third parties to whom we transfer your personal data and the purposes of such transfers:

 

Third Parties to Whom Data is Transferred Purposes of Transfer
Authorized Institutions and Organizations Where authorized institutions or organizations (Capital Markets Board (“CMB”), the Investor Compensation Centre (“ICC”), the Turkish Capital Markets Association (“TCMA”), Borsa Istanbul A.Ş. (“BIST”), Istanbul Takas ve Saklama Bankası A.Ş. (“Takasbank”) and the Merkezi Kayıt Kuruluşu A.Ş. (“MKK”), The Banking Regulation and Supervision Agency (“BRSA”), The Central Bank of the Republic of Turkey (“CBRT”), The Ministry of Trade, The Financial Crimes Investigation Board (“MASAK”), The Revenue Administration (“GİB”), The Union of Chambers and Commodity Exchanges of Turkey (“TOBB”), The Risk Centre of the Turkish Banks Association (“TBB”) and similar organisations) request information from our Company or where we are required to notify such institutions, sharing for the purpose of fulfilling our legal obligations,
Suppliers and Service Providers Sharing data for the purpose of obtaining support from suppliers and service providers in the context of the supply of goods or services (for example, obtaining infrastructure support from a supplier for the storage of your information, or obtaining support from our business partner based abroad for the opening of your accounts if you wish to invest abroad).

 

Your personal data is transferred outside of Turkey in accordance with the provisions of the Law and the Regulation on the Procedures and Principles Regarding the Transfer of Personal Data Abroad (‘Regulation’), which entered into force upon its publication in the Official Gazette dated 10/7/2024 and numbered 32598. When transferring personal data abroad, TEB Yatırım and the data recipient act in accordance with the requirements specified in Article 9 of the Law and the Regulation. In accordance with Article 9(4) of the Law, appropriate guarantees are provided for the transfer of personal data abroad, including the ability of the data subject to exercise their rights and to seek effective legal remedies in the country to which the transfer is made.

4. Methods of Collecting Personal Data

Your personal data is collected through non-automated methods, such as face-to-face meetings in physical environments, printed documents and printed forms, provided that they form part of a data recording system; it is collected electronically via platforms, internal company applications, systems, email and telephone, and processed by automated or partially automated means.

5. Rights of the Data Subject

Article 11 of the Law regulates ‘the rights of the data subject’. All actual persons whose personal data is processed by TEB Yatırım have the right to apply to TEB Yatırım in accordance with the Law and to exercise their legal rights as set out in the Law.

When applying to TEB Yatırım to exercise your rights, you may submit your requests in writing or by email by completing the Personal Data Rights Exercise Form or using one of the methods outlined in the Comminuque On The Principles And Procedures For The Request To Data Controller:

Address: İnkılap Mah. Sokullu Cad. No:7B Ümraniye/İstanbul

E-mail: kvkk-basvuru@tebyatirim.com.tr

KEP Address: tebyatirimmenkuldegerler@hs03.kep.tr