PERSONAL DATA PROTECTION AND PROCESSING DISCLOSURE STATEMENT

This disclosure statement has been prepared by Saf Yapı Yatırım A.Ş., acting as the data controller, in order to inform website visitors, contact form users, physical visitors, business partners, suppliers, supplier representatives/employees, job/internship applicants, and other relevant natural persons about the principles regarding the processing of personal data.

I. Definitions

In this statement;

• Company / Saf Yapı refers to Saf Yapı Yatırım A.Ş.,

• Data subject refers to the natural person whose personal data is processed,

• Personal data refers to any information relating to an identified or identifiable natural person,

• Special categories of personal data refers to the data specifically protected under Law No. 6698,

• Processing refers to any operation performed on personal data such as collection, recording, storage, disclosure, transfer, classification or prevention of use,

• Data controller refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system,

• Website / Site refers to the website located at https://saf.com.tr/,

• KVKK refers to the Turkish Personal Data Protection Law No. 6698,

• Law No. 5651 refers to the Law on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications.

II. Personal Data Processed, Purposes of Processing and Legal Grounds

1. Website Visitors and Contact Form Users

If you visit Saf Yapı’s website or use the communication channels available on the website, the following personal data may be processed:

• Identity information: name, surname

• Contact information: e-mail address, telephone information (if shared during the relevant process)

• Customer transaction / request information: selected subject, message content, request-suggestion-complaint information

• Transaction security data: IP address, log records, traffic data, date-time information, device and browser data

• Cookie data: records of cookies used according to your preferences

Such data may be processed for the following purposes:

• Receiving, evaluating and responding to communication requests

• Conducting request, suggestion and complaint processes

• Directing job/internship applications to relevant departments

• Ensuring website security and carrying out transaction security processes

• Fulfilling legal obligations

• Carrying out information security, audit and retention activities

• Managing cookie preferences and ensuring the core functionality of the website

In this context, your personal data may be processed pursuant to Article 5/2 of the KVKK based on the following legal grounds: being expressly provided for by law, being directly related to the establishment or performance of a contract, being necessary for the data controller to fulfill its legal obligations, being necessary for the establishment, exercise or protection of a right, and legitimate interest. Where required, explicit consent may be obtained for cookies.

2. Job / Internship Applicants

If an application is submitted through the Careers page or other communication channels, the following data may be processed:

• Identity information

• Contact information

• Resume information

• Education and professional experience information

• Reference information (if shared)

• Application evaluation notes

Such data is processed for the following purposes:

• Conducting applicant application processes

• Carrying out human resources planning processes

• Evaluating candidates for suitable positions

• Conducting communication activities

3. Suppliers, Business Partners and Their Representatives

Saf Yapı may process the following data within the scope of procurement processes, business partnership relations and contractual processes:

• Identity information

• Contact information

• Financial information

• Signature circulars, powers of attorney, contract information

• Invoice and accounting records

• Professional and commercial activity information

Such data is processed for the following purposes:

• Conducting procurement and contract processes

• Carrying out accounting and financial transactions

• Fulfilling obligations arising from legislation

• Conducting audit, reporting and business continuity activities

4. Physical Premises Visitors

If you visit the company’s premises or offices, the following data may be processed:

• Identity information

• Visitor registration information

• Entry-exit times

• Vehicle plate information

• Camera recordings

Such data may be processed for the following purposes:

• Ensuring physical premises security

• Keeping visitor records

• Conducting emergency and audit processes

• Fulfilling legal obligations

III. Methods of Collecting Personal Data

Your personal data may be collected through:

• forms on the website,

• e-mail and telephone communications,

• forms filled out during physical visits,

• camera systems,

• contracts and official documents,

• digital recording and log systems,

• cookies and similar technologies,
  by automatic, partially automatic or non-automatic means.

IV. Transfer of Personal Data

Your personal data may be transferred, in accordance with Articles 8 and 9 of the KVKK and for the fulfillment of the purposes stated above, to:

• authorized public institutions and organizations,

• judicial and administrative authorities legally authorized to request such data,

• suppliers providing information technologies, hosting, security, legal, audit and consultancy services,

• business partners supporting accounting, finance, operations and business development processes,

• relevant third parties where explicit consent is required.

V. Security of Personal Data

Saf Yapı takes appropriate technical and administrative measures suitable for the nature of the work in order to prevent unlawful processing of and unlawful access to personal data and to ensure its safekeeping. In this scope, for example:

• access authorization,

• maintenance of log records,

• use of up-to-date security software,

• network and application security measures,

• backup and data retention policies,

• employee confidentiality obligations and internal policy processes
  are implemented.

VI. Cookies

Saf Yapı may use cookies on its website in order to ensure the proper functioning of the website, remember user preferences, and perform performance and usage analyses. Mandatory cookies are used for the fulfillment of the core functions of the website. For optional cookies, explicit consent is obtained to the extent required by applicable legislation. A cookie preference management infrastructure is available on the website.

VII. Rights of the Data Subject

Pursuant to Article 11 of the KVKK, as a data subject, you have the right to:

• learn whether your personal data is being processed,

• request information if your personal data has been processed,

• learn the purpose of processing and whether it is used in accordance with that purpose,

• know the third parties to whom personal data is transferred domestically or abroad,

• request correction if personal data is processed incompletely or inaccurately,

• request deletion or destruction of personal data within the framework of the conditions set forth under the KVKK,

• request notification of such correction, deletion or destruction to third parties to whom the personal data has been transferred,

• object to the emergence of a result against you by means of analysis of the processed data exclusively through automated systems,

• request compensation for damages in case you suffer damage due to unlawful processing of your personal data.

VIII. Application Procedure

You may submit your requests regarding your rights under the KVKK to Saf Yapı Yatırım A.Ş. in writing or through other methods determined by the Personal Data Protection Board, in accordance with the applicable legislation.

Your application should include:

• name, surname, signature,

• Turkish ID number / passport number for foreigners,

• residence or workplace address for notification,

• e-mail address / telephone number for notification,

• subject of request.

IX. Contact Information

Data Controller: Saf Yapı Yatırım A.Ş.
Address: Ayazma Caddesi 37, Kağıthane 34406, Istanbul, Türkiye
E-mail: info@saf.com.tr
Phone: +90 (212) 287 44 77
Website: https://saf.com.tr/

X. Updates

Saf Yapı Yatırım A.Ş. may update this statement when necessary in line with the applicable legislation, company processes and technical infrastructure. The updated text shall become effective as of the date it is published on the website.