PROTECTION OF PERSONAL DATA

Taking into consideration the security of our valuable customers, we, as Deniz Gayrimenkul Yatırım Ortaklığı A.Ş. (“the Company”), would like to inform you about “the Law on Protection of Personal Data” introduced for protecting the privacy of personal life, fundamental rights and freedoms.

Our objective is to provide you the most transparent information, for customer satisfaction purposes, on how your personal data is obtained, the purposes of processing such data, the related legal reasons and your rights.

In terms of all kinds of personal and biometric data, data of private features including health data (“Data”) you conveyed to our Company or our Company obtained within the framework of its procedures and transactions, as per the Law on Protection of Personal Data No. 6698 which entered into force on 7th of April, 2016, our Company Deniz GYO A.Ş., as Data Controller, may obtain, record, maintain, update personal data to continue its services within the scope of the law, reorganize and disclose, transfer and share data to/with third parties in cases and to the extent permitted by legislation, transfer, convey, share, classify, make anonymous and process the data in other formats prescribed in the law.

The purposes and legal reasons for processing your personal data include providing services related to real estate products as well as carrying out, executing and developing related transactions within the scope of the Communiqué on Principles Pertaining to Real Estate Investment Trusts and other legislation, carrying out promotion, marketing and campaigns for these products, fulfilling terms in agreements that you and/or we signed, carrying out intelligence, data research and credibility assessments, planning, statistics and customer satisfaction studies, maintaining security, complying with the anti-money laundering and national and international legislation, complying with information keeping, reporting, notification requirements envisaged by CMB, FCIB, Revenue Administration, Under-secretariat of Treasury and other authorized bodies, and provide better and reliable services and to sustain this uninterruptedly.

Method of collecting personal data;your personal data may be collected automatically or manually, in writing or verbally or in electronic form through existing agreements, our corporate website and/or other similar channels.

Persons/institutions to whom your personal data may be transferred for purposes stated above: your personal data may be shared with our Company’s shareholders and their subsidiaries and institutions, employees, officers, legal, financial and tax consultants, auditors, consultants, institutions and parties from which the Company receives services that complete or extend its operations, which the Company collaborates with as well as support service institutions and contracted institutions, entities established abroad or domestically, authorities such as the CMB, FCIB, revenue administration, under-secretariat of Treasury, SGK, ministries, authorized public bodies like judicial bodies and third parties to whom you explicitly give consent to.

Your rights as per article 11 of Law; By applying to our Company, you have the right to a) query whether your personal data were processed, b) request information if your personal data was processed, c) learn the purpose of the processing of your personal data and whether it was used duly, ç) learn third parties domestic and abroad to whom your personal data was transferred, d) ask for the correction of any wrong or missing personal data, e) request the erasing or termination of your personal data as per terms given in article 7 of Law, f) request that the transactions done as per paragraphs (d) and (e) above by means of transferring your personal data to third persons be notified to you, g) object to any situation against your favor as your personal data are analyzed by exclusively automated systems and ğ) claim compensation for losses in case of any loss due to processing of your personal data by violation of Law.

Execution of your rights is possible after the enforcement date of the regulation which is 07.10.2016 and our rights are reserved to request costs to be incurred by our Company to fulfill your requests from you as per tariff given in article 13 under Law on Protection of Personal Data entitled “Applying to data controller”.

Conditions that do not require consent, as per paragraph 2 of article 5 of the Law numbered 6698 on Protection of Personal Data, on condition that it is explicitly foreseen in law and be directly linked to establishment or execution of an agreement; in cases when personal data belonging to agreement parties needs to be processed, data keeper Deniz GYO A.Ş is obliged to fulfill this legal obligation, when it is made public by the related person, data processing is obligatory to establish, use or protect a right, data processing is obligatory for the legal benefits of the Company as the data keeper on condition that fundamental rights and freedom of persons are not harmed, the Company reserves the right to process the personal data without receiving explicit consent.

As per principle of clarity in texts that are published or disclosed or given in Laws, in order to fulfill Data that is obliged to be disclosed to public as per terms of Law or given in official registries or balance sheets and activity reports and for the Company to fulfill legal obligations resulting from legislation; and/or data disclosure, usage and transfers are not subject to confidentiality obligation of the Company in order to fulfill data transfer obligation to persons who may request the secrets due to legal reasons and/or Laws; and the Company is authorized to disclose and give to related persons, process and transfer said data without any need for a separate letter of consent.

Our Legal Obligation of Keeping Documents and Information; as per article 82 of the Turkish Commercial Code numbered 6102, it is a legal obligation to keep your information and documents by our Company for 10 years. If you request the deletion or termination of your personal data, your request shall be fulfilled at the end of 10 years. Even if the said duration passes; your data might be made anonymous in line with legal benefits of our Company to conduct analysis and assessments to ensure that our Company’s services are improved and more secure. Your personal data out of the scope mentioned above shall be deleted upon your request.