Information Text Regarding Processing of Personal Data

Acting in the capacity of data controller, we at AK FİNANSAL KİRALAMA A.Ş. (“Aklease”) take all necessary precautions in the stages of storage and processing of your data in compliance with the Personal Data Protection Law No. 6698 (“KVKK”) and the principle of protecting personal privacy and the fundamental rights and freedoms of individuals, and in its transfer in accordance with legislation.

We have prepared Our Processing of Personal Data Information Text (“Information Text”) to inform the concerned data subjects regarding the processing, storage, and transfer of your personal data within the scope of the Personal Data Protection Law (KVKK) and legal regulations. Within this page, you can access our information as data controller, purposes for which personal data will be processed, to whom and for what purpose it may be transferred, methods and legal conditions for the collection of personal data, and any information regarding your enumerated rights under KVKK.

We may make changes in the Information Text if the need arises. Any changes made will become valid upon publication.

Our Purposes for Processing Your Personal Data and Reasons for Legal Compliance

We have separated our purposes for the processing, storage, and transfer of your personal data in the course of our financial leasing activities and operational leasing activities we as Aklease carry out within the scope of the Financial Leasing, Factoring and Funding Companies Law No. 6361 and listed them grouped in tables below.

By picking the relevant section according to your business relationship with Aklease, you may access the information regarding the personal data we process, our purposes and the reasons for legal compliance.

Category of Personal Data	Purposes for Processing	Reasons for Legal Compliance
ID, Contact, Risk Management Information, Customer Operation Information, Professional Experience	To identify and confirm of your identity and address information, To verify and update customer information, To conduct risk analysis, To conduct the risk management and information security processes, To conduct Internal Inspection/ Investigation/ Intelligence activities, To conduct the analysis, reporting work deemed necessary within the scope of our company’s activities and conduct reviews, To conduct and inspect business activities, To conduct storage and archival activities, To conduct financial and accounting activities, To store and report the documents requested by BRSA, CBRT, MASAK, GİB, CMB, and BAT Risk Center, and other public institutions we have an obligation to provide information to, and to satisfy the information and document requests of the aforementioned institutions, To ensure all of our activities are conducted in accordance with legislation,	It is expressly provided for by the laws, It is necessary for compliance with a legal obligation to which us is subject, It is directly related to the establishment or performance of the contract,
ID, Contact, Risk Management Information, Customer Operation Information, Professional Experience, Financial Data	To perform our obligations and responsibilities regarding any and all products and services, foremost being financial leasing services, that we provide within the field of activity of our company, act as an intermediary for or conduct in the capacity of an agent and to conduct our agreement processes To conduct advertising, campaign, and promotional activities regarding our company’s products and services and contact you for these purposes, To make product sales, send bulletins, provide information, and conduct marketing activities, To conduct customer satisfaction studies and share offers regarding services, To conduct customer relations management processes, To conduct product and service purchase processes and their related support services, To improve product and service quality, To conduct investment processes,	It is directly related to the establishment or performance of the contract, It is necessary for compliance with a legal obligation to which us is subject, It is necessary to process your data for our legitimate interests provided that it does not violate your fundamental rights and freedoms
ID, Contact, Risk Management Information, Customer Operation Information, Professional Experience	To ensure any and all products and services we provide within the scope of Financial Leasing, Factoring and Funding Companies Law and other relevant legal regulations can be maintained by affiliates and business partners, To be able to make developments in accordance with the needs of the customers and the sector, To conduct other analysis and reporting work deemed necessary within the scope of financial activities, and conduct reviews, To conduct strategic planning activities, To conduct social responsibility and civil society activities, To receive and evaluate recommendations regarding the improvement of business processes	It is necessary to process your data for our legitimate interests provided that it does not violate your fundamental rights and freedoms
ID, Contact, Risk Management Information, Customer Operation Information, Professional Experience	To pursue legal matters, To follow up on requests and complaints, • To conduct legal processes regarding outstanding debts, conduct control activities	Data processing is necessary for the establishment, exercise, or protection of any right
Identity, Contact, Risk Management Information, Customer Operation Information, Professional Experience	To offer in a personalized manner Products and services that Aklease offers, acts as an intermediary for or conducts in the capacity of an agent, communicate with you in this regard upon conducting marketing analyses and models To share personalized offers regarding our products and services, To conduct activities for the cross-selling of our products and services, To conduct customer acquisition activities, To conduct analysis and modelling activities deemed necessary within the scope of our company’s activities and conduct reviews Conducted in a relevant, limited, and proportionate manner and in accordance with the principles laid out in Article 4 of KVKK with the goal of conducting activities aiming for customer satisfaction.	If there is explicit consent
Special Categories of Personal Data	Purposes for Processing	Reasons for Legal Compliance
Biometric Data	In case of the establishment of a contractual relationship by remote identification method and establishment of contractual relations in electronic environment method	If there is explicit consent
Criminal Convictions, Associations, Foundations	To conduct investigations, store and report the documents requested during the pursuit of legal matters by BRSA, CBRT, MASAK, GİB, CMB, and BAT Risk Center, and other public institutions we have an obligation to provide information to, and to satisfy the information and document requests of the aforementioned institutions,	Data processing is necessary for the establishment, exercise, or protection of any right, It is expressly provided for by the laws, It is necessary for compliance with a legal obligation

Processes Regarding Risk Group

Partnerships where you, your spouse, your children and persons in question are board members or general managers of, or that they or a legal person alone or jointly, directly or indirectly control or participate with unlimited liability in, and partnerships where a bank’s qualified shareholders, board members and general manager, alone or jointly, directly or indirectly control or participate with unlimited liability in or are the board members or general manager of, and natural and legal persons that are in surety, guarantee or similar relationships which due to its size will in the case of insolvency of one will result in the insolvency of one or multiple others constitute a risk group.

Alongside these, other natural and legal persons that will constitute a risk group are determined by the Banking Regulation and Supervision Agency.

Within the scope of our above explanations, even if you are not our customer, especially within the scope of the Financial Leasing, Factoring and Funding Companies Law No. 6361 and other relevant legislation, our Company may process your personal data to identify, monitor, report on and investigate the risk group you may join for the determination of credit limits in relation to financial leasing and operational leasing transactions done in relation to a risk group.

Data Controller and Data Processor

Data Controller

Data Controller is the natural or legal person who determines the purposes and methods of processing personal data and is responsible for the establishment and management of the data filing system. In this instance our Company is the Data Controller for the data of our customers, visitors, and employees.

Below you may access the information of our Company, which is acting in the capacity of Data Controller.

Title	AK FİNANSAL KİRALAMA A.Ş.
Address	Sabancı Center Kule 2 Kat:8-9 34330 4.Levent/İstanbul
Central Registration System / Registry No	0178007230900031

Our group companies that are included in the Information Text are listed below.

Akbank T.A.Ş.

Aköde Elektronik Para ve Ödeme Hizmetleri A.Ş.

Ak Yatırım Menkul Değerler A.Ş.

Ak Portföy Yönetimi A.Ş

Insurance companies where we provide services in an agent capacity are as follows;

Aksigorta A.Ş.

Data Processor

“Data Processor” is the natural or legal person who processes personal data on behalf of the data controller upon its authorization. These persons may also be a separate natural or legal person authorized by the data controller to process personal data.

Your Personal Data and Methods of Collection

Personal data processed by our Company have been listed grouped in the table below. Hereby you may access information regarding personal data we process.

Your Personal Data

Category of Personal Data	Personal Data
ID information	Ex. Name and Surname, Republic of Türkiye Identity Number, sex, nationality, place of birth, date of birth, marital status.
Contact information	Ex. E-mail address, home/work address, phone number.
Risk management information	Ex. Income information, asset revenue information, education information, demographic information, opinion information drafted by our relevant branch, mode of work, duration of work, information obtained from KPS and APS ,KKB, BAT Risk Center Information
Customer operation information	Ex. credit information, deposit information, overdraft account information, credit card limit and balance information, deposit account activities, loan payment activities, customer data bank(“CDB”) information.
Risk Monitoring and Tracking Information	Debt information, lateness and number of late days information, maturity information, information regarding related persons, asset (vehicle and deed) information.
Visual and Auditory Records	Call center audio records, camera recordings, your visual and audio data, especially photographs
Legal Transaction	Information in correspondences with judicial authorities, information in case files etc.
Location	Location information of your current location.
Marketing	Cookies, pages viewed on banking apps, purchase history information, information obtained by polls and campaign work etc.
Professional Experience	Diploma information, classes attended, on-the-job training information, certificates, transcript information, workplace mode and duration of work etc.
Other	Demographic information, income information, asset information, reporting data

Our Methods of Collection

As Aklease, we collect your personal data in written, verbal, and visual form, with electronic and physical methods, in automated, semi-automated and nonautomated ways.

Your personal data we obtain in nonautomated or semi-automated ways are as follows;

From the information and documents you provide to Aklease during physical (branch etc.) product/service/campaign applications,
Indirectly through our representatives (Ex. proxy, guardian, trustee etc.),
Information provided by your place of employment (for example to confirm income information).

We can obtain information about you through automated means and technical support;

Through the applications you make via digital mediums (website, customer contact center etc.)
Public authorities where your ID and address information are registered and databases of other institutions (Ex. Turkish Identity Information Sharing System (“KPS”), Address Sharing System (“APS”),
Public institutions and organizations where your credit score information is available (EX. Credit Bureau (“KKB”), Banks Association of Türkiye Risk Center (“BAT Risk Center”),
Social networks and other technology providers (for example when you reach us through our advertisements),
Companies providing data services that we receive reporting services from to better understand our customers and evaluate general trends.

Recipients of Transfers

Primarily due to our obligations under the Financial Leasing, Factoring and Funding Companies Law and other legal provisions we are subject to, in cases where the below listed purposes of processing are fulfilled, personal data in the care of Ak Finansal Kiralama A.Ş. may be transferred in a relevant, limited and proportionate manner with the goal of conducting financial activities.

In this section we are listing the organizations we make transfers to and our purposes for the transfers.

Organizations	Our Purposes
To institutions legally entitled to receive information (ex. BRSA, CMB, CBRT, MASAK, SGK, İYS, Credit Bureau, Risk Center, Association of Financial Institutions, Banks Association of Türkiye, and other authorized institutions and organizations),	For the purpose of risk management, conducting risk monitoring activities and legal reporting, conducting regulation and supervision activities, running complaint and legal processes,
To our domestic/foreign affiliates, shareholders, third parties whose services are obtained to conduct our activities and cooperated institutions	For the purpose of establishing, running, and terminating a service relationship with the customer, conducting a credit evaluation, preparing a consolidated financial table, to conduct risk management and internal inspection activities
To companies we are an agent of	For the purpose of carrying out insurance transactions
To external service providers, program partners, parties we conduct joint brand work with and third parties they cooperate with, domestic/foreign banks and financial institutions with which we enter into a credit relationship with, independent audit companies, law firms	For the purpose of running of activities, being able to receive support and consultancy services
To banks and financial institutions we are in a financial relationship with, in relation to our financial activities	For the purpose of conducting the investigations regarding the controls done during and after the process concerning prevention of laundering the proceeds of crime and funding of terrorism
To asset management firms and potential buyers in sales of company receivables	For the purpose of being able to conduct valuations in the scope of sale of company receivables and assets and including but not limited to transfers made to natural and legal persons transfers to whom are mandatory for legal compliance reasons.

Rights of the Data Subject

Your Rights Enumerated Under Article 11 of KVKK

Pursuant to the provisions under KVKK, you may exercise your below listed rights by applying to Ak Finansal Kiralama A.Ş.:

To learn whether your personal data are processed or not,
To demand for information as to if your personal data have been processed,
To learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
To know the third parties to whom your personal data are transferred in country or abroad,
To request the rectification of the incomplete or inaccurate data, if any,
To request the erasure or destruction of your personal data,
In case personal data are processed incompletely or inaccurately, to request reporting the correction and / or deletion or destruction of personal data have been transferred to third parties to whom personal data are transferred,
To object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,
To claim compensation for the damage arising from the unlawful processing of his/her personal data.

Any requests made in this regard will be finalized by Ak Finansal Kiralama A.Ş. free of charge in thirty days at the latest. However, if a fee is stipulated by the Personal Data Protection Board our Company may charge a fee it determines

Meeting Your Requests

KVKK gives data subjects the right to request information on which personal data are processed in which processes and the current status of such data.

Pursuant to Article 13 of KVKK regulating "Request to the Data Controller", the data subject is required to make the requests relating to the implementation of this Law to the data controller in writing or by other means to be determined by the Board. For this reason, for your requests to be evaluated they must be submitted in written form.

Requests from data subjects are answered by our Company within 30 days. In this context, we would like to remind you that your written applications regarding this subject may be accepted following the identity verification to be made by us.

Therefore, in order for your request to be evaluated, you may submit your application in writing to our branches, to our Head Office address (Sabancı Center Kule 2 K:8-9 34330 4. Levent/Beşiktaş-İstanbul), through a notary public or to akfinansalkiralama@hs03.kep.tr with secure electronic signature.

If you would like to get in touch with us regarding your requests, if you wish you may submit your applications and requests using the Data Subject Request Form, listed on our website under the information and request forms, to;

our branches, to Sabancı Center 34330 4.Levent/Beşiktaş-Istanbul, or through a notary public, alongside your identity documents and the petition containing your request
akfinansalkiralama@hs03.kep.tr with secure electronic signature,
our branches directly, our Head Office address (Sabancı Center Kule 2 K:8-9 34330 4. Levent/Beşiktaş-İstanbul),
or through a notary public.

If you wish to withdraw the Explicit Consent you have given to our Corporation, you may submit your request in writing to our Head Office or branches.

Personal Data Protection Law

Your safety and personal privacy are always our top priority as Aklease. As a result of the legal regulation on information security, to which we give great import to, Personal Data Protection Law No. 6698, drafted in order to protect the fundamental rights and freedoms of individuals and their personal data has come into force and we would like to inform you on the scope of this law.

What is KVKK?

Personal Data Protection Law (KVKK) was adopted on 24 March 2016 by the Grand National Assembly of Turkey and came into force after being published in the Official Gazette No. 29677 dated 07 April 2016.

The Law aims at the compliance of all data processing persons and corporations within the framework of the fundamental objectives such as ensuring the confidentiality, protection, and prevention of unauthorized use of personal data. Our Corporation is obligated to obey this Law, as is every corporation, and any data processed in the processes of our Corporation falls under this scope.

What is Personal Data?

All data or sets of data that make the person directly or indirectly identifiable are considered personal data. Identifying information directly belonging to the person or created on behalf of the person such as name, surname, place/date of birth, phone number, resume, photograph, voice recording can be given as examples. Data identifying the person such as customer number, contract number generated for company transactions are also considered as Personal Data.

What is Data Processing?

Any operation performed on personal data is considered as "data processing". Therefore, archival, storage, modification, reorganization, disclosure, transfer, analysis, and classification of the data fall under the scope of data processing.

All data controllers only have the right to process data when the legal compliance conditions in paragraph 2 of Article 5 of KVKK occur or when the data subject gives explicit consent.

If one of the conditions listed below is present it is possible to process personal data without seeking the explicit consent of the data subject:

KVKK Article 5/2 (a) It is expressly provided for by the laws.
KVKK Article 5/2 (b) It is necessary for the protection of life or physical integrity of the person himself/herself or of any other person, who is unable to explain his/her consent due to the physical disability or whose consent is not deemed legally valid.
KVKK Article 5/2 (c) 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.
KVKK Article 5/2 (ç) It is necessary for compliance with a legal obligation to which the data controller is subject.
KVKK Article 5/2 (d) Personal data have been made public by the data subject himself/herself.
KVKK Article 5/2 (e) Data processing is necessary for the establishment, exercise, or protection of any right.
KVKK Article 5/2 (f) Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.

Who is the Data Subject?

"Data subject" is one of the expressions frequently used in the Law and in our corporate policies. It denotes natural persons whose data is processed. All of our current and potential customers, and all natural persons who make any transaction with our Corporation are data subjects.

Any natural person who is not our customer, who has been or will be a party to any security transaction (surety, guarantor, pledgor/assignor, spouse in cases where consent is required in accordance with the legislation), a natural person who is a shareholder, final natural beneficiary, board member or representative/agent of any company that is our customer may also be a data subject.

Policies

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