Zeca Bank

Personal Data Protection Law

The purpose of this Information on the Protection and Processing of Personal Data (Information) is to fulfill the obligation to inform, imposed by Article 10 of Law No. 6698 on the Protection of Personal Data (Law on the Protection of Personal Data), regarding the use of personal data obtained and/or received from third parties during the use of the website located at www.zecabank.com (Portal). Furthermore, it aims to transparently inform Users about the collection methods, processing purposes, legal reasons, and rights of personal data collected by our company or entered into the Portal by Users through their own positive actions. Providers of products and services in various categories and potential buyers meet and shop through the secure environment provided by (ZECABANK®). During this activity, personal data is processed as required for the use of (ZECABANK®) functions, as specified in this Information text. (ZECABANK®) invests in technology, continuously renews itself to better serve its Users online through innovative product and service applications, and strives to provide the best possible service. It takes the highest possible security measures to ensure the lawful collection, storage, and sharing of personal data, and to protect their privacy. To achieve this goal, Users' personal data is processed within the scope and conditions detailed below.

(ZECABANK®) may update and amend these Disclosure provisions at any time by publishing them on the Portal.

Updates and changes made by (ZECABANK®) will be effective from the date they are published on the Portal.

a) Data Controller: In accordance with the Personal Data Protection Law, your personal data will be collected and processed by (ZECABANK®), as the data controller, within the scope described below.

b) Collected Personal Data (ZECABANK®) collects various static (fixed) and dynamic (variable) data from Users through the methods specified below.

The data collected by (ZECABANK®) depends on the services and features used by Users. The data processed within the scope of the Services offered by (ZECABANK®) and considered personal data under the Personal Data Protection Law are listed below in groups. Unless explicitly stated otherwise, the terms "personal data" and "special categories of personal data" within the scope of the terms and conditions presented in this Information include the following information:

Name and Contact Information: First name, last name, mobile phone number, home phone number, work phone number, address, email address, billing information, Turkish ID number (national identity number), a photocopy of the ID, and other similar documents.

Identity Verification Information: User membership information, passwords used to verify identity and access the account, Username, contact information, password hints, User ID numbers, and job posting numbers.

Demographic Data: Date of birth, age, gender, marital status, education level, occupation, interests, and preferred language. Usage Data and Favorites: Data collected from your devices through various software and technological tools, including the reasons for calling (ZECABANK®) or the Call Centers, voice recordings, real estate index, appraisal, date and time of product use, the province, district, and neighborhood where the index query was created, chassis and license plate numbers for obtaining the damage inquiry report generated by the Insurance Association and Supervision Center system in case of a successful payment transaction, products viewed on the Portal, square meter prices, data specified in the relevant survey or banner for domestic or international companies to direct users to the relevant product through modules such as surveys and banner redirection, and for product suppliers to contact the user, information requested by the bank regarding the offer they wish to receive for real estate offered by banks through the real estate module, data entered to obtain information about the projects of contractor companies through the Portal for real estate projects, usage habits for the development and customization of services (prioritization options, preferred response method and date, channels responded to, last Portal login date, Doping ad type used, post type, websites visited). number of pages viewed, duration of visit and number of goal completions, user actions taken while using the services, search terms entered, categories of products and advertisements visited, errors and similar issues that occur during the use of the service in order to ensure the smooth provision of the services.

Location Data: User

This includes data related to the precise or approximate location of customers. Location data extracted from GPS data and IP and port addresses is used when the user, while using (ZECABANK®) mobile applications, searches for and places ads near their location, and with the user's consent.

Payment Data: Data such as agency and customer invoice and payment information (name, surname, billing address, Turkish ID number, tax identification number), invoices sent to members and receipts for payments received from members, payment number, invoice number, invoice amount, and invoice date.

Content Data: Documents requested to prove the brand is not counterfeit (invoice, warranty certificate, etc.), documents demonstrating ownership of the product or authorization over the product (such as title deed, license, trademark registration certificate), ad information, membership information, notification description, solution description, satisfaction, notification reason, customer rating, renewal date, ad rejection reason, feedback, document submission reason, error content reported during the use of the Service, interim notification status, interim notification, and similar data such as the search reason. Survey Responses: Responses to periodic surveys conducted by (ZECABANK®) within the Portal, as well as responses to surveys conducted by individuals and legal entities with whom (ZECABANK®) collaborates.

Fingerprint: You can choose to log in using your fingerprint instead of a password on the mobile application. Your fingerprint will not be transmitted to (ZECABANK®) in any way during the process, which will be performed by logging in using your fingerprint in the settings section of your mobile device. (ZECABANK®) will only receive a verification or error message from your mobile device, and you will be prompted to log in to the application based on this. If you do not receive confirmation, you will be directed to repeat the process or log in another way. You can disable the fingerprint login option at any time in the settings section of your device.

On-Site Messages Caught by Filters or Containing Content Violating the Terms of Use: These are the on-site messages sent by users to each other to ensure secure communication and commerce, but only those caught by filters or identified as containing content that violates the terms of use following a complaint/report.

Where is Personal Data Stored and Processed? Your personal data we obtain may be stored domestically or abroad in another country where (ZECABANK®) or its affiliates, subsidiaries, or collaborating service providers have facilities, and may be processed in accordance with and in proportion to the purposes set forth in this Information. Your personal data collected within the scope of this Information will be processed in accordance with the provisions herein and the legislation in force in the country where the data is stored and processed, and within the prescribed security measures. c) For What Purposes Will Personal Data Be Processed: In line with the purposes set forth in this Information and the Membership Agreement, your personal data will be processed in accordance with the Principles and Processing Conditions regulated by Law on the Protection of Personal Data and for the purposes detailed below:

Name and Contact Information: Internal evaluation, communication, user registration, obtaining potential customer information, improving after-sales processes, business development, collection, customer portfolio management, promotion, analysis, complaint management, managing customer satisfaction processes, marketing, advertising, research, billing, event notification, execution of operational activities, measurement and development of service quality, auditing, control, optimization, customer verification, marketing, sales, advertising, after-sales services, fraud detection and prevention;

Identity Verification Information: User registration, problem/error reporting, control, development and execution of operational activities, improvement of after-sales processes, business development, collection, internal evaluation, customer portfolio management, measurement of service quality, communication, optimization, moderation, control, risk management, audit, customer verification, fraud detection and prevention; Demographic Data: Promotion, internal evaluation, analysis, communication, development of after-sales processes, business development, collection, usage data and interests, favorites, marketing, sales, advertising, audit and control, risk management, development of after-sales processes, business development, collection, internal evaluation, customer portfolio management, after-sales services, measurement and development of service quality, communication, complaint management processes, execution and development of operational activities, registration, problem/error reporting;

Usage Data and Favorites: User registration, problem/error reporting, control, inquiry, execution and development of operational activities, after-sales services and sales results.

Developing post-transaction processes, business development, collection, internal evaluation, online behavioral advertising and marketing, customer portfolio management, measuring and improving service quality, communication, optimization, auditing, risk management and control, promotion, analysis, identifying interests, scoring, profiling, marketing, sales, advertising, communication, and conducting complaint management processes, registration, problem/error reporting;

Location Data: Enabling the use of location-based or location-related Portal functions, auditing and control, and risk management; Payment Data: Managing the billing process, accounting, developing post-transaction processes, business development, collection, internal evaluation, scoring, profiling, customer portfolio management, after-sales services, communication, marketing, auditing, and control, and processes conducted with payment service providers;

Content: Business development, optimization, customer portfolio management, auditing, and control, developing operational activities, business development, promotion, internal evaluation, customer management, analysis, scoring, profiling, developing post-transaction processes, collection, after-sales services, communication, measuring and improving service quality, and conducting complaint management processes; Survey and Test Responses: Information requested from users who respond to periodic surveys or tests organized by (ZECABANK®) within the Portal, and the use of Portal functions by (ZECABANK®) and the real and/or legal persons it cooperates with to fulfill these functions by (ZECABANK®) and third real and legal persons it cooperates with within the scope of all processing activities specified above in accordance with the purposes of use of the Portal, in order to conduct direct marketing to these users, perform statistical analysis, improve their processes and create a database; (ZECABANK®) will process your personal data in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698 for the purposes of fulfilling legal and commercial obligations within the framework of contracts or activities conducted with third parties in a business relationship with (ZECABANK®) and obligations arising from legal regulations, establishing rights, protecting rights, conducting commercial and legal assessment processes, conducting legal and commercial risk analyses, carrying out legal compliance processes, concluding tests to determine whether the user can obtain documents specified in relevant legal regulations, conducting financial affairs, fulfilling legal requirements, fulfilling the decisions of authorized institutions, organizations, and authorities, and responding to their requests.

On-Site Messages Caught by Filters or Containing Content That Violate the Terms of Use: Our messaging service is provided to facilitate communication between our users and the other party in purchasing, selling, and renting transactions. In these messages; Based on the legitimate interest stipulated in Article 5 of the Law, messages that contain insults, violate public morality, raise suspicion of fraudulent advertisements, may lead to unfair competition, violate personal rights, intellectual and industrial property rights, or otherwise violate the law are filtered and moderated. On-site messages that violate the Terms of Use may be reviewed and blocked.

Personal Data Retention Period: (ZECABANK®) will retain the personal data it obtains for the period necessary for the purpose for which they are processed, in accordance with the terms set forth in this Information and the Membership Agreement, to ensure that Users can make the most of the Service, and to fulfill its obligations arising from the nature of the Membership Agreement. In addition, (ZECABANK®) will retain personal data for the period specified in the relevant legislation, limited to the purpose of conducting administrative or judicial proceedings in the event of any dispute arising from the Membership Agreement. d) To Whom and For What Purpose Can Processed Personal Data Be Transferred: (ZECABANK®) may process the User's personal data and new data obtained using these personal data or personal information entered into the Portal by the Users' own positive actions, primarily to fulfill the requirements of the Membership Agreement and the Services, to improve the User experience (including improvement and personalization), to ensure the security of the Users, to detect and prevent fraud, to improve the Services, to carry out inquiry activities that may be important for the Services, to conduct operational evaluation research, to fix errors, to verify User identities, to improve system performance, to achieve any of the purposes specified in the processing purposes section above.

In order to be able to do so, the User shares the Personal Data with outsourcing service providers, business partners, suppliers, appraisal and real estate consultancy firms; with corporate members, cargo companies, law firms, research companies, call centers, software companies for complaint management and ensuring security, agencies, consultancy companies, companies in the printing sector, banks for real estate sales by banks, contracting companies related to real estate projects, social media channels, third parties including certification institutions, and with authorized institutions, organizations, authorities, administrative and judicial bodies within the scope of legal obligations. In addition, the User's Name and Contact Information will be shared with payment institutions for the purpose of identity verification in accordance with the payment institution framework agreement that the User will approve at the payment stage and in accordance with the Regulation on Measures for Preventing the Laundering of Proceeds of Crime and the Financing of Terrorism published in the Official Gazette dated January 9, 2008 and numbered 26751. Your personal data obtained through cookies placed on your device may be shared with third parties within the scope and for the purposes specified in this Information. (ZECABANK®) may transfer personal data to third parties domestically and internationally, limited and proportionate to these purposes, within the categories and purposes specified above.

d) Method and Legal Reason for Collecting Personal Data: (ZECABANK®) collects your personal data to operate more effectively and provide you with the best experience. (ZECABANK®) collects your personal data directly from you (the data subject), by an agent acting on your behalf, and/or by persons authorized to act using the following methods:

Data You Provide Directly to (ZECABANK®): This refers to personal data provided by Users to (ZECABANK®) on their own initiative for the performance of the Service and before or during use of the Portal. This personal data includes all personal data provided directly by Users to (ZECABANK®) as a result of their positive actions. For example, name-surname, contact information, identity information, survey responses, demographic data, and content information are included in this type of data.

Data We Obtain When You Use Our Platform: This includes personal data regarding Users' usage habits, collected through specific software or technological tools during the service provided by (ZECABANK®). For example, location data and favorites, as well as interests and usage data, are included in this type of data. (ZECABANK®) associates the site behavior of users, even if they are not members, with a cookie in the browser and collects usage data such as the number of pages viewed, duration of visit, and number of goal completions for the purpose of online behavioral advertising and marketing. How to manage cookies is also specified in our Cookie Policy. Your personal data collected through these methods is subject to the provisions of Articles 5 and 6 of Law No. 6698; It is based on the legal grounds that; It is expressly prescribed by law, It is mandatory to fulfill its legal obligation (Legal regulations regulating electronic commerce activities, fiscal and tax matters, consumer protection and other issues), It is directly related to the establishment or performance of the contract and processing is necessary (Membership Agreement, Terms of Use and performance of the contract based on them, establishment and protection of rights), Processing is mandatory for its legitimate interest (ZECABANK® collects the data necessary to perform services, especially to prevent fraud in its activities related to the Portal), It has been made public by you, Processing is mandatory for the establishment, exercise or protection of a right, Your explicit consent is present. Your personal data collected through these methods may be processed and transferred for the purposes specified in this Information within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698. The legal bases for collecting personal data are; The Membership Agreement, Terms of Use, and the performance of the contract based on these, as well as the establishment and protection of rights, are based on legal regulations governing electronic commerce activities, fiscal and tax matters, consumer protection, and other matters. (ZECABANK®)'s legitimate interest in collecting the data necessary for the performance of its services, particularly to prevent fraud, in its Portal-related activities.

e) Our Measures and Commitments Regarding Data Security: (ZECABANK®) is committed to securely protecting personal data. We will prevent unlawful processing and access of personal data.

Technical and administrative measures are implemented using various methods and security technologies to ensure the appropriate level of security to prevent unauthorized access and to ensure the protection of personal data. (ZECABANK®) will not disclose the personal data it obtains to anyone in violation of this Information and the provisions of Personal Data Protection Law No. 6698, and will not use it for purposes other than processing. (ZECABANK®) declares that if Users' personal data is shared with outsource service providers pursuant to this Information, it will carry out the necessary warning and inspection activities to ensure that such outsource providers also comply with the commitments set forth in this article. If links to other applications are provided through the Portal, (ZECABANK®) bears no responsibility for the privacy policies and content of the linked applications. The User undertakes that the information provided in this Information is complete, accurate, and up-to-date, and that they will immediately update this information at www.zecabank.com if any changes occur. (ZECABANK®) will not be held responsible if the User fails to provide up-to-date information. f) The Rights of the Personal Data Owner Listed in Article 11 of Law No. 6698. As personal data owners, if you submit your requests regarding your rights to (ZECABANK®) using the methods set out below, (ZECABANK®) will finalize the request as soon as possible and within thirty days at the latest, depending on the nature of the request. No fee will be charged for the response up to one page. A processing fee of 10 Turkish Lira will be charged for each page over ten pages. If the response to the application is given on a recording medium such as a CD or flash drive, the fee that (ZECABANK®) may charge will not exceed the cost of the recording medium. In this context, personal data owners; He/she has the right to learn whether his/her personal data is processed, to request information if his/her personal data has been processed, to learn the purpose of the processing of personal data and whether they are used in accordance with their purpose, to know the third parties to whom personal data is transferred at home or abroad, to request rectification in case personal data is processed incompletely or incorrectly and to request notification of the operation made in this context to third parties to whom personal data is transferred, to request deletion or destruction of personal data in case the reasons requiring processing are eliminated, despite having been processed in accordance with the provisions of Law No. 6698 and other relevant laws, and to request notification of the operation made in this context to third parties to whom personal data is transferred, to object to the emergence of a result to his/her detriment by analysis of processed data exclusively through automated systems, to request compensation in case he/she suffers damages due to unlawful processing of personal data. You can submit your request regarding exercising your rights specified above, in Turkish; You can send your request in writing to (ZECABANK®)'s address info@zecabank.com, along with documents proving your identity, through a notary, by registered e-mail to the e-mail address, or by other methods determined by the Personal Data Protection Authority. (ZECABANK®) reserves the right to verify your identity before responding.