INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA AND COOKIE POLICY
Website: https://www.turkishmenkuldegerler.com
1. Why are we sending this notice?
As TURKISH MENKUL DEĞERLER ANONİM ŞİRKETİ (“TMD”), we have prepared this information notice in our capacity as the Data Controller pursuant to the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the Communiqué on the Principles and Procedures to be Followed in Fulfilling the Obligation to Inform published in the Official Gazette dated 10.03.2018 and numbered 30356.
Within the scope of Article 10 (“Obligation of the Data Controller to Inform”) and Article 11 (“Rights of the Data Subject”) of the KVKK, and Articles 4 and 5 of the Communiqué, this notice has been issued to inform you about:
- for what purposes your personal data will be processed,
- to whom and for what purposes your processed personal data may be transferred,
- the method and legal basis for collecting your personal data, and
- your other rights listed under Article 11 of the
With this notice, we also aim to inform you, in relation to the processing of personal data obtained automatically via the placement of cookies used on our website on your device, about (i) which types of cookies we use for which purposes and (ii) how you can manage these cookies.
2. What do we inform you about?
- Which of your personal data are collected
- For which purposes your personal data are processed
- With whom and for which purposes your personal data are shared
- The method and legal basis for collecting your personal data
- Disposal (deletion/destruction/anonymization) of your data
- Your rights under the KVKK
3. General information about cookies and cookie types that may be used on the website
What are cookies and why are they used?
Cookies are small text files stored on your device or on a network server via browsers by the websites you visit. For more detailed information about cookies, you may visit: http:// www.aboutcookies.org
The main purposes for using cookies on our Website are listed below:
- To improve the services offered to you by increasing the functionality and performance of the website,
- To improve the website and offer new features through the website, and to personalize the offered features according to your preferences,
- To ensure the legal security of the website, you, and
Cookie types by duration (the following types are used on the website)
Session Cookies | Session cookies are temporary cookies used during our visitors’ visit to the website and deleted after the browser is closed. The main purpose of using such cookies is to ensure that the website functions properly during your visit. For example, they enable you to fill in online forms consisting of more than one page. |
Persistent Cookies | Persistent cookies are used to increase the functionality of the website and to provide our visitors with faster and better service. These cookies are used to remember your preferences and are stored on your device via browsers. Some types of persistent cookies may be used to provide you with tailored recommendations, taking into account matters such as your purpose of using the website. Thanks to persistent cookies, if you revisit the website with the same device, it is checked whether there is a cookie created by the website on your device; if so, it is understood that you have visited the website before, and the content to be delivered to you is determined accordingly—thus providing you with a better service. |
Cookie types by purpose of use (the following types may be used on the website)
Mandatory Cookies | |
Technical Cookies | Technical cookies ensure the operation of the website and help identify non-functioning pages and areas of the website. These cookies are necessary for the operation of the website. They are used mandatorily in order to provide an information society service requested by the user (such as logging in, filling in forms, remembering privacy preferences). In general, they may be considered as cookie types that rely on processing conditions other than explicit consent. |
Authentication Cookies | If visitors log in to the website using their passwords, these cookies identify that the visitor is a website user on each page visited, preventing the user from re-entering the password on each page. |
Flash Cookies | Cookies used to activate image or audio content on the website. |
Functional Cookies | Cookies used to remember users’ preferences when they visit different pages of the website. For example, remembering your selected language preference. |
Personalization Cookies | Cookies used on websites or applications (including desktop, mobile, or IoT applications) for personalization and remembering preferences. These cookies are used to provide functionality other than mandatory cookies. Where it is not clear that the data subject has explicitly requested the information society service, reliance on explicit consent will be required. |
Performance Cookies | |
Analytical Cookies | Analytical cookies enable the production of analytical results such as the number of visitors to the website, identification of pages viewed on the website, website visit times, and scrolling movements on website pages. |
Advertising/Marketing Cookies | Advertising and marketing cookies aim to display advertisements to users based on their personal interests by tracking users’ online movements in the internet environment and determining their areas of personal interest. |
Additional information on cookies requiring explicit consent
Social Plugin Tracking Cookies | Many social networks offer social plugin modules that website owners can integrate into their websites to provide certain services that may be considered “explicitly requested” by their members. However, these modules may also be used to monitor members/non-members via third-party cookies for additional purposes such as behavioral advertising, analytics, or market research. Therefore, they are subject to explicit consent. |
Online Behavioral Advertising Cookies | Cookies used for behavioral advertising require explicit consent. In this case, the requirement for explicit consent naturally covers relevant cookies used for advertising purposes, including cookies used for frequency capping, financial record keeping, advertising affiliation, detecting click fraud, research and market analysis, product development, and debugging; because none of these purposes relate to a service or functionality within information society services explicitly requested by the user as required by Criterion B. |
Cookie types by party
Third-Party Cookies | Whether a cookie is first-party or third-party varies depending on the webpage or domain that places the cookie. First-party cookies are placed directly by the website the user visits (i.e., the URL displayed in the browser address bar (example.com.tr)). Third-party cookies are placed by a third party other than the website (or domain) the user visits. |
Information on cookies that do not require explicit consent
User-Input Cookies | Session cookies that track user inputs and transmit them to the service provider. These are first-party cookies tied to a Session-ID value (typically a unique number) and are expected to expire at the latest when the session ends. They typically track a user while filling an online form or shopping cart, and keep a record of products selected or information entered by the user. |
Authentication Cookies | Used to identify the user when they log in to a website (e.g., an online banking site). These cookies are necessary for visiting the website or accessing content (e.g., viewing bank accounts, making transfers). They are generally session cookies but may in some cases also be persistent. |
User-Centric Security Cookies | Where cookie use is strictly necessary for information society services explicitly requested by the subscriber or user, cookies aimed at increasing security may also apply. This includes cookies used to detect repeated failed login attempts or other cookies designed to protect the login system from abuse. |
Multimedia Player Session Cookies | Used to store technical data needed for replaying video or audio content (e.g., image quality, network connection speed, buffer parameters). Multimedia player session cookies are also known as “flash cookies”. They expire when the session ends. |
Load Balancing Session Cookies | Load balancing distributes web server requests across a pool of machines. Requests are directed to a load balancing gateway and routed to available internal servers. To ensure consistency, requests from a specific user are always routed to the same server during the session. These are session cookies; their sole purpose is to identify communication endpoints (one of the servers in the pool). |
User Interface Customization Cookies | Used to store user preferences regarding a service on web pages and are not linked to persistent identifiers such as a username. They can be set only upon the user’s explicit request to remember a specific piece of information (e.g., clicking a button or checking a box). Depending on purpose, they may be valid during the session or for weeks/months. |
Social Plugin Content Sharing (like, share, comment) Cookies | These must be session cookies (since persistent authentication cookies do not fall within the criteria mentioned above). Because they serve a specific purpose, they should expire when the user logs out from the social network platform or closes the browser (if “remember me” is not used). |
Cookies Used for the Consent Management Platform | Cookies used to remember, for a certain period, the explicit consent preferences required for consent-based cookies on the pages visited by data subjects. |
Using traffic and/or performance statistics to manage a website or application is necessary for the proper functioning of the site/app and thus for providing the service. Cookies limited to measuring the target audience; performance measurement, identification of navigation problems, optimization of technical performance or ergonomics, estimating necessary server power, i.e., use for the functioning and daily management of a website or application, are related to the requested service.
If the website cannot provide service due to a security vulnerability, is taken out of service, or the user cannot access the requested service, cookies used for website security are also necessary for the service requested by the user.
First-Party Analytical Cookies | Using traffic and/or performance statistics to manage a website or application is necessary for the proper functioning of the site/app and thus for providing the service. Cookies limited to measuring the target audience are related to the requested service where used for performance measurement, identifying navigation problems, optimizing technical performance or ergonomics, estimating necessary server power, and daily management. |
Cookies Used for Website Security | Since inability to provide service due to a security vulnerability, taking the website out of service, or preventing access to the requested service would affect service delivery, cookies used for website security are necessary for the service requested by the user. |
4. Which personal data do we process?
For cookies used on our website other than mandatory cookies, we obtain users’ explicit consent and provide the opportunity to change consent at any time. Users can see the cookie types used on our website via the cookie management panel and can set their preferences as “on” or “off” for all cookies other than Mandatory Cookies. Users can always change their preferences through this panel.
Upon entering the website via Mandatory Cookies
Processing Security | Personal data processed for the operation of this type of cookie, such as browser information, IP address, and access logs. |
If you give explicit consent, via Performance & Analysis Cookies
Processing Security | Personal data processed for the operation of this type of cookie, such as browser information, IP address, access logs, most visited pages, problems encountered during navigation, visited pages, clicked links, search terms, and other texts/writings used and entered. |
If you give explicit consent, via Advertising and Targeting Cookies (third-party cookies placed by our advertising partners)
Processing Security | Personal data processed for the operation of this type of cookie, such as browser information, IP address, access logs, your interests, and your profile. |
- If you give explicit consent, via Functional & Functionality & Preference Cookies
Processing Security | Personal data processed for the operation of this type of cookie, such as browser information, IP address, access logs, and your preference options (language, region, theme, etc.), as well as information you previously entered into text boxes in form fields on the website. |
5. With whom do we share your personal data and for what purpose?
In the event of legal obligations or where the conditions of Articles 8/2 and 9 of the KVKK exist, your personal data may be shared—provided that it is accurate and up to date, processed for specific, explicit and legitimate purposes, and limited and proportionate—with:
- our lawyer,
- judicial and administrative authorities requesting information,
- third-party person(s) from whom TMD will procure services in order to carry out the stated purposes (primarily cookie service providers such as Google, Yandex, ), and
- public institutions or organizations authorized to request such data due to a legal
In addition, cookies used based on your explicit consent are shared with the suppliers from whom we receive services depending on the purpose of use of the relevant cookie type.
6. What is the method and legal basis of collecting and processing your personal data?
We collect your personal data automatically through cookies (during your site visits) and through the completion of various forms mentioned in Section 3; and we process them by digitally recording them in our IT system, storing them on physical servers and cloud servers, and—depending on the nature of the work and the nature of the requested/processed personal data—by automated or non-automated means such as creating databases, listing, filling documents, drafting petitions, filling forms, etc.
Upon entering the website via Mandatory Cookies
Personal Data Category | Processing Purposes | Legal Bases |
Processing Security | To provide an information society service you have requested (logging in, filling forms, keeping your session open while navigating pages, enabling multimedia/ video/audio/photos to be displayed); conducting and following up legal affairs; ensuring that activities are carried out in compliance with legislation; informing authorized persons, institutions and organizations; conducting information security processes; ensuring the security of data controller operations; managing access authorizations. | KVKK Article 5/2(a): “Explicitly stipulated in laws” (Law No. 5651)
KVKK Article 5/2(c): “Necessary for the establishment or performance of a contract, provided that it is directly related to the parties of the contract”
KVKK Article 5/2(f): “Processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject” |
If you give explicit consent, via Performance & Analysis Cookies
Personal Data Category | Processing Purposes | Legal Bases |
Processing Security | Producing analytical results such as the number of website visitors, determining pages viewed on the Site, visit times, and scrolling movements; counting visitors and measuring traffic; measuring and improving website performance; producing and analyzing statistics on how the website is used, which pages are visited, and which links are used; conducting marketing analysis studies; conducting and following up legal affairs; ensuring that activities are carried out in compliance with legislation; informing authorized persons, institutions and organizations; conducting information security processes; ensuring the security of data controller operations; managing access authorizations. | KVKK Article 5/1: “Explicit consent of the data subject”
If the cookie service provider is located abroad: KVKK Article 9/6(a): “The data subject gives explicit consent for the transfer, provided that they are informed about possible risks” |
In this way, we can measure and improve the performance of our website. Only anonymous statistics are produced; they are not used for cross-tracking individuals’ web browsing across different websites or applications. |
If you give explicit consent, via Advertising and Targeting Cookies
Personal Data Category | Processing Purposes | Legal Bases |
Processing Security | Via third-party cookies placed by our advertising partners: analyzing your website usage, interests and behaviors; creating a profile; conducting targeting analysis; carrying out product/service targeting activities; preparing personalized advertisements; conducting behavioral advertising and marketing analysis studies; conducting and following up legal affairs; ensuring that activities are carried out in compliance with legislation; informing authorized persons, institutions and organizations; conducting information security processes; ensuring the security of data controller operations; managing access | KVKK Article 5/1: “Explicit consent of the data subject”
If the cookie service provider is located abroad: KVKK Article 9/6(a): “The data subject gives explicit consent for the transfer, provided that they are informed about possible risks” |
authorizations.
These cookies are placed on and used through the website by our business partners to create your profile according to your interests and to show you relevant ads. |
If you give explicit consent, via Functional & Functionality & Preference Cookies
Personal Data Category | Processing Purposes | Legal Bases |
Processing Security | Making our website more functional and personalized (ensuring that your preferences—other than your privacy preferences—are remembered when you re-enter the website) and remembering preferences; enabling automatic form filling; and conducting and following up legal affairs; ensuring that activities are carried out in compliance with legislation; informing authorized persons, institutions and organizations; conducting information security processes; ensuring the security of data controller operations; managing access authorizations. | KVKK Article 5/1: “Explicit consent of the data subject”
If the cookie service provider is located abroad: KVKK Article 9/6(a): “The data subject gives explicit consent for the transfer, provided that they are informed about possible risks” |
8. Your rights under the KVKK
By applying to TMD, you have the right to request:
- (a) to learn whether your personal data are processed,
- (b) if processed, to request information,
- (c) to learn the purpose of processing and whether data are used in accordance with that purpose,
- (ç) to know the third parties to whom data are transferred domestically/abroad,
- (d) to request correction if incomplete/incorrectly processed,
- (e) to request deletion/destruction within the framework of the conditions set forth in Article 7 of the KVKK,
- (f) to request notification of third parties to whom data are transferred regarding the actions taken under (ç) and (d),
- (g) to object to a result against you arising solely from analysis by automated systems,
- (ğ) to request compensation for damages if you suffer damage due to unlawful
Cookie settings via browser settings
You may change your cookie preferences at any time by clicking the “Customize Your Cookie Settings (Cookie Management)” tab in the pop-up that opens during your first visit to our website. Set the buttons in the cookie management panel to on/off according to your preference and click the “Save settings” button.
In addition, partial control may be provided through browser settings. You can access information about cookie management in commonly used browsers via the links below:
- Google Chrome: https://support.google.com/accounts/answer/61416? co=GENIE.Platform%3DDesktop&hl=en
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enhanced-trackingprotection-firefox-desktop?redirectslug=enable-and-disable-cookies-websitepreferences&redirectlocale=en-US
- Microsoft Internet Explorer: https://support.microsoft.com/en-gb/windows/deleteand-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
- Safari: https://help.apple.com/safari/mac/9.0/#/sfri40732
- Opera: https://help.opera.com/en/latest/web-preferences/
9. Measures regarding the protection of your personal data
Protecting personal data is an important matter for TMD. TMD takes the necessary technical and administrative measures to protect personal data against unauthorized access or loss, misuse, disclosure, alteration or destruction. TMD undertakes to keep your personal data confidential, to take all necessary technical and administrative measures for confidentiality and security, and to exercise due care.
Despite TMD taking necessary information security measures, if personal data are harmed or obtained by third parties as a result of attacks on the website and the system, TMD will immediately notify you and the Personal Data Protection Board.
10. Keeping your personal data accurate and up to date
Those who share their personal data with TMD acknowledge and declare that keeping such information accurate and up to date is important both in terms of their rights over personal data under Law No. 6698 and under other relevant legislation, and that they bear full responsibility for any consequences arising from providing inaccurate information.
You may notify changes and/or updates regarding your personal data through the KEP address specified below or via physical mail to TMD’s address, or through the communication channels on https://www.turkishmenkuldegerler.com.
11. Deletion, destruction or anonymization of your personal data
Your personal data processed for the purposes set out in this notice will be deleted, destroyed or continued to be used by being anonymized by TMD ex officio or upon your request, in accordance with TMD’s Personal Data Retention and Disposal Policy, when the
purpose requiring processing ceases to exist pursuant to KVKK Article 7/1 and after the periods stipulated by law (if any) have elapsed.
Detailed time-based information on cookies used on the website
Type | Name | Duration | Domestic/ International Transfer | First/Third Party |
Functional & Functionality & Preference Cookie | Not used | |||
Performance & Analysis Cookie | googleanalytic_cookie | 2 years | Abroad | Third Party (Google Inc.) |
Advertising and Targeting Cookie | Not used | |||
Mandatory Cookie | Not used |
12. Identity of the Data Controller
Title: TURKISH MENKUL DEĞERLER ANONİM ŞİRKETİ
Address: Esentepe Mahallesi Ali Kaya Sokak Pol Center A Blok No:1 Inner Door No:62 Şişli / İstanbul
MERSIS No: 0871006330900018
Note: This is an English translation prepared from the provided Turkish text. In case of any discrepancy, the Turkish version may prevail.
INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA AND COOKIE POLICY
Website: https://www.turkishmenkuldegerler.com
As TURKISH MENKUL DEĞERLER ANONİM ŞİRKETİ (“TMD“), we have prepared this information notice in our capacity as the Data Controller pursuant to the Turkish Personal Data Protection Law No. 6698 (“KVKK“) and the Communiqué on the Principles and Procedures to be Followed in Fulfilling the Obligation to Inform published in the Official Gazette dated 10.03.2018 and numbered 30356.
Within the scope of Article 10 (“Obligation of the Data Controller to Inform”) and Article 11 (“Rights of the Data Subject”) of the KVKK, and Articles 4 and 5 of the Communiqué, this notice has been issued to inform you about:
- for what purposes your personal data will be processed,
- to whom and for what purposes your processed personal data may be transferred,
- the method and legal basis for collecting your personal data, and
- your other rights listed under Article 11 of the
With this notice, we also aim to inform you, in relation to the processing of personal data obtained automatically via the placement of cookies used on our website on your device, about (i) which types of cookies we use for which purposes and (ii) how you can manage these cookies.
2. What do we inform you about?
- Which of your personal data are collected
- For which purposes your personal data are processed
- With whom and for which purposes your personal data are shared
- The method and legal basis for collecting your personal data
- Disposal (deletion/destruction/anonymization) of your data
- Your rights under the KVKK
3. General information about cookies and cookie types that may be used on the website
What are cookies and why are they used?
Cookies are small text files stored on your device or on a network server via browsers by the websites you visit. For more detailed information about cookies, you may visit: http:// www.aboutcookies.org
The main purposes for using cookies on our Website are listed below:
- To improve the services offered to you by increasing the functionality and performance of the website,
- To improve the website and offer new features through the website, and to personalize the offered features according to your preferences,
- To ensure the legal security of the website, you, and
Cookie types by duration (the following types are used on the website)
| Session Cookies | Session cookies are temporary cookies used during our visitors’ visit to the website and deleted after the browser is closed. The main purpose of using such cookies is to ensure that the website functions properly during your visit. For example, they enable you to fill in online forms consisting of more than one page. |
| Persistent Cookies | Persistent cookies are used to increase the functionality of the website and to provide our visitors with faster and better service. These cookies are used to remember your preferences and are stored on your device via browsers. Some types of persistent cookies may be used to provide you with tailored recommendations, taking into account matters such as your purpose of using the website. Thanks to persistent cookies, if you revisit the website with the same device, it is checked whether there is a cookie created by the website on your device; if so, it is understood that you have visited the website before, and the content to be delivered to you is determined accordingly—thus providing you with a better service. |
Cookie types by purpose of use (the following types may be used on the website)
| Mandatory Cookies | |
| Technical Cookies | Technical cookies ensure the operation of the website and help identify non-functioning pages and areas of the website. These cookies are necessary for the operation of the website. They are used mandatorily in order to provide an information society service requested by the user (such as logging in, filling in forms, remembering privacy preferences). In general, they may be considered as cookie types that rely on processing conditions other than explicit consent. |
| Authentication Cookies | If visitors log in to the website using their passwords, these cookies identify that the visitor is a website user on each page visited, preventing the user from re-entering the password on each page. |
| Flash Cookies | Cookies used to activate image or audio content on the website. |
| Functional Cookies | Cookies used to remember users’ preferences when they visit different pages of the website. For example, remembering your selected language preference. |
| Personalization Cookies | Cookies used on websites or applications (including desktop, mobile, or IoT applications) for personalization and remembering preferences. These cookies are used to provide functionality other than mandatory cookies. Where it is not clear that the data subject has explicitly requested the information society service, reliance on explicit consent will be required. |
| Performance Cookies | |
| Analytical Cookies | Analytical cookies enable the production of analytical results such as the number of visitors to the website, identification of pages viewed on the website, website visit times, and scrolling movements on website pages. |
| Advertising/Marketing Cookies | Advertising and marketing cookies aim to display advertisements to users based on their personal interests by tracking users’ online movements in the internet environment and determining their areas of personal interest. |
Additional information on cookies requiring explicit consent
| Social Plugin Tracking Cookies | Many social networks offer social plugin modules that website owners can integrate into their websites to provide certain services that may be considered “explicitly requested” by their members. However, these modules may also be used to monitor members/non-members via third-party cookies for additional purposes such as behavioral advertising, analytics, or market research. Therefore, they are subject to explicit consent. |
| Online Behavioral Advertising Cookies | Cookies used for behavioral advertising require explicit consent. In this case, the requirement for explicit consent naturally covers relevant cookies used for advertising purposes, including cookies used for frequency capping, financial record keeping, advertising affiliation, detecting click fraud, research and market analysis, product development, and debugging; because none of these purposes relate to a service or functionality within information society services explicitly requested by the user as required by Criterion B. |
Cookie types by party
| Third-Party Cookies | Whether a cookie is first-party or third-party varies depending on the webpage or domain that places the cookie. First-party cookies are placed directly by the website the user visits (i.e., the URL displayed in the browser address bar (example.com.tr)). Third-party cookies are placed by a third party other than the website (or domain) the user visits. |
Information on cookies that do not require explicit consent
| User-Input Cookies | Session cookies that track user inputs and transmit them to the service provider. These are first-party cookies tied to a Session-ID value (typically a unique number) and are expected to expire at the latest when the session ends. They typically track a user while filling an online form or shopping cart, and keep a record of products selected or information entered by the user. |
| Authentication Cookies | Used to identify the user when they log in to a website (e.g., an online banking site). These cookies are necessary for visiting the website or accessing content (e.g., viewing bank accounts, making transfers). They are generally session cookies but may in some cases also be persistent. |
| User-Centric Security Cookies | Where cookie use is strictly necessary for information society services explicitly requested by the subscriber or user, cookies aimed at increasing security may also apply. This includes cookies used to detect repeated failed login attempts or other cookies designed to protect the login system from abuse. |
| Multimedia Player Session Cookies | Used to store technical data needed for replaying video or audio content (e.g., image quality, network connection speed, buffer parameters). Multimedia player session cookies are also known as “flash cookies”. They expire when the session ends. |
| Load Balancing Session Cookies | Load balancing distributes web server requests across a pool of machines. Requests are directed to a load balancing gateway and routed to available internal servers. To ensure consistency, requests from a specific user are always routed to the same server during the session. These are session cookies; their sole purpose is to identify communication endpoints (one of the servers in the pool). |
| User Interface Customization Cookies | Used to store user preferences regarding a service on web pages and are not linked to persistent identifiers such as a username. They can be set only upon the user’s explicit request to remember a specific piece of information (e.g., clicking a button or checking a box). Depending on purpose, they may be valid during the session or for weeks/months. |
| Social Plugin Content Sharing (like, share, comment) Cookies | These must be session cookies (since persistent authentication cookies do not fall within the criteria mentioned above). Because they serve a specific purpose, they should expire when the user logs out from the social network platform or closes the browser (if “remember me” is not used). |
| Cookies Used for the Consent Management Platform | Cookies used to remember, for a certain period, the explicit consent preferences required for consent-based cookies on the pages visited by data subjects. |
Using traffic and/or performance statistics to manage a website or application is necessary for the proper functioning of the site/app and thus for providing the service. Cookies limited to measuring the target audience; performance measurement, identification of navigation problems, optimization of technical performance or ergonomics, estimating necessary server power, i.e., use for the functioning and daily management of a website or application, are related to the requested service.
If the website cannot provide service due to a security vulnerability, is taken out of service, or the user cannot access the requested service, cookies used for website security are also necessary for the service requested by the user.
| First-Party Analytical Cookies | Using traffic and/or performance statistics to manage a website or application is necessary for the proper functioning of the site/app and thus for providing the service. Cookies limited to measuring the target audience are related to the requested service where used for performance measurement, identifying navigation problems, optimizing technical performance or ergonomics, estimating necessary server power, and daily management. |
| Cookies Used for Website Security | Since inability to provide service due to a security vulnerability, taking the website out of service, or preventing access to the requested service would affect service delivery, cookies used for website security are necessary for the service requested by the user. |
4. Which personal data do we process?
For cookies used on our website other than mandatory cookies, we obtain users’ explicit consent and provide the opportunity to change consent at any time. Users can see the cookie types used on our website via the cookie management panel and can set their preferences as “on” or “off” for all cookies other than Mandatory Cookies. Users can always change their preferences through this panel.
- Upon entering the website via Mandatory Cookies
| Processing Security | Personal data processed for the operation of this type of cookie, such as browser information, IP address, and access logs. |
- If you give explicit consent, via Performance & Analysis Cookies
| Processing Security | Personal data processed for the operation of this type of cookie, such as browser information, IP address, access logs, most visited pages, problems encountered during navigation, visited pages, clicked links, search terms, and other texts/writings used and entered. |
- If you give explicit consent, via Advertising and Targeting Cookies (third-party cookies placed by our advertising partners)
| Processing Security | Personal data processed for the operation of this type of cookie, such as browser information, IP address, access logs, your interests, and your profile. |
- If you give explicit consent, via Functional & Functionality & Preference Cookies
| Processing Security | Personal data processed for the operation of this type of cookie, such as browser information, IP address, access logs, and your preference options (language, region, theme, etc.), as well as information you previously entered into text boxes in form fields on the website. |
5. With whom do we share your personal data and for what purpose?
In the event of legal obligations or where the conditions of Articles 8/2 and 9 of the KVKK exist, your personal data may be shared—provided that it is accurate and up to date, processed for specific, explicit and legitimate purposes, and limited and proportionate—with:
- our lawyer,
- judicial and administrative authorities requesting information,
- third-party person(s) from whom TMD will procure services in order to carry out the stated purposes (primarily cookie service providers such as Google, Yandex, ), and
- public institutions or organizations authorized to request such data due to a legal
In addition, cookies used based on your explicit consent are shared with the suppliers from whom we receive services depending on the purpose of use of the relevant cookie type.
6. What is the method and legal basis of collecting and processing your personal data?
We collect your personal data automatically through cookies (during your site visits) and through the completion of various forms mentioned in Section 3; and we process them by digitally recording them in our IT system, storing them on physical servers and cloud servers, and—depending on the nature of the work and the nature of the requested/processed personal data—by automated or non-automated means such as creating databases, listing, filling documents, drafting petitions, filling forms, etc.
- Upon entering the website via Mandatory Cookies
| Personal Data Category | Processing Purposes | Legal Bases |
| Processing Security | To provide an information society service you have requested (logging in, filling forms, keeping your session open while navigating pages, enabling multimedia/ video/audio/photos to be displayed); conducting and following up legal affairs; ensuring that activities are carried out in compliance with legislation; informing authorized persons, institutions and organizations; conducting information security processes; ensuring the security of data controller operations; managing access authorizations. | KVKK Article 5/2(a): “Explicitly stipulated in laws” (Law No. 5651)
KVKK Article 5/2(c): “Necessary for the establishment or performance of a contract, provided that it is directly related to the parties of the contract”
KVKK Article 5/2(f): “Processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject” |
- If you give explicit consent, via Performance & Analysis Cookies
| Personal Data Category | Processing Purposes | Legal Bases |
| Processing Security | Producing analytical results such as the number of website visitors, determining pages viewed on the Site, visit times, and scrolling movements; counting visitors and measuring traffic; measuring and improving website performance; producing and analyzing statistics on how the website is used, which pages are visited, and which links are used; conducting marketing analysis studies; conducting and following up legal affairs; ensuring that activities are carried out in compliance with legislation; informing authorized persons, institutions and organizations; conducting information security processes; ensuring the security of data controller operations; managing access authorizations. | KVKK Article 5/1: “Explicit consent of the data subject”
If the cookie service provider is located abroad: KVKK Article 9/6(a): “The data subject gives explicit consent for the transfer, provided that they are informed about possible risks” |
| In this way, we can measure and improve the performance of our website. Only anonymous statistics are produced; they are not used for cross-tracking individuals’ web browsing across different websites or applications. |
- If you give explicit consent, via Advertising and Targeting Cookies
| Personal Data Category | Processing Purposes | Legal Bases |
| Processing Security | Via third-party cookies placed by our advertising partners: analyzing your website usage, interests and behaviors; creating a profile; conducting targeting analysis; carrying out product/service targeting activities; preparing personalized advertisements; conducting behavioral advertising and marketing analysis studies; conducting and following up legal affairs; ensuring that activities are carried out in compliance with legislation; informing authorized persons, institutions and organizations; conducting information security processes; ensuring the security of data controller operations; managing access | KVKK Article 5/1: “Explicit consent of the data subject”
If the cookie service provider is located abroad: KVKK Article 9/6(a): “The data subject gives explicit consent for the transfer, provided that they are informed about possible risks” |
authorizations.
These cookies are placed on and used through the website by our business partners to create your profile according to your interests and to show you relevant ads. |
- If you give explicit consent, via Functional & Functionality & Preference Cookies
| Personal Data Category | Processing Purposes | Legal Bases |
| Processing Security | Making our website more functional and personalized (ensuring that your preferences—other than your privacy preferences—are remembered when you re-enter the website) and remembering preferences; enabling automatic form filling; and conducting and following up legal affairs; ensuring that activities are carried out in compliance with legislation; informing authorized persons, institutions and organizations; conducting information security processes; ensuring the security of data controller operations; managing access authorizations. | KVKK Article 5/1: “Explicit consent of the data subject”
If the cookie service provider is located abroad: KVKK Article 9/6(a): “The data subject gives explicit consent for the transfer, provided that they are informed about possible risks” |
8. Your rights under the KVKK
By applying to TMD, you have the right to request:
- (a) to learn whether your personal data are processed,
- (b) if processed, to request information,
- (c) to learn the purpose of processing and whether data are used in accordance with that purpose,
- (ç) to know the third parties to whom data are transferred domestically/abroad,
- (d) to request correction if incomplete/incorrectly processed,
- (e) to request deletion/destruction within the framework of the conditions set forth in Article 7 of the KVKK,
- (f) to request notification of third parties to whom data are transferred regarding the actions taken under (ç) and (d),
- (g) to object to a result against you arising solely from analysis by automated systems,
- (ğ) to request compensation for damages if you suffer damage due to unlawful
Cookie settings via browser settings
You may change your cookie preferences at any time by clicking the “Customize Your Cookie Settings (Cookie Management)” tab in the pop-up that opens during your first visit to our website. Set the buttons in the cookie management panel to on/off according to your preference and click the “Save settings” button.
In addition, partial control may be provided through browser settings. You can access information about cookie management in commonly used browsers via the links below:
- Google Chrome: https://support.google.com/accounts/answer/61416? co=GENIE.Platform%3DDesktop&hl=en
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enhanced-trackingprotection-firefox-desktop?redirectslug=enable-and-disable-cookies-websitepreferences&redirectlocale=en-US
- Microsoft Internet Explorer: https://support.microsoft.com/en-gb/windows/deleteand-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
- Safari: https://help.apple.com/safari/mac/9.0/#/sfri40732
- Opera: https://help.opera.com/en/latest/web-preferences/
9. Measures regarding the protection of your personal data
Protecting personal data is an important matter for TMD. TMD takes the necessary technical and administrative measures to protect personal data against unauthorized access or loss, misuse, disclosure, alteration or destruction. TMD undertakes to keep your personal data confidential, to take all necessary technical and administrative measures for confidentiality and security, and to exercise due care.
Despite TMD taking necessary information security measures, if personal data are harmed or obtained by third parties as a result of attacks on the website and the system, TMD will immediately notify you and the Personal Data Protection Board.
10. Keeping your personal data accurate and up to date
Those who share their personal data with TMD acknowledge and declare that keeping such information accurate and up to date is important both in terms of their rights over personal data under Law No. 6698 and under other relevant legislation, and that they bear full responsibility for any consequences arising from providing inaccurate information.
You may notify changes and/or updates regarding your personal data through the KEP address specified below or via physical mail to TMD’s address, or through the communication channels on https://www.turkishmenkuldegerler.com.
11. Deletion, destruction or anonymization of your personal data
Your personal data processed for the purposes set out in this notice will be deleted, destroyed or continued to be used by being anonymized by TMD ex officio or upon your request, in accordance with TMD’s Personal Data Retention and Disposal Policy, when the
purpose requiring processing ceases to exist pursuant to KVKK Article 7/1 and after the periods stipulated by law (if any) have elapsed.
Detailed time-based information on cookies used on the website
| Type | Name | Duration | Domestic/ International Transfer | First/Third Party |
| Functional & Functionality & Preference Cookie | Not used | |||
| Performance & Analysis Cookie | googleanalytic_cookie | 2 years | Abroad | Third Party (Google Inc.) |
| Advertising and Targeting Cookie | Not used | |||
| Mandatory Cookie | Not used |
12. Identity of the Data Controller
Title: TURKISH MENKUL DEĞERLER ANONİM ŞİRKETİ
Address: Esentepe Mahallesi Ali Kaya Sokak Pol Center A Blok No:1 Inner Door No:62 Şişli / İstanbul
MERSIS No: 0871006330900018
Note: This is an English translation prepared from the provided Turkish text. In case of any discrepancy, the Turkish version may prevail.