Deniz Finansal Kiralama A.Ş.(Deniz Leasing) Data Privacy Notice Regarding Personal Data Processing (“Privacy Notice”) has been prepared in accordance with the Law on Protection of Personal Data (LPPD) numbered 6698 in order to inform you on your personal data processed by Deniz Leasing, methods of collecting your personal data, legal basis and purpose of processing your personal data regarding products and services, persons/institutions where your personal data are transferred to, purpose of transfer and the rights of the natural persons whose personal data are processed. As Deniz Leasing we act as the Data Controller as per LPPD and take necessary measures on processing and keeping your personal data.
The table below shows information about us.
-
Title
Deniz Finansal Kiralama A.Ş.
-
Address
Esentepe Mahallesi, Büyükdere Caddesi, No: 141, Kat:16, Şişli / İstanbul
-
Mersis No
0291010721300017
-
1. Your Processed Personal Data
Your personal data* processed by Deniz Leasing are listed in the table below on the basis of categories.
-
Identity
Name-surname, mother’s and father’s name, date of birth, place of birth, marital status, ID card serial number, Republic of Turkey ID number, etc.
-
Contact Information
Address number, e-mail address, contact address, registered e-mail address (KEP), telephone number, etc.
-
Legal Proceedings
Information in correspondence with judicial authorities, information in court files, etc.
-
Customer Transactions
Call center records, invoice, leasing, valuation, collateral, credit information and other transaction information related to them, transaction request information etc.
-
Risk Management
Information processed to manage commercial, technical and administrative risks etc. (Ex. Asset-income information, demographics, data from system integrations shared through public institutions and organizations, Credit Bureau indebtedness information, score information, fraud and money laundering control information)
-
Professional Experience
Profession, title, work information, education status, etc.
-
Transaction Security
IP address information, website log in – log out information etc.
-
Finance
Balance sheet information, financial performance information, credit and risk information, wealth information, etc.
-
Visual and Audio Records
Call center records, audio and visual records etc.
-
Physical Space Security
Entry exit record information to physical spaces (office, building), camera records etc
-
* In case there is special personal data such as religion and blood group information in the signature circulars and similar representations and authorization documents that you will send to us in the contract processes, we ask that these data be deleted or masked before the documents be forwarded to us.
2. Methods of Collecting Your Personal Data
Your personal data within Identity, communication, legal action, customer transaction, risk management, finance, Professional experience, Visual and Audiovisual Records data categories are collected by using partially automated means for you to benefit from the products or services offered by Deniz Leasing, to become our customer or to contact us in any way, fill out a form or submit a lease application, if you are a party to any collateral transaction established or to be established in favor of our customer and/or Deniz Leasing (as a guarantor, pledge/assignment debtor, spouse in cases where consent is sought under legislation), if you are a representative authorized to act on behalf of our customer (such as a company official, a representative, guardian or trustee), through physical (head office, branch, mail/cargo, fax, fax, preprinted forms etc.) or digital (mobile app, website, customer call center, electronic mail, phone, etc.) mediums from legal entity or natural persons, merchant customers or you.
You may have shared your personal data with us through social media, e-mail, mail, fax, text message, all kinds of notifications, applications, interviews and similar/other channels that you will make to our Company.
If you use our websites or other digital service channels, we may obtain information about the IP address and website entry and exit (traffic) information that your device is connected to in the transaction security data category in order to ensure your transaction security, according to the nature of your request and the products and services we will provide to you.
Your personal data in the Data categories Identity, Communication, Legal Action, Customer Transaction, Risk management, Finance, Audio and Visual Records and Physical Space Security :
To the extent permitted by the legislation we are subject to and the agreements made, from the systems shared by institutions and organizations, from Denizbank A.Ş. And DenizBank Financial Services Group* companies, which we receive support/services within the framework of service agreements; from system integrations shared through public institutions and organizations within the scope of intelligence activities (e.g. Identity sharing System (“KPS”), Address Registration System (“AKS”), Turkish Banks Association (TBB) Risk Center, Financial Institutions Association); from parties that mediate the establishment of a contract relationship with our company, where we receive services as complementary or extension of the activities of our company, business partners, contracted organizations and institutions such as dealers, sales offices, from publicly available sources such as news in the media and online recordings or directories, or through any notices, applications, visits and interviews made to our Company via fully or partially automated methods;
Associations and foundations, such as chambers of commerce and trades, persons appointed to act on your behalf (such as a company representative/official, agent, guardian or trustee), businesses owned or affiliated with you – investment companies, partnerships or business partnerships, as well as directors, partners, representatives, trustees, officers or agents of such entities, in connection with the follow-up and execution of legal and executive processes, we may obtain it by non-automatic means from the local authorities or public institutions and organizations as part of a data recording system.
(* Information about the group of companies of Deniz Leasing is part of along with its parent shareholders and subsidiaries and associated companies can be found at
https://www.denizbank.com/hakkimizda/denizbankin-iliskili-kuruluslari .)
3. What we use your personal data for and the legal basis for doing so
We have several legal bases for the activities we carry out. Those legal bases and our purpose of processing your personal data have been explained in the table below. Your personal data is processed in a limited and measured manner in connection with the purposes set out below.
-
PERSONAL DATA CATEGORIES
Identity, Communication, Client transaction, Legal transaction, Risk Management, Finance, Professional experience, Visual and Audible Records , and Transaction Security
WHAT WE USE YOUR PERSONAL DATA FOR
Financial Leasing, Factoring, Financing and Savings Financing Companies Law No. 6361 (Law No. 6361) and the related legislation, including the ones we can offer as agents within the scope of the relevant legislation, the creation of records on our financial leasing, fleet leasing, sales transactions or other products/services, the fulfillment of risk management operations on customer/credit/service, preparation and execution of lending works and establishing collateral, execution and proceedings of invoice transactions, procurement related to the property subject to financial lease, expertise, provision of all kinds of products and services, including operations such as insurance and claims management and other transactions that we may perform in accordance with the relevant legislation based on the lease agreement, performance of our obligations and responsibilities regarding them, establishment of contracts, execution of our contract and operational processes, evaluation of restructuring requests and planning and execution of processes related to them, compliance with internal systems, risk monitoring and information obligations, transfer of ownership, execution of assignment and registration transactions, other services to be determined by the Banking Regulation and Supervision Agency (BDDK) and receiving applications related to them, fulfillment of contracts and transactions concluded, in order to carry out and improve our processes;
For the establishment of our restructuring policy for debt collection purposes, for the execution of risk monitoring and analysis processes; for the establishment and performance of the mortgage or guarantee contract in case of establishing a mortgage or guarantee relationship as a guarantee between our company and legal entity or natural person merchant customer; to determine the value of the securities or real estate goods determined as collateral and for asset valuation studies;
THE LEGAL BASIS FOR DOING SO
Based on the legal grounds that it is “explicitly stipulated in laws” as per 5/2 (a) of LPPD and “the personal data of the contractual parties requires to be processed provided that they are directly related to the establishment or performance of the contract” as per the Article 5/2 (c) of the Personal Data Protection Law, and that it is mandatory for the fulfillment of the legal liability of the data supervisor as per the Article 5/2 (ç) of the same Law;
-
PERSONAL DATA CATEGORIES
Identity, Contact Information, Customer Transactions, Finance and Visual and Audio Records
WHAT WE USE YOUR PERSONAL DATA FOR
To contact you about our products or services or about legislative issues as well as about purposes of providing services;
THE LEGAL BASIS FOR DOING SO
Based on the legal grounds that it is “explicitly stipulated in laws” as per 5/2 (a) of LPPD and “the personal data of the contractual parties requires to be processed provided that they are directly related to the establishment or performance of the contract” as per the Article 5/2 (c) of the Personal Data Protection Law, and that it is mandatory for the fulfillment of the legal liability of the data supervisor as per the Article 5/2 (ç) of the same Law;
-
PERSONAL DATA CATEGORIES
Identity, Communication, Client Transaction, Legal Transaction, Risk Management, Finance, Professional Experience, Transaction Security, Physical Space Security
WHAT WE USE YOUR PERSONAL DATA FOR
Within the scope of the evaluation of claims for leasing transactions, credit history, creditworthiness and collateral evaluation is carried out if you are the owner, manager, shareholder, partner and/or representative/real beneficiary of the natural person customer or if required by our legal obligations due to your connection with the lease /sale transactions, to conduct intelligence and information researches, to carry out risk management activities in this context and to prevent fraud activities and to carry out credit sales, allocation, utilization, follow-up and monitoring processes,
For the purpose of ensuring physical safety in Deniz Leasing workplaces and buildings (Head Office, branch, etc.), to monitor the records of visits, to share them with the competent authorities where necessary and to carry out emergency management processes;
THE LEGAL BASIS FOR DOING SO
In accordance with subparagraph (c) of Article 5/2 of KVKK, the legal reasons "it is mandatory for the data controller to fulfill its legal obligation" and subparagraph (f) is "it is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person";
-
PERSONAL DATA CATEGORIES
Identity, Communication, Customer Transactions, Legal Proceedings, Risk Management, Financial, Professional Experience and Transaction Security
WHAT WE USE YOUR PERSONAL DATA FOR
In order to comply with the legislation we are subject to, especially the Law No. 6361 and the Banking Law No. 5411, to fulfill our obligations and to cooperate with regulatory bodies and law enforcement authorities; identifying and confirming your identity and contact information, verification of the customer information, keeping the data correct and up-to-date, risk analysis and management, management of the information security processes, performing internal audit, interrogation, intelligence activities, performing finance and accounting procedures;
To comply with the legislation on Prevention of Laundering Proceeds of Crime and Financing of Terrorism, and the information retention, reporting and information obligations stipulated by BRSA, Capital Markets Board (CMB), Turkish Central Bank (CBRT), Turkish Ministry of Treasury and Finance, Financial Crimes Investigation Board (MASAK), Banks Association of Türkiye (BAT), Revenue Administration (GİB), Social Security Institution (SGK), Credit Registration Bureau (KKB), Personal Data Protection Authority (KVK Institution), Information Technologies and Communication Authority (BTK), Central Registry Agency Inc. (MKK), Kredi Garanti Vakfı A.Ş. (KGF), Financial Institutions Association (FKB) and other authorities, to execute these liabilities and to fulfill the information and document requests of the relevant authorities;
As per the Law No. 6563 on the Regulation of Electronic Commerce and its sub-regulations, to use the system that allows to obtain commercial electronic message approval or to use the right for rejection and to manage the complaint processes ("IYS System"); in order to fulfill our obligations regarding identification and access, as set out in the Communiqué on the Management and Control of Information Systems of Financial Leasing, Factoring and Financing Companies;
THE LEGAL BASIS FOR DOING SO
To comply with the following provisions of the LPPD: Article 5/2/(a) “It is Explicitly stipulated by the Laws”, Article 5/2/(ç) “It is Necessary for Compliance with a Legal Obligation to which the Data Controller is subject”.
-
PERSONAL DATA CATEGORIES
Identity, Contact Information, Customer Transactions, Legal Proceedings, Finance, Visual and Audio Records, Physical Space Security
WHAT WE USE YOUR PERSONAL DATA FOR
To manage all complaints and requests including customer relations, experience, satisfaction, complaint, objection, request and proposal along with follow up and execution of legal processes before judicial and/or administrative authorities;
As per the Banking Law, in the preparation of consolidated financial statements of the main partnerships and in the planning or execution of the relations with the main partnership and risk management and evaluation studies, and risk, audit, operational services carried out with subsidiaries within the framework specified in the Banking Law and relevant legislation and performance of risk, audit and operational services to comply with the CMB legislation;
THE LEGAL BASIS FOR DOING SO
To comply with subparagraph (ç) of Article 5/2 of LPPD, which stipulates "it is mandatory for the data controller to fulfill its legal obligation" and subparagraph (e), which stipulates "it is directly related to the establishment or performance of the contract";
-
PERSONAL DATA CATEGORIES
Identity, Finance, Contact Information, Customer Transactions and Transaction Security
WHAT WE USE YOUR PERSONAL DATA FOR
To manage and plan the relationships and processes established with our service providers, business partners or suppliers, and to fulfill our legal and commercial obligations within the framework of the contracts and activities carried out with third parties with whom we have business relations;
THE LEGAL BASIS FOR DOING SO
To comply with the Article 5/2/(c) of the LPPD;
-
PERSONAL DATA CATEGORIES
Identity, Finance, Contact Information, Customer Transactions, Transaction Security and Risk Management
WHAT WE USE YOUR PERSONAL DATA FOR
As per article 5 of Regulation on Compliance Program towards Obligations on Preventing Laundering Proceeds of Crime and Financing of Terrorism; to ensure that the compliance program of DenizBank Financial Services Group is applied across the financial group and to share information on know-your-customer, account and transactions within the group, to make sure that customer information is correct and up-to-date;
THE LEGAL BASIS FOR DOING SO
To comply with the following provisions of the LPPD: Article 5/2/(a) “It is Explicitly stipulated by the Laws”, Article 5/2/(ç) “It is Necessary for Compliance with a Legal Obligation to which the Data Controller is subject”.
-
PERSONAL DATA CATEGORIES
Identity, Contact Information, Customer Transactions and Finance
WHAT WE USE YOUR PERSONAL DATA FOR
For the purposes of carrying out advertising, marketing and promotional activities related to our company's products and services, conducting studies including surveys and statistical studies, carrying out campaign processes and providing commercial electronic message sending services for marketing purposes
THE LEGAL BASIS FOR DOING SO
In case of the availability of your explicit consent in accordance with Article 5/1 of the LPPD.
-
4. Who we will share your personal data with and For What Purposes
Your personal data is shared with the below parties in a limited and proportionate way to fulfill our obligations within the scope of the Financial Leasing, Factoring, Financing and Savings Financing Companies Law No. 6361 (Law No. 6361), Banking Law and relevant legislation to which we are subject, and to perform our financial activities:
• In order to be able to fulfill our legal notification and regulatory reporting liabilities, carry out the regulatory and audit activities and to fulfill all other legal liabilities based on the provisions of the Banking Law no. 6361, the Law no. 5549 on the Prevention of Laundering Proceeds of Crime, the Capital Markets Law no. 6362 and other applicable legislation; BRSA, CMB, CBRT, Turkish Ministry of Treasury and Finance, MASAK, Social Security Institution, Credit Bureau (and/or Banks Association of Türkiye Risk Center or at least five banks or corporations established by financial institutions for the purposes of risk management and monitoring), Personal Data Protection Authority, BTK, MKK, KGF, FKB or other institutions/establishments authorized by the laws to obtain information, public institutions/bodies, ministries and judicial bodies,
• For the purposes of the execution of the financial leasing activities, offering you exclusive products and services in connection with and limited to your request, fulfilling the obligation to inform, store and report, and execution of the payment / collection and insurance processes; with third parties from whom we receive services to carry out our activities, our business partners, with our service providers such as dealers and sales offices who mediate consultancy, valuation, infrastructure and similar issues or to establish a contractual relationship with Deniz Leasing, program partner organizations we cooperate with, subcontractors, companies/organizations operating in the capacity of brokerage/agency, mobile service providers authorized by BTK, banks, leasing companies and insurance companies located in the country and/or abroad,
• Through system integrations shared via public entities and institutions (ID Sharing System, Address Based Population Registration System, etc.) to ensure that your applications are put into process accurately and to make inquiries in the systems for your security within the framework of know your customer obligations,
• Within the framework of the Article 73 of the Banking Law, BRSA activity expansion permits and legislation on Prevention of Laundering Proceeds of Crime and Financing of Terrorism, affiliates, subsidiaries, main shareholder, direct/indirect domestic/international subsidiaries of the Denizbank Financial Services Group and the companies where it is an agent,
• Courts, law firms, asset management companies for the purpose of monitoring and carrying out legal and executive legal proceedings and litigation processes before all judicial and/or administrative authorities, and independent audit companies to make sure that the activities are lawful,
• Other third parties covered by the explicit consent, as per the Articles 8 and 9 of the LPPD.
5. Your Rights
Pursuant to article 11 of the Personal Data Protection Law, you have the following rights related to your personal data:
a) to learn whether your personal data are processed or not,
b) to request information if your personal data are processed,
c) to learn the purpose of your data processing and whether this data is used for intended purposes,
d) to know the third parties to whom your personal data is transferred at home or abroad,
e) to request correction if your personal data were processed incompletely or inaccurately and to request that third persons, to whom your personal data are transferred, get notified about the transactions carried out within this scope,
f) Despite being processed as per the provisions of the Law numbered 6698 and other relevant laws, in the event that reasons requiring the processing have disappeared, to request the erasure or destruction of your personal data and to request that third persons, to whom your personal data are transferred, get notified about the transactions carried out within this scope,
g) to object to the processing, exclusively by automatic means, of your personal data, which leads to an unfavourable consequence for you,
h) to request compensation for the damage arising from the unlawful processing of your personal data.
In line with the Law no. 6698 on Protection of Personal Data, you may exercise your rights regarding your personal data by submitting a petition letter along with your ID document to our head office located in the address Büyükdere Cad. No: 141 34394 Esentepe - ISTANBUL in person or through your attorney or submitting your application to the address
denizfinansal@hs09.kep.tr using your registered e-mail address with e-signature or by using another method specified within the scope of the Communiqué on the Principles and Procedures for the Request to Data Controller.