Privacy Policy

Let us inform you how Global IT Bilişim Hizmetleri A.Ş (hereinafter also referred to as “we” or “our Company”) processes your personal data in connection with offering, concluding, providing and maintaining Company products and services.

The purpose of this Principles is to give you information about the particular personal data we collect, how we treat them, what sources we get them from, what purpose we use them for, whom we may provide the data to, where you can obtain information about your personal data we process, or what are your individual rights concerning the protection of personal data.

Personal Data Processing Principles 

As part of processing your personal data we respect top standards of personal data protection and particularly abide by the following principles:

We always process your personal data for a clearly and comprehensibly defined purpose, using defined means, in a defined manner, and only for a time necessary with regard to the purpose; we only process precise personal data of clients and ensure that their processing corresponds with and is necessary for the defined purpose;

We protect and process your personal data in a manner ensuring highest possible security of the data and preventing any unauthorized or accidental access to client personal data, their modification, destruction or loss, unauthorized transfers, other unauthorized processing or other abuse;

We always clearly inform you about processing your personal data and your rights to receive precise and full information about the circumstances of such processing as well as your other related rights;

At our Company we adhere to adequate technical and organizational measures to ensure a level of security matching all possible risks; all persons who come into contact with client personal data are obliged to keep confidential the information acquired in connection with the processing of such data.

Personal Data Processing Methods 

The method how our Company processes your personal data includes both manual and automated processing, including algorithmic processing, in our Company’s information systems.

Your personal data are mainly processed by employees of our Company and, to an extent as required, by third parties. Before any disclosure of your personal data to a third party, we always enter into a written agreement with the third party, containing the same warranties in respect of personal data processing as adhered to by our Company in line with its statutory obligations.

Scope of Processed Personal Data 

Identification data – these include data such as name, surname, date, email, phone number, employer or. represented company; for clients who are natural persons – entrepreneurs. 

Contact data – these include data such as telephone numbers, email addresses and messages. 

Transaction security data – such as IP Address, process date and time, consent and chooses.

Personal data acquired in connection with the provision of our products or services – these include personal data acquired during our interactions. In particular, these include:

(i) data serving to secure communications;

(ii) records of your preferred communication language, expressed interest in a product or service, your investment strategies, or your specific requirements disclosed to us.

Purpose and Legal Basis of Processing 

Processing of Personal Data without Your Consent 

This usually concerns situations where you are obliged to disclose certain personal data to us as a condition to let us provide you with our product or service, or where we are entitled to process your personal data acquired otherwise.

(a) By virtue of law, we are entitled to process your personal data without your consent for the following purposes of compliance with our statutory obligations, in particular:

(i) compliance with statutory disclosures to public authorities;

(ii) compliance with archiving obligations.

(b) Conclusion or performance of a contract with you.

(c) Protection of rights and interests protected by law, particularly in respect of resolution of any and all disputes, particularly for the purpose of court or other disputes.

Processing of Personal Data with Your Consent 

This particularly concerns situations where you voluntarily agree that we process the provided or otherwise acquired personal data. Not granting your consent may be a reason preventing our Company from providing certain products or services or forcing it to reasonably adjust the availability, scope or conditions of provided products and services.

Based on your consent, our Company processes your personal data for the following purposes:

(a) customer care; these are activities that do not stand for performance of a contract or another legal framework of personal data processing, and include the following: (i) market research;(ii) monitoring of client actions on our Company’s website in connection with the offered services;

(b) offering of products and services; in particular, this includes distribution of information, offering of products and services of our Company and other parties, including product and service offers targeted at particular clients, all via various channels, such as by mail, electronic means (including electronic mail and messages sent to mobile devices via a telephone number), or by telephone, via a website. To a certain extent, in these cases, our Company is also entitled to offer products and services to clients without obtaining their consent; if implied by the law, you will be informed in this regard about your right to express your disagreement with any further offering of products or services. In this regard, your personal data may also be forwarded to third parties for the purpose of distribution of information and offering of products and services of such third parties.

Term of Personal Data Processing 

Our Company processed personal data of clients only for a time necessary with regard to the purpose of processing. From time to time we evaluate existence of the need to process certain personal data required for a particular purpose. Once we detect that the data are no longer required for any of the purposes, for which they have been processed, we destroy the data. However, in respect of certain purposes of personal data processing, we have internally evaluated the usual term of usability of personal data, after expiration of which we most carefully assess the need to process such personal data for the particular purpose.

Recipients of Personal Data 

Your personal data are made available particularly to our Company’s employees in connection with performance of their professional duties requiring work with personal data of clients, however only to an extent necessary in the particular case and in compliance with all security measures.

In addition, your personal data are disclosed to third parties participating in the processing of personal data of our Company’s clients, or, such personal data may be made available to them on other grounds in line with the law. Before any disclosure of your personal data to a third party, we always enter into a written agreement with the third party to stipulate the processing of personal data in a way to contain the same warranties in respect of personal data processing as adhered to by our Company in line with its statutory obligations.

In accordance with applicable legislation, our Company is entitled, or directly, without your consent, obliged to disclose your personal data to:

  1. relevant state authorities, courts and law enforcement authorities for the purpose of performance of their obligations and for the purpose of enforcement of judgment;
  2. other parties to an extent stipulated by legislation, such as to third parties for the purpose of collection of our receivables from clients.

Transfer of Personal Data to Foreign Countries 

Your personal data is processed by our hosting provider (Google LLC / Google Ireland Limited), whose servers are located on EEA soil, and transferred to other countries where the European Union are seated and shares the same standard of personal data protection as the EU (eg.UK, Switzerland). Your personal data may be transferred to the Republic of Turkey where our company is based.

Company as a processor of personal data 

Our Company processes personal data which is submitted and authorized by another party (our clients are controller). In terms of users, employees and other persons authorized processed within the scope of corporate membership Our Company is not the data controller, only the data processor. The relevant company is the data controller. The relevant data controller is exclusively responsible for the processing of personal data within this scope. For detailed information, it is always necessary to contact the particular administrator (Company: the data controller) of personal data, unless our Company is authorized to provide information in the particular case.

Your Right to Ask for Access to Personal Data and Rights 

If you ask us for information related to the processing of your personal data, we will provide you with all information about the data we process about you without undue delay. For providing this information, we are entitled to claim reasonable compensation of cost incurred in order to provide the information. If you find out or think that our Company or a third party participating in the processing of data processes your personal data in conflict with the protection of your private life and/or in conflict with the law, in particular if your personal data are inaccurate, you may:

(a) request explanation from our Company or the third party participating in the processing of data;

(b) request remedy of the defective state; in particular, you may request correction or amendment of the personal data; if needed, the data will be temporarily blocked or destroyed.

If we find your request legitimate, our Company or the third party participating in the processing of data will remove the defective state free of charge and immediately.

Contact Information

Global IT Bilişim Hizmetleri A.Ş 

Fulya Mah. Ortaklar Cad. Bahçeler Sok. 

Onsekiz İş Merkezi No:18/4 Şişli

İstanbul, Turkey