Personal Data Disclosure Statement for Customers

FINNOVA Disclosure Statement

This Personal Data Disclosure Statement has been prepared by FINNOVA pursuant to Article 10 of the Turkish Personal Data Protection Law No. 6698 and the Communiqué on Procedures and Principles to be Followed in Fulfilling the Disclosure Obligation. It aims to inform users about the methods of collecting, processing, transferring, and the retention period of their personal data, as well as the rights they have concerning these personal data.

Kullanıcının kişisel verilerinin güvenliğinin sağlanması ve işlenmesine azami hassasiyet göstermekteyiz. Türkiye Cumhuriyeti Anayasası ve 6698 sayılı Kişisel Verilerin Korunması Hakkında Kanun kapsamında, kullanıcıya kişisel verileri hakkında bilgilendirilmek temel bir hak olarak tanınmaktadır. Bu doğrultuda, kişisel verilerin güvenliğinin sağlanması, FINNOVA için büyük önem ve hassasiyet içermesinin yanı sıra bir yükümlülük olup Anayasa, Kanun ve General Data Protection Regulation (“GDPR”) çerçevesinde işlenmekte ve korunmaktadır.

We ensure the utmost care in protecting and processing users' personal data securely. Under the Constitution of the Republic of Turkey and the Personal Data Protection Law No. 6698, informing users about their personal data is recognized as a fundamental right. Accordingly, safeguarding personal data is not only of great importance and sensitivity to FINNOVA but also a legal obligation processed and protected within the framework of the Constitution, the Law, and the General Data Protection Regulation (“GDPR”).

Your identity images and selfie photographs are shared with the "Sumsub" platform for verification purposes.

Data Controller

According to Article 3 of the Personal Data Protection Law, the natural or legal persons who determine the purposes and means of processing personal data and manage the systematic storage location (data registration system) of the data are called data controllers. FINNOVA is the data controller with respect to user-related data.

Data Controller: FINNOVA Cryptocurrency Trading Platform Joint Stock Company
Address: Barbaros Mah. Begonya Sk. Alive Tower No:7/15 Ataşehir/Istanbul
Tax Office: Kozyatağı
Tax Number: 3881587414

Your Processed Personal Data

FINNOVA may process the following data, among others, depending on the legal relationship or transaction established with the User. When the User logs into our site, these data will be linked to the username and processed according to the User’s activities. If the User does not log in, data subject to cookie settings may be processed anonymously on the FINNOVA website. Click here for the Cookie Policy.

Identity Information (name, surname, Turkish ID number, date of birth, signature, nationality, place of birth, parents’ names)
Contact Information (phone number, email address, address)
Financial Information (account transactions, IBAN, asset information, bank account details, cryptocurrency address, cryptocurrency balance, balance details)
Membership Information (membership details, membership number, password)
Customer Transaction Information (customer ID number)
Transaction Security Information (IP address details, device information, site membership date, password and credential information)
Legal Transaction Information
Visual and Audio Records (identity photo, voice recording)
Request and Complaint Information
Other Information (transaction date, type, amount, place and method of transaction, transaction type)
Marketing Information (cookie records) including targeted or advertising cookie use
Marketing Transaction Security Information (IP address information) including targeted or advertising cookie use

Purposes of Processing Personal Data

Your personal data are processed for the following purposes:

To provide your membership to FINNOVA’s website and platforms
To approve the account you have opened
To verify the information you have provided to FINNOVA
To enable you to submit questions, opinions, and requests related to FINNOVA
To facilitate your easy access to the products and services offered by FINNOVA
To allow you to start and continue your transactions via FINNOVA
To fulfill obligations under applicable laws and other regulations
To carry out your deposit and withdrawal transactions
To ensure your account security
To verify and execute your financial transactions
To keep records of logins and logouts and identify visitors to the website
To perform data analytics for market research and the development of platforms, products, and services
To enable FINNOVA to notify its customers about new developments via SMS, email, and similar channels

To Whom and For What Purpose Are Your Personal Data Transferred?

Personal data may be transferred to FINNOVA employees, public institutions and organizations where legal transfer is required, domestic/international third parties from whom services are procured for operational purposes, and real or legal persons with whom cooperation is established. If necessary, data may be shared with individuals and organizations abroad such as in Turkey, EU countries, the USA, and the UK for data storage, hosting, server services, and similar, based on legal grounds or explicit consent.

Methods and Legal Grounds for Personal Data Collection

Users' personal data are collected through FINNOVA’s website and platforms and, when necessary, from social media accounts and third-party environments with whom cooperation is established.

The methods of collecting personal data include but are not limited to:

By filling out any contracts, information forms, and other documents electronically signed or approved by you, based on explicit provisions in laws
Through applications made via communication channels where explicitly permitted by law
Interacting with us on social media and other publicly available platforms to the extent and with consent permitted by relevant legislation
Written digital applications and examination of legal records made to us, based on explicit provisions in laws
Providing requested information in physical environments where explicitly permitted by law
Permitting the use of electronic devices and cookies while using products and services as explicitly foreseen in laws
Granting permission to tools created on the website and other platform areas as explicitly stipulated by law
Collection of personal data via SMS, verbal, written, visual, voice recording, or any electronic communication channels

Our Legal Grounds

FINNOVA’s legal grounds for collecting, processing, and transferring your personal data are as follows:

Explicitly stipulated in laws
Necessary for the company to fulfill its legal obligations
Required for establishing, using, or protecting a right
Made public by the Users themselves
Necessary for the establishment or performance of a contract
Obtaining explicit consent
Necessary processing of personal data to protect the life or physical integrity of a person who cannot express consent due to actual impossibility or lack of legal validity of consent
Processing personal data for FINNOVA’s legitimate interests, provided it does not infringe on your personal rights and freedoms

Retention Periods

Personal data recorded for your membership processes will be kept for 10 years under Law No. 6098.
Data collected for identity verification processes and special categories of personal data will be retained for 3 years under Law No. 6563 and relevant legislation, and for 10 years after the termination of the legal relationship.
Data collected through cookies will be retained between 6 months and 2 years under Law No. 5651.
Demographic data will be retained for 2 years under Law No. 5651.
Data related to financial transactions will be kept for 10 years under Law No. 6102 and Law No. 213.
Personal data collected due to legal requirements will be retained for the periods stipulated by authorized authorities and will be destroyed or anonymized thereafter.
Data collected for customer service specialists will be retained for 10 years under Law No. 6098.
Personal data collected via firms and service providers with servers abroad, as well as data collected for foreign partners and affiliates, will be retained for 10 years under Law Nos. 6098 and 6102.
Data collected by customer service specialists or domestic service providers will be retained for 10 years under Law No. 6102.

User Rights under the Personal Data Protection Law

Under Article 11 of the Personal Data Protection Law, the rights granted to the User as the data subject are as follows:

To learn whether personal data has been processed,
To request information if personal data has been processed,
To learn the purpose of processing personal data and whether it is used accordingly,
To know third parties to whom personal data has been transferred domestically or abroad,
To request correction of personal data if it is incomplete or inaccurate,
To request deletion or destruction of personal data,
To request notification of third parties to whom personal data has been transferred about corrections, deletions, or destructions,
To object to the emergence of results against the person by analysis of processed data exclusively through automated systems,
To demand compensation for damages in case personal data is processed unlawfully.

Application Methods and Process

To make an application regarding personal data under the law, the User must submit their requests in accordance with Article 13 of the KVKK and Article 5 of the Communiqué on Procedures and Principles Regarding the Application to the Data Controller published in the Official Gazette No. 30356 dated 10.03.2018.

FINNOVA shall conclude applications made in compliance with relevant legislation within a maximum of 30 days in accordance with Article 13 of the Personal Data Protection Law, depending on the nature of the application. The User’s request will be either accepted or rejected, and a reasoned response will be provided in writing or electronically to the applicant. If the requested transaction requires an additional fee, the tariff determined by the Personal Data Protection Board will apply.

Methods to Apply

The User may apply through the following methods:

Address: Applications can be made in writing in person or through a notary to Barbaros Mah. Begonya Sk. Alive Tower No:7/15 Ataşehir/Istanbul following identity verification.
Registered Electronic Mail (KEP) Address and Electronic Applications: Applications can be submitted via KEP, secure electronic signature, mobile signature, or the email address specified by the User to finnovateknoloji@hs01.kep.tr.

Final Notes

This Disclosure Statement may be updated or amended to comply with Personal Data Protection regulations. The User should monitor the website and platforms to stay informed of relevant changes.