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Personal Data Protection Policy
Information Notice on the Processing and Protection of Personal Data
This Information Notice on the Processing and Protection of Your Personal Data (“Information Notice”) has been prepared by TEB Faktoring A.Ş. (“TEB Faktoring / Company”) within the scope of Article 10 of the Law on the Protection of Personal Data No. 6698 (“KVKK/Law”), in order to fulfill the obligation to provide information regarding your personal data processed in connection with the activities, products, and services provided by TEB Faktoring.
The definitions set forth in the Information Notice shall have the following meanings:
Explicit Consent: Consent that is related to a specific subject, based on information and free will, given in a manner leaving no room for any uncertainty, limited only to that particular transaction.
Data Subject: The natural person whose personal data is processed.
Personal Data: Any information relating to an identified or identifiable natural person.
Processing of Personal Data: Any operation performed on personal data, whether fully or partially automated or non-automated provided that it is part of a data recording system, such as collection, recording, storage, preservation, alteration, reorganization, disclosure, transfer, acquisition, making available, classification, or prevention of use.
Data Controller: The natural or legal person who determines the purposes and means of processing personal data, and who is responsible for the establishment and management of the data recording system.
I. IDENTITY OF THE DATA CONTROLLER
This Information Notice is provided by TEB Faktoring A.Ş., acting in the capacity of data controller, operating at the address Yener Sokak No:1 K:7-8 Gayrettepe/Istanbul, registered with Istanbul Trade Registry under number 372141, with MERSIS number 0833007688600077, and contact details www.tebfaktoring.com.tr and +90 212 370 45 00.
II. CATEGORIES OF PERSONAL DATA PROCESSED
Your personal data processed by TEB Faktoring are listed below on a category basis. Depending on the nature of the products and services you shall receive from our Company, within the scope of the relationship to be established; the type, nature, history of the relationship, the method of obtaining the data, and the purposes set out below, the personal data that vary accordingly shall be as follows:
| CATEGORIES | TYPES |
| Identity Data | Name and surname, mother’s and father’s name, date of birth, place of birth, data contained in identity documents, Turkish ID / passport / tax identification number. |
| Contact Data | Home / office address, e-mail address, registered e-mail address, telephone and fax number. |
| Transaction Security and Cybersecurity Data | IP address information, website login/logout information, device type, username, password and passcode information, audit trails, log records such as security applications, notifications regarding fraud prevention, and other data that may relate to Company security. |
| Marketing Data | Financial product and service usage habits, past-period financial transaction information, information that may be subject to financial product and service offerings, survey responses and results, data obtained through campaign activities. |
| Education, Employment and Professional Life Data | Profession, title, employment information, education status, curriculum vitae information, employment history, information on the workplace where employed. |
| Date relating to Commercial Life | Information relating to natural persons contained in documents issued for the legal entities such as tax certificate, trade registry gazette, authorization certificate, trade registry documents, qualification certificates, signature circulars and certificate of activity, as well as information relating to tax liability status and various demographic information identifying the data subject. |
| Customer Transaction Data | Call records, promissory note, check and invoice information, appraisal, collateral, credit information and other transaction information connected thereto, suitability and appropriateness test results, in formation on orders and transaction requests, payment instructions. |
| Location Data | Information relating to your location. |
| Risk Management Data | Data required for know-your-customer, prevention of financing of terrorism, and prevention of fraud. |
| Premises Security Data | Data such as entry/exit records and camera footage relating to employees and visitors for the purpose of ensuring physical security, and visitor records. |
| Visual and Audio Data | Call/telephone recordings, visual and audio recordings, and photographic records. |
| Request / Complaint and Reputation Management Data | Information contained in requests or complaints submitted to our Company, information used in the Company’s reputation management.. |
| Legal Transaction Data | Information obtained with respect to legal disputes in which our Company is a party, information contained in correspondence with judicial authorities, information in case files and legal follow-up files, information kept within the scope of alternative dispute resolution, and data contained in any administrative and judicial-authority documents served on our Company. |
Some of your personal data are subject to stricter protection and are classified as “special categories of personal data” as enumerated in the Law. In the activities carried out by our Company, we endeavor not to process your special categories of personal data. However, in certain circumstances, for example, within the scope of the obligation to obtain a photocopy of your identity card, data such as dress code (your ID photograph), religion, and blood group information may be obtained. In processes where obtaining a photocopy of your identity card is mandatory, the blood group, religion field information, and dress code information arising from the photograph on your identity card shall not be held subject to any additional processing by our Company. They are only present in our systems due to the copying of the identity document. We are diligently continuing the necessary technical work to ensure the destruction of such information in our systems.
III. METHODS OF OBTAINING YOUR PERSONAL DATA
Your personal data may be obtained by TEB Faktoring directly from you in person or from third parties, through automated or non‑automated methods, as explained below.
(i) Methods of Obtaining Your Personal Data Directly from you in person
• Information or documents containing your personal data may be obtained through verbal and written communications conducted face‑to‑face with TEB Faktoring headquarters, branches, sales teams, or via electronic communication channels (telephone / call center, SMS, fax, e‑mail, etc.), or through non‑automated methods such as mail, courier, or cargo services.
• Information or documents containing your personal data may be obtained through automated methods when you apply, fill out forms, transmit your information or document images to benefit from the products or services offered by TEB Faktoring, to become our customer, or to contact us in any way, or when you are a party to any collateral transaction established or to be established in favor of our customer and/or TEB Faktoring (as guarantor, surety, pledge/assignment debtor, or spouse in cases where consent is required by law), or when you act as an authorized representative on behalf of our customer (such as company officer, proxy, guardian, or custodian).
• You may also have shared your personal data with us through any notifications, applications, communications, and similar channels such as social media, e‑mail, mail, fax, or SMS.
(ii) Methods of Obtaining Your Personal Data from Third Parties
• Information or documents containing your personal data may be obtained, within the limits permitted by applicable legislation and agreements, from external service or support providers; chambers of commerce, tradesmen and professional associations, similar unions, associations, and private law entities; judicial authorities; legally authorized public and private institutions and organizations such as the Banking Regulation and Supervision Agency; or from your representatives such as proxy, parent, guardian, through physical or electronic channels by non‑automated methods.
• Your personal data may be obtained, within the limits permitted by applicable legislation and agreements, from systems shared by institutions and organizations, from group companies from which we receive support/services under service agreements, from system integrations shared by public institutions and organizations within the scope of intelligence activities (e.g., Identity Sharing System (“KPS”), Address Registration System (“AKS”), The Banks Association of Turkey (TBB) Risk Center, Financial Institutions Association), from parties providing services complementary or ancillary to our Company’s activities and
intermediating contractual relationships, from correspondent / counterparty factoring companies, business partners, contracted institutions, dealers, sales offices, from publicly available sources such as media reports and online records or directories, or through any notifications, applications, visits, and communications made to our Company, by fully or partially automated means.
• If you download the TEB Faktoring mobile application and/or use TEB Faktoring’s digital service channels, in order to ensure your transaction security, we may obtain information within the transaction security data category such as the IP address to which your device is connected, website login and logout (traffic) information, depending on your request and the nature of the products and services we shall provide to you (where necessary), the type of device you use, type of operating system information, your password and passcode information, how you access and use these services. Your location information may be processed, subject to your consent, to customize branch locations according to your current location.
IV. PURPOSES AND LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA
Your personal data obtained by TEB Faktoring are processed in connection with, limited to, and proportionate to the purposes primarily including the provision of secure, effective, and high‑quality services to you, and fundamentally for the purposes set out below.
| DATA CATEGORIES | PURPOSES OF PROCESSING | LEGAL GROUNDS |
|---|---|---|
| Identity, Contact, Customer Transaction, Legal Transaction, Risk Management, Finance, Professional Experience, Visual and Audio Records, and Transaction Security | Within the scope of the Law No. 6361 and the relevant legislation, for the creation of records regarding factoring transactions and the products/services we provide, the performance of risk management processes concerning customers/ credit/ services, the preparation and execution of financing activities, as well as the establishment, enforcement, and release of collateral, the execution of invoice transactions, the provision of all our products and services including the transactions we may carry out pursuant to the relevant legislation based on the factoring agreement, the fulfillment of our obligations and responsibilities in relation thereto, the establishment of contracts, the execution of our contractual and operational processes, compliance with internal systems, risk monitoring and information obligations, the provision of other services to be determined by the Banking Regulation and Supervision Agency (BRSA), and the receipt of applications thereto, the performance, execution, and improvement of the contracts and transactions entered into, the establishment of our restructuring policy for the purpose of debt collection, and the execution of processes for risk monitoring and analysis; For the establishment and performance of a suretyship or guarantee agreement as collateral for the legal relationship between our Company and the corporate or natural person merchant customer, in case a suretyship or guarantee relationship is established; and for the determination of the values of movable or immovable properties designated as collateral and for asset valuation studies. | Pursuant to Article 5/2(a) of the Law on the Protection of Personal Data (“KVKK”), on the basis of “explicitly stipulated in the laws”, and Article 5/2(c), “Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract”, and Article 5/2(ç), “It is necessary for compliance with a legal obligation to which the data controller is subject” |
| Identity, Contact, Customer Transaction, Finance, and Visual and Audio Records | For the purpose of contacting you in relation to our products or services, or matters concerning the legislation, in order to provide services. | Pursuant to Article 5/2(a) of KVKK, “explicitly stipulated in the laws”, Article 5/2(c), “Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract”, and as per Article 5/2(ç), “It is necessary for compliance with a legal obligation to which the data controller is subject”; |
| Identity, Contact, Customer Transaction, Legal Transaction, Risk Management, Finance, Professional Experience, Transaction Security | Within the scope of the evaluation of factoring transaction requests, for the assessment of credit history, creditworthiness, and collateral of the owner, manager, shareholder, partner and/or authorized representative / ultimate beneficial owner / guarantor / assignment debtor of the natural person or legal entity customer, or in case you are connected with the factoring transaction; for the conduct of intelligence and information inquiries; for the execution of risk management activities within this scope and the prevention of fraudulent activities; and for the execution of credit sales, allocation, disbursement, follow‑up, and monitoring processes. | Pursuant to Article 5/2(ç) of KVKK, “It is necessary for compliance with a legal obligation to which the data controller is subject” |
| Identity, Contact, Customer Transaction, Legal Transaction, Risk Management, Finance, Professional Experience, and Transaction Security | In order to comply with the Law No. 6361 and the Banking Law No. 5411 in particular, and the legislation to which we are subject, to fulfill obligations and to cooperate with regulatory authorities or law enforcement agencies; for the identification and verification of your identity and contact information, the verification of customer information, ensuring that data is accurate and up to date, the execution of risk analysis, management and information security processes, the conduct of internal audit, investigation, intelligence and audit/ethics activities, and the execution of finance and accounting operations; For compliance with the legislation on the prevention of laundering proceeds of crime and financing of terrorism, and the obligations of data retention, archiving, reporting, and information as stipulated by the Banking Regulation and Supervision Agency (BDDK), the Capital Markets Board (SPK), the Central Bank of the Republic of Türkiye (TCMB), the Ministry of Treasury and Finance of the Republic of Türkiye, the Financial Crimes Investigation Board (MASAK), the Banks Association of Türkiye (TBB), the Revenue Administration (GİB), the Social Security Institution (SGK), the Credit Bureau (KKB), the Personal Data Protection Law (KVKK), the Information and Communication Technologies Authority (BTK), the Central Registry Agency (MKK), the Credit Guarantee Fund (KGF), the Association of Financial Institutions (FKB), and other authorities, the execution thereof and the fulfillment of information and document requests received from the relevant authorities within this scope For the use of the system (“İYS System”) enabling the receipt of commercial electronic communication consent, the exercise of the right of refusal, and the management of complaint processes pursuant to the Law No. 6563 on the Regulation of Electronic Commerce and its secondary legislation; for the fulfillment of our identity and access obligations pursuant to the Communiqué on the Management and Supervision of Information Systems of Financial Leasing, Factoring and Financing Companies. | Pursuant to Article 5/2(a) of KVKK, “explicitly stipulated in the laws”, and Article 5/2(ç), “It is necessary for compliance with a legal obligation to which the data controller is subject” |
| Identity, Contact, Customer Transaction, Transaction Security, Finance, and Risk Management | Pursuant to Article 5 of the Regulation on Compliance Programs Regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism; in addition to the implementation of the compliance program on a financial group basis, for the sharing of information within the group regarding customer identification, accounts and transactions, and for ensuring the accuracy and up‑to‑dateness of customer information. | Pursuant to Article 5/2(a) of KVKK, “explicitly stipulated in the laws”, and Article 5/2(ç), “It is necessary for compliance with a legal obligation to which the data controller is subject”; |
| Identity, Contact, Customer Transaction, Legal Transaction, Finance, Visual and Audio Records | Within the framework specified in the Banking Law and the relevant legislation, for the preparation of consolidated financial statements by parent companies and, in this context, for the planning or execution of relations with the parent company and for risk management and assessment activities; for the execution of risk, audit, and operational services carried out together with subsidiaries; and additionally, for the execution of risk, audit, and operational services for the purpose of compliance with the Capital Markets Board (SPK) legislation. | Pursuant to Article 5/2(ç) of KVKK, “It is necessary for compliance with a legal obligation to which the data controller is subject”, and Article 5/2©, “Data processing is necessary for the establishment, exercise or protection of any right” |
| Identity, Finance, Contact, Customer Transaction, and Transaction Security | For the management and planning of relations and processes established with our service providers, business partners, or suppliers, and for the fulfillment of legal and commercial obligations within the framework of contracts concluded and activities carried out with third parties with whom we have business relations. | Pursuant to Article 5/2© and (ç) of KVKK; |
arşiv, raporlama, bilgilendirme yükümlülüklerine uyulması, bunların icrası ve bu kapsamda ilgili otoritelerden gelen bilgi ve belge taleplerinin yerine getirilmesi için; 6563 sayılı Elektronik Ticaretin Düzenlenmesi Hakkında Kanun ve alt düzenlemeleri uyarınca ticari elektronik ileti onayı alınması, reddetme hakkının kullanılmasına ve şikâyet süreçlerinin yönetilmesine imkân tanıyan sistemin ("İYS Sistemi") kullanılması için; Finansal Kiralama, Faktoring ve Finansman Şirketlerinin Bilgi Sistemlerinin Yönetimine ve Denetimine İlişkin Tebliğ uyarınca kimlik ve erişim yükümlülüklerimizin yerine getirilmesi için; | ||
| Identity, Contact, Customer Transaction, Finance | For the execution of advertising, marketing, and promotional activities related to our Company’s products and services, for conducting studies including surveys and statistical analyses, for the management of campaign processes and for contacting you for these purposes, for presenting offers, and for the provision of commercial electronic communication delivery services for marketing purposes | On the basis of the existence of Explicit Consent, provided that the fundamental rights and freedoms of the data subject are not harmed, and the processing of data is mandatory for the legitimate interests of our Company. |
V. PURPOSE OF TRANSFER OF PERSONAL DATA AND RECIPIENT GROUPS
Your personal data processed by TEB Faktoring, the categories of which are listed above, may be transferred to the recipient groups specified in the table below for the purposes indicated, in accordance with the legal grounds set forth in Articles 8 and 9 of the Law on the Protection of Personal Data (“KVKK”).
| RECIPIENT GROUPS | PURPOSE OF TRANSFER |
| Legally Authorized Public/Private Institutions or Organizations (Banking Regulation and Supervision Agency, Capital Markets Board, Central Bank of the Republic of Türkiye, Revenue Administration, Financial Crimes Investigation Board, Interbank Card Center, Banks Association of Türkiye, Risk Center of the Association of Financial Institutions, Courts, Prosecutor’s Offices, etc.) | • Providing information to authorized public and private institutions within the scope of legislation • Designing necessary actions to ensure that company activities are carried out in compliance with the relevant legislation • Ensuring the legal and physical security of the Company • Enabling customers to benefit from Company services • Being mandatory for the execution of the transaction or performance of the contract • Carrying out the activities required for the continuation of the Company’s commercial activities |
| External Service or Support Service Providers (Consultants, institutions, and parties from which TEB Faktoring receives services or cooperates with, in areas such as archiving services, call center, information systems, company operational services, collection management, audit, rating, etc., which are complementary to TEB Faktoring’s activities) | • Enabling customers to benefit from Company services • Being mandatory for the execution of the transaction or performance of the contract • Carrying out the activities required for the continuation of the Company’s commercial activities • Ensuring the legal and physical security of the Company • Designing necessary actions to ensure that company activities are carried out asper the relevant legislation • Conducting marketing and cross‑selling activities |
| Business Partners (Institutions with which cooperation relationships are established within the scope of the provision of financial products and services) and TEB Group* | Carrying out the activities required for the continuation of the Company’s commercial activities • Developing and improving the Company’s reputation and business relations and determining its strategies • Enabling customers to benefit from Company services • Being mandatory for the execution of the transaction or performance of the contract |
| Domestic and Foreign Banks and Financial Institutions | Enabling customers to benefit from Company services • Being mandatory for the execution of the transaction or performance of the contract • Carrying out the activities required for the continuation of the Company’s commercial activities |
| Domestic and Foreign Banks and Financial Institutions | Enabling customers to benefit from Company services • Being mandatory for the execution of the transaction or performance of the contract • Carrying out the activities required for the continuation of the Company’s commercial activities |
| Direct or Indirect Shareholders of TEB and BNP Paribas Group ** | Responding to information/document requests of our main shareholders in matters such as consolidated financial statement preparation, risk management, internal audit, and credit assessment within the limits permitted by factoring legislation • Developing and improving the Company’s reputation and business relations and determining its strategies |
| * “TEB Group” | refers to TEB Holding A.Ş. and the group of companies consisting of subsidiaries including our Company. |
| ** “BNP Paribas Group” | refers to BNP Paribas S.A. and the group of companies consisting of its subsidiaries. |
VI. YOUR RIGHTS UNDER KVKK
With respect to your personal data processed by our party, you may submit your requests within the scope of Article 11 of the Law on the Protection of Personal Data (“KVKK”) in accordance with the Communiqué on the Principles and Procedures of Application to the Data Controller, or by filling out the Personal Data Rights Exercise Form available on our Company’s website, in writing or by using your registered electronic mail (KEP) address, secure electronic signature, mobile signature, or the electronic mail address previously notified to us and registered in our system, to the following addresses at any time:
• Your requests may be sent or delivered to our Company’s address via registered mail with return receipt or through a notary,
• Transmitted by e‑mail to basvurukvkk@tebfaktoring.com.tr, or
• Sent via KEP to tebfaktoring@hs03.kep.tr.
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