MobilDeniz Application Privacy Policy – Mobile Application Disclosure Statement | Personal Data Protection | DenizBank

As DenizBank A.Ş. (“Bank”), we would like to inform you about the processing of your personal data and other data during your use of the ‘MobilDeniz’ mobile application (“MobilDeniz” or “Application”) in order to improve your user experience and provide the application functions, as well as the permissions we collect via MobilDeniz. We are sensitive about protecting the confidentiality and security of all of your information. We are taking necessary measures in line with our legal obligations with regards to protecting customer information and transaction security. The table below shows information about the data controller that processes your personal data.

Data Controller	DenizBank A.Ş.
Address	Büyükdere Cad. No:141 Esentepe 34394 Şişli / İSTANBUL
Central Registry System / Registry No.	0292-0084-4960-0341 / 368587

1.Rights of the Data Subject under Article 11 of the Law

You have the following rights related to your personal data:

You have the right to learn whether your personal data are processed or not.
If your personal data has been processed, you can request information about this data.
You can learn the purpose of your data being processed and whether this data is used for intended purposes,
You have the right to learn which third parties your personal data is transferred to at home or abroad.
You can request correction if your personal data were processed incompletely or inaccurately and request that these corrections be notified to the third parties to which your personal data has been transferred.
You can request the erasure or destruction of your personal data within the relevant legislation.
You may request that the correction, deletion and destruction of your personal data be notified to third parties with whom this data is shared.
You may object to the emergence of results against you as a result of your personal data being analyzed exclusively by automated systems.
You can request compensation for the damage arising from the unlawful processing of your personal data.

2.Method and Legal Basis of Collecting Personal Data

While you use the MobilDeniz application, your personal data such as identity data, contact data, financial data and usage/transaction security data are collected through MobilDeniz and Internal Bank systems in order to ensure legal and technical security and fulfill your requests. Your personal data collected within the scope of the services we offer you can be processed within the framework of the personal data processing requirements stipulated in the art. 5 of the Personal Data Protection Law (“Law”).

3.Purpose Of Processing Your Personal Data And Its Legal Grounds

We must have a legal basis (lawful reason) to process your personal data. Within the scope of the KVKK, when we process your personal data, we need to fulfill at least one legal basis defined for processing. Your personal data which is collected can be processed under the conditions of data processing stipulated in the art. 5 of the Law and under the purposes below:

Cases whereby your personal data may be processed without seeking your explicit consent have been stipulated in paragraph 2 of Article 5. Accordingly, in cases below, your personal data may be processed without your explicit consent.

being explicitly stipulated in the laws.
If it is obligatory for the protection of life or bodily integrity of the person himself or herself or of any other person, who is unable to express his or her consent due to factual impossibility or whose consent is not considered legally valid at all,
Processing of personal data belonging to the parties to the agreement is required, on condition that it is directly related to the establishment or performance of such agreement.
Being mandatory for the Data Controller to fulfill its legal obligation.
Being anonymized by the data subject.b
data processing being obligatory to establish, exercise or protect a right,
Data processing is mandatory for the legitimate interests of the data controller, on condition that such processing does not violate the fundamental rights and freedoms of the data subject.

Your personal data collected is processed for the purposes below:

Offering banking services and fulfilling requests
Defining user and device
Updating your information
Increasing service quality
Obtaining application security
Service and product promotions (in case you give permission)
Fulfilling official institution requests
Providing information resulting from legislation to the authorized institutions
Ensuring compliance with the retention obligations laid out in the legislation
Fulfilling our legal obligations resulting from the legislation we are subject to (including detecting if there is malware in your mobile device)

You can access the notification forms regarding your personal data being processed within the scope of banking transactions, loan and investment processes performed via application on the https://www.denizbank.com/en/personal-data-protection website.

Regarding the processing of personal data obtained automatically through the placement of cookies on your device in the application, you can access the information text about what types of cookies we use for what purposes and how you can manage these cookies from the https://www.denizbank.com/yasal-uyari

4.Processing Personal Data on MobilDeniz and Application Permits

4.1.Personal Data Being Processed Specific to the Application Use:

Personal data below can be processed within the scope of the use of MobilDeniz application:

Identity and contact information (full name, TR ID No, telephone number, email address vs)

To carry out your membership to the Mobile Application, to carry out identity verification processes, to contact you when necessary, etc.

Financial product and service use information (income information, credit history, current debt/receivable status, details on the product and service used etc)

To offer products, service and proposals tailored to you, perform financial analyses,

User profile information (login frequency, transaction habits etc.)

to create user profile, improve the user experience etc.

IP Address and connection log information

To perform security controls, report to the official authorities when required by the legal obligations etc.

Information about the device on which mobile application is downloaded (device brand/model, operating system version, device language,IMEI no etc.)

To ensure that the application works as optimized exclusively to the device, handle the technical support processes, detect security gaps and make device-based risk assessment etc.,

Application version information, crash logs, error and performance information etc

To analyze the technical performance of the application etc,

Data collected through security instruments used for the purpose of malware and fraud (list of applications uploaded on the phone, detecting the unauthorized system access on the device (root/jailbreak control etc)

To detect the security status of mobile device, determine the asset of malicious applications etc.

4.2.Application Permissions and Processed Data Specific to iOS and Android Platforms:

As DenizBank, we obtain permissions through different functions for various purposes on the basis of different operating systems in our Mobile Application and process your personal data through these functions. The main purposes and application purposes of these application permissions and collected data are as follows:

4.2.1.On iOS Devices:

Location: Access to services such as finding nearby branches/ATMs, location-specific campaign notifications, fraud prevention, etc. is available with the "While using the app" or "Always" options.
Camera: Used for QR code scanning, document scanning/upload, identification, ATM transactions etc.
Storage/Photos: Used for document/photo access and upload etc. from the device memory.
Notifications: Used for transaction notifications, campaign and information messages etc.
Contact: Used for operations such as making a money transfer by selecting a person from contacts etc.
Application Information: Processed for security and analysis pruposes for device model, operating system, any unauthorized intervention to bypass the security measures in the system (root/jailbreak), downloaded applications etc.
NFC (Near Field Communication): Used for verifying transaction etc.
SMS (Text Message Service): Used for automatically detecting smart passwords etc.
Device Identifiers: Used to access device information for performance and security analysis, error follow-up etc.
Microphone: It can be used for parts of the application that work with audio, such as interactive customer experience.
Call: Can be used to start a call so that Call Center can be directly called.
Behavioral Analysis: Used to improve the user experience by analyzing application interaction, transaction preference etc and marketing processes.

4.2.2.On Android Devices:

Location: Access to services such as finding nearby branches/ATMs, location-specific campaign notifications, fraud prevention, etc. is available with the "While using the app" or "Always" options.
Camera: Used for QR code scanning, document scanning/upload, identification, ATM transactions etc.
Storage/Gallery: Used for document/photo access and upload etc. from the device memory.
Notifications: Used for transaction notifications, campaign and information messages etc.
Contact: Used for operations such as making a money transfer by selecting a person from contacts etc.
Application Information: Processed for security and analysis pruposes for device model, operating system, any unauthorized intervention to bypass the security measures in the system (root/jailbreak), downloaded applications etc.
NFC (Near Field Communication): Used for verifying transaction etc.
SMS (Text Message Service): Used for automatically detecting smart passwords etc.
Device Identifiers: Used to access device information for performance and security analysis, error follow-up etc.
Microphone: It can be used for parts of the application that work with audio, such as interactive customer experience.
Call: Can be used to start a call so that Call Center can be directly called.
Behavioral Analysis: Used to improve the user experience by analyzing application interaction, transaction preference etc and marketing processes.

5.For what purposes and to whom the processed personal data may be transferred

Your personal data collected in line with the fulfillment of the above-mentioned purposes may be transferred to our business partners, subsidiaries or suppliers within the scope of the establishment and execution of the agreement and our legitimate interest, to legally authorized public institutions and legally authorized private persons within the scope of the establishment and execution of the contract, and to fulfill our legal obligations, as expressly provided for by law, in accordance with the data processing conditions stipulated in Article 5 of the Law and the rules regarding the transfer of personal data stipulated in Article 8 of the Law.

6.Data Subject Application Methods

You can submit your requests regarding your personal data, including your request for deletion of Your Personal Data and MobilDeniz account;

Provided that you verify your identity, through a written petition to the attention of our DenizBank A.Ş.Head Office located in Büyükdere Cad. No: 141 Esentepe 34394 Şişli / İSTANBUL or through a public notary.
By e-mail to denizbank.haberlesme@hs09.kep.tr , using your registered e-mail address, with electronic or mobile signature.
By using your e-mail address that you have previously reported to our bank and registered in our system, to oncemusteri@denizbank.com.
“Notification type given under https://www.denizbank.com/en/customer-satisfaction/contact-form Complaint-Subject: Retail Banking-Sub-topic: by filling out the form that comes up after selecting the subheadings “Personal Data Protection Law Complaint Notifications”;

The application must contain the following information:

Full name, if the application is written, signature,
For citizens of Republic of Türkiye, your Republic of Türkiye ID Number; for foreigners, your nationality, passport number or ID number, if any,
Your residential or work address that is the basis for the notification,
Your e-mail address, telephone number, fax number, if any, that is for such reporting,
Subject of the request.

Your application shall be finalized as soon as possible and within thirty (30) days at the latest, free of charge. If transactions pertaining to your request entail a separate cost, a fee may be charged from you as per the tariff stated by the Personal Data Protection Board.

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