CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

This clarification text is drafted by BN TEKNOLOJİ ANONİM ŞİRKETİ (“Binance Turkey”) in its capacity as a data controller within the scope of Article 10 of the Personal Data Protection Law No. 6698 and the Communique on Principles and Procedures to be Followed in Fulfillment of the Obligation To Inform.

Dear our esteemed clients: personal data is defined as any information relating to an identified or identifiable natural person within the scope of the Personal Data Protection Law No. 6698 entered into force on 7 of April 2016 (“Law”), and the protection of your personal data and to be informed about your personal data is your fundamental rights as per the Constitution of the Republic of Turkey (“Constitution”). In this regard, since ensuring the safety and processing of your personal data requires great importance and diligence of Binance Turkey and also constitutes an obligation, your data is processed and protected by Binance Turkey within the scope of the Constitution, Law and General Data Protection Regulation (“GDPR”).

“Data Controller” is obliged to inform the related persons at the time of collection of personal data, under the Article 10 of the Law, about the identity of the data controller and of its representative, if any, the purpose of processing of personal data, to whom and for which purposes the processed personal data can be transferred, the method and legal basis of collection of personal data and other rights referred to in Article 11 of the Law, and it is aimed to inform you by making statements about personal data processing operation carried out by Binance Turkey holding the title of data controller within the scope of the “Law” though this clarification text.

1. Binance Turkey as Data Controller

Data Controller is defined as, under Article 3-1 of the Law, the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data filing system, and Binance Turkey is a data controller in terms of data of our esteemed clients/potential clients.

2. The Purpose of Processing Your Personal Data

Personal data of our esteemed clients such as name and surname, date of birth, place of birth, mother's name-father's name, mobile phone number, e-mail address, identification number/numbers, other identification information, photos, bank account numbers, address, occupation information, device type and identity personal data in the form of tracking information about usage, IP address and information obtained from WLAN (Wireless Local Area Network), transaction history, access date and time, browser type and version and location information within the scope of all stages, including the conclusion, execution and termination of the agreements you will make shall be processed in accordance with Article 20 of the Constitution of the Republic of Turkey and Article 4 of the Law for the following purposes by Binance Turkey as data controller:

2.1 providing our services and also verifying your customer identity within the same scope;

2.2 protection of customer accounts and archives;

2.3 compliance with legal and administrative measures;

2.4 use of the products and services that you receive/to be received, communication of offers for new product and service to you;

2.5 maintaining customer satisfaction at a high level by measuring the performance of our systems;

2.6 planning commercial/business strategies;

2.7 ensuring the security of our website, mobile applications, other online applications and products;

2.8 modeling, reporting, scoring, risk monitoring, intelligence, current or new product studies, and potential customer detection;

2.9 drafting information and documents that will be the basis for the work and operations to be performed;

2.10 compliance with the information retention, reporting and disclosure obligations stipulated by all judicial and administrative authorities in accordance with the relevant legislation, and ensuring the execution of the requests or decisions made by these authorities;

2.11 notifying such authorities thereof for the purpose of investigation, detection, prevention of breach of contract and violation of laws;

2.12 settlement of current and potential legal disputes;

2.13 ensuring customer account security and system security; fulfilling our legitimate interests such as fulfilling obligations under anti-money laundering legislation and prevention of fraud and crime.

2.14 ensuring that our systems, services and interface are accessible for users using all platforms (IOS, Android).

3. Transferring Your Personal Data

Your personal data is stored safely under the control of Binance Turkey and not transferred to third parties except for the following cases:

Your personal data shall be transferred by Binance Turkey to its business partners, consultants and competent courts and/or enforcement offices and public institutions and organizations for the purpose of legal and financial audits in Turkey in accordance with Article 8 of the Law, in order to realize the purposes of processing the personal data herein.

In addition, your personal data may be transferred by Binance Turkey directly or indirectly to any third party whom has received or intends to receive or will receive consultancy, support or other services, competent institutions and organizations within the framework of specified personal data processing conditions and purposes.

Specifically, Binance Turkey can transfer, process or store your personal data to:

  1. 3.1 persons, institutions and/or organizations obliged/permitted by the provisions of the Law and other legislation;
  2. 3.2 all kinds of public legal entities and authorities authorized to receive personal data;
  3. 3.3 Binance Turkey affiliated companies, groups of companies;
  4. 3.4 third parties from whom we receive services in the fields of law, tax, etc. to carry out our activities;
  5. 3.5 the program partner with whom we cooperate institutions, organizations, domestic/foreign banks, funds, organizations with whom cooperated;
  6. 3.6 domestic/foreign/international organizations from which service/support/consultancy is provided or which are project/program/financing partners, and organizations from which independent audit and support services are provided;
  7. 3.7 provided that the necessary security measures are taken, electronic media such as servers, hosting companies, programs, cloud information technology etc. -located in Turkey or abroad particularly EU, UK, OECD countries- from which storage, archiving, information technology support provided.

Your personal data can be transferred only under legal limitations due to legal obligations.

Binance Turkey takes all the necessary technical and administrative measures in case your personal data is transferred to home or abroad. The data processing activity in the form of transferring the data abroad will be carried out on the condition that the “explicit consent” of the person concerned is obtained. Binance Turkey will make reasonable effort to precure such third parties take necessary technical and administrative measures to protect the personal data being transferred.

4. The Method and Legal Basis of Your Personal Data Collection

Your personal data is processed:

4.1 with all agreements/information forms and other documents;

4.2 by means of your notifications;

4.3 through our website, mobile applications, other online applications and products;

4.4 through your calls to our call center or call center where we receive services;

4.5 through third party service providers;

4.6 through channels such as KPS (ID Share System), SMS, electronic mail, provided that in oral, written or electronic media;

by means of various methods which are fully or partially automated, or non-automated as part of any data recording system, our domestic/foreign subsidiaries, our collaborative program partner organizations and institutions, government agencies, including domestic/international and the other 3rd persons other than Binance Turkey and stored within the statutory legal periods set out within the framework of the legislation.

Personal data collected for these legitimate reasons shall be processed and transferred by Binance Turkey in accordance with the basic principles stipulated by the Law, personal data processing conditions and purposes specified in Article 5 and Article 6 of the Law for the purposes specified herein.

Your personal data is processed:

4.7 Upon conclusion and execution of the membership agreement (Personal Data Protection Law Art.5/2-c);

4.8 Provided that it does not impair the fundamental rights and freedoms of the person concerned, as per the legal basis that Binance Turkey is obliged to process data for its legitimate interests (Personal Data Protection Law Art.5/2-f).

4.9 Furthermore, the data processing activity in the form of transferring the data abroad will be carried out on the condition that the “explicit consent” of the person concerned is obtained.

Binance Turkey will not process the personal data in a manner incompatible with the purposes for which they are collected within the framework of this Clarification Text and the Law and shall erase, destruct or anonymize ex officio or upon demand by the data subject, upon disappearance of reasons which require the process erasure or destruction or anonymizing.

5. Your Rights Under Article 11 of the Law

By applying to Binance Turkey, you have the right to:

5.1 learn whether personal data is processed;

5.2 request information if personal data has been processed;

5.3 learn the purpose of processing personal data and whether they have been used in accordance with the purpose;

5.4 be informed of the third parties from which personal data is transferred domestically or abroad;

5.5 request personal data to be corrected if it is incompletely or improperly processed;

5.6 request the deletion or destruction of personal data within the framework of the conditions stipulated in the Article 7 of the Law;

5.7 requesting the transactions made in accordance with paragraphs (5.5) and (5.6) to be notified to third parties to whom personal data has been transferred;

5.8 object to the appearance of a result against you by analyzing the processed data exclusively through automated systems;

5.9 claim to recover damages in case of damage caused by illegal processing of personal data.

6. The Data Controller You Can Refer To

Your claims within the scope of your right stated under previous article (within the scope of Article 11 of the Law) can be made:

6.1 personally to the address of Binance Turkey written below with information confirms your identity;

6.2 with secure electronic signature, mobile signature or your current electronic mail address notified to Binance Turkey and saved in the Binance Turkey system to the Binance Turkey’s destek@trbinance.com address.

In your applications made according to the abovementioned procedure:

6.3 your name, surname, date and signature if the application is written;

6.4 11-digit TR ID number if you're a Turkish citizen;

6.5 your residence permit and ID number, if you are not a Turkish citizen;

6.6 your residence or work place address subject to the notification;

6.7 your electronic mail address subject to the notification and telephone number, if any;

6.8 request subject.

shall be definitely included, and all information and documents relating to your request should be legibly added to your application.

Your application will be accepted following ID authentication to be made by Binance Turkey and will be answered in writing or in electronic form within the statutory period. We would very much like to point out that for written applications the date when the documents are delivered to Binance Turkey and for applications made with other methods the date when the application is delivered to Binance Turkey will be considered as the application date. The response to your applications is essentially a free of charge process and if the response process requires a cost, the fee will be reflected to you within the scope of the legislation or in the tariff determined/to be determined administratively.

The Clarification Text has been arranged in two languages, namely Turkish and English; hence in case there is a conflict/contradiction between the two versions, the Turkish version shall prevail.

Trade Registry No: 221729-5

Mersis (Central Trade Registry System) No: 178140451300001

Company Title: BN TEKNOLOJİ A.Ş.

Address: Esentepe Mah. Büyükdere Cad. Ferko Apt. No:175/7 Şişli İstanbul.

The website address: https://www.trbinance.com