Commercial Electronic Communications Consent Notice

Pursuant to Law No. 6563 on the Regulation of Electronic Commerce and Law No. 6698 on the Protection of Personal Data (KVKK), by granting this consent, you acknowledge and agree that your personal data shared with Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş. may be stored, processed, and shared for the purpose of informing you about various services and product groups, providing you with exclusive advantages, and delivering personalized communications including promotions, marketing activities, advertisements, campaigns, surveys, and similar content. Such communications may be delivered via SMS (text message), MMS (multimedia message), email, telephone, call center services, automated calling systems, WhatsApp, and other digital communication platforms. Your personal data will be processed solely for the purpose of ensuring the seamless delivery of our services, the proper execution of your requests, and the timely delivery of our communications via phone, SMS, and/or email. Where necessary and to the extent required, your data may be shared with our affiliates and third-party service providers with whom we have a contractual relationship, provided that they comply with applicable data protection regulations and uphold equivalent standards of data security.

MERSIS Nr: 0-7710-3054-3200013
Phone: +90 212 310 27 00
Address: Sinpaş Plaza, Barbaros Boulevard, Yenidoğan Street No:36, Beşiktaş, Istanbul, Türkiye

You may withdraw your consent at any time, free of charge, by sending an SMS with the text SNP to 3172, by emailing info@sinpas.com.tr, or by calling 444 19 74.

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Information Notice on the Protection of Personal Data

This Information and Disclosure Notice has been prepared in accordance with Law No. 6698 on the Protection of Personal Data (KVKK), governing the processing and transfer of personal data relating to natural persons. Within the scope of the aforementioned Law, any and all information pertaining to you and shared with our Company shall be deemed as “Personal Data.” The security of your personal data is of utmost importance to us. Your personal data will be stored in compliance with applicable legislation, under the highest possible security standards, and retained for the duration required by legal obligations.

a) Data Controller and Representative
Pursuant to Law No. 6698 on the Protection of Personal Data (KVKK), your personal data may be processed by Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş. (“Sinpaş REIT”), acting in its capacity as the Data Controller, within the scope and for the purposes set forth herein.

b) Purposes of Processing Your Personal Data
Your collected personal data may be processed by Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş., in accordance with Articles 5 and 6 of Law No. 6698 on the Protection of Personal Data (KVKK), for the purposes of ensuring the fulfillment of obligations of our Company and of natural and legal persons with whom we maintain a business relationship, providing you with updates and relevant notifications, establishing and performing contractual relationships with you and fulfilling related legal obligations, conducting advertising, promotional, and marketing activities, managing and monitoring finance, accounting, and legal processes, following up and resolving your requests, inquiries, and complaints as well as managing contractual processes and/or legal claims, planning and executing customer satisfaction activities including surveys, polls, and feedback mechanisms, identifying, analyzing, and developing products, projects, and services suitable for you and customizing them based on your preferences, delivering effective and efficient customer service, notifying you of changes in applicable legislation, internal policies, or other matters that may concern you, organizing and executing events, promotions, campaigns, and similar activities in your favor including but not limited to birthday greetings, raffles, competitions, and gift offerings, informing you via electronic communication channels including but not limited to email, SMS, fax, telephone, and similar means and ensuring that you are informed about campaigns and announcements, sending printed materials such as newsletters, magazines, and promotional content, conducting visitor and customer profiling and analytics, evaluating requests, demands, and complaints, carrying out and managing the Company’s human resources policies, and responding to inquiries and requests submitted by you.

c) Transfer of Personal Data and Its Recipients
Your personal data shall be processed in compliance with the principles of lawfulness and fairness, accuracy and being up to date where necessary, processing for specific, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed. Furthermore, subject to compliance with the conditions set forth under Articles 8 and 9 of Law No. 6698 on the Protection of Personal Data (KVKK) and the implementation of necessary security measures, your personal data may be transferred, limited to the purposes specified under section (b) of this Notice, to our direct or indirect domestic and/or international affiliates and subsidiaries, to domestic and/or international public and private institutions and organizations, companies, and third parties with whom we cooperate, from whom we receive services, support, or consultancy, or with whom we are engaged as project, program, or financing partners, as well as to our group companies, consultants, shareholders, solution partners, the Central Securities Depository, other authorized institutions and organizations, suppliers, and subcontractors. Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş. may, provided that necessary security measures are taken, process and store your personal data within Türkiye or abroad, provided that adequate protection exists in the recipient country; in the absence of such adequate protection, personal data may be processed and stored in servers or other electronic media located abroad, provided that sufficient protection is undertaken in writing by the data controllers in the relevant foreign country and the approval of the competent authority is obtained.

ç) Method of Collection of Personal Data and Legal Basis
Your personal data may be collected by our Company through various channels, including but not limited to physical environments such as the headquarters, branches, agencies, and sales offices of Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş., as well as offices and other physical locations where you may interact with our subcontractors or business partners; call centers; websites; mobile applications and similar electronic transaction platforms; social media and other publicly available platforms; through your participation in training sessions, conferences, and similar events organized by the Company; through investigative methods; or via other group companies or third parties with whom the Company has contractual relationships, in written, verbal, audio, visual, or other physical or electronic forms. Your personal data may be collected, processed, transferred, and stored within the scope of the personal data processing conditions and purposes specified under Articles 5 and 6 of Law No. 6698 on the Protection of Personal Data (KVKK), and for the purposes set forth in sections (b) and (c) of this Notice. Your personal data shall be retained in compliance with applicable legislation for the duration required by legal obligations or for the period permitted under the relevant laws.

d) Rights of the Data Subject
As data subjects, if you submit your requests regarding your rights to our Company through the methods set forth below, our Company shall conclude your request as soon as possible and, in any event, within a maximum period of thirty (30) days, free of charge. However, if a fee is stipulated by the Personal Data Protection Board, the fee determined under the applicable tariff may be charged by our Company. Within this scope, data subjects have the right to;

• To learn whether personal data is processed,
• To request information regarding personal data if it has been processed,
• To learn the purpose of processing of personal data and whether they are used in accordance with their purpose,
• To know the third parties to whom personal data is transferred domestically or abroad,
• To request the rectification of incomplete or inaccurate personal data and to request that such rectification be notified to third parties to whom the personal data has been transferred,
• To request the deletion or destruction of personal data in the event that the reasons requiring its processing no longer exist, despite having been processed in accordance with the Law and other relevant legislation, and to request that such action be notified to third parties to whom the personal data has been transferred,
• To request the deletion or destruction of personal data in the event that the reasons requiring its processing no longer exist, despite having been processed in accordance with the Law and other relevant legislation, and to request that such action be notified to third parties to whom the personal data has been transferred,
• To object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,
• To request compensation for damages in case of loss arising from the unlawful processing of personal data.

Pursuant to Article 13, paragraph 1 of Law No. 6698 on the Protection of Personal Data (KVKK), you may submit your request regarding the exercise of your rights set forth above to our Company in writing. Within this scope, you may complete the form available at www.sinpas.com.tr and submit a signed hard copy of the form, addressed to Sinpaş REIT Customer Relations Department, to the following address: Sinpaş Plaza, Barbaros Bulvarı, Yenidoğan Street No:36, Beşiktaş, Istanbul, together with documents verifying your identity, either in person or through a notary public, including your explanations regarding the right you wish to exercise as specified under Article 11 of the Law.

Our Company reserves the right to amend this Information Notice due to any changes that may occur in the Law or in the procedures to be determined by the Personal Data Protection Board.

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