Pension
Privacy Notice on the Processing of Personal Data
Data Controller Information:
Data Controller: Türkiye Hayat ve Emeklilik Anonim Şirketi
MERSIS No: 0434005145200019
Address: Levent Mah. Çayır Çimen Sok. No:7 34330 Levent - Beşiktaş / ISTANBUL
Phone & Fax: +90 212 310 37 00 & +90 212 310 39 99
Customer Service Number: 0850 202 2020
E-mail: [email protected]
Registered Electronic Mail (KEP) Address: [email protected]
Website: www.turkiyehayatemeklilik.com.tr
As Türkiye Hayat ve Emeklilik Anonim Şirketi (“Company”), in our capacity as the Data Controller, we would like to inform you in accordance with the Law on the Protection of Personal Data No. 6698 (“Law No. 6698”) about the purposes of processing your personal data, the legal grounds for such processing, and your rights.
The Company takes the highest level of security measures necessary to ensure that your personal data is collected, stored, shared, and kept confidential in full compliance with Law No. 6698.
Purposes of Processing Personal Data:
Your personal data and sensitive personal data* may be processed by our Company in accordance with the principles set forth in Article 4 and the conditions specified in Articles 5 and 6 of Law No. 6698 for the following purposes:
Execution of all processes related to the establishment and performance of private pension and life insurance contracts provided by our Company,
Fulfillment of our legal obligations under the Turkish Commercial Code, Insurance Law, Private Pension Savings and Investment System Law, Law on the Prevention of Laundering Proceeds of Crime, Turkish Civil Code, and other relevant legislation,
Ensuring that insurance and private pension activities are carried out in accordance with Company procedures and/or applicable legal regulations,
Execution of business transactions with business partners and/or suppliers within the scope of offering and developing our products and services,
Management of risk assessment, indemnity payments, and policy issuance processes related to the insurance coverage provided,
Execution of reinsurance and co-insurance activities,
Preparation and retention of all records and documents that serve as a basis for transactions, whether in electronic form (internet branch, mobile application, digital assistant, WhatsApp line, call center, social media, etc.) or in physical (paper) form,
Recording information such as identity and address details, profession, income status, and purpose of transaction with our Company, primarily to fulfill our obligations regarding customer identification under applicable laws,
Management of customer relations and ensuring customer satisfaction in connection with the products and services offered by our Company,
Obtaining information from local postal services, the national address database (Central Civil Registration System - “MERNİS”), and similar institutions for the purpose of verifying and updating addresses,
Management of business transactions conducted with our Company’s main shareholders and affiliated companies,
Planning and execution of business activities and operational processes,
Management of corporate sustainability, corporate governance, and strategic planning processes,
Planning, auditing, and execution of information security processes,
Processing of online visitor data in accordance with the relevant legislation,
Execution of membership procedures on our online platforms,
Recording of video footage by security cameras at our Company’s headquarters and service locations for workplace safety practices and legal obligations,
Planning and execution of marketing, sales, and after-sales support service activities,
Based on your explicit consent and the permission you have provided for the sending of commercial electronic messages, your preferences and interests may be used for conducting targeting, profiling, and analysis activities for the purposes of enhancing service quality and/or marketing analysis, promoting and marketing applications, products, and services, conducting cross-selling activities, as well as carrying out surveys, statistical analyses, and market research studies,
Based on your explicit consent, sharing of your data with reinsurance companies located abroad for the purpose of reinsuring risks,
Your sensitive personal data, including health data, may be obtained from you and/or from public or private healthcare providers, recorded in our Company's data recording system, and retained for the duration required by the applicable legislation,
Fulfillment of information and reporting obligations upon request by official and administrative authorities such as the Republic of Türkiye Ministry of Treasury and Finance, the Central Bank of the Republic of Türkiye, the Insurance and Private Pension Regulation and Supervision Agency, the Capital Markets Board, the Central Securities Depository Inc., the Association of Insurance, Reinsurance and Pension Companies of Türkiye, the Insurance Arbitration Commission, the Insurance Information and Monitoring Center, the Pension Monitoring Center, the Financial Crimes Investigation Board, and the Credit Bureau,
Execution of lawsuits and enforcement proceedings in which our Company is a party,
Planning and execution of audit activities,
Processing of data received during the quotation stage (for life insurance) to determine insurance coverage limits, and processing of such data—even if you do not become our policyholder/customer—as required by underwriting and risk assessment procedures.
Furthermore, within the scope of the legislative amendment that entered into force on June 1, 2024, your sensitive personal data, including your health data, are processed based on the legal grounds specified in Article 6/3(b) of Law No. 6698 (“explicitly provided for by law”) and Article 6/3(d) (“necessary for the establishment, exercise, or protection of a right”). These data may be obtained from you and/or public or private healthcare providers, recorded in our Company’s data registry system, and retained for the periods prescribed by applicable legislation.
Transfer of Your Personal Data:
Your personal data and sensitive personal data may be transferred in accordance with Articles 8 and 9 of Law No. 6698 on the transfer of personal data within and outside Türkiye for the purposes specified in Article 1 of this Clarification Text, and within the scope of the Insurance Law, the Private Pension Savings and Investment System Law, and other relevant legislation, to official and administrative authorities including, but not limited to, the Republic of Türkiye Ministry of Treasury and Finance, the Central Bank of the Republic of Türkiye, the Insurance and Private Pension Regulation and Supervision Authority, the Capital Markets Board, the Central Securities Depository Inc., the Association of Insurance, Reinsurance and Pension Companies of Türkiye, the Insurance Arbitration Commission, the Insurance Information and Monitoring Center, the Pension Monitoring Center, the Financial Crimes Investigation Board, and the Credit Bureau; to our shareholders and their direct/indirect affiliates; to our subsidiaries; to insurance and pension companies; and to domestic and/or international agencies, brokers, intermediaries, financial institutions, investment/portfolio management companies, reinsurance companies, suppliers, program partners, and other relevant third parties with whom we cooperate or from whom we receive services.
Method and Legal Basis for Collection of Personal Data:
Your personal data may be collected verbally, in writing, or electronically through automatic or partially automatic methods by our Head Office Units, Regional Directorates, Contact Offices, Agencies, Intermediaries, Brokers, Insurance and Pension Companies, official institutions and organizations, policy and contract parties , call center, digital platforms (internet branch, mobile application, digital assistant, WhatsApp line, social media, etc.) and cookies on these platforms, the Identity Sharing System and other similar channels.
These data are processed within the scope of the personal data processing conditions specified in Articles 5 and 6 of Law No. 6698, and for the purposes outlined in Article 1 of this Clarification Text, on the basis of:
The establishment and performance of a contract with our Company,
Fulfillment of legal obligations,
Explicitly provided for by law,
Necessity for the establishment, exercise, or protection of a right,
The legitimate interests of our Company,
And where required, your explicit consent, and—if commercial electronic message permission has been granted—your consent to such communication.
Rights of the Data Subject:
If you, as the data subject, submit your requests regarding your rights listed below to our Company, your request will be finalized free of charge as soon as possible and within no later than thirty (30) days, depending on the nature of the request, after your identity has been verified, through written or secure electronic communication channels. However, if the transaction requires an additional cost, the tariff determined by the Personal Data Protection Board may be applied by our Company.
It is important that the personal data we hold about you is accurate and up to date. Therefore, you are kindly requested to inform our Company of any changes to your personal data.
As the data subject, you have the right to:
Learn whether your personal data is being processed,
Request information if your personal data has been processed,
Learn the purpose of the processing of your personal data and whether it is used in accordance with this purpose,
Know the third parties to whom your personal data has been transferred, whether domestically or abroad,
Request the correction of your personal data if it has been processed incompletely or inaccurately and request that such correction be notified to third parties to whom the data has been transferred,
Request the deletion or destruction of your personal data if the reasons requiring the processing no longer exist, even though it has been processed in accordance with the Law No. 6698 and other relevant legal provisions, and request that such deletion or destruction be notified to third parties to whom the data has been transferred,
Object to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
Request compensation for damages in case you suffer harm due to the unlawful processing of your personal data.
If you would like to obtain more information on the subject or review our policies, you may access the full version of our privacy notice and policies at www.turkiyehayatemeklilik.com.tr. Additionally, regarding your rights specified in Article 11 of Law No. 6698, you may submit your requests by filling out the “Data Subject Application Form” available on our website. In accordance with Law No. 6698, you can exercise your rights regarding your personal data by submitting a written application containing your request and documents verifying your identity, in person or via notary public, to the address stated above; or via secure electronic signature, mobile signature or using the email address previously notified to our Company and registered in our system, to our KEP address.
*Personal data relating to the race, ethnic origin, political opinion, philosophical belief, religion, religious sect or other belief, appearance, membership to associations, foundations or trade-unions, data concerning health, sexual life, criminal convictions and security measures, and the biometric and genetic data are deemed to be sensitive personal data.