Altinordu Football Investments Inc. (Altinordu) takes great care and approaches the privacy and security of your personal data with utmost importance. In this regard, it is our priority to process and store all kinds of personal data belonging to individuals associated with Altinordu, including our members, customers benefiting from our products and services, and our business connections, in compliance with the Law on Protection of Personal Data No. 6698 ("KVKK"). As Altinordu, acting as the "Data Controller" in accordance with KVKK, we would like to inform you about the purposes of processing your personal data, the methods and reasons for collecting your data, personal data processing activities, your rights regarding the processing of your personal data, and the procedures and principles for exercising these rights, as outlined below.

1. Identity and Contact Information of the Data Controller
This information notice has been prepared by Altinordu Football Investments Inc., which is established in Turkey, as the "Data Controller" addressing the data subjects with the status of Data Controller as described below.

Name: Altinordu Football Investments Inc.
Address: 9163/1 Sok. No:9 Pazaryerialtı Yeşilyurt Konak/IZMIR
MERSIS No: 0064020207800011
Tel: 0232 425 1923
Fax: 0232 483 01 60
Email address:

This information notice covers the personal data processing activities related to Altinordu and its affiliated companies/organizations, including Altinordu and its associated companies/organizations* operating under the umbrella of Altinordu and Altinordu Football Investments Inc.

2. What Personal Data Do We Collect?

As Altinordu, we collect personal data of individuals, including but not limited to our employees, partners, athletes, visitors (real persons who visit/visited our internet sites, mobile sites, social media accounts including our affiliated companies/organizations operating under the company umbrella in electronic media or physical locations/facilities), customers benefiting from our products and services, business partners, business connections (such as suppliers, subcontractors, contractors, authorized persons, and employees of institutions with whom we have any kind of business relationship), and other third parties, in compliance with the KVKK when necessary.
We may collect the following personal data and any information and documents containing such data related to the data subjects, to be processed in compliance with KVKK, as required by Altinordu:

- Identity data: Data relating to the individual's identity, such as name, surname, national identification number, passport number, nationality, and date of birth
- Contact data: Data that enables communication with the individual, such as telephone number, address, and email address
- Financial data: Data that can be collected according to the legal relationship established with the relevant person, such as payment information, bank account information, and credit card information
- Visual-Audio data: Personal data such as photographs and voice recordings
- Employee Data: Employment-related data that can be collected from individuals associated with our organization
- Professional Experience Data: Data related to the professional information of individuals
- Physical Space Security Data: Personal data such as security and camera recordings taken during entry to and stay within physical spaces
- Special Categories of Personal Data: Data related to disability status, appearance and clothing, membership in associations, foundations or unions, health, criminal convictions and security measures, biometric and genetic data
- Risk Management Information: Data that can be processed for the management of commercial, technical, and administrative risks
- Transaction Security Information: Data related to transaction security, such as IP address, password, and password transactions
- Legal Transaction Information: Personal data and customer transaction data processed in files, lawsuits, and correspondences with judicial authorities, data collected through marketing activities, cookies, and other automated means

3. How Do We Collect/Process Your Personal Data and What Are the Legal Grounds?

We collect your personal data through various methods, whether provided by you or obtained through other means, and process them based on one or more of the following legal grounds:

- Information, documents, correspondence, and forms including special categories of personal data, such as application forms and registration forms, submitted to us by you.
- Our websites and mobile sites, as well as our social media accounts operated on various social media platforms, belonging to our company and companies/organizations operating under our company umbrella.
- Communication channels such as email, telephone, short messages (SMS) or multimedia messages (MMS), printed and electronic forms, used within the scope of sales, marketing, and public relations activities.
- Communication channels such as email, telephone, short messages (SMS) or multimedia messages (MMS), printed and electronic forms, used within the scope of communication and support activities.
- Records obtained through the call center services of our company and companies/organizations operating under our company umbrella.
- Closed-circuit security cameras located in our facilities.
- Communication channels including printed and electronic forms, and other communication methods, including electronic and printed forms, used during sports and social events/activities organized by Altinordu, as well as during sports activities in which you participate.
- Contracts we sign with companies/organizations/third parties, commercial offers, printed and electronic forms, documents, correspondence, and applications submitted to us within the scope of our business activities.
- Business cards and other documents provided to us during job interviews and events.
- Third parties such as Altinordu's affiliated companies/organizations*, business connections, or companies from which we receive services/products.

We collect your personal data through verbal, written, or electronic means, either entirely or partially automated or as part of any non-automated data recording system. We process your personal data collected through the above-mentioned methods based on one or more of the following legal grounds:

- Having your explicit consent,
- The necessity of processing under the laws and regulations in force in the Republic of Turkey,
- The necessity of protecting your or someone else's life or bodily integrity when it is impossible to obtain your consent due to actual impossibility,
- The necessity for the performance of the contract concluded with you or your company,
- The necessity of processing your personal data for the fulfillment of our legal obligations,
- The personal data being made public by you,
- The necessity for the exercise or protection of our legal or contractual rights as a company,
- The necessity of processing your personal data for our legitimate interests, provided that it does not harm your fundamental rights and freedoms.

We keep all your personal data processed by us, in compliance with the mandatory periods stipulated by the Personal Data Protection Law (KVKK) and other relevant legislation, and taking all necessary administrative and technical measures to ensure their security, as long as the legitimate purposes mentioned above still exist.

4. For What Purposes Do We Process Your Personal Data?

We process your collected personal data for the following purposes, depending on their nature:

(1) Planning and execution of our company activities in accordance with the purposes defined in our articles of association and in compliance with the relevant legislation;
(2) Necessary planning, organization, work, and announcements regarding the activities and events carried out by our company;
(3) Planning, evaluation, and work by our business units to provide you with the products and services offered by Altınordu or its affiliated companies/organizations;
(4) Carrying out commercial activities conducted by Altınordu's related companies/organizations and conducting related business processes;
(5) Carrying out advertising and marketing activities for the products and services offered, informing about promotions, campaigns, offers, bulletins, sponsorships, events, and similar matters, conducting corporate communication activities;
(6) Conducting Marketing and Customer Relationship Management activities;
(7) Organizing corporate communication activities, campaigns, and invitations, providing information about them, conducting market research studies;
(8) Improving the digital platforms we offer to our customers and providing them with efficient and personalized experiences, extracting statistics such as the number, type, frequency of visits, behaviors, geographical locations of users, and similar information, providing personalized content, campaigns, and advertisements based on the interests and needs of platform users, using cookies for this purpose;
(9) Tracking, evaluating, managing requests, suggestions, and complaints from relevant individuals, managing individual satisfaction, and implementing planning, statistics, and satisfaction evaluation studies in this regard;
(10) Making domestic and international travel, transportation, visa, and accommodation arrangements for sports activities/events;
(11) Managing relationships with business connections, suppliers, subcontractors, and similar companies and conducting business and commercial relationships;
(12) Ensuring the legal and commercial security of individuals in business relationships with Altınordu and its affiliated companies/organizations (such as planning administrative operations related to the services provided by our company, evaluating business partner/customer/supplier (authorized or employees) processes, legal compliance process, etc.);
(13) Planning and execution of occupational health and safety processes;
(14) Ensuring the legal, technical, and commercial occupational safety of individuals in our facilities and building security;
(15) Using legal rights, using information about transaction history as evidence in case of disputes after the termination of legal relationships;
(16) Determining and implementing commercial, legal, and business strategies;
(17) Execution of financial affairs policies; e-invoice management;
(18) Planning, auditing, and implementation of information security processes, management of information technology infrastructure;
(19) Conducting planning, reporting, statistical studies, and similar examinations within the scope of Altınordu and its affiliated companies/organizations' activities; or
(20) Compliance with relevant domestic legislation, provision of information requested by public institutions and organizations, fulfillment of reporting obligations.

5. Do we transfer your Personal Data to third parties or abroad?

We transfer your collected personal data to Altınordu's affiliated companies/organizations*, including future companies/organizations to be established under the Altınordu umbrella, in compliance with the provisions of the Law on the Protection of Personal Data (KVKK) and for the purposes stated above.

In addition, we may transfer your personal data to business partners, business connections, suppliers, sponsors, consultancy firms providing support in legal, tax, etc. areas, storage, archiving, payment systems, information technology support providers that we receive support from domestically or abroad (such as servers, hosting, software, cloud computing, etc.), banks and financial institutions, shareholders, legally authorized public institutions, and private individuals, authorized institutions/organizations and their affiliated business partners domestically or abroad for football match events, in compliance with the provisions of the KVKK.

*Altınordu and its affiliated companies/organizations are listed below.
- Altınordu Ticari Ürünler Pazarlama Tic. ve San. AŞ
- Kuşadası Efes Spor Tesisleri Tur.Sey.Tic.Ltd.Şti.
- Altınordu Spor Kulübü Derneği
- Gümüşordu Spor Kulübü Derneği
- Sponsors and football schools listed on the website ""
We commit to keeping your personal data securely and not processing it unlawfully.
6. Personal Data Subject's Rights under the KVKK and Application Procedure and Principles
i. Your Rights Regarding Your Personal Data

We would like to inform you that you have the following rights regarding your data processed within Altınordu:

(1) Learn whether your personal data is being processed,
(2) Obtain information if your personal data is being processed,
(3) Learn the purpose of processing your personal data and whether your personal data is used in line with its purpose,
(4) Learn the third parties, if any, to whom your data is transferred domestically or abroad, and which data is transferred,
(5) Request the correction of your personal data if it is incomplete or inaccurate,
(6) Request that the correction, deletion, or destruction of your personal data be notified to the third parties to whom your personal data has been transferred,
(7) Request the deletion or destruction of your processed personal data if the reasons requiring the processing of your personal data cease to exist, or if your personal data becomes outdated,
(8) Object to the occurrence of a result against you due to the analysis of your personal data solely through automated systems,
(9) If you incur any damages due to the unlawful processing of your personal data, you have the right to demand compensation for your damages.

ii. Application

You can submit your requests regarding the above-mentioned rights to our company in writing by filling out the application form provided below or through your registered email address, secure electronic signature, mobile signature, or the email address previously notified and registered in our system. Altınordu will respond to your requests free of charge within the shortest time and at the latest within thirty days, depending on the nature of the request. In order to determine whether the application belongs to you and to protect your rights, we may request additional verification (sending a message to your registered phone, phone call, etc.) depending on the nature of your request. If there is a cost associated with fulfilling your requests, we may only ask you to pay the fees set forth by the Personal Data Protection Board.
We may accept or reject the requests addressed to Altınordu and communicate this response to the requester in writing or electronically, along with an explanation of the grounds for rejection. If the request is accepted, Altınordu is obliged to fulfill the request immediately.

iii. Complaint
If your requests addressed to Altınordu are rejected, if you are not satisfied with the response provided by Altınordu, or if no response is given, you can file a complaint with the Personal Data Protection Board within 30 days from the date of receiving the response, or within 30 days after the end of the 30-day period if no response is received.