Personal Data Protection Notice

Data Controller and Personal Data Processed

Under Turkish Personal Data Protection Law No. 6698 (“KVKK”), your personal data is processed by Pusula Group Insurance and Reinsurance Brokerage Inc. (“Proxima Brokers” or the “Company”) as data controller, within the scope described below.

Address: Dumlupınar Mahallesi, Yenitepe Kadıköy Nuhoğlu Plaza 1. Etap B Blok No:19 Kadıköy/İSTANBUL. E-mail: info@pusulabrokerlik.com. Telephone: +90 (216) 606 59 19.

Depending on the nature of your relationship with the Company, the following categories of personal data may be processed:

Identity data: name, surname, Turkish ID number, date of birth
Contact data: telephone number, e-mail address, postal address
Request and complaint data: the content of requests, questions and complaints you send us
Transaction security data: records relating to e-mail correspondence and system access
For our clients, data relating to insurance transactions: insured risk, policy, premium, cover and claims information, and financial information
Special categories of personal data: health data where required for health and life insurance products, processed only on the basis of your explicit consent

Purposes of Processing

Your personal data is processed for the following purposes:

Assessing and responding to your requests, questions and applications
Analysing insurance needs, assessing risks and obtaining quotations from insurers
Placing insurance and reinsurance, and managing the issuance and renewal of policies
Following up claims and supporting our clients throughout the claims process
Entering into and performing contracts, and carrying out finance and accounting operations
Complying with obligations under applicable legislation, in particular insurance legislation, and providing information to competent authorities
Managing information security and protecting legal rights in disputes

Legal Grounds and Method of Collection

Your personal data is processed on the legal grounds set out in Article 5(2) of the KVKK: where it is expressly provided for by law, where it is directly related to the conclusion or performance of a contract, where it is necessary for the data controller to comply with a legal obligation, where it is necessary for the establishment, exercise or protection of a right, and where it is necessary for the legitimate interests of the data controller, provided that your fundamental rights and freedoms are not harmed.

Special categories of personal data, such as health data, are processed in accordance with Article 6 of the KVKK and, where required, on the basis of your explicit consent.

Your personal data is collected by partly automated and non-automated means through e-mail, telephone, e-mails generated via the contact form on our website, face-to-face meetings, documents you provide to us, and information obtained from business partners such as insurers in the course of insurance processes.

Transfer of Personal Data

Your personal data may be transferred, for the purposes stated above and in accordance with Articles 8 and 9 of the KVKK, to the following categories of recipients:

Insurance and reinsurance companies
Experts and loss adjusters
Public authorities legally authorised to request information, in particular the Insurance and Private Pension Regulation and Supervision Agency (SEDDK), and judicial authorities
Advisers and service providers from whom we obtain legal, financial and technical services

Cross-Border Transfers and Retention

Owing to the nature of transactions such as reinsurance placement, certain risks may need to be presented to reinsurers or intermediaries established outside Türkiye. In such cases, your personal data may be transferred abroad in compliance with the conditions and safeguards set out in Article 9 of the KVKK. Where possible, such transfers are made without personal data or with data kept to a minimum.

Your personal data is retained for as long as required by the purpose of processing and for the periods prescribed by applicable legislation; after these periods expire, it is erased, destroyed or anonymised.

Your Rights

Under Article 11 of the KVKK, you may apply to the Company to exercise the following rights:

To learn whether your personal data is processed and, if so, to request information about it
To learn the purpose of processing and whether the data is used in line with that purpose
To know the third parties, in Türkiye or abroad, to whom your personal data is transferred
To request rectification of incomplete or inaccurate data, or erasure or destruction under the conditions of Article 7 of the KVKK, and to request that third parties to whom the data was transferred be notified of these actions
To object to an outcome against you arising from analysis exclusively by automated systems
To claim compensation for damage suffered as a result of unlawful processing

How to Apply

You may submit requests regarding your rights in writing, including information that identifies you, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, to Dumlupınar Mahallesi, Yenitepe Kadıköy Nuhoğlu Plaza 1. Etap B Blok No:19 Kadıköy/İSTANBUL, or by e-mail to info@pusulabrokerlik.com from an e-mail address registered with the Company.

Applications are concluded as soon as possible depending on the nature of the request, and within thirty days at the latest.