How do we use the personal information?
We may use personal information for the following purposes:
To verify your identity and establish and manage your account
As part of providing services, or information about our services, to you, we will need to verify your identify to set you up as a customer and we will need to use those details in order to effectively manage your account with us to ensure that you are getting the best possible service from us. This may include third parties carrying out credit or identity checks on our behalf. It is not only in our legitimate interest to do so but the use of your personal information in this way is necessary for us to know who you are as we have a legal obligation to comply with certain Know Your Customer regulatory obligations.
To provide you with products and services, or information about our products and services, and to review your ongoing needs
Once you open an account with us, or subscribe to an update, we will need to use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to ensure that we are providing the best products and services so we may periodically review your needs to ensure that you are getting the benefit of the best possible products and services from us.
To help us improve our products and services, including customer services, and develop and market new products and services
We may from time to time use personal information provided by you through your use of the services and/or through customer surveys to help us improve our products and services. It is in our legitimate interests for us to use your personal information in this way to ensure that we provide you with the best products and services we can and to continue to be a market leader in our industry.
To form a profile about you
We may from time to time use personal information about you to form profiles about you so that we can understand you and provide the very best products and services we can. We may also make decisions about you through automated profiling or automated credit checks which may affect your ability to use our services. We may need to do this either to perform our legal obligations or because it is in our legitimate interest to use your personal information in such a way.
To investigate or settle enquiries or disputes
We may need to use personal information collected from you to investigate issues and/or settle disputes with you as it is in our legitimate interests to ensure that issues and/or disputes get investigated and resolved as quickly and efficiently as possible.
To comply with applicable law, court order, other judicial process, or the requirements of any applicable regulatory authorities
We may need to use your personal information to comply with applicable law, court order or other judicial process, or the requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.
To provide references about you
From time to time, third parties, such as credit agencies may approach us to provide a credit reference about you for credit and identity checks. It may be in our legitimate interest to comply with our legal obligations or we may be obliged to provide such a reference in order to comply with a legal obligation. However if we are unsure we will speak to you first before providing any reference.
To send you surveys
From time to time, we may send you surveys as part of our customer feedback process and it is in our legitimate interest to ask for feedback to ensure that we provide the best service to you. However, we may from time to time also ask you to participate in other surveys and if you agree to participate in such surveys we rely on your consent to use the personal information we collect as part of such survey. All responses to any survey we send out whether for customer feedback or otherwise will be aggregated and depersonalised before survey results are shared with any third parties.
Our web pages and e-mails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
Marketing by us
We may use your personal information to send you marketing communications by email or phone or other agreed forms (including social media campaigns) to ensure that you are always kept up to date with our latest products and services. Where we send you marketing communications we will either do so as it is in our legitimate interest or with your consent.
Internal business purposes and record keeping
We may need to process your personal information for internal business and research purposes and record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your obligations under any contract you have entered into with us.
If we undergo a corporate restructure or part or all of our business is acquired by a third party, we may need to use your personal information in association with that restructure or acquisition. Such use may involve disclosing your details as part of a due diligence exercise. It is our legitimate interest to use your information in this way provided we comply with any legal obligation we have to you.
If you enter any of our premises we may record your image on our CCTV for security reasons. We may also take your details to keep a record of who has entered our premises on any given day. It is in our legitimate interest to do this to maintain a safe and secure working environment.
The personal information we hold about you
The information about any rights that might be available to you in relation to the personal information we hold about you is set out below.
If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable administration fee.
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it or you withdraw your consent (where applicable) provided that we have no legal obligation to retain that data. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations and subject to section 'How do we store personal information and for how long'. If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Under the General Data Protection Regulation (679/2016), you have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
You can ask us to stop processing your personal information, and we will do so, if we are:
1- relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
2- processing your personal information for direct marketing; or
3- processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.
Automated decision-making and profiling
If we have made a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to use the services or has another significant effect on you, you can ask to not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us. Even where a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention.
Our Investment products and services are not suitable for everyone. It is possible to lose all or part of your investment. Trading on margin carries a higher level of risk and it is possible to be required to deposit additional funds. You should not invest money that you cannot afford to lose. Please click here for our detailed risk warning.
Order Execution Disclosure
The purpose of this disclosure is to provide clients of the Firm with information about the Firm’s order execution policy and to seek their consent to that policy.
The Firm is required to take all reasonable steps to obtain the best possible results (“Best Execution”) on a consistent basis on behalf of its clients when executing their orders or placing orders with (or transmitting orders to) other entities for execution, in each case when such orders relate to securities which are “financial instruments”.
The Firm’s order execution policy is designed to obtain the best possible results for the Firm’s clients’ orders subject to and taking into account, any specific instructions from the client, the nature of such orders, the priorities its clients’ place upon it in filling those orders and the nature of the markets and products in question. In order to deliver Best Execution, the Firm uses its knowledge, experience and judgement to execute trades on behalf of its clients taking into consideration a number of execution factors including:
- The price that the order can be executed at;
- The costs of execution of the transaction to the client;
- The speed of execution of the transaction;
- The likelihood of achieving execution and settlement;
- The size of the order; and
- Any other relevant factors specific to the execution of the specific order (the “Execution Factors”).
The Firm is required to determine the relative importance of the Execution Factors for its clients by taking into account the following criteria:
- The characteristics of the client, including the categorisation of the client;
- The characteristics and nature of the client order;
- The characteristics of the financial instruments that are the subject of that order;
- The characteristics of the execution venues/brokers to which that order can be directed; and, where relevant (the "Execution Criteria").
In considering the Execution Criteria and the importance of the Execution Factors, the Firm also takes into account the client’s understanding and experience of the market in question, the client’s dealing profile, the nature of the dealing service the client requires and the specific and general instructions given to the Firm by the client which may prioritise how the Firm fills client orders.
EXECUTION VENUES AND BROKERS
The Firm will primarily select the execution venue or broker that in the Firm’s judgment is the most appropriate, taking into account the Execution Factors and Execution Criteria. The Firm will also consider the market coverage and market intelligence that the execution venue or broker can provide. The execution venues that the Firm may use are:
- Regulated markets
- Multilateral Trading Facility (“MTF”)
- Direct Market Access (“DMA”) – DMA refers to electronic facilities that allow the Firm to benefit generally from a better cost for financial securities the Firm may wish to buy or sell
- Systematic internalisers
- Market makers
- Unregulated markets
- Dark pools
The Firm has identified above those venues on which it most regularly seeks to execute or direct orders and which the Firm believes offer the best prospects for affording its clients Best Execution.
In selecting the most appropriate venues for the purpose of executing client orders, the Firm will take into full account the Execution Factors and Execution Criteria relevant to the order, and the following:
- (a) what the Firm reasonably assesses to be its clients’ best interests in terms of executing the orders; and
- (b) such other factors as may be appropriate, including the ability of the venue to manage complex orders, the speed of execution, the creditworthiness of the venue and the quality of any related clearing and settlement facilities.
The diversity in the markets and instruments in which the Firm trades mean that different factors will have to be taken into account when the Firm assesses the nature of its Policy in the context of different instruments and different markets. In some markets, price volatility may mean that the timeliness of execution is a priority, whereas, in other markets that have low liquidity, the fact of execution may itself constitute Best Execution. In other cases, the Firm’s choice of venue may be limited (even to the fact that there may only be one platform/market upon which the Firm can execute client orders) because of the nature of the client order or of specific client requirements.
Selection of Brokers
The Firm has a thorough selection process with respect to the brokers that it transacts with, which is designed to identify those brokers which consistently provide a high quality execution service, taking account of the relevant Execution Factors and Execution Criteria. Orders may only be placed with brokers who have been approved by the Firm following its selection process.
Internal cross trades may allow for cost reduction to the benefit of clients. Therefore, unless prohibited by law or by a client, internal cross trades are allowed if the following conditions are satisfied:
- The internal cross is opportune for both portfolios concerned;
- The reasons for the internal cross and why it is opportune for both portfolios are documented;
- The execution benchmark (if relevant) is unbiased between buying and selling party;
- The internal cross is in line with the Best Execution procedures described in this Policy.
Any internal cross trade that does not satisfy these conditions is not permitted unless expressly authorised by the Compliance Department.
DETAILED REQUIREMENTS FOR EACH FINANCIAL INSTRUMENT CLASS TRADED
For each class of financial instruments that the Firm trades, the Firm has defined the key Execution Factors that will be taken into account when placing orders for execution, in order to choose the counterparty that best suits its requirements.
In case of extreme circumstances, such as disruption of the execution system, the Firm may not be able to execute an order in accordance with this Policy. In such exceptional circumstances the Firm will endeavour to execute client orders in the most advantageous way for its clients under the prevailing circumstances.
If only one place of execution exists, Best Execution is realised when executing the order in that execution venue. The Firm will be able to demonstrate that only one place of execution exists.
Financial Instruments Traded
|Instruments||Brokers/ Execution venues||Relevant Execution Factors and Execution Criteria (rate order of importance: 1=most important to 5=least important)|
|Turkish Equities||Gedik Yatirim/ Borsa Istanbul||1- Price 2- Likelihood of Execution 3- Cost 4- Speed 5- Size|
|Turkish Eurobonds||Gedik Yatirim/ Borsa Istanbul||1- Price 2- Likelihood of Execution 3- Cost 4- Speed 5- Size|
|Turkish Futures||Gedik Yatirim/ Borsa Istanbul||1- Price 2- Likelihood of Execution 3- Cost 4- Speed 5- Size|
To the extent that the Firm follows specific instructions from a client when placing an order with, or transmitting an order to, another entity for execution, such instructions supersede this Policy and the Firm will be deemed to have complied with its Best Execution obligations by following the clients’ specific instructions. It is likely to be only in rare circumstances that the Firm would receive such specific instructions.
MONITORING AND REVIEW
The Firm actively monitors the effectiveness of its order execution arrangements and policy. The Firm’s processes are designed to ensure that monitoring assists the Firm in delivering Best Execution for its clients on a consistent basis.
The Firm’s senior management is responsible for ensuring that robust business practices are operating in all its trading activities to deliver Best Execution on a consistent basis and for promoting a culture that proactively identifies and manages conflicts of interest. The Firm will regularly, and at a minimum annually, review its order execution policy and execution procedures and will notify its clients of any material changes to them.