1. Who We Are

Akyol Fintech L.L.C-FZ ("Akyol Fintech", "Akyol", "we", "us" or "our") is a limited liability company registered in Dubai, United Arab Emirates.

Company information:

• Legal name: Akyol Fintech L.L.C-FZ
• Formation number: 2653760
• Registered address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates.
• Privacy contact: compliance@akyolfintech.com
• Website: akyolfintech.com

For the purposes of applicable data protection laws, Akyol Fintech may act as a data controller when it determines why and how personal information is processed. In other situations, such as where we process information on behalf of a client under written instructions, our role may be that of a data processor or service provider.

2. Scope of This Policy

This policy applies to personal information collected through our website, contact channels, business communications, enquiries, events and other interactions to which this policy is linked.

It may apply to individuals who visit our website, contact us about our business or services, represent a client or supplier, apply for a business relationship, or otherwise communicate with us.

If a specific product or service has a separate privacy notice, customer agreement or data processing agreement, that document may provide additional information or govern particular processing activities. This policy does not replace those documents.

3. Information We Collect

The categories of information we collect depend on your interaction with us. We seek to collect information that is relevant to the purpose for which it is needed.

We may receive information directly from you, from your organisation or authorised representatives, from service providers supporting our operations, or from other sources where permitted by law and relevant to the purpose for which the information is used.

Please do not send us sensitive personal information or identity documents through ordinary website forms or email unless we have specifically requested them through an appropriate and secure process.

4. How We Use Personal Information

Depending on the context, we may use personal information to:

• Respond to enquiries, requests and messages.
• Provide information about our company, capabilities and services.
• Assess and manage potential or existing business relationships.
• Prepare proposals, communicate with clients and suppliers, and administer agreements.
• Operate, maintain and improve our website and digital services.
• Understand website performance and usage where appropriate analytics are in place.
• Protect our systems, website, personnel and business against fraud, abuse, unauthorised access and other security risks.
• Meet applicable legal obligations and respond to valid legal requests.
• Establish, exercise or defend legal claims.
• Send business updates or marketing communications where permitted and, where required, with your consent.

We do not intend to collect more personal information than is reasonably necessary for the relevant purpose. If we need to use information for a materially different purpose, we will take the steps required by applicable law.

5. Legal Grounds for Processing

Where applicable data protection law requires a legal basis for processing, we rely on an appropriate basis for the relevant activity. Depending on the circumstances, this may include:

• Consent: where you have agreed to a particular use, such as certain non-essential cookies or marketing communications.
• Contractual necessity: where processing is necessary to take steps at your request before entering into a contract or to perform a contract with you.
• Legal obligation: where processing is required to comply with applicable law.
• Legitimate interests: where permitted by law, for purposes such as maintaining business communications, securing our systems, managing our operations or protecting legal rights, provided relevant rights and interests are considered.
• Other permitted grounds: where another lawful basis applies under the legislation governing the particular activity.

The available legal grounds and the rights attached to them vary according to the law that applies. Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect processing that took place lawfully before it was withdrawn.

6. Cookies and Website Analytics

Our website may use cookies and similar technologies. These technologies can help websites operate, remember preferences, understand performance and support security.

Types of cookies and technologies

• Essential technologies: those needed for core website functionality, security or the delivery of a service you request.
• Preference technologies: those used to remember choices, where implemented.
• Analytics technologies: those used to understand website traffic and performance, if analytics tools are enabled.
• Marketing technologies: those used to measure or personalise advertising, if such tools are used.

The actual cookies and technologies in use depend on the website configuration and the third-party tools enabled at the time of your visit. Where consent is required for non-essential cookies or similar technologies, we will seek it through an appropriate mechanism before using them.

You may be able to manage cookies through your browser settings and, where available, through the website's cookie preference controls. Blocking some cookies may affect website functionality. Browser settings alone may not control every type of tracking technology.

If analytics or advertising tools are enabled, their providers may process technical or usage information under their own terms and privacy notices, subject to the arrangements and controls applicable to our website.

7. How We Share Personal Information

We do not sell personal information as a business practice. We may share it where necessary and lawful with the following categories of recipients:

• Service providers: providers supporting website hosting, email, IT, cybersecurity, communications, analytics, document management or other business operations.
• Professional advisers: lawyers, auditors, accountants, consultants and insurers where appropriate.
• Business counterparties: clients, suppliers, implementation partners or other parties where sharing is necessary for a requested service or business relationship.
• Financial or compliance partners: relevant providers where a particular service or transaction requires their involvement and sharing is lawful.
• Public authorities and legal recipients: regulators, courts, law enforcement agencies or other authorities when required or permitted by applicable law.
• Corporate transaction parties: potential or actual buyers, investors or advisers in connection with a merger, restructuring, financing, sale of assets or similar transaction, subject to appropriate safeguards.

Where appropriate, we use contractual terms, confidentiality commitments and other safeguards to require recipients to protect personal information and use it only for authorised purposes.

If we provide services jointly with, or through, a third-party provider, that provider may have its own privacy responsibilities and terms. We encourage you to review the relevant documentation before submitting information to that provider.

8. International Data Transfers

Akyol Fintech operates from the United Arab Emirates and has international business connections, including in Türkiye and Ireland. Depending on our service providers, systems and business relationships, personal information may be accessed or processed in countries other than the country in which it was collected.

Where personal information is transferred across borders, we will take the steps required by the data protection laws applicable to that transfer. These steps may include assessing the destination's legal framework, relying on a permitted transfer mechanism, implementing contractual protections or obtaining consent where legally required.

International transfers will be subject to applicable restrictions and safeguards. The protections available to you may differ depending on the countries involved and the law governing the processing.

9. How Long We Retain Information

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, including to respond to enquiries, manage business relationships, maintain appropriate records, comply with legal obligations and establish, exercise or defend legal claims.

Retention periods vary according to the type of information, the purpose for which it was collected, the nature of the relationship, security considerations and any applicable legal or contractual requirements.

When information is no longer required, we will take reasonable steps to delete it, securely dispose of it or anonymise it, subject to lawful retention requirements and the technical limits of routine backup and archival systems.

10. How We Protect Personal Information

We take reasonable technical and organisational measures designed to protect personal information against unauthorised access, alteration, disclosure, loss or destruction.

Depending on the systems and activities involved, safeguards may include access restrictions, account controls, secure communications, system monitoring, backup procedures, staff guidance and supplier assessments.

No website, electronic transmission or storage system can be guaranteed to be completely secure. You should use appropriate precautions when sending information online and contact us promptly if you believe that information submitted to us has been compromised.

11. Your Privacy Rights

Depending on the data protection law applicable to your information, you may have rights that include:

• Access: request confirmation of whether we process your personal information and, where applicable, obtain a copy.
• Correction: ask us to correct inaccurate or incomplete information.
• Deletion: request deletion where the relevant legal conditions are met.
• Restriction or objection: request that we restrict or stop certain processing where the law provides that right.
• Consent withdrawal: withdraw consent where processing is based on consent.
• Data portability: request a portable copy of certain information where this right applies.
• Complaint: raise a concern with a competent data protection authority where available under applicable law.

These rights are not absolute and may be subject to legal exceptions, identity verification, the rights of other individuals, confidentiality obligations and record-retention requirements. The rights available to you depend on the applicable legal regime.

How to submit a request

Email compliance@akyolfintech.com with the subject line "Privacy Request". Please describe the request and the context in which you interacted with us. We may request reasonable information to verify your identity before acting on the request.

We will review and respond to requests within the period required by applicable law. If we cannot fulfil a request in full, we will explain the position where legally required.

12. Third-Party Websites and Services

Our website may contain links to external websites, platforms or services. These third parties operate independently and may have their own privacy notices, cookies and data practices.

This policy does not govern third-party websites or services that we do not control. We encourage you to read their privacy documentation before providing personal information or using their services.

13. Children's Privacy

Our website and business communications are intended for business and general professional audiences, not specifically for children. We do not knowingly seek to collect personal information from children in circumstances where doing so would be unlawful.

If you believe a child has provided personal information to us inappropriately, please contact compliance@akyolfintech.com so that we can review the circumstances and take appropriate action.

14. Automated Processing and Artificial Intelligence

We may use digital tools, software and automation to support website operations, communications, analysis and business administration. The extent of such use depends on the systems enabled and the services being provided.

This policy does not mean that Akyol Fintech makes decisions about individuals using automated systems. If a particular service involves profiling or automated decision-making that is subject to additional notice or rights under applicable law, further information will be provided in the relevant service documentation or notice.

15. Changes to This Privacy Policy

We may update this policy from time to time to reflect changes in our business, website, systems, service providers or legal requirements.

The revised version will be published on this page with an updated effective date. Where applicable law requires additional notice or consent for a material change, we will take the required steps.

16. Applicable Law and Regulatory Context

Our handling of personal information is subject to the data protection laws and other legal requirements that apply to the relevant processing activity. These may include applicable UAE data protection requirements and, where their territorial and material scope is met, the data protection laws of other jurisdictions.

The precise legal framework may depend on the nature of the information, the service, the location of the relevant parties and the rules applicable to the company's registration and activities. Nothing in this policy excludes or limits a right that cannot lawfully be excluded or limited.