Privacy Policy & Personal Data Protection
Last updated on 23 Jan 2025
Syria Restart Investment Platform (the “Website”, “we”, “us”, or “our”) is committed to protecting the privacy of users and processing personal data in full compliance with applicable laws and regulations, including but not limited to:
Turkish Personal Data Protection Law No. 6698 (KVKK)
Turkish Capital Markets Law No. 6362
Regulations and guidelines issued by the Capital Markets Board of Türkiye (SPK)
Applicable Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations
By accessing this Website or submitting any form, you expressly consent to the collection, processing, and use of your personal data in accordance with this Privacy Policy.
1. Definitions
For the purposes of this Privacy Policy:
Personal Data means any information relating to an identified or identifiable natural person.
Processing means any operation performed on Personal Data, whether automated or not, including collection, recording, storage, modification, use, disclosure, transfer, or deletion.
Data Subject means the natural person whose Personal Data is processed.
Website refers to the Syria Restart digital investment platform.
2. Personal Data Collected
We may collect Personal Data when you:
Complete contact forms or Expression of Interest / Inquiry forms
Communicate with us through the Website or provided contact channels
Submit information for regulatory qualification or verification purposes
The collected data may include, without limitation:
Full name
Email address
Phone number
Country and location
Professional and investment profile
Investment interests and experience
Any other information voluntarily provided
3. Purposes of Processing
Personal Data is processed solely for the following purposes:
Investor Communication and Engagement
Responding to inquiries
Evaluating expressions of interest
Providing preliminary investment information
Regulatory and Legal Compliance
Investor qualification and verification (KYC)
Anti-Money Laundering compliance (AML)
Compliance with SPK regulations and applicable laws
Responding to regulatory or legal requests
Operational and Technical Improvement
Website functionality and performance optimization
Analytics and service quality improvement
Cybersecurity and system integrity
Personal Data shall not be used for unauthorized marketing activities without explicit consent.
4. Legal Basis for Processing
Personal Data is processed based on one or more of the following legal grounds:
Explicit consent of the Data Subject
Compliance with legal and regulatory obligations
Necessity for the establishment or performance of a contractual or pre-contractual relationship
Legitimate interests of the Website, provided that such interests do not override fundamental rights and freedoms
5. Data Security
We implement appropriate technical and organizational measures to safeguard Personal Data against unauthorized access, loss, misuse, alteration, or disclosure, including access controls, encryption, monitoring, and secure infrastructure practices.
6. Data Sharing and Disclosure
Personal Data is not sold, rented, or commercially disclosed to third parties, except in the following cases:
Where required by applicable law or regulatory authority
With trusted service providers (hosting, form management, analytics, IT services) under strict data protection and confidentiality obligations
With regulatory or supervisory authorities upon lawful request
With explicit consent of the Data Subject
7. Cross-Border Data Transfers
Personal Data may be transferred or stored outside Türkiye where technically necessary, subject to adequate data protection safeguards in accordance with KVKK requirements.
8. Data Retention
Personal Data is retained only for the period necessary to fulfill the purposes for which it was collected or as required by applicable laws and regulatory obligations. Upon expiration of such period, data shall be securely deleted or anonymized.
9. Data Subject Rights
In accordance with KVKK, Data Subjects have the right to:
Learn whether Personal Data is processed
Request access to Personal Data
Request correction or update of inaccurate or incomplete data
Request deletion or destruction where lawful grounds cease to exist
Object to unlawful processing
Withdraw consent at any time, without affecting the lawfulness of prior processing
Requests may be submitted through the Website contact channels.
10. Cookies and Tracking Technologies
The Website may use cookies and similar technologies to enhance user experience, analyze traffic, and improve performance. Users may control cookie preferences through their browser settings.
11. Investment Disclaimer
All content on this Website is provided for informational purposes only and does not constitute an offer, solicitation, or recommendation to invest in any financial instrument. Participation in any investment opportunity is restricted to qualified investors and subject exclusively to official documentation approved by relevant regulatory authorities.
12. Amendments
We reserve the right to amend this Privacy Policy at any time in order to remain compliant with applicable laws and regulatory requirements. Updated versions shall be published on the Website.
13. Contact
For any questions regarding this Privacy Policy or Personal Data processing, please contact us through the official contact page of the Website.