Turkish Citizenship by Investment Funds

Privacy Policy & Personal Data Protection

Last updated on 04 April 2026

İsra Gayrimenkul Yatırım İnşaat Pazarlama Anonim Şirketi (the "Company," "we," "us," or "our") is committed to protecting the privacy of users and processing personal data in compliance with applicable laws and regulations, including:

• Turkish Personal Data Protection Law (No. 6698) (KVKK)

• Turkish Capital Markets Board of Turkey (SPK) regulations

• Applicable Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations

• EU General Data Protection Regulation (GDPR) where applicable

This Privacy Policy explains how we collect, use, store, process, and protect your personal data when you visit our website at winvestpassport.com (the "Website") and interact with our services. By using the Website, you acknowledge that you have read and understood 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 collecting, recording, storage, adaptation, retrieval, use, disclosure, or deletion.

Data Subject means the natural person whose Personal Data is processed.

Website refers to the site at winvestpassport.com.

2. Personal Data Collected

We may collect Personal Data when you:

• Submit an inquiry through our contact forms

• Communicate with us via email, phone, or WhatsApp

• Subscribe to our newsletter

• Browse the Website

Categories of Personal Data collected:

• Identity data: full name, nationality

• Contact data: email address, phone number, WhatsApp number

• Communication data: message content, inquiries submitted

• Professional and investment profile: area of interest, how you heard about us

• Technical data: IP address, browser type, device type, pages visited, session duration

• Any other information voluntarily provided

3. Purposes of Processing

Personal Data is processed for the following purposes:

• Investor communications and engagement

• Responding to inquiries and requests for information

• Providing general information about Turkish citizenship by investment processes

• Conducting preliminary qualified investor eligibility assessment

• Anti-Money Laundering compliance (AML)

• Know Your Customer verification (KYC)

• Compliance with Capital Markets Board (SPK) regulatory obligations

• Responding to regulatory or legal requests

• Ensuring the technical functionality and security of the Website

• Analytics and service quality improvement

• Sending marketing communications (only with your explicit consent)

Personal Data will not be used for marketing or communications purposes without your 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 apply appropriate technical and organizational measures to safeguard Personal Data against unauthorized access, loss, misuse, alteration, or disclosure, including access controls, encryption, monitoring, and business continuity measures.

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 and stored outside Türkiye where technically necessary, subject to adequate data protection safeguards in accordance with KVKK requirements, including:

• Standard Contractual Clauses approved by the KVKK Board

• Adequate protection assessments for the recipient country

• Explicit consent of the Data Subject where no other legal basis applies

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:

• Contact form submissions: 2 years from last interaction

• Investment inquiry data: 10 years (SPK record-keeping requirements)

• AML/KYC documentation: 10 years from end of business relationship (MASAK, Law No. 5549)

• Marketing consent records: duration of consent + 2 years

• Technical and analytics data: maximum 2 years

• Email and WhatsApp correspondence: 5 years (Turkish Commercial Code)

Upon expiration of such period, data shall be securely deleted or anonymized.

9. Data Subject Rights

Under KVKK Article 11, Data Subjects have the right to:

• Learn whether Personal Data is processed

• Request information about the processing if data has been processed

• Learn the purpose of processing and whether data is used accordingly

• Know the third parties to whom data has been transferred domestically or internationally

• Request correction of incomplete or inaccurate Personal Data

• Request deletion or destruction where lawful grounds exist

• Request notification of corrections or deletions to third parties to whom data was transferred

• Object to any result arising exclusively from automated processing that is to the Data Subject's detriment

• Claim compensation for damages arising from unlawful processing

Requests may be submitted via email to: kvkk@winvest.com.tr

Or by post to: İsra Gayrimenkul Yatırım İnşaat Pazarlama A.Ş., [Registered Address], Istanbul, Turkey

Subject line: "KVKK Data Subject Request"

Requests will be processed free of charge within 30 days.

For Data Subjects located in the European Economic Area (EEA), additional rights under GDPR include the right to data portability, the right to restrict processing, and the right to lodge a complaint with a local supervisory authority.

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.

Cookie types used:

• Strictly Necessary Cookies: essential Website functionality, security, language preferences (no consent required)

• Analytics Cookies: understanding visitor behavior, page views, traffic sources (consent required)

• Marketing Cookies: delivering relevant content and measuring advertising effectiveness (consent required)

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 as defined by the Capital Markets Board of Turkey (SPK). Fund participation shares are available exclusively to qualified investors. Investment funds are capital market instruments whose value may increase or decrease depending on market conditions. Past performance does not guarantee future results. Investors may lose part or all of their invested capital. Before making investment decisions, consulting a professional advisor is recommended.

Winvest is a sales and marketing organization operating under İsra Holding. Winvest does not hold a portfolio management or investment advisory license. Fund management is conducted by the licensed portfolio management company as disclosed in each fund's official documentation.

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 this page with the revised "Last updated" date. Material changes will be communicated through a prominent notice 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 or via:

Email: kvkk@winvest.com.tr

Phone: +90 850 360 47 72