Ensuring the privacy and security of our valued investors is a top priority for Open Prime, a subsidiary of VIZYON MRKT YAZILIM VE BILISIM SANAYI VE TICARET LIMITED SIRKETI. We urge you to carefully review our privacy policy, which outlines the terms and conditions governing the information and services we provide.

Please be aware that we retain the right to modify our privacy policy periodically, necessitating regular checks on this page for any updates. Your personal information is subject to our most recent privacy notice. It is crucial to note that, given the significance of alterations in this document, we may send update notifications to our investors. If you are an employee or third-party service provider within the Open Prime family, your personal data, business policies, and contractual relationships will be handled in accordance with our other existing policies, and we will maintain communication with our company.

In our aforementioned confidentiality agreement, the references “our”, “us”, “we” or “VIZYON MRKT YAZILIM VE BILISIM SANAYI VE TICARET LIMITED SIRKETI”, “Open Prime” refer to each group company within Beybi Giz Plaza A D:55, No 1, Maslak Mahallesi Maslak Meydan Sokak, Istanbul, unless otherwise stated. Similarly, within this privacy policy, the terms "you," "your," "yours," or "yourself" pertain to our prospective investors, unless explicitly stated otherwise. When utilizing any of our communication channels or accessing our website, you affirm that you have read and understood the terms outlined in this notice. Furthermore, you acknowledge being informed about how we handle any personal data you disclose to us prior to becoming an investor.

By accepting this policy, you acknowledge your understanding of the procedures involved in obtaining, storing, processing, sharing, and managing your personal data and rights throughout our business relationship. This acknowledgment extends beyond the termination of the customer relationship, encompassing updates following the creation of your account with Open Prime.

About Us

This privacy policy applies to the data processing activities of data controller entities within the VIZYON MRKT YAZILIM VE BILISIM SANAYI VE TICARET LIMITED SIRKETI group of companies located at: Beybi Giz Plaza A D:55, No 1, Maslak Mahallesi Maslak Meydan Sokak, Istanbul.

Collection and Storage of Personal Information

The personal information requested from our investors and potential investors is as follows:

Types of personal information we collect and store include:

• Name, surname, and contact information

• Email address

Cookies

We use cookies to collect and store information about your use of the Open Prime site. Cookies are small text files stored on your device’s hard drive. When you enter the Open Prime site, these files send back data to our web server.

Cookies enable us to remember your personal settings and preferences to improve your experience. You can find more information in the "Our Cookies Policy" section on the Borsa Prime website.

We also keep records of your business transactions, such as:

• Products you trade with Open Prime

• Historical investment data

• Your preferences for specific products and services

If you are an institutional investor, you must share additional data such as company address, shareholder and director information, and other required details.

We may also collect information via our services, websites, account applications, demo and webinar registrations, cookies, and similar tracking technologies.

We may gather data about you through third-party marketing lists, public sources, social media, brokers and affiliates, financial institutions, or purchased databases.

Note: If you do not provide the necessary information, we may not be able to offer the requested product or service.

We may record communications (including electronic and phone) related to services we provide, and these will remain the property of our company. Calls may be recorded without a tone or warning. Our offices may also use CCTV surveillance.

With Whom Can Your Personal Data Be Shared?

We may share your personal data with:

• Group companies providing financial and other services within Open Prime

• Third-party providers using Open Prime platforms and systems

• Contracted consultants and service providers (IT, compliance, legal, analytics, etc.)

• Brokers and affiliated promotional service providers

• Payment processors and banks

• Auditors, consultants, or legal advisors

• Legal authorities, courts, or regulators

• Any third party where disclosure is required to enforce our terms or protect legal rights

• Any party you authorize

We only disclose the minimum data necessary. Third parties must not use your data for any purposes other than providing the contracted services.

External links: Our platforms may include links to third-party websites. These are not governed by our privacy policy; please consult their own policies for more details.

When and How Do We Get Your Approval?

We may process your personal data under the following legal bases:

• To fulfill a contract with you

• To comply with legal/regulatory obligations

• To pursue legitimate interests

Where required by law, we will request your consent—freely given and revocable at any time via the Open Prime contact information in this policy.

Management of Personal Data

Open Prime implements strict technical and organizational measures to protect personal data. This includes:

• A designated Data Protection Officer

• Two-factor authentication and role-based data access

• Data encryption during online transfers

• Use of firewalls, intrusion detection, and virus protection

• Clean desk policies and secure storage for physical documents

• Access cards, cameras, and physical security systems

Storage Period of Personal Information

We store personal data in secure systems and paper records. When it’s no longer needed, we securely erase or anonymize it.

Certain data must be retained by law (e.g., for money laundering prevention) for five years post-business relationship or longer, if required by regulators.

Opt-out requests for marketing are added to our suppression lists.

Data Transfers Outside the EEA
If your data is transferred outside the European Economic Area, we ensure compliance through mechanisms such as:

• Standard contractual clauses

• Binding corporate rules

• The EU-U.S. Privacy Shield or equivalents

Contact us if you’d like a copy of these safeguards.

Investor Rights

Subject to certain conditions, your rights include:

• Access to your personal data (“data subject access request”)

• Request corrections

• Request deletion (with some legal exceptions)

• Object to processing based on legitimate interests

• Object to direct marketing

• Request restriction of processing

• Request data portability

• Withdraw consent at any time

Investor Complaints and Requests

We aim to respond within 1 month. For complex or large requests, we may extend this period and will inform you.

We may charge a reasonable fee for repetitive or excessive requests or deny them where appropriate.