Law on the Protection of Personal Data in Turkey (KVKK Law in short) was published in the Official Gazette dated 7 April 2016. The purpose of this law is to protect the fundamental rights and freedoms of individuals, the privacy of private life, and to impose obligations against any wrongful act in Turkey.
We aim to establish a data security and storage policy with the Personal Data Protection Law. We protect and preserve your personal data with this policy.
Tekce Exclusive Gayrimenkul Pazarlama AŞ is a registered brand. We are an overseas real estate company based in Turkey. tekceexclusive.com is owned and run by Tekce Exclusive Gayrimenkul Pazarlama AŞ.
The scope of this policy covers the Tekce Exclusive Gayrimenkul Pazarlama AŞ team and tekceexclusive.com visitors. The policy is used in all activities created and carried out by Tekce Exclusive Gayrimenkul Pazarlama AŞ.
This policy has been prepared in accordance with the KVKK Law and must be accepted by our all employees. Tekce Exclusive Gayrimenkul Pazarlama AŞ expects that all customers, visitors, and employees comply with this policy. The company provides necessary information about this policy and provides relevant materials to the employees.
GLOSSARY OF TERMS
3.1. Tekce Exclusive Gayrimenkul Pazarlama AŞ
Tekce Exclusive Gayrimenkul Pazarlama AŞ is an overseas real estate company.
3.2. Explicit Consent
Limited permission is given for the processing of data. It is based on free will and is presented for informational purposes only.
It is the rendering of personal data that cannot be associated with an identified or identifiable person, even if it is matched with other data.
The team of Tekce Exclusive Gayrimenkul Pazarlama AŞ.
3.5. Service Provider
Employees of the third-party company that Tekce Exclusive Gayrimenkul Pazarlama AŞ receives service from.
3.6. Individual / Customer / Visitor
The person whose personal information is kept and processed by Tekce Exclusive Gayrimenkul Pazarlama AŞ.
3.7. Personal Information / Personal Data
Information about contacts/customers/visitors allows them to be identified, such as e-mail address and phone number.
3.8. Processing of Personal Data
Automatically collecting, changing, storing, saving, editing, or disclosing personal information, in whole or in part.
3.9. Data Controller
Persons who decide what personal information Tekce Exclusive Gayrimenkul Pazarlama AŞ will hold and how it will be held and used.
3.10. Data Processor
Natural or legal persons who process data under the authority of the Data Controller.
3.11. KVKK Board
The Board of Protection of Personal Data. (Kişisel Verilerin Korunması Kanunu (KVKK) in Turkish)
3.12. KVKK Corporation
The Corporation for the Protection of Personal Data.
3.13. Law of KVKK
The Turkish Personal Data Protection Law was published in the Official Gazette numbered 29677.
Tekce Exclusive Gayrimenkul Pazarlama AŞ’s Personal Data Protection and Processing Policy.
ROLES AND RESPONSIBILITIES
4.1. Data Controller
The processing of Personal Data refers to the automatically collecting, amending, storing, saving, editing, or disclosing of personal data, in whole or in part, within the framework of the provisions of the Turkish Personal Data Protection Law.
Tekce Exclusive Gayrimenkul Pazarlama AŞ needs to collect and use certain types of information about visitors or customers to continue our work. Tekce Exclusive Gayrimenkul Pazarlama AŞ is the Data Controller within the scope of the Law and determines the purpose for which the data will be used.
4.2. Data Controller Agent
A Data Controller Agent will be needed when the Data Controllers Registry is established. This agent should be an expert in keeping data confidential, processing, and taking the necessary security steps.
4.3. Data Processor
Data processors are natural or legal persons who process Personal Data. The processor must be operating under the authority of Tekce Exclusive Gayrimenkul Pazarlama AŞ.
If the data is processed by natural or legal persons, Tekce Exclusive Gayrimenkul Pazarlama AŞ and Data Processors are obliged to take precautions. As Data Controllers, Tekce Exclusive Gayrimenkul Pazarlama AŞ supervises the trust process between the two parties; Tekce Exclusive Gayrimenkul Pazarlama AŞ and individuals.
Tekce Exclusive Gayrimenkul Pazarlama AŞ has legal obligations regarding the security and processing of Personal Data in accordance with the KVKK Law. These are:
5.1. The Obligation to Clarify
Tekce Exclusive Gayrimenkul Pazarlama AŞ is obliged to inform the visitors and customers about the following issues during Data Processing:
- The identity of the Data Controller
- Reasons for keeping Personal Data
- Legal reasons for keeping Personal Data
- Rights of persons
5.2. The Obligation to Inform
Tekce Exclusive Gayrimenkul Pazarlama AŞ is obliged to inform the visitors and customers in accordance with Article 13 of the KVKK Law. In addition, information requests must be fulfilled via [email protected] or 0850 811 07 00.
The special requests must be written by persons manually or by any other methods to be determined by the KVKK Board.
5.3. The Obligation to Provide Personal Data Security
As Data Controllers, Tekce Exclusive Gayrimenkul Pazarlama AŞ is obliged to provide the necessary security services in accordance with Article 12 of the KVKK Law.
5.4. The Obligation to Enlist in the Data Controllers Registry
Tekce Exclusive Gayrimenkul Pazarlama AŞ is obliged to register with the Data Controllers Registry in accordance with Article 16 of the KVKK Law.
CLASSIFICATION OF PERSONAL DATA
6.1. Personal Data
Information considered as Personal Data is an individual’s name, surname, date and place of birth, identity, social security number, telephone number, e-mail address, address, image, payment information, and other such information.
Tekce Exclusive Gayrimenkul Pazarlama AŞ keeps some of this data, such as name, surname, telephone number, and e-mail address, due to membership conditions.
6.2. Private Personal Data
Information considered as Private Personal Data is an individual’s race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, rig, membership to any foundation or organization, health problems, sexual life, convictions, security measures, biometric and genetic data.
It is strictly forbidden to keep such data without the consent of individuals in accordance with Article 6 of the Turkish KVKK Law. As Data Controllers, Tekce Exclusive Gayrimenkul Pazarlama AŞ never request such Private Personal Data unless it is specified by laws.
THE POLICY OF PERSONAL DATA PROCESSING
7.1. The Principles for Data Processing
All collected data must be processed in accordance with Articles 4, 5, and 6 of the KVKK Law.
- Tekce Exclusive Gayrimenkul Pazarlama AŞ must process the data in accordance with the KVKK Law and other legal regulations.
- Tekce Exclusive Gayrimenkul Pazarlama AŞ must be transparent, fulfill the obligations to clarify and inform by adhering to the rules of honesty.
- Tekce Exclusive Gayrimenkul Pazarlama AŞ should only process the data for justifiable reasons. The reasons must be lawful and specified in the KVKK Law or other legal regulations.
- The data must be relevant to the purpose and limited to that purpose only.
- Tekce Exclusive Gayrimenkul Pazarlama AŞ must process data at the required scale. The code of proportion must be enforced and only the necessary bit of the data must be processed.
- Tekce Exclusive Gayrimenkul Pazarlama AŞ must keep data only for as long as needed (see section 9) and must not keep data if the required time has passed anonymously.
7.2. The Objectives of Data Processing
Tekce Exclusive Gayrimenkul Pazarlama AŞ does not collect and save any personal information from any customer in order to send unwanted and unsolicited information (spam). We aim to process data for some purposes such as:
- Personal and contact data, such as name, surname, phone number, e-mail address, are processed for website registration and higher quality communication.
- Demographic site or app browsing data is processed to analyze and collect user points of interest. This data is used to improve business and operational activities, such as remarketing, retargeting, and communications.
- Social web information is used to provide a better and easier experience on the website. Some social websites, such as Facebook, Twitter, Linkedin, can only be used to register on the Tekce Exclusive Gayrimenkul Pazarlama AŞ website.
- Location data is used if the user gives permission from mobile phones while browsing. We process location data to suggest properties and show the closest offices by location.
The data is processed for other purposes in addition to the above-mentioned purposes;
- Tekce Exclusive Gayrimenkul Pazarlama AŞ sends properties and hot offers via e-mail addresses in a newsletter format.
- Tekce Exclusive Gayrimenkul Pazarlama AŞ deals with each customer individually by answering any questions and needs provided by the contact data.
- Tekce Exclusive Gayrimenkul Pazarlama AŞ informs about new services.
- Tekce Exclusive Gayrimenkul Pazarlama AŞ engages in direct marketing.
- Tekce Exclusive Gayrimenkul Pazarlama AŞ can communicate directly with people when necessary.
7.3. Ensuring the Data to be Processed on Legal Grounds
Tekce Exclusive Gayrimenkul Pazarlama AŞ takes the following technical precautions for the processing of personal data on legal grounds:
- Arranging an intercorporate institution for the processing and storage of Personal Data in accordance with the Law
- Establishing the technical infrastructure for the database where all Personal Data will be kept
- Supervising the created technical infrastructure and process
- Designating the necessary procedures for reporting technical procedures and inspection periods
Tekce Exclusive Gayrimenkul Pazarlama AŞ takes the following legal precautions for the processing of personal data on legal grounds:
- To educate and inform Tekce Exclusive Gayrimenkul Pazarlama AŞ employees about the legal processing of personal data
- To take precautions against any unlawful processing of personal data in contracts, legal files, and policies
- To inspect the personal data processing of third-party processors and partners
THE POLICY OF TRANSFERRING THE PERSONAL DATA
8.1. Transferring the Personal Data Inland
Tekce Exclusive Gayrimenkul Pazarlama AŞ is obliged to act in accordance with the KVKK Law and the regulations determined by the KVKK Board. As Data Controllers, Tekce Exclusive Gayrimenkul Pazarlama AŞ is obliged to comply with the KVKK Law.
We never share any personal data or information with third-party companies without the consent of the person. However, in case of obligations arising from the KVKK Law and other Constitutional Laws, we may transfer the data to the relevant jurisdiction, governmental or legal bodies.
8.2. Transferring the Personal Data Abroad
Tekce Exclusive Gayrimenkul Pazarlama AŞ can also transfer data abroad for processing and storage. The country that will receive the Personal Data must have taken the necessary security measures. The measures should be controlled by the KVKK Board.
In case the necessary measures are not sufficient, Data Controllers from both Turkey and the recipient country must make a written commitment, and the KVKK Board must approve it.
8.3. Which Person/Organization Receives the Personal Data?
Authorized institutions and organizations: Public legal entities can receive the Data as they request, according to Article 8.1. Tekce Exclusive Gayrimenkul Pazarlama AŞ customer program, TEKÇE, receives and stores Personal Data and keeps track of customers.
Some third-party software and tools, such as Bing, Google AdWords, Google Analytics, Yandex Metrica, Yandex Direct, Whatsapp, Facebook, Twitter, Instagram, and JivoChat, collect Personal Data from cookies to facilitate your browsing experience.
8.4. The Precautions for Transferring the Personal Data
Tekce Exclusive Gayrimenkul Pazarlama AŞ is obliged to take the necessary technical measures in case of unauthorized access to and use of Personal Data by any data processor person or company, even if these data processors are authorized by Tekce Exclusive Gayrimenkul Pazarlama AŞ.
Tekce Exclusive Gayrimenkul Pazarlama AŞ has established internal policies on how and for what purpose the data should be transferred. We also determine the parties to whom the data should be transferred.
THE POLICY OF THE PERSONAL DATA PRESERVATION
9.1. Preserving the Data for a Specific Amount of Time
According to the KVKK Law, any information related to persons known or found is personal data. All information, such as e-mail addresses and phone numbers, are securely saved and stored by Tekce Exclusive Gayrimenkul Pazarlama AŞ.
In this context, Tekce Exclusive Gayrimenkul Pazarlama AŞ is obliged to act in accordance with the law while obtaining and storing the data. The data will be stored until the preservation purpose (see 7.2) is finished. According to government obligations, data must be kept for an average of 2 years.
This period changed from law to law. For example, according to the Tax Procedure Law, registration and credentials must be kept for 5 years.
9.2. The Precautions for Processing the Personal Data
Tekce Exclusive Gayrimenkul Pazarlama AŞ takes measures to ensure the safety and security of personal data. The needed systems and control mechanisms as technical measures are established.
We also create awareness and education among our employees on the protection of Personal Data. We are obliged to examine these measures for the protection of personal data.
SAFETY POLICY OF THE PERSONAL DATA
10.1. Responsibilities of Tekce Exclusive Gayrimenkul Pazarlama AŞ about the Safety of Data
We have the responsibility to keep Personal Data safe in accordance with Article 12 of the Personal Data Protection Law. We are responsible for:
- Preventing the processing of Personal Data in violation of any law,
- Checking the measures regularly,
- Providing adequate technical equipment to stop any infiltration of Personal Data,
- Informing the authorized institutions in case of any infiltration.
10.2. Precautions for Keeping the Personal Data Safe
We take the necessary precautions at times of security risk in order to keep Personal Data safe and secure. These precautions are as follows;
Technical and Executive Precautions
Technical and executive measures regarding the processing, transfer, and security of Personal Data are specified in the relevant articles. We are obliged by the Law to take measures for the protection of individuals in the event that Personal Data is still leaked and in the hands of third parties unlawfully.
Precautions and Inspection for Safety of the Personal Data
We prepare a report on the compliance of the Data recorder with the KVKK Law. The recorder is periodically inspected, and the report is submitted to the authorized person or board.
Precautions in Case of Disclosure without Authorization
We are obliged to hinder all disclosure activities, take the necessary precautions, and establish an internal policy. In case of any unauthorized disclosure, we are obliged to inform the disclosed person and the KVKK Board.
THE RIGHTS OF INDIVIDUALS
11.1. Right to Access Own Personal Data
Individuals, customers, and visitors have the right to access their personal data without making any payment. They can:
- Learn whether their Personal Data is processed or not,
- Request information about the operation if the data is processed,
- Question the purpose of processing and learn whether the data is used in accordance with its purpose.
11.2. Right to Change or Delete Own Personal Data
Individuals, customers, and visitors can change or delete their personal data without any payment. They can:
- Request the correction of the Data in case of any wrong or incomplete information,
- Request the deletion of the Data if the purpose of storing the data is no longer active,
- Request notification of these procedures to third-party processors,
- Object to any negative results resulting from the analysis of the processed data by automatic systems.
11.3. Updating Own Personal Data
You may contact us when you have a request to access, change, or delete your own Personal Data;
Phone: 0850 811 07 00
E-mail: [email protected]
Personal meeting or letter: Business İstanbul Plaza Merdivenköy Mah. Yumurtacı Abdibey Cd., Dikyol Sk. No:2/A B Blok Kat:2 Ofis: B/19 Kadıköy, İstanbul
11.4. Application of Individuals and Evaluation
Individuals may request access to their processed data and the use of their rights specified in this policy. Tekce Exclusive Gayrimenkul Pazarlama AŞ creates these communication opportunities. All applications are answered in a short time, not more than the KVKK Law foresees.
These persons should consult the representatives who are clarified by Tekce Exclusive Gayrimenkul Pazarlama AŞ and declared by the Data Controllers Registry. The Data Controller Representative will conclude these applications in a short time and not more than 30 days, without any fee or payment determined by the KVKK Board.
In order to initiate this process, individuals must send their applications to the Data Controller Representative as determined by the KVKK Board. Applications must be written in letters until the Board determines another method. The person must express their application clearly and send their official letter as a registered and reply-paid letter to:
Business İstanbul Plaza Merdivenköy Mah. Yumurtacı Abdibey Cd., Dikyol Sk. No:2/A B Blok Kat:2 Ofis: B/19 Kadıköy, İstanbul
The application is accepted or rejected by the Data Controller Representatives and answered in writing or electronically. If the application is accepted, the request will be made by Tekce Exclusive Gayrimenkul Pazarlama AŞ. If the fault belongs to Tekce Exclusive Gayrimenkul Pazarlama AŞ, the payment is refunded to the person.
In case the application is rejected, the answer is not sufficient, or the answer is not given within the given time, the person can write a complaint letter within 30 days as it is answered within 60 days.
Visitors can always block Cookies from their browser settings. However, blocking or limiting Cookies may affect the smooth experience visitors have. Visitors are considered to accept Cookies as long as they do not block or limit Cookies.
PUBLISHING AND PRESERVING THE POLICY
THE PERIOD OF UPDATING THE POLICY
This policy will be valid from the moment of its publication until it is removed from the mobile app or website.
We have taken technical and organizational security measures to prevent accidental loss, use or unauthorized access, change, or disclosure of your personal data. However, no method of transmission or electronic storage via the Internet or mobile device is 100% secure.
Tekce Exclusive Gayrimenkul Pazarlama AŞ expressly disclaims any such liability and obligation.
INTERNATIONAL DATA TRANSFER
We take our users’ privacy seriously. Therefore, we take steps to protect your information, including ensuring an adequate level of data protection in line with EU standards.
These include the application of the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect the personal information they process from the EEA in accordance with European Union data protection laws.
We have implemented similar appropriate measures with our third-party service providers and partners, and more details can be provided on request.
* This document has been updated on May 11, 2022.