Privacy Policy and Protection and Processing of Personal Data
1. PURPOSE
The Government of the Republic of Turkey has created the “Privacy Policy” to protect the rights of individuals, the privacy of their personal lives and their commitments against any illegal use of personal data within the scope of the Personal Data Protection Law (in short “KVKK Law”) published in the Official Gazette on April 7, 2016.
The purpose here is to establish a data protection and retention policy with the Personal Data Protection Law. Properties & Partners stores the personal data in accordance with this law.
2. SCOPE
This policy applies to https://properties-partner.com visitors and the Properties & Partners team. The policy has an impact on all activities created and carried out by Properties & Partners.
Our privacy policy has been created in accordance with the Law on the Protection of Personal Data and Properties & Partners requests the participation and support of all its employees, visitors and customers. This policy has been accepted by all employees of Properties & Partners.
3. TERMS AND ABBREVIATIONS
3.1. Properties & Partners
Properties & Partners Limited Company is briefly referred to as Properties & Partners.
3.2. Express Assent
For the processing of data, it is the consent of a specific subject based on information and expressed with free will.
3.3. Anonymization
It is a way of applying changes on identifiable personal information in a way that cannot be matched with any individual.
3.4. Employees
The team of Properties & Partners.
3.5. Service provider
The employee of the third company whom Properties & Partners get services from.
3.6. Personal Data Owner (Client / Visitor)
The person whose personal data is kept and processed by Properties & Partners.
3.7. Personal Information / Data
Data such as e-mail, address and telephone number that enables the identification of people / visitors / clients.
3.8. Processing of Personal Data
The process of storing, collecting, recording, changing, disclosing or editing personal data is carried out partially or completely automatically.
3.9. Data Supervisor
Persons who decide what personal information Properties & Partners will keep and how they will be kept and used.
3.10. Data Processor
Natural or legal persons who are authorized to process data as data controllers.
3.11 KVKK Board
Personal Data Protection Board.
3.12. KVKK Institution
The Institution for the Protection of Personal Data.
3.13. Law of KVKK
The Law on Protection of Personal Data was published in the Official Gazette numbered 29677 on April 7, 2016.
3.14. Policy
Policy on Protection and Processing of Personal Data by Properties & Partners.
4. ROLES AND RESPONSIBILITIES
4.1. Data Supervisor
The storage, collection, recording, modification, disclosure or arrangement of personal data is carried out partially or completely automatically in accordance with the Personal Data Protection Law.
Properties & Partners collects and uses some information about clients and visitors to carry out the business. The Data Controller is Properties & Partners who clearly defines which data will be used in accordance with the Law.
4.2. Data Controller Representative
The Data Control Representative is the specialist who ensures the storage, processing and security of data.
4.3. Data Processor
A natural or legal person to process personal data authorized by Properties & Partners.
4.4. Responsibility
If personal data is processed by a natural or legal person, Properties & Partners and the data processing persons are obliged to take the necessary precautions. As a data controller, Properties & Partners oversees the trust process between itself and the relevant persons who share their personal data.
5. LEGAL OBLIGATIONS
Properties & Partners has legal obligations to protect and process personal data in accordance with the Law on KVKK. These obligations are as follows:
5.1. Disclosure Obligation
During the collection of personal data, Properties & Partners is obliged to inform its visitors / clients about the following:
Identity of the Data Controller,
Reasons to protect personal data,
The method and legal reason for collecting personal data,
Rights of the person concerned.
5.2. Informing Obligation
In accordance with Article 13 of the KVKK Law, Properties & Partners is obliged to inform the relevant persons and to provide any additional information, if necessary, via the e-mail address of info@properties-partner.com or by phone at
+90 536 420 83 06.
These requests should be written manually by the relevant persons or by other methods determined by the KVKK Board of Directors.
5.3. Obligation to Ensure Personal Data Security
Properties & Partners, as Data Controllers, is obliged to provide all necessary security measures in accordance with Article 12 of the KVKK Law.
5.4. Obligation to Register to the Data Controllers Registry
Properties & Partners is obliged to register with the Data Controllers Registry pursuant to Article 16 of the KVKK Law.
6. LIMITATION OF PERSONAL DATA
6.1. Personal Data
A person’s name, surname, social security number, identity number, place of birth, date of birth, telephone number, address, e-mail address, payment information and all similar information are considered personal information.
Properties & Partners preserves certain data such as name, surname, e-mail address and telephone number due to membership conditions.
6.2. Special Quality Personal Data
Personal data such as individuals’ political views, ethnicity, religion, beliefs, membership in any foundation or organization, biometric and genetic data, dress code, philosophical beliefs, health, sexual life, criminal conviction are considered Special Qualified Personal Data.
As the Data Supervisor, Properties & Partners does not need Special Quality Personal Data and does not request such personal data.
7. OPERATION OF PERSONAL DATA POLICY
7.1. Personal Data Processing Principles
All personal data collected by Properties & Partners can only be processed in accordance with Articles 4, 5 and 6 of the KVKK Law.
Properties & Partners is obliged to process data by complying with the KVKK Law and other legal regulations.
Properties & Partners has the obligation to be transparent, respect the rules of honesty and inform the users.
Properties & Partners will only process personal data for legal limited purposes specified in the KVKK Law or other legal regulations.
Data usage should be defined according to its purposes, limited and measured.
The processing of data is limited by Properties & Partners only to the necessary scale.
Properties & Partners can only keep the data within the required period.
7.2. Purposes of Processing Personal Data
Properties & Partners does not collect or store personal data from any client in order to send unsolicited information (spam). Properties & Partners processes personal data for the following purposes;
Properties & Partners processes personal data such as name, surname, e-mail address and telephone number for website registration and more efficient communication.
The app uses browsing data and demographic data to run operational services such as marketing, retargeting, and communications.
Information provided by social media provides a better experience on our website. Some social networking sites such as Facebook, Twitter, LinkedIn, Instagram and Google Plus can only be used to log into the Properties & Partners website.
Location data is used only if the user consents to their device while browsing. These data are used by Properties & Partners to show the most suitable properties in the location.
In addition to the purposes stated above, Properties & Partners collects data for the following issues;
Properties & Partners sends hot offers and property proposals in newsletter format by e-mail.
Properties & Partners responds to all kinds of questions by dealing with each customer individually according to the communication data it provides.
Properties & Partners informs its clients about new services.
Properties & Partners makes direct marketing.
Properties & Partners reserves the right to communicate directly with individuals when necessary.
7.3. Ensuring the Processing of Personal Data in Accordance with the Law
Properties & Partners takes the following technical measures for the processing of personal data for legal reasons;
To organize in-house organizations for the storage and processing of Personal Data in accordance with the law,
Providing a suitable technical infrastructure for the storage of the personal database,
Inspection of technical infrastructure and process,
Determining the necessary procedures for audit periods and technical procedures.
Properties & Partners takes the necessary legal measures within the scope of personal data processing in accordance with the law:
Informing and training employees of Properties & Partners about the processing of personal data for legal reasons,
Taking precautions in case of any illegal personal data processing on legal files, contracts and policies,
Verification that personal data are processed by partners and third party processors.
8. PERSONAL DATA TRANSFER POLICY
8.1. Transfer of Personal Data Within The Country
As Data Controllers, Properties & Partners has the obligation to act in accordance with the KVKK Law. Properties & Partners does not share any personal information or data with third party companies without the consent of the person.
However, Properties & Partners may transfer the data to the judicial, official or judicial authorities in the obligations established by the KVKK Law and the Constitutional Authorities.
8.2. Transfer of Personal Data Abroad
Personal Data can be transferred abroad for storage and processing by Properties & Partners, provided that it fulfils the obligations set by the KVKK Board. In case the security measures are not sufficient, Turkish Data Controllers and Controllers in the receiving country should prepare a written commitment and request the approval of the KVKK Board.
8.3. Which Person / Organization Are Personal Data Transferred to?
Authorized institutions and organizations, official authorities can provide personal data as they want according to the article 8.1.
Properties & Partners and its client program collect and store Personal Data and follow the customers.
There are third-party tools and software such as Google AdWords, Bing, Google Analytics, WhatsApp, Yandex Direct, Yandex Metrica, Twitter, Facebook, Instagram, and JivoChat that collect some Personal Data through cookies to better ensure your browsing experience.
8.4. Precautions to Be Taken During Personal Data Transfer
Technical Precautions:
Even if Properties & Partners authorizes these data processors, it is obliged to take important technical security measures for the access and use of any illegal Personal Data by any person or companies that process the data.
Administrative Precautions:
Properties & Partners policies define for what purpose and how data should be transferred. Properties & Partners is also obliged to indicate to which parties it will transfer the data.
9.PERSONAL DATA PROTECTION POLICY
9.1. Protecting Data for a Specified Time
Every information about a known or found person is a personal data in accordance with the KVKK Law. All information such as phone number and e-mail address are recorded and protected by Properties & Partners.
As a result, the acquisition and storage of data transactions are carried out by Properties & Partners in accordance with the laws. Data can be stored for about 2 years, depending on the state’s obligations.
Also, some laws define the retention period differently. For example, according to the Tax Procedure Law, registration and identity information can be kept for 5 years.
9.2. Precautions for Processing Personal Data
Technical precautions:
Properties & Partners has established the necessary control mechanisms and system to fulfill the requirements regarding the precautions for the processing of Personal Data.
Administrative precautions:
Properties & Partners provides training for its employees on the protection of Personal Data.
Properties & Partners is responsible for the supervision of these precautions for the protection of personal data.
10. SECURITY OF PERSONAL DATA POLICY
10.1. Obligations of Properties & Partners Regarding Data Security
Properties & Partners, as the data controller, has an obligation to ensure its security in accordance with Article 12 of the Personal Data Protection Law. Properties & Partners is responsible for:
Prevention of unlawful processing of Personal Data,
Regular monitoring of these measures,
Providing the necessary technical equipment to prevent the unlawful capture of Personal Data by others,
Informing the authorities in case of any leakage.
10.2. Precautions to Keep Personal Data Safe
Properties & Partners takes the necessary security measures to ensure that Personal Data is safe and secure. These security measures are as follows:
Technical and Administrative Precautions
Administrative and technical security measures regarding the processing, process and security of Personal Data are defined in the relevant articles. Properties & Partners has the obligation to take security measures to protect the personal data in case of illegal access by third parties.
Precautions and Inspection for the Security of Personal Data
A report is made by Properties & Partners to the authorized person or organization regarding the compliance of the data recording systems with the KVKK Law and the relevant legislation. In addition, the recorder is checked regularly, then a report is prepared to the accredited person or commission.
Precautions to be Taken in Case of Unauthorized Disclosure of Data
Properties & Partners is obliged to prevent all disclosure activities, to take necessary security measures and to formulate policies. In the event of any illegal transaction such as disclosure of data, Properties & Partners is obliged to inform the disclosed person and the Board of Directors of the KVKK.
11. RIGHTS OF THE PERSONAL DATA OWNER
11.1. Right to Access Personal Data
Everyone whose personal data is retained reserves the right to access their personal data at no cost. Individuals can;
Checking whether their data is processed,
Requesting information about the operation of data processing,
Checking the purpose of data processing and whether this data is used for its purpose.
11.2. Right to Change or Delete Personal Data
Everyone whose personal data is kept reserves the right to change or delete their personal data without any charge. Individuals can;
Request correction of data in case of missing or incorrect information,
Request deletion of data if the purpose of storing the data is no longer valid,
Request to inform third parties about these procedures,
Object to any undesirable result that occurs during the analysis of the processed data with automatic systems.
11.3. Updating Personal Data
If you request access to, change or delete your personal data, you can contact us with the following information.
Telephone: +90 536 420 83 06
E-Mail: info@properties-partner.com
Address: Oba Mahallesi, 225 Sk., No:8A, Summer Park Business Centre, Blok D, Ofis 5, Alanya, Antalya Province
We will take steps we deem necessary to confirm your identity before sharing any personal data with you. We will respond to duly approved requests for personal data within 30 days or as required by applicable law.
11.4. Application and Evaluation of the Relevant Person
Relevant persons can make a request to Properties & Partners in order to gain access to the processed personal data as soon as possible. Applications are answered as soon as possible or within the period stipulated in the KVKK Law.
Relevant persons should apply to the representative to be announced by Properties & Partners and declared in the Data Controllers Registry when the legal infrastructure is provided. The representative of the data controller will finalize these applications within 30 days at the latest, without a fee or payment determined by the KVKK Board of Directors. In order to initiate this process, the relevant persons must send their applications to the data controller representative determined by the KVKK Board of Directors. Applications must be made in writing until a method is determined by the Board. During the application to be made, the person concerned must clearly indicate which right he/she uses and send the information and documents, if any, to the corporate address via registered post;
Oba Mahallesi, 225 Sk., No:8A, Summer Park Business Centre, Blok D, Ofis 5, Alanya, Antalya Province.
The requests made by the relevant person are accepted by the representative of the data controller or rejected by explaining the reason. The answer is given in written or electronic form. If the application is accepted, it is fulfilled by Properties & Partners, and in case of a company error, the fee received is returned to the relevant person.
In cases where the application is rejected by Properties & Partners, the answer given is insufficient or the response is not given in time; The person concerned has the right to file a complaint to the KVKK Board within 30 days from the date of learning the answer and within 60 days from the application date.
12. COOKIE POLICY
The Cookie Policy applies to mobile platforms, websites and applications operated by Properties & Partners.
Properties & Partners uses cookies to enrich the experience of its visitors and to provide them with a better internet and mobile service. Visitors can block cookies from their browser settings at any time. However, blocking the use of cookies may affect the usage performance of the website.
Our visitors who use https://properties-partner.com without blocking the use of cookies are deemed to have accepted all of these.
13. PUBLISHING AND STORAGE OF THE POLICY
We may make changes to this Privacy Policy from variable times. The most current version of the Privacy Policy will govern the collection, use and disclosure of information about you and will be found here. If we make material changes to this Privacy Policy, we will notify you by posting a notice on the service or by email prior to the date the changes take effect. By continuing to access or use the Service after these changes become effective, you agree to this revised Privacy Policy.
14. UPDATE PERIOD
In case of a change in line with the economic and commercial decision of Properties & Partners or the policy decisions of the Personal Data Protection Board, this situation will be notified to our members whose data are registered. This policy will be updated by the provision of Properties & Partners or KVKK Law and the latest updates will be communicated to all relevant persons.
Last Updated: 28.09.2020 This Privacy Policy will be valid immediately for users who visit the Properties & Partners website on September 28, 2020 and after this date.
15. ENFORCEMENT
This policy will be valid as soon as it is published until it is removed from the mobile platform or website.
16. SECURITY
We take appropriate technical and organizational security measures to protect personal information submitted to us, both during transmission and after it has been received, from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. However, transfer methods over the Internet or via mobile devices as well as electronic storage methods are not 100% secure. Therefore, we endeavor to use commercially acceptable methods to protect your personal information, but we cannot guarantee their absolute security.
17. INTERNATIONAL DATA TRANSFER
For residents of the EEA or Switzerland, please note that the personal data information we obtain from or about you may be transferred, processed and stored outside of the EEA or Switzerland for the purposes described in this Privacy Policy, including in the United States of America. We take the privacy of our users seriously and therefore take steps to safeguard your information, including assuring an adequate level of data protection in accordance with E.U. standards. These include implementing 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 safeguards with our third-party service providers and partners and further details can be provided upon request.
