Privacy Policy & Protection of Personal Data
1. PURPOSE
Turkish Law on the Protection of Personal Data (shortly “KVKK”) is published in the Official Gazette on 7th April 2016. This law’s main purpose is to protect the rights and freedoms of individuals, the privacy of personal life, and to set obligations against any wrongful act in Turkey.
The purpose is to create a policy of data security and storage by the Law on the Protection of Personal Data. Trabzon Homes creates and manages this policy for protecting and preserving personal data.
2. SCOPE
The scope of this policy covers the visitors of trabzonhomes.com and the Trabzon Homes team. Trabzon Homes ® is a registered brand of the overseas real estate company, Tekçe Overseas Gayrimenkul Anonim Şirketi. The website trabzonhomes.com is owned by Tekçe Overseas Gayrimenkul AŞ. The policy is in use on all activities created and executed by Tekçe Overseas Gayrimenkul AŞ.
This policy was created in accordance with the KVKK Law, and it should be agreed upon by all Trabzon Homes employees.
All of Trabzon Homes' clients, guests, and personnel are expected to become familiar with and act adheres to this policy. The company gives proper information about this policy and provides relevant materials to its employees.
3. GLOSSARY OF TERMS
3.1.Trabzon Homes
Trabzon Homes is one of the brands of the international overseas real estate company, Tekçe Overseas Gayrimenkul AŞ.
3.2. Explicit Consent
Limited consent is given for data processing. It is based on free will and presented for the purpose of information.
3.3. Anonymization
The way of rendering personal data impossible to link with an identified or identifiable person, even if it matches other data.
3.4. Employees
The Trabzon Homes team.
3.5. Service Provider
The staff of the third-party company from that Trabzon Homes getting service.
3.6. Individual / Customer / Visitor
The person whose personal information is kept and processed by Trabzon Homes.
3.7. Personal Information / Personal Data
Information of individuals/customers/visitors that enables to be identified. In this case, the e-mail address and telephone number.
3.8. Processing of Personal Data
The processes of collecting, amending, storing, saving, editing, or disclosing personal information fully or partially automatically.
3.9. Data Controller
Persons who decide what personal information Trabzon Homes will keep and how it will be kept and used.
3.10. Data Processor
The natural or legal persons who process the data under the authority of the Data Controller.
3.11. KVKK Board
The Board of Personal Data Protection. (KVKK is the short form of Personal Data Protection Law in Turkish)
3.12. KVKK Corporation
The Corporation for the Protection of Personal Data.
3.13. Law of KVKK
Turkish Law on the Protection of Personal Data published in the number 29677 edition of the Official Gazette.
3.14. Policy
The policy of Trabzon Homes on Protection and Processing of Personal Data.
4. ROLES AND RESPONSIBILITIES
4.1. Data Controller
The processing of Personal Data means the operations of collecting, amending, storing, saving, editing, or disclosing personal information fully or partially automatically under the conditions of the Turkish Law on Personal Data Protection.
As Trabzon Homes, we are required to collect and use certain types of information about visitors or customers in order to carry on our work. Trabzon Homes is the Data Controller under the Law and decides what the data will be used for.
4.2. Data Controller Agent
When Data Controllers Registry is established there will be a need to have a Data Controller Agent. This agent needs to be an expert in the area of keeping the data private, processing it, and taking essential security measures.
4.3. Data Processor
Data processors are the natural or legal persons that process Personal Data. The processor should be operating under the authorization of Trabzon Homes.
4.4. Responsibilities
In case of data being processed by natural or legal persons, Trabzon Homes Real Estate and the Data Processors are obliged to take safeguards. Trabzon Homes, as the Data Controllers, inspects the process of trust between two parties; Trabzon Homes and individuals.
5. LEGAL OBLIGATIONS
Trabzon Homes have legal responsibilities for the security and process of Personal Data in accordance with the KVKK Law. The obligations are;
5.1. The Obligation to Clarify
During the Data Process, Trabzon Homes is obliged to clarify its visitors and customers about following elements;
• The identity of the Data Controller,
• The reasons for preserving the Personal Data,
• The legal reasons for keeping the Personal Data,
• The rights of individuals.
5.2. The Obligation to Inform
In accordance with the 13th article of KVKK Law, Trabzon Homes is obliged to inform individuals. It is also needed to fulfill the requests for information through info@trabzonhomes.com or +90 462 341 0101
Those specific requests should be written by those individuals manually or with any other medium that KVKK Board determines.
5.3. The Obligation to Provide Personal Data Security
As Data Controllers, Trabzon Homes is obliged to provide essential security services in accordance with the 12th article of the KVKK Law.
5.4. The Obligation to Enlist in the Data Controllers Registry
Trabzon Homes is required to register in the register of data controllers in accordance with Article 16 of the KVKK Law.
6. CLASSIFYING THE PERSONAL DATA
6.1. Personal Data
First name, last name, date and place of birth, identity, social security number, telephone number, e-mail address, address, visual information, payment information, and such other information of a person are considered personal data.
Due to membership clauses, Trabzon Homes store some of this data such as name, surname, telephone number, and email address.
6.2. Private Personal Data
Race, ethnic origin, political opinion, philosophical beliefs, religion, sect or other beliefs, platforms, membership in a foundation or institution, health problems, sexual life, beliefs, security measures, and biometric and genetic data of an individual are assumed to be Private Personal Data. According to Article 6 of the Turkish KVKK Law, it is strictly prohibited to retain such data without an individual's consent.
As a Data Controller, Trabzon Homes never asks for such Private Personal Data unless it is stated in legal laws.
7. THE POLICY OF PERSONAL DATA PROCESSING
7.1. The Principals for Data Processing
All data collected must be properly processed in accordance with Article 4 and in accordance with Articles 5 and 6 of the KVKK Act.
• Trabzon Homes should process the data by abiding by the KVKK Law and other legal regulations.
• Trabzon Homes should be transparent, follow the obligations to clarify, and inform by abiding by the code of honesty.
• Trabzon Homes should process the data for only rightful causes. The causes should be legal and indicated in the KVKK Law or other legal regulations.
• The data should be in connection with its aim and only limited to this purpose.
• Trabzon Homes should process the data on the necessary scale. The code of proportion must be obliged and only the necessary bit of the data should be processed.
• Trabzon Homes should preserve the data only in the needed period (See the 9th section) and should not preserve the data if the necessary period has passed anonymously.
7.2. The Objectives of Data Processing
Trabzon Homes does not collect and keep any personal information from any customers for sending any unwanted and unsolicited information (spam). Trabzon Homes aim to process the data with some objectives like the following:
• For website registration and improved communication, personal and communication data like name, surname, phone number, and email address are processed.
• Demographic information about users' online activity is processed to identify and gather their interests. These data are used to improve business and operational processes like communication, remarketing, and retargeting.
• Social media information is used to make using the website better and simpler.
In addition to the previously stated goals, the data is processed for other purposes;
• Trabzon Homes sends properties and hot offers to email addresses in the form of a newsletter.
• Trabzon Homes responds to each customer's questions and needs individually by using the provided communication data.
• Trabzon Homes gives information about the latest services.
• Trabzon Homes does direct marketing.
• Trabzon Homes can directly communicate with individuals if required.
7.3. Ensuring the Data to be Processed on Legal Grounds
For processing personal data on legal grounds, Trabzon Homes take these technical precautions;
• Organizing an intercorporate institution for processing and keeping Personal Data in accordance with the Law,
• Creating a technical infrastructure for the database that will store all the Personal Data,
• Inspecting the created technical infrastructure and process,
• Designating the required procedures for reporting the technical procedures and inspection periods.
Trabzon Homes take the following legal precautions for processing personal data on legal grounds;
• Educating and informing the Trabzon Homes employees about processing the personal data on legal grounds,
• Putting the precautions against any unlawful acts of processing the personal data on the contracts, legal files and policies,
• Inspecting the personal data processing of the third-party processors and partners.
8. THE POLICY OF TRANSFERRING THE PERSONAL DATA
8.1. Transferring the Personal Data Inland
Trabzon Homes is obliged to act in accordance with the KVKK Law and the regulations designated by the KVKK Board.
As the Data Controllers, Trabzon Homes is obliged to proceed by the KVKK Law. Trabzon Homes never share any personal data or information with third-party companies without the individual's consent.
However, in case of obligations from the KVKK Law and other Constitutional Laws, Trabzon Homes can transfer the data to the related governmental, judicial, or legal bodies.
8.2. Transferring the Personal Data Abroad
Trabzon Homes can also transfer the data abroad for processing and preservation. The country which will receive the Personal Data must have the required safety precautions. The precautions must be checked by the KVKK Board. the Data Controllers from both Turkey and the receiving country must make a written commitment and the KVKK Board must approve it if the required precautions are not enough.
8.3. Which Person / Organization Receives the Personal Data?
Authorized institutions and organizations: Public statutory bodies can receive the Data as they request according to article number 8.1.
The customer program of Trabzon Homes, TEKCE, receives Personal Data, preserves it, and keeps track of the customers.
Some third-party software and tools such as Bing, Google AdWords, Google Analytics, Yandex Metrica, Yandex Direct, Whatsapp, Facebook, Twitter, Instagram, and JivoChat receive Personal Data from the cookies to make your browsing experience more comfortable.
8.4. The Precautions for Transferring the Personal Data
Technical Precautions
• Trabzon Homes is obliged to take the essential technical precautions for any unauthorized access to and usage of the Personal Data by any data processor person or companies even though these data processors are authorized by Trabzon Homes.
Executive Precautions
• Trabzon Homes created inner policies about how and for what purpose the data should be transferred. Trabzon Homes also decides the parties to whom the data should be transferred.
9. THE POLICY OF PERSONAL DATA PRESERVATION
9.1. Preserving the Data for a Specific Amount of Time
According to the KVKK Law, every piece of information related to known or findable individuals is personal data. All the information such as e-mail addresses and telephone numbers is saved and kept safely by Trabzon Homes.
In this regard, Trabzon Homes is obliged to act in accordance with the laws while obtaining and keeping the data. The data will be kept until the aim of preservation (see 7.2) is finished. According to governmental commitments, the data should be stored for an average of 2 years.
This period changes from law to law. For example, the registries and credentials must be kept for 5 years, according to the Tax Procedure Law.
9.2. The Precautions for Processing the Personal Data
Technical Precautions
• Trabzon Homes ® takes precautions for keeping personal data safe and secure. The required systems and control mechanisms are created as technical precautions.
Executive Precautions
• Trabzon Homes also creates awareness for and education about holding Personal Data among its employees.
• Trabzon Homes is responsible for examining these precautions for holding personal data.
10. SAFETY POLICY OF THE PERSONAL DATA
10.1. Responsibilities of Trabzon Homes about the Safety of Data
Trabzon Homes has responsibilities to keep Personal Data safe according to the 12th Article of Law on the Protection of Personal Data. Trabzon Homes is responsible for;
• precluding the Personal Data to be processed against any law,
• checking the precautions regularly,
• providing sufficient technical equipment for stopping any infiltration to Personal Data,
• informing authorized bodies in any case of infiltration.
10.2. Precautions for Keeping the Personal Data Safe
Trabzon Homes take essential precautions in times of security risk with the aim of keeping Personal Data safe and secure. These precautions are;
Technical and Executive Precautions
The technical and executive precautions of the Personal Data process, transfer, and safety are stated in the related articles. If the Personal Data is still infiltrated and reached by third parties illegally, Trabzon Homes is obliged to take precautions for the protection of the individuals by the Law.
Precautions and Inspection for Safety of the Personal Data
Trabzon Homes prepare a report about the Data recorder’s suitability to the KVKK Law. The recorder is inspected periodically and the report is presented to the authorized person or board.
Precautions in Case of Disclosure without Authorization
Trabzon Homes is obliged to hinder all disclosure activities, take the essential precautions, and create an internal policy. In any case of the disclosure without authorization, Trabzon Homes is obliged to notify the disclosed individual and the KVKK Board.
11. 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 any cost. Individuals can;
• learn about whether Data are processed or not,
• demand information about the operation, if the Data are processed,
• question the aim of processing and learn if the Data used for 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 cost. Individuals can;
• request the Data be corrected in any case of wrong or missing information,
• request the Data to be deleted if the purpose of keeping the Data is not active anymore,
• request those procedures to be notified to third party processors,
• object to any negative result that appears with the analysis of the processed Data by automatic systems.
11.3. Updating Own Personal Data
In any case of demand to access, change or delete your own Personal Data, you can contact us;
via Phone: +90 462 341 0101
via e-mail: info@trabzonhomes.com
via Personal meeting or letter: Kaşüstü Mahallesi, Devlet Karayolu Caddesi No: 29, Kat: 4, Daire:32 61250, Yomra, Trabzon.
11.4. Application of Individuals and Evaluation
Individuals can request access to their processed data and make use of the rights that are outlined in this policy. Trabzon Homes creates those communication opportunities. The applications are all responded to in a brief period of time, not longer than the KVKK Law allows.
Those individuals should consult with the representatives who will be identified by Trabzon Homes and listed in the Data Controllers Registry. Data Controller Representative will conclude those applications in a brief period of time, not to exceed 30 days, without charge or with payment as determined by KVKK Board.
Individuals should send their applications to the Data Controller Representative via the channels that the KVKK Board determines in order to begin this process. Until the Board decides otherwise, the applications must be written as letters. The individual sending the formal letter should clearly state their requests and send the formal letter as a registered and reply-paid letter to;
Kaşüstü Mahallesi, Devlet Karayolu Caddesi No: 29, Kat: 4, Daire:32 61250, Yomra, Trabzon.
Data Controller Representatives review the application, accept it or reject it, and respond in writing or electronically. Trabzon Homes will fulfill the request if the application is approved. If the error belongs to Trabzon Homes, the payment would be repaid to the individuals.
If the application is declined, the answer is not sufficient enough or it is not answered in the given time, the individual can write a complaint letter within 30 days if it is answered to 60 days.
12. COOKIE POLICY
The Cookie Policy is valid for mobile/websites that are conducted by Trabzon Homes.
Trabzon Homes uses Cookies for improving the experience of its visitors and presenting them with a better web and mobile service. The visitors can always block the Cookies from their browser settings. However, blocking or limiting the Cookie transaction can affect the smooth experience the visitors would have.
As long as they don't block or restrict cookies, visitors are deemed to have accepted them.
13. PUBLISHING AND PRESERVING THE POLICY
We will only collect, use, and disclose information about you in accordance with the most recent version of the Privacy Policy, which is available here. If we make material changes to the Data and Privacy Policy, we will notify you by email or by posting a notice on the Service prior to the effective date of the changes. You acknowledge the updated Privacy Policy by continuing to access or use the Service after those changes take effect.
14. THE PERIOD OF UPDATING THE POLICY
We may update the Privacy Policy to reflect changes to our information practices. If we make any changes we will provide notice on the Trabzon Homes website. Changes will enter into effect after the last update date.
15. VALIDNESS
As soon as it is published, this policy will be valid until it is removed from the mobile or website.
16. SECURITY
To prevent the unintentional loss, alteration, unauthorized access, use, disclosure, or other processing of your personal data, we have implemented technical and organizational security measures.
However, no method of transmission over the Internet or via the mobile device, or method of electronic storage, is 100% secure. Trabzon Homes expressly rejects any such obligation.
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. As we value our users' privacy, we take precautions to protect it, including ensuring 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.
* This document has been updated on April 28, 2021.
