Privacy Policy

This consent text regarding the processing of personal data (“Consent Text”) has been prepared for the purpose of obtaining the explicit consent of data subjects, in accordance with Articles 5 and 6 of the Law on the Protection of Personal Data No. 6698 (“KVKK”), for the processing of their personal data and special categories of personal data by ARSAVEV GAYRIMENKUL TEKNOLOJILERI A.Ş (“Company”), acting in the capacity of data controller, or by data processors authorized by it by ensuring necessary security measures, for the scope and purposes specified in the Clarification Text, in compliance with the KVKK.

Article 5; Personal data cannot be processed without the explicit consent of the relevant person. In the presence of one of the following conditions, it is possible to process personal data without seeking the explicit consent of the relevant person:

a) It is clearly provided for in the laws.

b) It is mandatory for the protection of the life or physical integrity of the person or another person who is unable to express their consent due to actual impossibility or whose consent is not legally valid.

c) It is necessary to process the personal data of the parties to a contract, provided that it is directly related to the establishment or performance of the contract.

ç) It is mandatory for the data controller to fulfill its legal obligation.

d) It has been made public by the relevant person themselves.

e) Data processing is mandatory for the establishment, exercise, or protection of a right.

f) Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person.

Article 6; Data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, are special categories of personal data. Processing of special categories of personal data without the explicit consent of the relevant person is prohibited. Personal data other than health and sexual life listed in the first paragraph may be processed without seeking the explicit consent of the relevant person in cases provided for by law. Personal data relating to health and sexual life may only be processed without seeking the explicit consent of the relevant person by persons under the obligation of secrecy or authorized institutions and organizations for the purposes of protecting public health, performing preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and their financing. In the processing of special categories of personal data, it is also mandatory to take adequate measures determined by the Board.

As used in this Consent Text;

“personal data” refers to any information relating to an identified or identifiable natural person; “processing of personal data” refers to any operation performed on data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying, or preventing the use of personal data by fully or partially automated means or by non-automated means provided that they are part of any data recording system,

“special categories of personal data” refers to data relating to a person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.

I accept and declare that I have read and understood the matters stated above, and that I know that my personal data and data falling within the scope of special categories of personal data that I have shared may be kept, processed, and used by the Company and/or the data processor appointed by the Company in the common database established by the Company under the scope and conditions specified in the Clarification Text, and may be transferred to companies acting on behalf and account of the Company, representatives, dealers, law offices, our direct or indirect business partners in Turkey and abroad within the framework of the personal data processing conditions specified in Articles 8 and 9 of the Law on the Protection of Personal Data, and may be stored within the personal data processing conditions in the places where the transfer is made.

Article 8; Personal data cannot be transferred without the explicit consent of the relevant person.

Personal data may be transferred without seeking the explicit consent of the relevant person in the event that one of the conditions specified in;

a) The second paragraph of Article 5,

b) The third paragraph of Article 6, provided that adequate measures are taken, is present.

Provisions in other laws regarding the transfer of personal data are reserved.

Transfer of personal data abroad

Article 9; Personal data cannot be transferred abroad without the explicit consent of the relevant person. Personal data may be transferred abroad without seeking the explicit consent of the relevant person, provided that one of the conditions specified in the second paragraph of Article 5 and the third paragraph of Article 6 is present and in the foreign country where the personal data will be transferred;

a) There is adequate protection,

b) In the absence of adequate protection, the data controllers in Turkey and in the relevant foreign country undertake adequate protection in writing and the permission of the Board is obtained.

Countries with adequate protection shall be determined and announced by the Board.

The Board shall decide whether there is adequate protection in the foreign country and whether permission will be granted pursuant to subparagraph (b) of the second paragraph by evaluating;

a) International conventions to which Turkey is a party,

b) The state of reciprocity regarding data transfer between the country requesting personal data and Turkey,

c) Regarding each concrete personal data transfer, the nature of the personal data and the purpose and duration of processing,

ç) The relevant legislation and practice of the country to which the personal data will be transferred,

d) The measures undertaken by the data controller in the country to which the personal data will be transferred, and by obtaining the opinion of relevant institutions and organizations if needed.

Personal data may only be transferred abroad with the permission of the Board after obtaining the opinion of the relevant public institution or organization in cases where the interest of Turkey or the relevant person will be seriously harmed, without prejudice to the provisions of international conventions.

Provisions in other laws regarding the transfer of personal data abroad are reserved.

I accept, declare, and undertake that I have read and understood the matters stated above; that in accordance with Articles 5 and 6 of the Law on the Protection of Personal Data, for the purposes of providing the products and services offered by the Company to its customers under the best conditions, ensuring the reliable and uninterrupted provision of products or services, maximizing customer satisfaction, fulfilling various transactions related to said services, conducting and developing operations, performing promotion, marketing, advertising, and campaign activities for said services or services, informing customers about opportunities, campaigns, and other services, fulfilling the requirements of contracts concluded with customers, and receiving services from insurance companies and other companies that will provide insurance services; my personal data that can identify me, such as identity information, name, surname, telephone number, TR Identity number, date and place of birth, address information, residence information, e-mail address, educational status, marital status, family information/number of children, profession information, gender, photograph, picture, image, video or biometric data for profile descriptions, application user number, contract number, institution and title information, tax number and office information, signature circular, and user ID assigned to the user/customer, may be processed in accordance with the general principles stated in Article 4 of the Law on the Protection of Personal Data No. 6698 (“LPPD”), primarily the principle of being preserved for the period stipulated in the legislation or required for the purpose for which they are processed; that they can be obtained, recorded, stored securely in physical or electronic environments for a period appropriate for the purpose of processing, preserved, changed, rearranged, disclosed and transferred in accordance with the legislation, taken over, classified, processed, or the use of data can be prevented; that the data processing operations implemented in accordance with Company rules may be kept, processed, and used by the Company and/or the data processor appointed by the Company in the common database established by the Company; that I have been informed by the Company regarding the matters stated above; that I know my personal data may be transferred by the Company to Company employees, officers, group companies if any (Company and/or domestic and international business partners, shareholders, managers if any), business partnerships related to the provision of services, insurance companies and companies that will provide insurance services, legally authorized public institutions and organizations, independent audit companies, survey companies, lawyers, legal departments, tax consultants, and business partners and service providers from whom the Company receives services or works with for the execution of services and/or activities to be provided by auditors within the framework of legal obligations and legal limitations in order to carry out its activities; and that I have explicit consent for these within the personal data processing conditions specified in Articles 8 and 9 of the Law on the Protection of Personal Data.

Furthermore, in accordance with Article 11 of the LPPD and relevant legislation, I acknowledge that I have the right to apply to the Company to: learn whether personal data is processed, request information if personal data has been processed, learn the purpose of processing personal data and whether they are used in accordance with their purpose, know the third parties to whom personal data are transferred domestically or abroad, request correction of personal data if they are processed incompletely or incorrectly, request the deletion or destruction of personal data in the event that the reasons requiring the processing of such data disappear, request notification of these correction and deletion requests to third parties to whom personal data have been transferred, object to the occurrence of a result against myself by analyzing the processed data exclusively through automated systems, and demand compensation for damages in case of loss due to unlawful processing of personal data; and that I have the right to submit my request, including the necessary information to identify my identity and explanations regarding the right I request to use, in person with documents identifying my identity to the Directorate of the Company located at “ESENTEPE MAH. TALAT PASA CAD. NO: 5 IC KAPI NO: 1 ŞİŞLİ / İSTANBUL” or through other methods specified in the LPPD.

In addition, I accept and declare that the personal data I have shared with the Company is accurate and up-to-date, and that I will notify the Company of any changes in this information.

I Accept that I have explicit consent for the processing of my relevant personal data, including my special categories of personal data as defined in the LPPD, for its use and sharing limited to the purpose of processing within the scope of the relevant process, and for its storage for the required period, and that I have been provided with the necessary clarification in this regard; and that I have read and understood this text, the Regulation on the Protection and Processing of Personal Data, and the Clarification Text.

CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

This clarification text on the processing of personal data (“Clarification Text”) has been prepared by ARSAVEV GAYRIMENKUL TEKNOLOJILERI A.Ş (“Company”), acting in the capacity of data controller, for the purpose of informing data subjects about their rights specified in Articles 10 and 11 of the Law on the Protection of Personal Data No. 6698 (“KVKK”) regarding processed personal data and special categories of personal data.

Article 10; During the collection of personal data, the data controller or the person authorized by it is obliged to provide information to the relevant persons regarding;

a) The identity of the data controller and its representative, if any,

b) The purpose for which personal data will be processed,

c) To whom and for what purpose the processed personal data can be transferred,

ç) The method and legal reason for collecting personal data,

d) Other rights listed in Article 11.

Article 11; Everyone has the right to apply to the data controller and, regarding themselves, to;

a) Learn whether personal data is processed,

b) Request information if personal data has been processed,

c) Learn the purpose of processing personal data and whether they are used in accordance with their purpose,

ç) Know the third parties to whom personal data are transferred domestically or abroad,

d) Request correction of personal data if they are processed incompletely or incorrectly,

e) Request the deletion or destruction of personal data within the framework of the conditions provided for in Article 7,

f) Request notification of the operations performed pursuant to subparagraphs (d) and (e) to third parties to whom personal data have been transferred,

g) Object to the occurrence of a result against the person themselves by analyzing the processed data exclusively through automated systems,

ğ) Demand compensation for damages in case of loss due to unlawful processing of personal data.

As used in this Clarification Text;

“personal data” refers to any information relating to an identified or identifiable natural person,

“processing of personal data” refers to any operation performed on data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying, or preventing the use of personal data by fully or partially automated means or by non-automated means provided that they are part of any data recording system,

In accordance with the Law on the Protection of Personal Data No. 6698, which entered into force after being published in the Official Gazette dated 07.04.2016; your personal data that you have shared (name, surname, contact number, e-mail addresses, date of birth, address information, shopping information and details, interests and likes, payment information, and location information accessible due to electronic programs) will be stored, recorded, and updated by the Company in accordance with the Law, and may be transferred to third parties such as companies with which there is a contractual relationship, relevant banks where payments are made via virtual POS, business partners of the Company, suppliers, social networking sites, and legally authorized public institutions and organizations in accordance with the form permitted by the legislation, and may be processed in the ways listed in the Law.

About the Data Controller

Your personal data and data falling within the scope of special categories of personal data may be processed by the Company for the scope and purposes specified in Article 2 of this Clarification Text within the scope of the KVKK. Within the scope of the KVKK, the Company is considered the data controller.

Purposes of Processing Your Personal Data

Your personal data and special categories of personal data may be processed for the following purposes:

To perform the transaction in question if you benefit from our products and services and to inform you about your transaction processes,

To inform you about our new products and services and to provide you with the most suitable product and service,

Your personal data that can identify you, such as your name, surname, telephone number, TR Identity number, date of birth, address information, residence information, your e-mail address, educational status, user/customer/contract number, institution and title information, tax number and office information, signature circular, your contract number, and your user ID assigned to you regarding your subscription,

Your personal data that can identify you, such as your place and date of birth, marital status, gender, identity information, profession information, and family information/number of children,

Your voice call recordings kept by customer representatives in accordance with call center standards and your personal data obtained when you contact us via e-mail, letter, or other means,

Recording of photographs, pictures, video images, or biometric data for profile descriptions,

Your traffic data such as system connection date and time information, system exit date and time information, source and destination point information, relevant location information, etc., regarding all kinds of access made in the internet environment,

Device, network, application, location, and usage information that mobile applications can collect from your device,

Execution of Customer Relationship Management Processes,

Conducting analysis for the purpose of developing our services,

Confirming your identity, preserving your identity copy and other information that must be kept as per the relevant legislation, checking the accuracy of the identity information and documents you have declared,

Responding to all kinds of questions and complaints regarding our products or services,

Taking all necessary technical and administrative measures within the scope of data security,

Preventing and detecting abuses in the use of our products and services,

Detecting, resolving, and trying to prevent the recurrence of malfunctions that may occur during service delivery,

Providing necessary information to regulatory and supervisory institutions and official authorities in line with their requests and audits,

Preserving information regarding your being a user/customer that must be kept as per the relevant legislation,

Ensuring financial reconciliation with relevant business partners and other third parties regarding the products and services we offer to you,

For the purposes of obtaining insurance support and issuing policies by us in the event that the customer decides to purchase a service or product,

Ensuring the control of the consistency of your information,

Conducting survey studies focused on measuring customer satisfaction and researching customer trends and increasing service quality, offering reward/lottery/competition/gift/thank you/celebration/reminder applications,

Execution of customer service operations,

Developing products, services, and business in conventional and digital media within the scope of network and technological progress/improvements for better service delivery,

Sharing information/documents requested by regulatory and supervisory institutions and official authorities, fulfilling legal obligations in the relevant legislation, and conducting audit activities,

Establishing brand collaborations touching different sectors within the scope of ensuring that customers benefit from various opportunities,

Fulfilling contract requirements regarding products and services offered together with our business partners or other third parties,

Execution of legal follow-up and legal processes, and similar purposes.

To Whom and For What Purpose the Processed Personal Data Can Be Transferred

Your personal data and special categories of personal data may be transferred to the Company's group companies if any, shareholders, managers, business partners, business partnerships related to the delivery or performance of the products and services you use, insurance companies, companies and business partners that enable working with insurance companies, companies operating to fulfill the services that can be provided to you, third parties from whom we receive consultancy including lawyers, tax consultants, and auditors, and public institutions and organizations in accordance with the conditions specified in Articles 8 and 9 of the KVKK, limited to the realization of the purposes specified in Article 2 of this Clarification Text, and your data may also be processed by these organizations to which the transfer is made.

Article 8; Personal data cannot be transferred without the explicit consent of the relevant person.

Personal data may be transferred without seeking the explicit consent of the relevant person in the event that one of the conditions specified in;

a) The second paragraph of Article 5,

b) The third paragraph of Article 6, provided that adequate measures are taken, is present.

Provisions in other laws regarding the transfer of personal data are reserved.

Transfer of personal data abroad

a) There is adequate protection,

b) In the absence of adequate protection, the data controllers in Turkey and in the relevant foreign country undertake adequate protection in writing and the permission of the Board is obtained.

Countries with adequate protection shall be determined and announced by the Board.

The Board shall decide whether there is adequate protection in the foreign country and whether permission will be granted pursuant to subparagraph (b) of the second paragraph by evaluating;

a) International conventions to which Turkey is a party,

b) The state of reciprocity regarding data transfer between the country requesting personal data and Turkey,

c) Regarding each concrete personal data transfer, the nature of the personal data and the purpose and duration of processing,

ç) The relevant legislation and practice of the country to which the personal data will be transferred,

d) The measures undertaken by the data controller in the country to which the personal data will be transferred, and by obtaining the opinion of relevant institutions and organizations if needed.

Provisions in other laws regarding the transfer of personal data abroad are reserved.

Method and Legal Reason for Collecting Personal Data

Your personal data and special categories of personal data are collected through our mobile applications, call centers, or via e-mail, SMS, WhatsApp, or other communication channels during the signing of commercial contracts during our business relationships and/or within the commercial relationship process and/or at your request and/or through information and documents you submit for the realization of the purposes specified in Article 2 of this Clarification Text through various channels such as our systems and forms while you visit our website or create a user membership, for the purpose of promoting products and services, organizing all records and documents that will be the basis for processing in electronic or paper environment, recognizing users who use the application via mobile applications, ensuring user security, preventing transactions that may involve fraudulent or illegal activities, being able to communicate, and providing information about campaigns and products, via all kinds of oral, written, visual, video-recorded, or electronic channels.

The legal reasons for collecting your personal data are as follows in accordance with Article 5 of the Law on the Protection of Personal Data:

The existence of your explicit consent regarding the collection of your personal data,

It is clearly provided for in the laws,

It is mandatory for the protection of your life or physical integrity or that of another person in the event that you are unable to express your consent due to actual impossibility or your consent is not legally valid,

It is necessary to process your personal data, provided that it is directly related to the establishment or performance of the contracts you will sign after recruitment interviews,

It is mandatory for the data controller to fulfill its legal obligation,

It has been made public by you,

Data processing is mandatory for the establishment, exercise, or protection of a right,

Data processing is mandatory for the legitimate interests of the Company, provided that it does not harm your fundamental rights and freedoms.

The legal reasons for collecting your special categories of personal data are as follows in accordance with Article 6 of the Law on the Protection of Personal Data:

The existence of your explicit consent regarding the collection of your special categories of personal data,

Cases provided for by law for the processing of your special categories of personal data other than health and sexual life,

Processing of your personal data relating to health and sexual life by persons under the obligation of secrecy or authorized institutions and organizations for the purposes of protecting public health, performing preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and their financing, without seeking your explicit consent.

Transfer of Your Personal Data:

Your Personal Data is collected and transferred based on the legal reasons of ensuring compliance with the legislation and Company policies for the purpose of carrying out Company activities. Your collected personal data may be transferred to companies acting on behalf and account of the Company, representatives, dealers, our direct or indirect business partners in Turkey and abroad, insurance companies, other companies that will provide insurance services, our suppliers, social networking sites, affiliates if any, lawyers, auditors, consultants and service provider firms, attorneys, guardians and representatives authorized by you, other operators (your invoice amount and payment information for electronic communication services may be shared for the purpose of managing the risk related to collection and preventing malicious use), asset management companies, municipalities, business partners and suppliers, credit institutions, financial institutions, banks and similar organizations, third parties from whom we receive consultancy including the legal unit, tax consultants and auditors, regulatory and supervisory institutions, official authorities, service providers and/or subcontractors and GSM Operators, legally authorized public institutions and organizations, and legally authorized private law natural and legal persons within the framework of the personal data processing conditions specified in Articles 8 and 9 of the Law on the Protection of Personal Data.

Your Rights Listed in Article 11 of the KVKK as a Personal Data Subject

Your rights under Article 11 of the KVKK are as follows;

Learn whether personal data is processed,

Request information if personal data has been processed,

Learn the purpose of processing personal data and whether they are used in accordance with their purpose,

Know the third parties to whom personal data are transferred domestically or abroad,

Request correction of personal data if they are processed incompletely or incorrectly and request notification of the operation performed in this context to third parties to whom personal data have been transferred,

Request the deletion or destruction of personal data in the event that the reasons requiring processing disappear, even though they have been processed in accordance with the KVKK and other relevant law provisions, and request notification of the operation performed in this context to third parties to whom personal data have been transferred,

Object to the occurrence of a result against the person themselves by analyzing the processed data exclusively through automated systems,

Demand compensation for damages in case of loss due to unlawful processing of personal data.

The Company reserves the right to update this Clarification Text on the Protection of Personal Data at any time within the framework of changes that may be made in the current legislation.

In accordance with the provision of Article 13, paragraph 1 of the KVKK, "The relevant person shall submit their requests regarding the implementation of this Law to the data controller in writing or by other methods to be determined by the Board," you may submit your request regarding the exercise of your rights stated above in writing to the Company's address at ESENTEPE MAH. TALAT PASA CAD. NO: 5 IC KAPI NO: 1 SISLI / İSTANBUL with the necessary information to identify your identity.

In accordance with Article 13, paragraph 2 of the KVKK, the Data Controller shall conclude the requests in the application free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Board may be charged. In accordance with Article 13, paragraph 3 of the KVKK, the Data Controller accepts the request or rejects it by explaining the reason and notifies the relevant person of its response in writing or electronically. In case the request in the application is accepted, the requirement shall be fulfilled by the data controller. If the application is due to the fault of the data controller, the fee collected shall be returned to the relevant person.

I accept, declare, and undertake that I have read and understood the matters stated above, and that I have been fully informed about my rights as a data subject within the scope of Article 10 of the KVKK, which states: “During the collection of personal data, the data controller or the person authorized by it is obliged to provide information to the relevant persons regarding; The identity of the data controller and its representative, if any, The purpose for which personal data will be processed, To whom and for what purpose the processed personal data can be transferred, The method and legal reason for collecting personal data, and other rights listed in Article 11.”