Privacy Policy and Protection of Personal Data
Data and Privacy Policy
- PURPOSE
Turkish Personal Data Protection Law (shortly ” KVKK Law “) was published in the Official Gazette dated 7 April 2016 . This Law aims to protect the rights and freedoms of individuals and their privacy and to impose obligations on them. It is a wrong move in Turkey.
The aim is to establish a data security and storage policy in accordance with the Personal Data Protection Law. Investist creates and controls this policy for the protection and storage of personal data.
- SCOPE
The scope of this policy covers Investist team as well as investist.com.tr visitors. İnvestist is a registered trademark of İnvestist Gayrimenkul Anonim Şirketi, a real estate company. investist.com.tr is owned by İnvestist Gayrimenkul AŞ. The policy is used in all activities created and carried out by İnvestist Gayrimenkul AŞ.
This policy has been prepared in accordance with the KVKK Law and must be accepted by all employees of Investist.
Investist wants all its customers, visitors and employees to learn this policy and act accordingly. The company provides accurate information about this policy and provides relevant materials to its employees.
- DICTIONARY OF TERMS
3.1. investist
İnvestist is the brand of the real estate company whose legal name is İnvestist Gayrimenkul Anonim Şirketi.
3.2. Explicit Consent
Limited consent is given for the processing of data. It is based on free will and is presented for informational purposes.
3.3. Anonymization
Making personal data unable to be associated with an identified or identifiable natural person, even if it is matched with other data.
3.4. Employees
Investist team.
3.5. Service provider
Personnel of the third party company from which Investist receives services.
3.6. Individual / Customer / Visitor
Person whose personal information is kept and processed by Investist.
3.7. Personal Information / Personal Data
Information about individuals/customers/visitors enables their identification. In this case, email address and phone number.
3.8. Processing of Personal Data
Processes of collecting, changing, storing, recording, editing or disclosing personal information in whole or in part automatically.
3.9. Data control
People who decide what personal information Investist keeps and how it is kept and used.
3.10. data processor
Natural or legal persons who process data under the authority of the Data Controller.
3.11. KVKK Board
Personal Data Protection Board. (KVKK is simply Personal Data Protection in Turkish)
3.12. KVKK Company
Personal Data Protection Authority
3.13. KVKK Law
Official Gazette No. 29677 .
3.14. Policy
Investist Personal Data Protection and Processing Policy
- ROLES AND RESPONSIBILITIES
4.1. Data control
Processing of Personal Data refers to the automatic collection, modification, storage, recording, editing or disclosure of personal information in whole or in part within the framework of the provisions of the Turkish Personal Data Protection Law.
Investist must collect and use certain types of information about visitors or customers to operate our operations. Investist 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
Once the Data Controllers Registry is established, a Data Controller Representative will be required. This representative must be an expert in keeping data private, processing it and taking the necessary security steps.
4.3. data processor
Data processors are natural or legal entities that process Personal Data. The processor must be operating under Investist’s authority.
4.4. Responsibilities
If the data is processed by real or legal persons, the Investor and Data Processors are obliged to take the necessary measures. Investist, as Data Controllers, oversees the trust process between the two parties; Investors and individuals.
- LEGAL OBLIGATIONS
Investist has legal obligations regarding the security and processing of Personal Data in accordance with the KVKK Law. Obligations;
5.1. Disclosure Obligation
Investist is obliged to inform its visitors and customers about the following elements during Data Processing;
- Identity of the Data Controller,
• Reasons for storing Personal Data, • Legal reasons for storing Personal Data, • Rights of individuals.
5.2. Lighting Obligation
Investist is obliged to inform people in accordance with Article 13 of the KVKK Law. Requests for information should also be made via investist.com.tr@gmail.com or +90(850) 309 06 70 .
These special requests must be written by these persons manually or in any medium determined by the KVKK Board.
5.3. Obligation to Ensure Personal Data Security
As Data Controllers, Investist is obliged to provide the necessary security services in accordance with Article 12 of the KVKK Law.
5.4. Obligation to Register in the Data Controllers Registry
Investist 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
A person’s name, surname, date and place of birth, identity, social security number, telephone number, e-mail address, address, image, payment information and other similar information are considered Personal Data.
Due to membership terms, İnvestist stores some of this Data such as name, surname, telephone number and e-mail address.
6.2. Private Personal Data
An individual’s race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, equipment, membership of any foundation or organization, health problems, sexual life, convictions, security measures, biometric and genetic data are considered Personal Personal Data. . Data. It is strictly prohibited to store such Data without the consent of the person, in accordance with Article 6 of the Turkish Personal Data Protection Law.
As a Data Controller, Investist will never request such Specific Personal Data unless otherwise provided by legal statutes.
- PERSONAL DATA PROCESSING POLICY
7.1. Data Processing Principles
All collected data must be processed in accordance with Article 4 and Articles 5 and 6 of the KVKK Law.
- Investist must process the data in accordance with the KVKK Law and other legal regulations.
• Investor must be transparent, fulfill its disclosure obligations and provide information in accordance with the rules of honesty.
• Investist must process data only for justified reasons. The reasons must be legal and specified in the KVKK Law or other legal regulations.
• The data must be relevant to its purpose and limited to that purpose. • The Investor must process the data at the required scale. The proportionality rule should be followed and only the necessary part of the data should be processed.
• The investor should only store data for the required period (See section 9) and should not store data if the required period has passed anonymously.
7.2. Purposes of Data Processing
Investist does not collect or store any personal information from any customer to send unsolicited and unsolicited information (spam). Investist aims to process data for certain purposes as follows:
- Personal and contact data such as name, surname, telephone number, e-mail address are processed for site registration and better quality communication.
• Demographic site or app browsing data is processed to analyze and collect user interests. 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 sites such as Facebook, Twitter, Linkedin, Google Plus can only be used to register to the İnvestist site.
• Location data is used if the user allows it from their mobile phone while browsing. Investist processes location data to recommend properties and show the nearest offices by location.
In addition to the previously mentioned purposes, the data is also processed for other purposes;
- Investist sends real estate and hot offers in the form of a newsletter via e-mail addresses.
• Investist deals with each customer individually by answering all questions and needs provided by contact data.
• Investist provides information about new services.
• Investist does direct marketing.
• Investist can communicate directly with people when necessary.
7.3. Ensuring the Processing of Data for Legal Reasons
Investist takes the following technical measures to process personal data in accordance with the law;
- Organizing an intercompany organization 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 stored, • Supervising the created technical infrastructure and process, • Determining the necessary procedures for reporting, technical procedures and inspection periods.
Investist takes the following legal measures to process personal data in accordance with the law;
- To train and inform Investist employees about the lawful processing of personal data,
• To include measures against unlawful processing of personal data in contracts, legal files and policies, • To supervise the processing of personal data by third parties, party processors and partners.
- PERSONAL DATA TRANSFER POLICY
8.1. Transfer of Personal Data Within the Country
Investist is obliged to act in accordance with the KVKK Law and the regulations determined by the KVKK Board.
Investist, as Data Controllers, is obliged to comply with the KVKK Law. Investist never shares any personal data or information with third party companies without the individual’s consent.
However, in case of obligations arising from the KVKK Law and other Constitutional Laws, Investist may transfer the data to the relevant judicial, official or legal institutions.
8.2. Transfer of Personal Data Abroad
Investist may also transfer data abroad for processing and preservation. The country that will receive Personal Data must have taken the necessary security measures. Measures must be checked by the KVKK Board. If the necessary measures are not sufficient , the Data Controllers in both Turkey and the recipient country must make a written commitment and the KVKK Board must approve it.
8.3. Which Person/Organization Receives Personal Data?
Authorities and institutions and organizations: Public legal entities, 8.1. They may receive the Data as they wish in accordance with the article.
İnvestist’s customer program, İnvestist Gayrimenkul A.Ş., 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, receive Personal Data from cookies to facilitate your browsing experience.
8.4. Precautions Regarding the Transfer of Personal Data
Technical Measures
- Investist is obliged to take the necessary technical precautions against unauthorized access and use of Personal Data by any data processing person or company, even if it is authorized by Investist.
Administrator Measures
- Investist has established internal policies regarding how and for what purpose data should be transferred. Investist also determines to whom the data should be transferred.
- PERSONAL DATA STORAGE POLICY
9.1. Storing Data for a Specific Period of Time
According to the KVKK Law, all information regarding real persons known or available is personal data. All information such as e-mail addresses and phone numbers are recorded and securely protected by Investist.
In this context, Investist is obliged to act in accordance with the law when obtaining and storing data. The data will be stored until the preservation purpose (see 7.2) is fulfilled. According to government obligations, data must be stored for an average of 2 years.
This period varies from law to law. For example, according to the Tax Procedure Law, registration and identity information must be kept for 5 years.
9.2. Precautions Regarding the Processing of Personal Data
Technical Measures
- Investist takes precautions to keep personal data safe and secure. The systems and control mechanisms needed as technical measures are created.
Administrator Measures
- Investist also creates awareness and training among its employees regarding the storage of Personal Data.
• Investist is obliged to supervise these measures for the protection of personal data.
- SECURITY POLICY OF PERSONAL DATA
10.1. Investist’s Responsibilities Regarding the Security of Data
Investist is obliged to keep Personal Data secure in accordance with Article 12 of the Personal Data Protection Law. Investist;
- To prevent the unlawful processing of Personal Data,
• To regularly monitor the measures taken, • To provide sufficient technical equipment to stop the leakage of Personal Data, • To inform the competent authorities in cases of leakage.
10.2. Measures to Keep Personal Data Safe
Investist takes the necessary precautions when there is a security risk in order to keep Personal Data safe and secure. These measures are as follows;
Technical and Administrative Measures
Technical and executive measures regarding the processing, transfer and security of Personal Data are specified in the relevant articles. If Personal Data continues to be processed and accessed by third parties unlawfully, Investist is legally obliged to take the necessary measures to protect individuals.
Precautions and Audit for the Security of Personal Data
Investist prepares a report on the data logger’s compliance with the KVKK Law. The recording device is inspected periodically and the report is presented to the authorized person or board.
Precautions to be Taken in Case of Unauthorized Disclosure
Investist is obliged to prevent all information activities, take necessary precautions and establish an internal policy. In case of any unauthorized disclosure, Investist is obliged to inform the disclosed person and the KVKK Board.
- RIGHTS OF PERSONS
11.1. Right to Access Their Own Personal Data
Individuals, customers and visitors have the right to access their personal data without making any payment. Individuals;
- Learning whether their data has been processed,
• Requesting information if their data has been processed, • Inquiring about the purpose of processing and learning whether their Personal Data is used for its intended purpose.
11.2. Right to Change or Delete Own Personal Data
Individuals, customers and visitors can change or delete their personal data without making any payment. Individuals;
- Requesting correction of incorrect or incomplete information in the data
, • Requesting deletion if the purpose of storage is no longer possible, • Requesting that these transactions be notified to third party processors, • Objecting to the data. Unfavorable result arising from the analysis of the processed Data by automatic systems.
11.3. Updating Your Own Personal Data
You may contact us if you request access, change or deletion of your own Personal Data;
By phone: +90(850) 309 06 70
by e-mail: investist.com.tr@gmail.com
Personal conversation or by letter: Mecidiyeköy Yolu Caddesi No:12 Trump Towers Kat:4 34381 Şişli/İSTANBUL
11.4. Application and Evaluation of Individuals
Individuals may request access to their processed data and exercise of the rights specified in this Policy. Investist creates these communication opportunities. All applications are answered in a short time, not exceeding the period stipulated by the KVKK Law.
These persons should consult the representatives, which will be clarified by Investist and announced by the Data Controllers Registry. The Data Controller Representative will finalize these applications within a short period of time, not exceeding 30 days, with a fee or payment to be determined by the KVKK Board.
In order for this process to begin, individuals must submit their applications to the Data Controller Representative determined by the KVKK Board. Applications must be written as letters until another method is determined by the Board. The person must clearly state his application and send his official letter by registered mail;
Mecidiyeköy Yolu Caddesi No:12 Trump Towers Floor:4 34381 Şişli/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 fulfilled by Investist. If the error belongs to Investist, the payment is returned to the individuals.
a complaint letter within 30 days if it is answered within 60 days .
- COOKIE POLICY
The Cookie Policy applies to mobile/websites and applications operated by Investist.
Investist uses cookies to enrich the experience of its visitors and provide them with a better web and mobile service. Visitors can always block Cookies through their browser settings. However, blocking or limiting Cookie processing may affect the smooth experience of visitors.
Visitors are considered accepted Cookies unless they block or limit Cookies.
- PUBLISHING AND STORAGE OF THE POLICY
The most current version of the Privacy Policy will govern the collection, use and disclosure of information about you and will be located 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. By continuing to access or use the Service after those changes become effective, you accept the revised Privacy Policy.
- POLICY UPDATE PERIOD
We may update the Privacy Policy to reflect changes in our information practices. If we make any changes, we will post a notice on the Investist website and notify you by email (sent to the email address specified in your account). Changes will take effect after the last update date.
Last Updated April 24, 2024. This Privacy Policy is effective immediately for users who visit the Investist website on or after April 24, 2024.
- VALIDITY
This policy will be valid from the moment it is published until it is removed from the mobile or website.
- SECURITY
We have implemented technical and organizational security measures to prevent your personal data from accidental loss, use or unauthorized access, alteration or disclosure. However, no method of transmission or method of electronic storage via the Internet or mobile device is 100% secure. Investist expressly denies any such obligation.
- INTERNATIONAL DATA TRANSFER
For residents of the EEA or Switzerland, please note that personal data information we obtain from or about you may be transferred, processed and stored outside the EEA or Switzerland for the purposes described in this Privacy Policy, including in the United States. America. We take the privacy of our users seriously and therefore take steps to protect your information, including ensuring an adequate level of data protection in accordance 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 personal information they process from the EEA in accordance with European Union data protection laws.
* This document was updated on April 24, 2024.