PRIVACY POLICY

INFORMATION NOTICE WITHIN THE SCOPE OF LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

INFORMATION NOTICE

In accordance with the Law No. 6698 on the Protection of Personal Data (hereinafter referred to as the “KVKK” or the “Law”), the processing and safeguarding of personal data and/or sensitive personal data is of great importance. Therefore, as REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE INC. (hereinafter referred to as “REPORTAGE” or the “Company”), we act in compliance with the KVKK regarding the protection, storage, and processing of your personal data and/or sensitive personal data.

We frequently collect data from you through online platforms. The personal data and/or sensitive personal data collected and recorded during visits to our website are processed in accordance with the Law on the Protection of Personal Data. In this context, REPORTAGE, acting as the data controller, collects and stores your data within the legal limits.

Additionally, we would like to state that all personal data and/or sensitive personal data collected during visits to our website are protected within the scope of our Privacy Policy. You may review our Privacy Policy and KVKK Information Notice available on our website at www.reportage.com.tr.

This information notice has been prepared by REPORTAGE in its capacity as data controller within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform.

1. WHAT IS PERSONAL DATA?

Personal data is defined in the Law No. 6698 on the Protection of Personal Data as “any information relating to an identified or identifiable natural person.” As understood from this definition, any information that makes you identifiable constitutes personal data.

In addition, data relating to political opinions, sect, race, religion, membership of associations or foundations, health data, philosophical beliefs, religious beliefs, sexual orientation, criminal records, criminal convictions, and biometric data are considered sensitive personal data.

2. LEGAL BASIS

Law No. 6698 on the Protection of Personal Data requires that individuals whose personal data are processed must be informed prior to such processing. This obligation, referred to as the “Obligation to Inform,” is regulated under Article 10 of the Law.

According to Article 10, the data controller or the person authorized by the data controller must inform the relevant persons about:

The identity of the data controller and its representative, if any,
The purpose of processing personal data,
The recipients to whom personal data may be transferred and the purposes of such transfer,
The method and legal basis of data collection,
The rights of the data subject listed in Article 11.

Under Article 3 of the Law, the data controller is defined as the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

In this context, the data controller is REPORTAGE, whose details are provided below.

Data Controller: REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE INC.

Address: Mah. Sümer St. No: 4 Maslak Office Building (MOB) Ground Floor No: 3 Sarıyer, Istanbul, Türkiye

Phone: +90 444 4 515

Email: info@reportage.com.tr

3. SCOPE OF REPORTAGE’S OBLIGATION TO INFORM

Within the scope of this Information Notice, REPORTAGE informs data subjects about who processes personal data, for what purposes, to whom and for what purposes such data may be transferred, the method and legal basis of data collection, and the rights of data subjects regarding the protection of their personal data.

4. PURPOSES OF PROCESSING YOUR PERSONAL DATA BY REPORTAGE

Your personal data are processed within the limits prescribed by Law No. 6698 and in accordance with the principles of the Law. The purposes of data processing by REPORTAGE include:

Ensuring that you benefit from our website in the most efficient manner,
Informing you promptly about innovations, products, and services offered by REPORTAGE,
Conducting commercial activities and fulfilling our obligations completely,
Informing you about our updated products and services,
Contacting you regarding your requests or complaints and resolving issues efficiently,
Developing commercial partnerships and strategies,
Strengthening corporate identity and internal operations,
Ensuring compliance with the Privacy Policy published on www.reportage.com.tr,
Managing financial processes such as offers and payments,
Carrying out accounting and finance activities before and after sales,
Managing current account processes,
Conducting marketing activities and increasing brand awareness,
Ensuring information security,
Managing cargo and shipment processes,
Executing legal processes related to company projects.

Your personal data may be stored both digitally and physically within REPORTAGE’s information systems and physical archives.

REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE INC.

INFORMATION REQUEST FORM

PURSUANT TO THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

1. GENERAL INFORMATION

You may submit your requests regarding your rights arising from Article 11 of the Law No. 6698 on the Protection of Personal Data through this form to REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE JOINT STOCK COMPANY (“REPORTAGE”). Your requests will be responded to as soon as possible and no later than thirty (30) days from the date they are received by REPORTAGE. The response to your information request will be delivered to you in written or electronic form via the communication channels you select below.

All information must be completed in full and accurately at the time of application. Otherwise, your information request may not be fulfilled by REPORTAGE. REPORTAGE shall not accept any responsibility in the event that the information provided is incorrect or incomplete and therefore the request cannot be answered.

Data Controller: REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE JOINT STOCK COMPANY

Address: Mah. Sümer St. No: 4 Maslak Office Building (MOB) Ground Floor No: 3 Sarıyer, Istanbul, Türkiye

Tel: +90 444 4 515

Email: info@reportage.com.tr

2. INFORMATION REGARDING THE DATA SUBJECT MAKING THE REQUEST

Name:
Surname:
Turkish ID Number / Nationality and Passport Number:
Phone and Fax Number:
Email:
Residential or Business Address:
Relationship with our Company: Customer □ / Business Partner □ / Visitor □ / Other □

3. SUBJECT OF THE REQUEST (If applicable, please attach any relevant information and documents.)

...............................................................................................................

4. DECLARATION OF THE DATA SUBJECT

I hereby request the evaluation of my application and the provision of a response in line with the requests explained above. I declare and undertake that the information I have provided during my application is accurate, up to date, and belongs to me personally. I consent to the processing of my personal data and/or special categories of personal data shared for the purpose of my request by REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE JOINT STOCK COMPANY, limited to and in connection with the purpose of this request.

☐ I would like to receive the response to my application in person. (No information regarding the application shall be shared with anyone other than the applicant.)
☐ I would like the response to my application to be sent to my email address specified in this Application Form.
☐ I would like the response to my application to be sent to my address specified in this Application Form. (Please tick the selected option.)

Name and Surname of the Applicant:

Application Date:

Signature:

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Information Notice Regarding Communication and Application Channels

This Information Notice has been prepared by REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE INC., acting as the data controller and service provider, within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, in order to inform you about the processing of your personal data and to provide information within the scope of the Law on the Regulation of Electronic Commerce.

The details of the data controller, REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE INC. (hereinafter referred to as “REPORTAGE” or the “Company”), are as follows:

Data Controller: REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE INC.

Address: Mah. Sümer St. No: 4 Maslak Office Building (MOB) Ground Floor No: 3 Sarıyer, Istanbul, Türkiye

Phone: +90 444 4 515

Email: info@reportage.com.tr

Regarding the Processing of Your Personal Data;

Your personal data that you provide to us through our communication channels such as our website, call center, and corporate email account are processed for the purposes of carrying out communication activities, managing and responding to requests and complaints, and managing emergency processes.

Such personal data are processed automatically based on the legal grounds stipulated under Article 5 of the Law No. 6698, namely that processing is mandatory for the data controller to fulfill its legal obligations and necessary for the establishment, exercise, or protection of a right. The personal data you provide are evaluated solely within our Company and are not transferred to third parties.

If deemed necessary by our Company, we may contact you to verify the accuracy of your personal data and request additional information. All such processes are carried out in compliance with the Law No. 6698 on the Protection of Personal Data, our Privacy Policy, and other applicable legislation.

As a data subject, you may apply to REPORTAGE to exercise the rights set forth in Article 11 of the Law No. 6698 on the Protection of Personal Data, including:

Learning whether your personal data are processed,
Requesting information if your personal data have been processed,
Learning the purpose of processing personal data and whether they are used in accordance with such purpose,
Knowing the third parties to whom personal data are transferred domestically or abroad,
Requesting correction of incomplete or inaccurate personal data,
Requesting deletion or destruction of personal data within the conditions stipulated under Article 7 of the Law,
Requesting notification of correction, deletion, or destruction to third parties to whom personal data are transferred,
Objecting to a result against you arising from the analysis of data exclusively through automated systems,
Requesting compensation for damages in case of unlawful processing of personal data.

You may exercise the above-mentioned rights.

You may submit your requests regarding the above rights to REPORTAGE in accordance with the procedures and principles set forth in the Communiqué on the Procedures and Principles of Application to the Data Controller. Applications must be submitted personally. We would like to emphasize that applications cannot be made to request information regarding the personal data of another person.

REPORTAGE will finalize your information requests free of charge as soon as possible and no later than thirty (30) days. To exercise your rights regarding personal data, you may access the relevant information via https://reportage.com.tr/ and use the “Information Request Form Pursuant to the Law No. 6698 on the Protection of Personal Data” available on our website.

Regarding the Sending of Electronic Commercial Messages to You;

This Information Notice has been prepared to inform you, in accordance with the Law No. 6563 on the Regulation of Electronic Commerce, the Regulation on Commercial Communication and Commercial Electronic Messages, and other relevant legislation, about the sending of commercial electronic messages and other communications for purposes such as announcing general/special opportunities related to the products and services offered by REPORTAGE, keeping you informed of current developments, sending congratulatory messages, delivering content such as presentations and newsletters, and carrying out promotional and advertising activities.

In this context, if you give consent to receive electronic commercial messages, you are hereby informed that messages related to sales, advertising, campaigns, and promotions regarding goods or services may be sent to you via your preferred communication channels; that you may change your communication preferences at any time; and that you may unsubscribe free of charge without providing any justification by following the instructions included in the messages sent to you. Commercial electronic messages and other communications will be sent to you via email/mail channels in accordance with applicable legislation.

You hereby acknowledge and declare that you have read and understood the above Information Notice regarding the commercial electronic messages to be sent to you. Accordingly, if you provide your explicit consent with full knowledge and without any doubt for the sending of commercial electronic messages through your preferred channels, REPORTAGE may send electronic commercial messages to you.

REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE INC.

PRIVACY POLICY

PREAMBLE

Within the scope of the Law on the Protection of Personal Data, REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE JOINT STOCK COMPANY (hereinafter referred to as “REPORTAGE” or the “Company”) attaches great importance to the protection of your personal data and/or sensitive personal data. We show due care in storing all personal data and/or sensitive personal data belonging to you that are transmitted to our Company through various means. Accordingly, REPORTAGE has taken the necessary technical and administrative measures to comply primarily with Law No. 6698 on the Protection of Personal Data, the Constitution of the Republic of Türkiye, and other relevant legislation. We hereby share with you our Privacy Policy, which has been implemented within REPORTAGE and is of particular importance for the protection of personal data.

1. DEFINITIONS

Data Controller: Refers to REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE JOINT STOCK COMPANY, which determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

Data Subject / Relevant Person: Refers to the natural person whose personal data is processed.

Company: Refers to REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE JOINT STOCK COMPANY within the scope of this Policy.

Law: Refers to the Law No. 6698 on the Protection of Personal Data.

Personal Data: Refers to any information relating to an identified or identifiable natural person.

Sensitive Personal Data: Refers to personal data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.

Board: Refers to the Personal Data Protection Board.

Policy: Refers to this “Privacy Policy”.

Processing of Personal Data: Refers to any operation performed on personal data such as collection, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, acquisition, making available, classification or prevention of use, whether fully or partially automated or non-automated as part of a data recording system.

Explicit Consent: Refers to consent that is freely given, based on information, and related to a specific subject.

Destruction: Refers to rendering personal data inaccessible, irretrievable, and unusable by anyone in any manner.

Deletion: Refers to rendering personal data inaccessible and unusable for relevant users.

Anonymization: Refers to rendering personal data impossible to associate with an identified or identifiable natural person, even if matched with other data.

Disposal: Refers to deletion, destruction, or anonymization of personal data.

Data: Refers collectively to personal data and sensitive personal data.

2. PURPOSE OF THE PRIVACY POLICY

The protection of personal data and compliance with the Law constitute our fundamental principle. As REPORTAGE, all personal data and/or sensitive personal data obtained from you in the course of our activities are kept confidential and are not shared with third parties. In this context, our Company has always shown due care in protecting personal data and/or sensitive personal data. In accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”), internal regulations have been revised and necessary technical and administrative measures have been taken. REPORTAGE hereby accepts, declares, and undertakes to comply with all obligations imposed by the Law.

3. SCOPE OF THE PRIVACY POLICY

This Privacy Policy has been prepared in accordance with Law No. 6698. Your personal data and/or sensitive personal data are processed based on your explicit consent or within the scope of lawful processing conditions. Such data are used for the following purposes:

Ensuring company security,
Providing you with complete services,
Conducting our commercial activities,
Resolving your issues promptly,
Improving service quality.

Certain personal data and/or sensitive personal data may be anonymized in accordance with the procedures stipulated by the Law. Data used solely for statistical purposes fall outside the scope of this Policy. REPORTAGE reserves the right to amend this Policy to ensure compliance with the Law.

4. FUNDAMENTAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA

REPORTAGE processes personal data in accordance with the following principles:

Lawfulness: Personal data must be obtained and processed in compliance with the law.

Fairness: Data must be processed in accordance with the principles of honesty and transparency.

Purpose Limitation and Proportionality: Data must be processed only for specific, explicit, and legitimate purposes and be limited to what is necessary.

Accuracy: Data must be accurate and up to date where necessary.

Storage Limitation: Data must be retained only for the period required by relevant legislation or for the purpose for which it was processed.

5. DELETION, DESTRUCTION, AND ANONYMIZATION OF PERSONAL DATA

Personal data and/or sensitive personal data are deleted, destroyed, or anonymized upon the expiration of statutory retention periods, completion of legal processes, or cessation of processing purposes, either upon request of the data subject or ex officio by REPORTAGE.

6. DATA MINIMIZATION PRINCIPLE

Only data that are necessary for the intended purpose are processed. Excess data unrelated to the purpose are not recorded and are deleted, destroyed, or anonymized if collected.

7. CONFIDENTIALITY AND SECURITY OF DATA

REPORTAGE attaches great importance to the confidentiality and security of personal data and takes all necessary technical and administrative measures to prevent unauthorized access.

8. RIGHTS OF DATA SUBJECTS

Pursuant to Article 11 of Law No. 6698, data subjects have the right to:

Learn whether their personal data are processed,
Request information if their personal data have been processed,
Learn the purpose of processing and whether data are used in accordance with that purpose,
Know the third parties to whom personal data are transferred domestically or abroad,
Request correction of incomplete or inaccurate data,
Request deletion or destruction of personal data,
Request notification of such actions to third parties,
Object to adverse outcomes resulting from automated processing,
Claim compensation for damages arising from unlawful processing.

REPORTAGE TURKEY REAL ESTATE DEVELOPMENT INVESTMENT SALES MARKETING TRADE JOINT STOCK COMPANY