PRIVACY POLICY
FOREWORD
Within the scope of the Personal Data Protection Law, as REPORTAGE TURKEY GAYRİMENKUL GELİŞTİRME YATIRIM SATIŞ PAZARLAMA TİCARET ANONİM ŞİRKETİ (hereinafter referred to as 'REPORTAGE' or the 'Company'), we attach importance to the protection of your personal data and/or special category personal data. We show sensitivity regarding the storage of all your personal data and/or special category personal data transmitted to our Company through various channels. In this context, as REPORTAGE, we have taken the necessary technical and administrative measures in order to comply with the provisions of the T.R. Constitution and other legislation, primarily the Personal Data Protection Law No. 6698. We share with you our Privacy Policy, which has been put into effect within REPORTAGE, which is particularly important in terms of the protection of your personal data.
1. DEFINITIONS
Data Controller: Refers to REPORTAGE TURKEY GAYRİMENKUL GELİŞTİRME YATIRIM SATIŞ PAZARLAMA TİCARET ANONİM ŞİRKETİ, which determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. Data Owner-Relevant Person: Refers to the natural person whose personal data is processed. Company: Refers to REPORTAGE TURKEY GAYRİMENKUL GELİŞTİRME YATIRIM SATIŞ PAZARLAMA TİCARET ANONİM ŞİRKETİ in accordance with this policy. Law: Refers to the Personal Data Protection Law No. 6698. Personal Data: Refers to any information relating to an identified or identifiable natural person. Special Category Personal Data: Refers to data relating to race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dressing, membership of association, foundation or trade-union, health, sexual life, criminal conviction and security measures, and biometrics and genetics data. Board: Refers to the Personal Data Protection Board. Policy: Refers to this 'Privacy Policy'. Processing of Personal Data: Refers to any operation performed upon personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or provided that the process is a part of any data registry system, through non-automatic means. Explicit Consent: Refers to freely given, specific and informed consent. Destruction: Refers to making personal data inaccessible, irretrievable, and unusable by anyone in any way. Deletion: Refers to making personal data inaccessible and unusable for the relevant users in any way. Anonymization: Refers to rendering personal data impossible to link with an identified or identifiable natural person, even through matching them with other data. Disposal: Refers to the deletion, destruction, or anonymization of personal data. Data: Refers to personal data and special category personal data together.
2. PURPOSE OF THE PRIVACY POLICY
The protection of personal data and compliance with the law are our fundamental principles. In all the works we do as REPORTAGE, the personal data and/or special category personal data we have received from you have been kept confidential and have not been shared with third parties. In this context, our company has always shown the necessary sensitivity regarding the protection of personal data and/or special category personal data. Again, our internal company regulations have been remade in accordance with the Personal Data Protection Law No. 6698 (hereinafter referred to as the 'Law' or 'KVKK'); technical and administrative measures have been taken. In the ongoing process, as REPORTAGE, we accept, declare, and commit to complying with all obligations imposed by the law.
3. SCOPE OF THE PRIVACY POLICY
This Privacy Policy of ours has been prepared in accordance with the Personal Data Protection Law No. 6698. Your personal data and/or special category personal data are processed with your consent or within the scope of legal compliance situations. Your said data are used for the purposes of; Ensuring company security, Offering you complete service, Carrying out our commercial activities, Resolving your problems quickly, Increasing our quality. Some personal data and/or special category personal data coming from you are depersonalized and anonymized in the procedures stipulated by the Law. Data used for statistical purposes are not currently included in the regulation of the Law and the scope of our policy. We have the right to change this policy as REPORTAGE for the purpose of protecting personal data within the scope of compliance with the Law. The privacy policy aims to protect the data of real and legal persons with whom REPORTAGE has a solution partnership, its customers, its employees, and all other persons, obtained through any means. In this context, it contains various regulations to achieve the intended goal.
4. BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA AND/OR SPECIAL CATEGORY PERSONAL DATA
Our basic principles regarding the processing of personal data and/or special category personal data are as follows. In this context, these principles will be valid in the data processed by REPORTAGE based on explicit consent or within the scope of legal compliance situations. Lawfulness: REPORTAGE questions the source and lawfulness of the personal data and/or special category personal data coming to it from real and legal persons and collected by various means. In this context, obtaining data in accordance with the law is important for REPORTAGE. Compliance with the Rules of Honesty: REPORTAGE questions the source of the personal data and/or special category personal data coming to it from real and legal persons and collected by various means. In this context, obtaining data within the framework of honesty rules is important for REPORTAGE. Being Limited, Measured, and Related to the Purpose for which They are Processed: REPORTAGE uses the personal data and/or special category personal data it has obtained by various means in accordance with the purpose for which they are processed, limited to the purpose of processing, measuredly, and to the extent required by the performance of the service. Accuracy of Personal Data and/or Special Category Personal Data: REPORTAGE attaches importance to the fact that the personal data and/or special category personal data coming to it from real and legal persons and collected by various means do not contain incorrect information and are correct. However, REPORTAGE does not have to investigate the accuracy of the personal data and/or special category personal data declared by its customers or the real and legal persons it is in contact with. Because this matter is legally and in line with our working principles not possible. Being Up-to-Date When Necessary: REPORTAGE attaches importance to the notification of the said change to the company if there is a change in the personal data and/or special category personal data it has obtained in various ways, and to updating the data if notified. Processing for Specific and Legitimate Purposes: REPORTAGE processes personal data and/or special category personal data without obtaining explicit consent within the framework of the explicit consent given by the data owner or the exceptions stipulated by law. The processing purpose of each data is specific, and no personal data processing activity is carried out for any illegitimate purpose. Preserving for the Period Stipulated in the Law and/or Required for the Purpose for which They are Processed: REPORTAGE stores the personal data and/or special category personal data it obtains for the periods stipulated in the relevant laws and/or required for the purpose for which they are processed. When the said purposes end, it anonymizes, destroys, or deletes the data.
5. DELETION, DESTRUCTION, AND ANONYMIZATION OF PERSONAL DATA
Your personal data and/or special category personal data are deleted, destroyed, or anonymized with the expiration of the limitation and retention periods stipulated in the Law, the completion of judicial processes, or the termination of other requirements appropriate to the purpose. Deletion, destruction, and anonymization processes are carried out upon the request of the relevant data owner or ex officio (automatically) by REPORTAGE.
6. PRINCIPLE OF PARSIMONY
The principle of parsimony is also known as the principle of maximum savings. Personal data and/or special category personal data reaching through various channels are transferred to our company's system. In accordance with the said principle, data are processed into the system as much as necessary. The data to be collected by REPORTAGE are determined in accordance with the purpose and vary. In this context, data are collected in accordance with the purpose, and data that are not parallel to the purpose are not collected. Excess data outside its purpose are not recorded in the company system, deleted, destroyed, or anonymized. However, such data can be used for statistical purposes.
7. PRIVACY AND SECURITY OF DATA
As REPORTAGE, we attach importance to the confidentiality of your personal data and/or special category personal data. In this context, your personal data and/or special category personal data reaching our Company through any channel are confidential. REPORTAGE complies with the confidentiality of the said data at every stage of conducting its commercial activities. In this context, full compliance with this company privacy policy is ensured. Necessary technical and administrative measures are taken to prevent personal data and/or special category personal data collected through various channels from falling into the hands of unauthorized persons, to prevent damage to the rights of the data owner-not to be victimized, and to protect the data. Additionally, data protection is requested from third parties with whom we share personal data and/or special category personal data within the framework of legal compliance, when necessary. Again, our software programs are updated and continuously renewed. In order to provide high-level protection, technological requirements are met and compliance with standards is ensured.
8. UP-TO-DATENESS OF DATA
The principle of up-to-dateness is essential within REPORTAGE. Because personal data and/or special category personal data obtained in various ways can be updated when necessary or upon request. Necessary precautions regarding updating are also taken by REPORTAGE.
9. ACCURACY OF DATA
The principle of accuracy of the declared personal data and/or special category personal data has been adopted by REPORTAGE. REPORTAGE does not have to investigate the accuracy of the personal data and/or special category personal data declared by its customers or the real and legal persons it is in contact with. Because this matter is legally and in line with our working principles not possible. In this context, transactions are carried out on the premise that the declared data are correct.
10. PURPOSES OF PROCESSING PERSONAL DATA AND/OR SPECIAL CATEGORY PERSONAL DATA
The processing of personal data and/or special category personal data is carried out in parallel with the purposes in the Illumination Texts belonging to REPORTAGE. The said Illumination Texts may vary according to the processed personal data and/or special category personal data. Parallel to the difference in the Illumination Texts, the purposes of processing personal data and/or special category personal data may also vary.
11. COLLECTION AND PROCESSING OF PERSONAL DATA AND/OR SPECIAL CATEGORY PERSONAL DATA WITHIN A CONTRACTUAL RELATIONSHIP
If a contractual relationship has been established with customers or potential customers, the personal data collected pursuant to the contract may be processed by REPORTAGE without explicit consent. In case the processing of special category personal data is in question, data can be processed based on explicit consent or legal reasons within the scope of Article 6 of the Law. The said data are used within the framework of the performance of goods and/or services, the execution of the contract, and the conduct of commercial activities. These data can always be updated by contacting customers.
12. PERSONAL DATA AND/OR SPECIAL CATEGORY PERSONAL DATA PROCESSED THROUGH AUTOMATED SYSTEMS
Data acquired from information obtained through automated systems without the explicit consent of the persons cannot be used against the persons. REPORTAGE acts in accordance with the relevant legislative provisions regarding personal data and/or special category personal data processed through automated systems.
13. PERSONAL DATA AND/OR SPECIAL CATEGORY PERSONAL DATA BELONGING TO REPORTAGE'S EMPLOYEES
PROCESSING CONDUCTED WITHIN THE FRAMEWORK OF LEGAL OBLIGATIONS: Personal data belonging to employees can be processed by REPORTAGE without seeking explicit consent in order to fulfill the legal obligation of the data controller or if there is an explicit provision in the relevant Law regarding the processing of data. PROCESSING OF PERSONAL DATA PURSUANT TO THE EMPLOYMENT CONTRACT AND EMPLOYMENT RELATIONSHIP: The personal data of the employees can be processed without seeking the explicit consent of the employees within the framework of proportionality as much as necessary for ensuring the employment relationship of the employees with the company. REPORTAGE commits to protecting the data of the employees, their confidentiality, and taking the necessary measures in this regard under all circumstances. PROCESSING OF SPECIAL CATEGORY PERSONAL DATA BELONGING TO EMPLOYEES: According to the Personal Data Protection Law No. 6698, for the processing of special category personal data, the explicit consent of the person whose data will be processed and additionally taking the necessary measures stipulated by the Board is required. While processing special category personal data within the framework of compliance with Law No. 6698 and the principles of the Board, REPORTAGE obtains both the explicit consent of the relevant person and takes the necessary measures determined by the Board when necessary. However, special category personal data can be processed without the explicit consent of the relevant person in exceptional cases stipulated in the Law, provided that it is limited and measured. PERSONAL DATA PROCESSED THROUGH AUTOMATED SYSTEMS: Some personal data of employees can be processed in automated systems. The said data are used in the performance evaluation of employees, keeping statistical data, promotions for the company, and scoring. Employees have the right to object to the unfavorable results that arise regarding them. The objection must be made in accordance with internal company rules and procedures. The said objection is subjected to evaluation within the company. PROCESSING OF PERSONAL DATA FOR THE BENEFIT OF EMPLOYEES: Personal data belonging to employees can be processed by REPORTAGE without explicit consent within the framework of the relationship provided by the employment contract for transactions relating to the benefit of the employee. Again, in disputes concerning the employment relationship with REPORTAGE, the Company can process personal data belonging to employees. IN-COMPANY TELECOMMUNICATION, INTERNET, AND COMMUNICATION: In order to ensure the easier performance of the work, computer, phone, car, applications, software, and e-mail can be allocated to employees within the company by REPORTAGE. REPORTAGE can control and audit the personal data on the vehicles allocated within the scope of illumination obligations. The employee, on the other hand, cannot use the vehicles allocated to him/her for private purposes. It is obligatory to use it only to ensure the performance of the work. Again, the employee accepts, declares, and commits that he/she will not keep any data or information other than the work and the necessity of the work in the allocated vehicles from the moment the working relationship with REPORTAGE begins.
14. TRANSFER OF PERSONAL DATA AND/OR SPECIAL CATEGORY PERSONAL DATA DOMESTICALLY AND ABROAD
REPORTAGE can transfer data domestically and abroad in accordance with the conditions stipulated in the Personal Data Protection Law and within the framework of the principles determined by the Board, within the scope of legal compliance situations or with the explicit consent of the relevant person. REPORTAGE acts in accordance with Articles 8 and 9 of the Law No. 6698 while transferring personal data and/or special category personal data.
15. AUDIT AND TRANSACTION SECURITY
Necessary technical and administrative measures are taken to prevent personal data and/or special category personal data collected through various channels from falling into the hands of unauthorized persons, to prevent damage to the rights of the data owner-not to be victimized, and to protect the data. Additionally, data protection is requested from companies with which we share personal data and/or special category personal data within the framework of legal compliance, when necessary. Again, our software programs are updated, continuously renewed, and developed. In order to provide high-level protection, all technological requirements are met, and compliance with standards is ensured. Parallel to all these, REPORTAGE has all necessary internal and external audits conducted for the protection of personal data and/or special category personal data.
16. NOTIFICATION OF DATA BREACHES
In case of any breach situation regarding the data, REPORTAGE acts immediately to do its part to remedy the breaches reported to it. It takes the necessary measures to minimize the damage of the relevant person. You can apply according to the procedures specified on our company's website for the notification of breaches. In addition, in the event that personal data and/or special category personal data are obtained by unauthorized third parties from outside, the company notifies the Personal Data Protection Board directly of the said matter.
17. RIGHTS OF the DATA OWNER RELEVANT PERSON REQUESTING INFORMATION
The rights of the data owner are ruled in Article 11 of the Personal Data Protection Law No. 6698. REPORTAGE accepts that in accordance with the law, the relevant person must be illuminated before data processing and, when necessary, their explicit consent must be obtained, and after the data is processed, the relevant person has the right to request information about their data, update, delete, destroy, and anonymize. The relevant persons have the following rights; Learning whether personal data is processed or not, Requesting information if personal data has been processed, Learning the purpose of processing personal data and whether they are used in accordance with their purpose, Knowing the third parties to whom personal data is transferred domestically or abroad, Requesting correction of personal data in case of incomplete or incorrect processing, Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the law titled 'Deletion, destruction or anonymization of personal data', Requesting notification of the third parties to whom personal data has been transferred regarding the correction of incomplete or incorrectly processed data or the deletion or destruction of the data upon the request of the relevant person, Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems, Requesting the compensation of the damage in case of suffering damage due to unlawful processing of personal data. Information requests made on behalf of someone else will not be answered by the company. If it is determined by REPORTAGE that an application is made on behalf of someone else in the information request; all rights of litigation and claim of REPORTAGE are reserved. It will be answered as soon as possible and within thirty days at the latest from the date the relevant person reaches REPORTAGE. If REPORTAGE deems it necessary, it may request other information and documents from the relevant person making the application.
REPORTAGE TURKEY GAYRİMENKUL GELİŞTİRME YATIRIM SATIŞ PAZARLAMA TİCARET ANONİM ŞİRKETİ