İHLAS GAYRİMENKUL PROJE GELİŞTİRME VE TİCARET ANONİM ŞİRKETİ
CLARIFICATION TEXT ON PROCESSING OF PERSONAL DATA
| Data Controller : | İhlas Gayrimenkul Proje Geliştirme ve Tic. A.Ş.
Merkez Mahallesi, 29 Ekim Caddesi, İhlas Plaza No:11 A/11 Yenibosna / Bahçelievler / İstanbul |
As İhlas Gayrimenkul Proje Geliştirme ve Tic. A.Ş. (the “Company”), we are extremely sensitive to the security of your personal data. With this awareness, we attach great importance to the processing and preservation of the personal data of our customers, consumers, and employees affiliated with our Company, including those who benefit from our products and services, in accordance with the Constitution of the Republic of Turkey, international human rights agreements to which our country is a party, and relevant legislation, particularly the Personal Data Protection Law No. 6698 (“KVKK”).
In this context, as the “Data Controller” as defined in the Personal Data Protection Law, we would like to inform you.
With full understanding of this responsibility, we process your personal data as explained below and within the limits stipulated by the legislation. Your personal data that you share with our company as a consumer, subscriber, customer, supplier or employee may be processed in accordance with the KVKK (Personal Data Protection Law), in connection with and proportionate to our activity and service objectives, and may be transferred to third parties at home and abroad, stored, used for profiling and classified.
- Collection, Processing, and Purposes of Processing of Personal Data: While your personal data may vary depending on the services provided by our Company and our Company’s commercial activities, it may be collected verbally, in writing, or electronically through automatic or non-automatic methods, through our Company’s units, website, social media channels, mobile applications, and similar means. Your personal data may be processed, created, and updated as long as you utilize the products and services offered by our Company and the İhlas Group Companies.
In addition, when you use our call centers or our website to use the services of the Company or İhlas Group Companies, when you visit our Company or our website, when you participate in training, seminars or organizations organized by our Company, your personal data may be processed.
Your collected personal data is used to:
- Provide you with the benefits of the products and services offered by our Company and İhlas Group Companies; understand your preferences, usage habits, and needs regarding the products and services offered, respond more quickly to your requests, improve our communication with you, and offer you better service and more personalized products, services, and offers. We also conduct analysis to do this; inform you about our products and services; measure your satisfaction with our products and services; and develop and diversify our products and services in line with your requests and needs.
- Ensure the legal and commercial security of our Company, İhlas Group Companies, and individuals who have business relationships with our Company (administrative operations related to communication conducted by our Company, ensuring the physical security and supervision of Company-owned locations, İhlas Group Company customer evaluation/complaint management processes, reputation research processes, event management, legal compliance processes, auditing, financial affairs, etc.);
- Determine and implement our Company’s commercial and business strategies;
- Ensure the implementation of our Company’s human resources policies; Our employees’ data are processed in accordance with the obligations stipulated by the Labor Law, labor and social security legislation and other legislation in force, as well as for the purposes of increasing the performance level and employee satisfaction and ensuring occupational safety and peace, as stated in the 5th and 6th articles of the Personal Data Protection Law clearly stated below;
ARTICLE 5 – Conditions for Processing Personal Data
(1) Personal data cannot be processed without the explicit consent of the data subject.
(2) Processing of personal data without the explicit consent of the data subject is possible if one of the following conditions is met:
- It is expressly provided for by law.
- It is necessary for the protection of the life or physical integrity of the data subject or another person who is unable to give consent due to a de facto impossibility, or whose consent is not legally valid.
- The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
- It is necessary for the data controller to fulfill its legal obligation.
- It is made public by the data subject.
- Data processing is necessary for the establishment, exercise, or protection of a right.
- Data processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
ARTICLE 6 – Conditions for Processing Sensitive Personal Data
(1) 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 unions, health, sexual life, criminal convictions, and security measures, as well as biometric and genetic data, constitute sensitive personal data.
(2) The processing of sensitive personal data is prohibited without the express consent of the data subject.
(3) Personal data, other than those related to health and sexual life as listed in the first paragraph, may be processed without the express consent of the data subject in cases prescribed by law. Personal data related to health and sexual life may only be processed without the express consent of the data subject by persons under a confidentiality obligation or by authorized institutions and organizations for the purposes of protecting public health, providing preventive medicine, medical diagnosis, treatment and care services, and planning and managing healthcare services and their financing.
(4) In the processing of sensitive personal data, adequate measures determined by the Board must also be taken.
Within the scope and within the conditions and purposes of processing personal data, personal data is processed;
- In a manner prescribed by law and the principle of good faith,
- In a limited and proportionate manner, in connection with the purposes of processing,
- Accurately and up-to-date,
- For specific, clear, and legitimate purposes.
- To Whom and For What Purposes Can Processed Personal Data Be Transferred?
Your collected and processed personal data may be shared within our subsidiaries and affiliates and İhlas Group companies for the purposes listed in Article 1 of this document, in accordance with the Personal Data Protection Law and applicable legislation, and may also be transferred domestically or internationally, including but not limited to, our business partners, business contacts, subcontractors, suppliers, company officials, and shareholders, in line with the purpose of the service we provide, or in cases stipulated by legislation regarding regulatory and supervisory institutions and official authorities, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law.
- Method and Legal Reason for Collecting Personal Data
Your personal data is collected verbally, in writing, or electronically, in accordance with the purposes outlined above, to ensure that the products and services we offer as the Company are provided within the legal framework and to enable our Company to fulfill its contractual and legal responsibilities fully and accurately.
Your personal data is collected verbally, in writing, or electronically by our Company or by natural or legal persons processing data on our Company’s behalf, including, but not limited to, through tools such as websites, various contracts, mobile applications, email, application forms, and written or verbal communications with our Company.
Your personal data collected for this purpose and legal reasons may also be processed and transferred for the purposes specified in Articles (1) and (2) of this text, in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law.
- Rights of the Personal Data Owner Listed in Article 11 of the Personal Data Protection Law
As personal data owners, if you submit your requests regarding your rights to our Company using the methods outlined below in this Information Notice, our Company will process your request free of charge within thirty days at the latest, depending on the nature of the request. However, if the Personal Data Protection Board stipulates a fee, the fee specified by our Company will be charged.
In this context, personal data owners have the right to:
- Learn whether their personal data has been processed or not,
- Request information regarding the processing of their personal data if their data is already processed,
- Learn the purpose of the processing and whether it is being used in accordance with its intended purpose,
- Know the third parties to whom personal data has been transferred, both domestically and internationally,
- Request rectification of incomplete or inaccurate personal data and notification of the action taken to the third parties to whom the personal data has been transferred,
- Request the deletion or destruction of personal data if the reasons requiring processing no longer exist, despite the data being processed in accordance with the provisions of the Personal Data Protection Law and other relevant laws, and request notification of the action taken to the third parties to whom the personal data has been transferred,
- Object to any detrimental consequences arising from the analysis of processed data exclusively through automated systems,
- Request compensation for damages suffered due to the unlawful processing of personal data.
Pursuant to Article 13, Paragraph 1 of the Personal Data Protection Law, you may submit your request to exercise your aforementioned rights to our Company in writing or, if the Personal Data Protection Board determines a separate method, in accordance with that method.
In this application, which includes your explanation of the right you wish to exercise and the rights you have as a personal data subject, we remind you that the matter you request must be clear and understandable, the matter you request must concern you personally, or if you are acting on behalf of someone else, you must be specifically authorized to do so and your authority must be documented, and the application must also include your identity and address information. Documents confirming your identity must be attached to the application.
In this context, the channels and procedures for submitting your written application to our Company under Article 11 of the Personal Data Protection Law are explained below.
To exercise your rights specified above, you can submit your request, which includes the necessary information to establish your identity and an explanation of the right you wish to exercise, as stipulated in Article 11 of the Personal Data Protection Law, by completing the form (“PERSONAL DATA OWNER APPLICATION FORM”) at www.ihlasgayrimenkul.com/ in accordance with the information provided at the beginning of the form. You can also personally deliver a signed copy of the form, along with documents confirming your identity, to
İhlas Gayrimenkul Proje Geliştirme ve Tic. A.Ş. Merkez Mahallesi, 29 Ekim Caddesi, İhlas Plaza No:11 A/11 Yenibosna / Bahçelievler / Istanbul
send it through a notary public, or send it via other methods specified in the Personal Data Protection Law, or forward the form to kvk.basvuru@ihlasgayrimenkul.com.
İHLAS GAYRİMENKUL POLICY OF PROTECTION AND PROCESS OF PERSONAL DATA