Turkish Government set up the law to protect the rights of individuals, privacy of their personal life and the commitments against any illegitimate use of personal data under the Law on the Protection of Personal Data (shortly “KVKK Law”), published on 7th April 2016.
The purpose is to create a policy of data safeguard and storage by the Law on the Protection of Personal Data. BODRUM WHITE Real Estate is preserving the personal data accordingly to this law
The policy implies to visitors of bodrumwhite.com as well as to BODRUM WHITE Real Estate team. The policy has an impact on all activities created and carried out by BODRUM WHITE Real Estate.
Our policy is formulated in accordance to KVKK Law and all employees of BODRUM WHITE Real Estate as well as visitors, customers are obliged to apply this policy. Employees are also getting a proper information and necessary materials about how to protect the individuals’ data.
3. GLOSSARY OF TERMS
3.1. BODRUM WHITE Real Estate
BODRUM WHITE GAYRİMENKUL is called “BODRUM WHITE Real Estate” shortly.
3.2. Explicit Consent
The limited consent is collected with web user agreement on processing the data information.
The way of implementing the modifications on identifiable information so it cannot be matched with any individual.
The BODRUM WHITE Real Estate team.
3.5. Service Provider
Third parties’ personnel from whom BODRUM WHITE Real Estate get services.
3.6. Individual / Customer / Visitor
The individual whose personal data is held and processed by BODRUM WHITE Real Estate.
3.7. Personal Information / Personal Data
Information such as e-mail, address and telephone number from individuals/visitors/customers that enables them to be identified.
3.8. Processing of Personal Data
The process of storing, collecting, saving, amending, disclosing or editing the personal information is carried out partially or fully automatically.
3.9. Data Controller
The people who decide what personal information BODRUM WHITE Real Estate will hold and how it will be held and used.
3.10. Data Processor
The natural or eligible individuals who have the authority to process the data under as data controller.
3.11. KVKK Board
The Panel of Protection of Personal Data (Protection of Personal Data in Turkish is KVKK).
3.12. KVKK Corporation
The Corporation for the Protection of Personal Data
3.13. Law of KVKK
Protection of Personal Data law is published under the number 29677 in Official Gazette.
Processing of Personal Data and protection by BODRUM WHITE Real Estate.
4. ROLES AND RESPONSIBILITIES
4.1. Data Controller
The process concerning storing, collecting, saving, amending, disclosing or editing the personal information carried out partially or fully automatically accordingly to Turkish Law on the Protection of Personal Data.
BODRUM WHITE Real Estate collects and use some information about customers and visitors to perform the work. Data Controller is BODRUM WHITE Real Estate that explicitly define which data will be used in conformity to Law.
4.2. Data Controller Agent
Data Controller Agent is an expert ensuring the storage and process of data and keep it secure.
4.3. Data Processor
An authorized By BODRUM WHITE Real Estate person who can process the personal data.
Data processors must take some precautions and Data Controllers, BODRUM WHITE Real Estate audit if the process relies on trust of two parties.
5. LEGAL OBLIGATIONS
According to KVKK Law, BODRUM WHITE Real Estate have legal commitments to process the data safely:
5.1. The Obligation to Clarify
During the Data Process, BODRUM WHITE Real Estate has an obligation to inform its visitors / customers about the following aspects:
• Data Controller’s identity
• Why Personal Data is preserved
• The legal explanations why the Personal Data is stored
• Individuals’ rights
5.2. The Obligation to Inform
According to the 13th article of KVKK Law, BODRUM WHITE Real Estate is obliged to keep individuals informed and if necessary, to provide any further information via bodrumwhite.com or +90 537 035 1795.
5.3. The Obligation to Provide Security Within Personal Data
BODRUM WHITE Real Estate, as Data Controllers is obliged to provide all necessary security measures in conformity to the 12th article of the KVKK Law.
5.4. The Obligation to Enlist in the Data Controllers Registry
BODRUM WHITE Real Estate has to enlist into the Data Controllers Registry accordingly to the KVKK Law of 16th article.
6. CLASSIFYING THE PERSONAL DATA
6.1. Personal Data
Personal Data is an individual’s surname, name, social security number, identity, place of birth, telephone number, address, e-mail address and payment information.
Due to membership conditions, BODRUM WHITE Real Estate stores certain Data such as surname, name, e-mail address and telephone number.
6.2. Private Personal Data
Other personal data such as political opinion, ethical roots, religion any other beliefs, membership to any foundation, biometric and genetic data, philosophical beliefs, convictions are considered as Private Personal Data and it’s forbidden to store such Data without individual’s authorization in conformity to the 6th article of the Turkish KVKK Law.
As a Data Controller, BODRUM WHITE Real Estate never requires Private Personal Data.
7. THE POLICY OF PERSONAL DATA PROCESSING
7.1. Data Processing Principles
All data collected by the BODRUM WHITE Real Estate can be processed only in conformity to 4th, 5th and 6th article of the KVKK Law
• BODRUM WHITE Real Estate has an obligation to process the data by respecting the KVKK Law and other legal regulations.
• BODRUM WHITE Real Estate has an obligation to be transparent, respect the code of honesty and keep users informed.
• BODRUM WHITE Real Estate will process the data in only lawful causes indicated by KVKK Law or other legal regulations.
• The data use should be defined by its purposes and limited to them.
• The processing of data is restricted to only necessary scale by BODRUM WHITE Real Estate.
• BODRUM WHITE Real Estate can store the data only within the necessary period (Read the 9th paragraph).
7.2. Data Processing Objectives
BODRUM WHITE Real Estate doesn’t collect nor store the personal data from any customers sending any undesirable and unsolicited information (spam). BODRUM WHITE Real Estate process the data with the following objectives:
• Name, surname, e-mail address and telephone number are processed for website registry and effective communication.
• Remarketing, retargeting and communication use application browsing data and demographic data with the aim to correct the operational services.
• Information provided by Social Media should ensure a better experience on our website. Facebook, Twitter, LinkedIn and Instagram are used only for the possibility of registering to the BODRUM WHITE Real Estate sites.
• Location data is collected only if the user permits it to their device during the browsing. This data is used by BODRUM WHITE Real Estate in aim to show the most appropriate properties in the location.
The data is processed accordingly to another objective not previously stated:
• BODRUM WHITE Real Estate sends hot offers and properties suggestions via newsletter format as an email.
• BODRUM WHITE Real Estate answers any questions and queries by dealing with every customer individually according to communication data provided.
• BODRUM WHITE Real Estate provides information concerning new services.
• BODRUM WHITE Real Estate carries out the direct marketing.
• BODRUM WHITE Real Estate reserves the right to communicate directly with individuals if required.
7.3. Ensuring the Data to be Processed on Legal Grounds
BODRUM WHITE Real Estate ensures the following technical measures for personal data processing for legal reasons:
• Settling an intercorporate organization for storing and processing the Personal Data in conformity to the Law
• Ensuring an appropriate technical infrastructure for storage of the Personal database
• Auditing technical infrastructure and process provided
• Formulate the necessary procedures for audit periods and technical procedures.
BODRUM WHITE Real Estate takes the necessary legal precautions within the personal data processing for legal reasons:
• Informing and Educating the BODRUM WHITE Real Estate staff about personal data processing on legal grounds,
• Implementing precautions in case of any unlawful acts of personal data processing on the legal files, contracts and policies,
• Verifying the processing of personal data by partners and the third-party processors.
8. THE POLICY REGULATING TRANSFER OF THE PERSONAL DATA
8.1. Transferring the Personal Data Inland
As Data Controllers, BODRUM WHITE Real Estate has an obligation to act in conformity to KVKK Law. BODRUM WHITE Real Estate never shares any personal information nor data with third party companies without the authorization of the individual.
However, BODRUM WHITE Real Estate can provide the data to the judicial, governmental or legal authorities in the case of obligations formulated by KVKK Law and Constitutional Authorities.
8.2. Transferring the Personal Data Abroad
Personal Data can be transferred for storage and processing to other countries by BODRUM WHITE Real Estate under the condition that receiving country fulfils the obligations regulated by KVKK Board. In case if the safety measures are not enough, Turkish Data Controllers and Controllers from receiving country must prepare a written commitment and ask the KVKK Board for approval.
8.3. Which Person/Organization Receives the Personal Data?
Institutions and organizations having an authorization: Public authorities can obtain the Data as they require in conformity to the article number 8.1.
BODRUM WHITE Real Estate and its customer program obtain the Personal Data, preserves it and keeps track of the clients.
There are third party tools and software like Google AdWords, Bing, Google Analytics, WhatsApp, Yandex Direct, Yandex Metrica, Twitter, Facebook, Instagram and JivoChat that collect some Personal Data through cookies to ensure your browsing experience better.
8.4. Personal Data Precautions during Transferring
• BODRUM WHITE Real Estate has an obligation to take the important technical safety measures for any unlawful Personal Data access and usage by any person processing the data or companies even if BODRUM WHITE Real Estate authorized these data processors.
• BODRUM WHITE Real Estate’s policies define in what purpose and how the data should be transferred. BODRUM WHITE Real Estate also specifies the parties to whom the data will be transferred.
9. THE POLICY OF THE PERSONAL DATA PRESERVATION
9.1. Protecting the Data for a Certain Amount of Time
Every information concerning a known or findable individual is a personal data, in conformity to the KVKK Law. All the information such as telephone number and e-mail address are saved and protected by BODRUM WHITE Real Estate.
Consequently, obtaining and keeping the data process is done in conformity to the laws by BODRUM WHITE Real Estate. According to the governmental obligations the data must be kept for about 2 years, data will be kept no longer than the purpose is achieved.
Furthermore, some laws define the period of preservation differently, like for example registries and credentials according to Tax Procedure Law should be kept for 5 years.
9.2. The Precautions for Processing the Personal Data
• BODRUM WHITE Real Estate creates the necessary mechanisms and system to fulfil the requirements concerning the precautions in terms of Personal Data processing.
• BODRUM WHITE Real Estate employees are taking place in trainings concerning the preservation of Personal Data
• BODRUM WHITE Real Estate is in charge of controlling these precautions measures for preserving the personal data.
10. SAFETY POLICY OF THE PERSONAL DATA
10.1. Obligations of BODRUM WHITE Real Estate about the Safety of Data
BODRUM WHITE Real Estate has obligations to protect the Personal Data and keep it safe according to Law on the Protection of Personal Data, 12th Article. BODRUM WHITE Real Estate is responsible for:
• prevention of the Personal Data being processed in unlawful way,
• auditing these precautions in a regular way,
• providing necessary technical equipment to block any infiltration to Personal Data,
• notifying authorities in any case of infiltration.
10.2. Precautions for Keeping the Personal Data Safe
BODRUM WHITE Real Estate takes the necessary safety measures in times of security risk with the purpose of ensuring the Personal Data being safe and secure. These security measures are:
Technical and Executive Precautions
The executive and technical safety measures of Personal Data transfer, process and safety are defined in the related articles. BODRUM WHITE Real Estate has an obligation to take security measures for the protection of the individuals, in case if third parties access the Personal Data unlawfully.
Precautions and Inspection for Safety of the Personal Data
A report about the Data recorder’s appropriateness to the KVKK Law is prepared by BODRUM WHITE Real Estate. Moreover, the recorder is checked regularly, followed by the preparation of the report to the accredited person or commission
Precautions in Case of Disclosure without Authorization
BODRUM WHITE Real Estate has an obligation to block all disclosure actions, take the necessary security measures and create a policy. In any case of unlawful actions like disclosure, BODRUM WHITE Real Estate should inform the disclosed person and the KVKK Board.
11. THE RIGHTS OF INDIVIDUALS
11.1. Right to Access Own Personal Data
Everyone whose data is kept reserves a right to access their personal data without any charge. Individuals can:
• Check if their Data is processed or not,
• Ask for information about the operation of Data processing,
• Ask for a purpose of processing and check if the Data is used for this aim.
11.2. Right to Change or Delete Own Personal Data
Everyone whose data is kept reserves a right to change or delete their personal data without any charge. Individuals can:
• Request to correct the Data in any case of missing or wrong information
• Request to delete the Data in case if the purpose of keeping the Data is not valid anymore
• request to inform the third-party processors about those procedures
• Reject any unwanted result that shows up during the analysis of the processed Data by automatic systems.
11.3. Updating Own Personal Data
In case if you require to access, delete or change your Personal Data, contact us:
via Phone: +90 537 035 1795
via e-mail: [email protected]
11.4. Individuals Requests and Evaluation
Individuals can require reaching their processed Data and use of their rights in accordance to the policy. BODRUM WHITE Real Estate offers easy and clear communication opportunities. The requests are all answered quickly, not longer than it’s determined by KVKK Law.
Individuals applying to access their data, should be advised by the representatives declared by Data Controllers Registry. Data Controller Representative will answer those applications within maximum 30 days, without any extra charge or with a possible payment if KVKK Board declares so.
Individuals should send their application to the Data Controller Representative in order to start the process. The application has to be a formal, registered letter, unless KVKK Board doesn’t demand other option.
Data Controller Representative may accept or declined the application and inform about the decision in an electronic or written format. If the representatives accept the application, the request will be carried out by BODRUM WHITE Real Estate. In case if the error belongs to BODRUM WHITE Real Estate, the company agrees to make a payment to the individuals.
In case if application is declined, the individual may request more information or write a complaint letter within 30 days.
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13. PRESERVING AND PUBLISHING THE POLICY
14. THE PERIOD OF UPDATING THE POLICY
15. PERIOD OF VALIDITY
We implemented organizational and technical precautions to protect your Personal Data from being accidentally accessed, used or lost in unlawful way. Nevertheless, we would like to underline that none of the methods of transmission via mobile device or Internet either techniques of electronic storage are 100% secure. BODRUM WHITE Real Estate rejects such an obligation.
17. INTERNATIONAL DATA TRANSFER