PRIVACY NOTICE ON THE PROTECTION OF PERSONAL DATA
1. Data Controller
Pursuant to the Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”), your personal data may be processed by Propin Gayrimenkul Yatırım ve Danışmanlık Hizmetleri Anonim Şirketi (“Company” or “Propin”), acting as the data controller, within the scope explained below.
2. Categories of Personal Data Processed
• Identity information: name, surname, and, where necessary, information used for identity verification.
• Contact information: telephone number, e-mail address, address, and preferred communication channel.
• Customer transaction information: requested real estate type, location, budget, rental or purchase preferences, offers, and communication records.
• Prospective customer and sales process information: lead source, communication notes, sales stage, appointment, offer, and follow-up information.
• Transaction security and digital records: IP address, date and time, log records, form submission records, and security records.
• Marketing and communication preferences: commercial electronic communication consent, opt-out records, newsletter subscription, campaign, and report delivery preferences.
• Request, suggestion, and complaint information: applications submitted to the Company and records relating to the processing of such applications.
3. Purposes of Processing Personal Data
• Providing real estate purchase, sale, rental, investment consultancy, and portfolio services.
• Receiving and evaluating customer and prospective customer requests, preparing offers, and managing the sales process.
• Responding to contact forms, appointment requests, and requests for information.
• Managing customer relations, tracking communication history, and improving service quality.
• Managing pre-contractual processes and establishing and performing contracts.
• Fulfilling legal obligations, managing disputes, and establishing, exercising, or protecting legal rights.
• Ensuring information security, auditing, business continuity, and the accuracy of records.
• Where explicit consent or commercial electronic communication consent has been obtained, sending weekly e-newsletters, promotional and campaign content, and special real estate reports published four times a year.
• Analyzing, reporting on, and improving the Company's activities and measuring customer satisfaction.
4. Legal Grounds for Processing Personal Data
Your personal data is processed based on the following legal grounds set forth under Articles 5 and, where applicable, Article 6 of the KVKK:
• Being expressly stipulated by law and fulfilling the Company's legal obligations.
• Being directly related to the establishment or performance of a contract.
• Being necessary for the establishment, exercise, or protection of a right.
• Being necessary for the legitimate interests of the Company, provided that this does not prejudice the fundamental rights and freedoms of the data subject.
• The explicit consent and/or approval of the data subject for activities subject to explicit consent or commercial electronic communication consent, such as marketing, newsletters, promotional content, and report delivery.
The fulfilment of the obligation to provide a privacy notice is independent of obtaining explicit consent or commercial electronic communication consent.
5. Methods of Collecting Personal Data
Your personal data may be collected through websites and contact forms, e-mail, telephone, face-to-face meetings, digital advertising and referral channels, contracts, offer and request forms, CRM records, cookies, and similar electronic or physical means, either automatically or through non-automated means, provided that they form part of a data recording system.
6. Cookies and Similar Technologies
Cookies and similar technologies are used on the Company's website (propin.com.tr) to provide a smooth browsing experience, remember language preferences, and measure visitor statistics. The main cookies actually used on the website are listed below:
Cookie Information:
- i18n_redirected
- Provider: Propin (website infrastructure)
- Type: Necessary / Functional
- Purpose: To remember the visitor's language preference (e.g., Turkish)
- Duration: ~1 year
- _ga
- Provider: Google (Google Analytics)
- Type: Analytics
- Purpose: Assigning a unique identifier to distinguish visitors from one another
- Duration: ~2 years
- _ga_5MW96YF7L2
- Provider: Google (Google Analytics 4)
- Type: Analytics
- Purpose: Maintaining session and measurement status
- Duration: ~2 years
Analytics cookies other than necessary and functional cookies are activated only upon obtaining your explicit consent, and a cookie consent tool is used on the website for this purpose. You may manage or reject cookies at any time through your browser settings or the cookie preference panel on the website. Detailed information regarding cookies is provided in the Cookie Policy.
7. Transfer of Personal Data
Your personal data may be transferred, to the extent limited to and proportionate to the purposes stated above, to authorized public institutions and organizations, legal and financial advisers, business partners, suppliers, hosting and information technology service providers, e-mail and communication service providers, audit companies, and other persons authorized by law.
9. Commercial Electronic Communications and Marketing Activities
The sending of e-newsletters, campaigns, promotional content, and real estate reports may be subject to separate commercial electronic communication consent under Law No. 6563 on the Regulation of Electronic Commerce and the relevant legislation. Commercial electronic communication consent is obtained separately from the KVKK privacy notice and the performance of a contract. Refusal to provide consent does not prevent the provision of the main service.
10. Retention Periods
Your personal data is retained for the periods prescribed by the relevant legislation and for the period required by the purpose of processing. When the retention period expires or the conditions for processing cease to exist, the data is deleted, destroyed, or anonymized in accordance with the applicable legislation. Commercial electronic communication consent and opt-out records are retained for the periods prescribed by the relevant legislation.
11. Rights of the Data Subject
Pursuant to Article 11 of the KVKK, you have the right to apply to the Company and:
• Learn whether your personal data is being processed,
• Request information about the processing if it has been processed,
• Learn the purpose of processing and whether the data is used in accordance with that purpose,
• Know the third parties to whom your personal data has been transferred,
• Request the correction of incomplete or inaccurately processed personal data,
• Request the deletion or destruction of personal data where the conditions for processing no longer exist,
• Request that correction, deletion, or destruction operations be notified to third parties to whom the data has been transferred,
• Object to a result arising against you as a result of the analysis of your data exclusively by automated systems,
• Request compensation for damages in the event that you suffer damage due to unlawful processing
of your personal data.
12. Application Method and Contact Information
Data Controller
Propin Gayrimenkul Yatırım ve Danışmanlık Hizmetleri Anonim Şirketi
Address
Eski Büyükdere Cad. Hümeyra Sk. Nef09 Dört Levent Ofis B Blok No:7 Kat:5/114, 34400 4. Levent / Istanbul, Türkiye
Telephone
0 (212) 217 85 55
Applications must be submitted together with information and documents verifying your identity, in accordance with the KVKK and the Communiqué on the Procedures and Principles of Application to the Data Controller. Applications shall be concluded free of charge as soon as possible and within thirty days at the latest, depending on their nature. If the transaction requires an additional cost, the tariff determined by the Board may be applied.