Personal Data Protection Notice

1.Identity of the Data Controller

Your personal data is processed by Property Time Istanbul in its capacity as "data controller" within the meaning of Article 3 of the KVKK. Detailed contact information of the data controller is set out in Section 10 of this Notice.

2.Categories of Personal Data Processed

The categories of personal data processed by the Company are set out below:

3.Purposes of Processing Personal Data

Your personal data is processed strictly for the following purposes, within the conditions for processing set out in Articles 5 and 6 of the KVKK:

1. Receiving, evaluating, and responding to your requests and applications;
2. Providing you with information regarding real estate projects and investment opportunities in Istanbul;
3. Contacting you in relation to the services you have requested;
4. Subject to your explicit consent, delivering property listings, investment opportunities, and promotional content via telephone, email, WhatsApp, and similar channels;
5. Developing our website and services and improving user experience;
6. Subject to your explicit consent, conducting advertising and marketing activities, including targeted advertising and remarketing;
7. Fulfilling legal obligations and providing information to competent authorities.

4.Legal Grounds for Processing

Your personal data is processed on the basis of the following legal grounds set out in Article 5 of the KVKK:

1. Processing being necessary for the establishment or performance of a contract, provided that it is directly related to the parties of the contract (KVKK Art. 5/2-c);
2. Processing being mandatory for the data controller to fulfil its legal obligations (KVKK Art. 5/2-ç);
3. Processing being mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed (KVKK Art. 5/2-f);
4. Your explicit consent, with respect to marketing, targeted advertising, remarketing, and the delivery of commercial electronic messages (KVKK Art. 5/1).

5.Method of Collecting Personal Data

Your personal data is collected by fully or partially automated means, or by non-automated means forming part of a data recording system, through the following channels:

1. Contact and consultation forms available on our website;
2. Lead generation forms (Lead Ads) published on Meta platforms (Facebook and Instagram);
3. Website visits originating from Google Ads and other digital advertising campaigns;
4. Communications conducted via telephone, email, and WhatsApp;
5. Cookies and similar technologies used on our website (Meta Pixel, Google Analytics, Google Ads conversion and remarketing tags).

6.Transfer of Personal Data

Your personal data may be transferred, in accordance with the conditions set out in Articles 8 and 9 of the KVKK and strictly limited to the purposes stated in this Notice, to the following parties:

1. Authorized employees and consultants of the Company;
2. Business partners engaged in the provision of services you have requested (including our contracted law office providing legal advisory services);
3. Competent public institutions, authorities, and judicial bodies where required by law.

International Data Transfers

As the servers of service providers used on our website and in our digital marketing activities — including Meta Platforms Inc., Google LLC, and WhatsApp LLC — are located abroad, data collected through cookies and pixel technologies, as well as the form data you submit through these platforms, may be transferred abroad on the basis of your explicit consent pursuant to Article 9 of the KVKK. We recommend that you review the privacy policies of these platforms for information on their data processing practices.

7.Cookies and Digital Marketing Technologies

Our website uses cookies and similar technologies to ensure the proper functioning of the website, improve user experience, analyze website traffic, and — subject to your explicit consent — conduct targeted advertising activities.

Third-Party Technologies Used

1. Google Analytics: Anonymous statistical analysis of website traffic and user behavior;
2. Google Ads: Conversion measurement and, subject to your explicit consent, remarketing activities;
3. Meta Pixel: Measuring the effectiveness of Facebook and Instagram advertisements and, subject to your explicit consent, building advertising audiences.

All cookies other than strictly necessary cookies are activated solely on the basis of the explicit consent you provide through our cookie consent tool. You may change your cookie preferences at any time via the cookie settings panel on our website or through your browser settings.

You may also manage personalized advertising through the following channels: Google Ads Settings, Meta Ad Preferences, Your Online Choices.

8.Commercial Electronic Messages

Pursuant to the Turkish Law No. 6563 on the Regulation of Electronic Commerce, promotional and marketing communications may be sent to you via telephone, email, SMS, or WhatsApp only on the basis of your consent to that effect.

You may withdraw your consent at any time, free of charge and without providing any justification, through the contact channels set out in Section 10 of this Notice. The delivery of commercial electronic messages will cease upon receipt of your opt-out request.

9.Your Rights Under Article 11 of the KVKK

Pursuant to Article 11 of the KVKK, you may exercise the following rights by applying to the data controller:

1. To learn whether your personal data is being processed;
2. To request information regarding the processing of your personal data, if processed;
3. To learn the purpose of processing and whether your data is used in accordance with that purpose;
4. To know the third parties to whom your personal data has been transferred, whether domestically or abroad;
5. To request the correction of your personal data in case of incomplete or inaccurate processing;
6. To request the deletion or destruction of your personal data within the conditions set out in Article 7 of the KVKK;
7. To request that the correction, deletion, or destruction operations be notified to third parties to whom your data has been transferred;
8. To object to the emergence of a result to your detriment through the analysis of your processed data exclusively by automated systems;
9. To claim compensation for damages arising from the unlawful processing of your personal data.

Application Procedure

You may submit your requests regarding the above rights — together with documents verifying your identity, in accordance with the Communiqué on the Principles and Procedures of Application to the Data Controller — in writing to the postal address or by email to the address set out in Section 10 of this Notice. Applications will be concluded free of charge within thirty (30) days at the latest, depending on the nature of the request. Where the process requires an additional cost, the fee set out in the tariff determined by the Turkish Personal Data Protection Board may be charged.