Privacy Policy

Privacy Policy & Protection of Personal Data by TERRA Real Estate

1. PURPOSE

The Turkish Government has enacted legislation to protect the rights of individuals, safeguard their privacy, and regulate the lawful processing of personal data. This is known as the “Law on the Protection of Personal Data” (hereinafter referred to as the “KVKK Law”), published on 7th April 2016.

This policy outlines how personal data is stored and protected in accordance with the KVKK Law. TERRA Real Estate ^® stores and processes personal data in full compliance with this regulation.

2. SCOPE

This policy applies to all visitors of the website dogasehir.top as well as to employees and affiliates of TERRA Real Estate ^®. It governs all data-related activities performed by or on behalf of TERRA Real Estate ^®.

This policy is implemented in accordance with the KVKK Law. All employees, visitors, and customers are required to adhere to its terms. TERRA Real Estate ^® ensures its team receives appropriate training and resources regarding data protection responsibilities.

3. GLOSSARY OF TERMS

3.1. TERRA Real Estate
Refers to TERRA Real Estate Emlak İnşaat Limited Şirketi.

3.2. Explicit Consent
Consent that is freely given, specific, informed, and unambiguous, provided by the data subject regarding the processing of their personal data.

3.3. Anonymization
The process by which personal data is altered in such a way that it can no longer be associated with an identified or identifiable individual.

3.4. Employees
All staff members working under TERRA Real Estate ^®.

3.5. Service Provider
Third-party individuals or organizations that provide services to TERRA Real Estate ^®.

3.6. Individual / Customer / Visitor
Any natural person whose personal data is processed by TERRA Real Estate ^®.

3.7. Personal Information / Personal Data
Any information that identifies or can identify a person, such as name, email address, telephone number, or postal address.

3.8. Processing of Personal Data
Any operation performed on personal data, whether automated or not, such as collection, storage, alteration, use, or disclosure.

3.9. Data Controller
The party that determines the purposes and methods of processing personal data. TERRA Real Estate ^® acts as the Data Controller.

3.10. Data Processor
A person or organization authorized by the Data Controller to process data on its behalf.

3.11. KVKK Board
The Personal Data Protection Board established under Turkish law to oversee data protection matters.

3.12. KVKK Authority
The institution responsible for implementing and enforcing the KVKK Law — the Personal Data Protection Authority of Turkey.

3.13. KVKK Law
The Law on the Protection of Personal Data, officially published in Official Gazette No. 29677.

3.14. Policy
The Personal Data Protection and Processing Policy of TERRA Real Estate ^®.

4. ROLES AND RESPONSIBILITIES

4.1. Data Controller
The Data Controller is responsible for the collection, storage, modification, and disclosure of personal data, either partially or fully by automated means, in accordance with the KVKK Law.

TERRA Real Estate ^®, acting as the Data Controller, determines the scope and purpose of personal data processing. The company processes information required to perform its business operations and provide services to customers and visitors, strictly within the boundaries of the law.

4.2. Authorized Data Controller Representative
This is the individual or team authorized by the Data Controller to oversee and ensure proper data handling and storage in accordance with legal requirements.

4.3. Data Processor
Any individual or organization authorized by TERRA Real Estate ^® to process personal data on its behalf, under its instructions and supervision.

4.4. Responsibilities
Data Processors must take all necessary measures to ensure data security. TERRA Real Estate ^®, as the Data Controller, audits data processing operations and ensures mutual compliance and trust between all parties involved.

5. LEGAL OBLIGATIONS

In accordance with the KVKK Law, TERRA Real Estate ^® has several legal responsibilities to ensure safe and transparent processing of personal data:

5.1. Obligation to Inform
TERRA Real Estate ^® is required to inform data subjects about the following:

• The identity of the Data Controller,
• The purpose for processing their personal data,
• The legal basis for such data collection,
• Their legal rights regarding their data.

5.2. Obligation to Respond to Inquiries
As per Article 13 of the KVKK Law, TERRA Real Estate ^® must respond to all data-related inquiries submitted by individuals, either through its website (dogasehir.top) or by phone at +90 242 512 25 00.

5.3. Obligation to Ensure Data Security
TERRA Real Estate ^® must implement all necessary technical and administrative measures to prevent unauthorized access, loss, or misuse of personal data, in line with Article 12 of the KVKK Law.

5.4. Obligation to Register with the Data Controllers Registry
Under Article 16 of the KVKK Law, TERRA Real Estate ^® must be registered in the Data Controllers Registry and maintain accurate records of its data processing activities.

6. CLASSIFYING PERSONAL DATA

6.1. Personal Data
Personal data includes but is not limited to: name, surname, identity number, social security number, date of birth, address, phone number, email address, and payment information.

As part of its services and user registration processes, TERRA Real Estate ^® may collect and store basic personal information such as name, surname, phone number, and email address.

6.2. Sensitive Personal Data
Sensitive data includes details about an individual's race, ethnicity, political opinion, religious belief, philosophical belief, trade union membership, health status, biometric data, and criminal records.

According to Article 6 of the KVKK Law, processing of sensitive personal data is strictly prohibited without explicit consent from the individual. TERRA Real Estate ^® does not request or store sensitive personal data under any circumstances.

7. PERSONAL DATA PROCESSING POLICY

7.1. Principles of Data Processing
TERRA Real Estate ^® processes all personal data in accordance with Articles 4, 5, and 6 of the KVKK Law, based on the following principles:

• Compliance with laws and regulations,
• Fair and transparent processing,
• Processing for specific, legitimate, and clearly stated purposes,
• Data is relevant, limited, and proportionate to the purpose,
• Data is stored only as long as necessary for the defined purpose (See Section 9).

7.2. Objectives of Data Processing
TERRA Real Estate ^® does not collect or store unsolicited or spam data from users. The company processes personal data for the following purposes:

• Names, email addresses, and phone numbers are used for website registration and communication,
• Browsing data and demographics may be used for remarketing, retargeting, and service optimization,
• Social media data enhances the user experience (e.g., via Facebook, Twitter, LinkedIn, Instagram login options),
• Location data (if permitted by the user’s device) helps display relevant property listings.

Additionally, data may be processed for:

• Sending newsletters with property offers,
• Answering individual inquiries,
• Providing updates on new services,
• Conducting direct marketing and communication activities,
• Maintaining contact when necessary.

7.3. Legal Basis and Safeguards for Data Processing
TERRA Real Estate ^® implements both technical and administrative safeguards to ensure legal compliance when processing data:

• Establishing internal procedures for secure data processing,
• Providing infrastructure for protected data storage,
• Regular audits and reviews of data handling systems,
• Employee training on lawful data use,
• Verification and control of third-party processors.

8. PERSONAL DATA TRANSFER POLICY

8.1. Domestic Transfers
TERRA Real Estate ^® does not share personal data with third parties without explicit consent, except where required by law or governmental authorities.

8.2. International Transfers
Personal data may be transferred abroad for storage or processing only if the receiving country ensures adequate protection as defined by the KVKK Board. If not, a formal agreement must be signed between parties, and approval from the KVKK Board is required.

8.3. Recipients of Personal Data
Authorized entities such as judicial and governmental bodies may receive data as legally required. Internally, personal data is processed and stored within TERRA Real Estate’s ® customer systems.

In addition, third-party tools and services like Google AdWords, Bing, Google Analytics, WhatsApp, Yandex Direct, Yandex Metrica, Twitter, Facebook, Instagram, and JivoChat may collect limited data via cookies to enhance user experience.

8.4. Security Measures During Data Transfer

Technical Measures
TERRA Real Estate ^® ensures technical precautions are in place to prevent unauthorized access or breaches, even by third parties it has authorized.

Administrative Measures
The company defines the scope, methods, and parties involved in all data transfer procedures and ensures such policies are followed by internal teams and partners.

9. PERSONAL DATA RETENTION POLICY

9.1. Data Retention Period
All personal data collected by TERRA Real Estate ^® is retained in accordance with applicable Turkish laws. For example:

• Personal contact details may be stored for up to 2 years,
• Accounting-related data (e.g., for tax compliance) must be kept for up to 5 years per the Tax Procedure Law.

Data will not be retained longer than necessary for the purposes it was collected unless legally required.

9.2. Security Measures for Data Retention

Technical Measures
TERRA Real Estate ^® utilizes secure systems and infrastructure to protect stored personal data from unauthorized access.

Administrative Measures
Employees receive training on data retention policies and are monitored for compliance. The company regularly reviews retention measures for adequacy and effectiveness.

10. PERSONAL DATA SECURITY POLICY

10.1. TERRA Real Estate's Obligations on Data Security
TERRA Real Estate ^® is obligated under Article 12 of the KVKK Law to ensure the safety of personal data. These obligations include:

• Preventing unlawful access, processing, or disclosure of personal data,
• Regularly auditing security measures,
• Implementing the necessary technical infrastructure to prevent data breaches,
• Informing relevant authorities in case of a data breach or security incident.

10.2. Measures to Ensure Data Security

Technical and Administrative Measures
TERRA Real Estate ^® takes both technical and organizational steps to protect personal data against unauthorized access, disclosure, loss, or destruction. These measures include:

• Encryption and secure data transmission channels,
• Access control and user permission protocols,
• Regular software and system updates,
• Employee training on data privacy and security policies,
• Security protocols for third-party processors and software integrations.

Monitoring and Inspection
TERRA Real Estate ^® conducts regular internal audits to assess compliance with the KVKK Law. Any irregularities are documented and corrected as necessary. Reports are shared with authorized individuals or committees within the organization.

In the Event of Unauthorized Disclosure
In the case of unauthorized access or data leakage, TERRA Real Estate ^® will immediately notify both the affected individual(s) and the KVKK Board. The company is committed to taking prompt corrective action and implementing preventive measures to avoid recurrence.

11. RIGHTS OF INDIVIDUALS

11.1. Right to Access Personal Data
Each individual has the right to access their personal data stored by TERRA Real Estate ^® at no cost. This includes the right to:

• Verify whether personal data has been processed,
• Request information regarding the data processing procedure,
• Learn the purpose for processing and whether data is used in accordance with that purpose.

11.2. Right to Rectify or Erase Data
Individuals may request the rectification or deletion of their personal data if:

• The data is inaccurate or incomplete,
• The purpose for which the data was collected is no longer valid,
• They object to automatic processing outcomes,
• They request notification of such actions to third parties involved in the processing.

11.3. Updating Personal Data
To access, modify, or delete your personal data, please contact us through one of the following channels:

• Phone: +90 242 512 25 00
• Email: [email protected]
• Postal address: Atatürk Blv. 62, 07400 Alanya, Antalya, Turkey

11.4. Requests and Evaluations
Individuals may submit a formal request to exercise their rights under this policy. TERRA Real Estate ^® ensures a fast and transparent response within the period defined by the KVKK Law (maximum 30 days).

All applications must be submitted to the Data Controller Representative using a written, signed, and registered letter unless the KVKK Board defines another valid method.

The representative will review the request and respond either in writing or electronically. If the request is accepted, the necessary actions will be taken by TERRA Real Estate ^®. If the issue is caused by the company, there will be no charge and compensation may be offered.

If the application is denied, individuals may request additional explanation or file a complaint within 30 days.

12. COOKIE POLICY

This Cookie Policy applies to both mobile and desktop versions of the website provided by TERRA Real Estate ^®.

TERRA Real Estate ^® uses cookies to enhance your browsing experience and to provide you with a better web and mobile service. These cookies help improve functionality, personalization, and analytics.

Users have the option to disable or restrict cookies through their browser settings. However, doing so may negatively impact your browsing experience and limit some features of the website.

Unless blocked or disabled by the user, cookies are considered accepted upon continued use of the website.

13. PRESERVATION AND PUBLICATION OF THE POLICY

The current version of the Privacy Policy is always accessible on the official website of TERRA Real Estate ^®. In the event of updates or amendments to the Privacy Policy, users will be notified via email or through a visible notice on the website prior to the changes taking effect.

By continuing to use the website after changes are published, users are considered to have accepted the revised Privacy Policy.

14. POLICY UPDATE PERIOD

TERRA Real Estate ^® reserves the right to make updates or modifications to this Privacy Policy based on legal requirements or internal operational changes.

In such cases, a notification will be sent to users by email or posted on the website. The updated version becomes effective immediately upon publication on the website.

Last Updated: 01.04.2019. This Privacy Policy has been in effect since that date.

15. POLICY VALIDITY

This Privacy Policy is valid and effective from the date of its publication on the website and remains in force until it is updated or removed.

TERRA Real Estate ^® reserves the right to make changes in accordance with legal regulations and operational needs, as explained in Section 14.

16. SECURITY DISCLAIMER

TERRA Real Estate ^® has implemented both organizational and technical safeguards to protect your personal data from unauthorized access, loss, misuse, or alteration.

However, please note that no method of data transmission over the Internet or via mobile devices, nor any method of electronic storage, is 100% secure. Therefore, while TERRA Real Estate ^® strives to protect your personal data, it cannot guarantee absolute security and disclaims liability for breaches beyond its control.

17. INTERNATIONAL DATA TRANSFER

Residents of the European Economic Area (EEA) and Switzerland should be aware that personal data collected by TERRA Real Estate ^® may be stored or processed outside of these regions for the purposes outlined in this Privacy Policy.

TERRA Real Estate ^® is committed to protecting your data and takes appropriate steps to ensure that such data transfers comply with EU data protection standards, including the use of Standard Contractual Clauses where applicable.

When transferring data within group companies or to service providers located outside the EEA, TERRA Real Estate ^® ensures that similar levels of protection are implemented and maintained. More information about these safeguards can be provided upon request.