1. PURPOSE
Turkish Government set up the law to protect the rights of individuals, the 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. ELYSEE HOME is preserving the personal data accordingly to this law
2. SCOPE
The policy implies to visitors of terrarealestate.com as well as to the TERRA Real Estate team. The policy has an impact on all activities created and carried out by ELYSEE HOME.
Our policy is formulated in accordance with KVKK Law and all employees of ELYSEE HOME as well as visitors, customers are obliged to apply this policy. Employees are also getting proper information and necessary materials about how to protect the individuals’ data.
3. GLOSSARY OF TERMS
3.1. ELYSEE HOME
ELYSEE HOME İnşaat Emlak Turizm Gida Limited Şirketi is called “ELYSEE HOME” shortly.
3.2. Explicit Consent
The limited consent is collected with web user agreement on processing the data information.
3.3. Anonymization
The way of implementing the modifications on identifiable information so it cannot be matched with any individual.
3.4. Employees
The ELYSEE HOME team.
3.5. Service Provider
Third parties’ personnel from whom ELYSEE HOME gets services.
3.6. Individual / Customer / Visitor
The individual whose personal data is held and processed by ELYSEE HOME.
3.7. Personal Information / Personal Data
Information such as e-mail, address, and telephone number from individuals/visitors/customers enables them to be identified.
3.8. Processing of Personal Data
The process of storing, collecting, saving, amending, disclosing or editing personal information is carried out partially or fully automatically.
3.9. Data Controller
The people who decide what personal information ELYSEE HOME will hold and how it will be held and used.
3.10. Data Processor
The natural or eligible individuals have the authority to process the data under a 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.
3.14. Policy
Processing of Personal Data and protection by ELYSEE HOME.
4. ROLES AND RESPONSIBILITIES
4.1. Data Controller
The process concerning storing, collecting, saving, amending, disclosing, or editing personal information is carried out partially or fully automatically accordingly to Turkish Law on the Protection of Personal Data.
TERRA Real Estate collects and uses some information about customers and visitors to perform the work. Data Controller is ELYSEE HOME that explicitly defines which data will be used in conformity to Law.
4.2. Data Controller Agent
Data Controller Agent is an expert in ensuring the storage and process of data and keeping it secure.
4.3. Data Processor
An authorized By ELYSEE HOME person can process the personal data.
4.4. Responsibilities
Data processors must take some precautions and Data Controllers, ELYSEE HOME audit if the process relies on the trust of two parties.
5. LEGAL OBLIGATIONS
According to KVKK Law, ELYSEE HOME has legal commitments to process the data safely:
5.1. The Obligation to Clarify
During the Data Process, ELYSEE HOME 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, ELYSEE HOME is obliged to keep individuals informed and if necessary, to provide any further information via elysee-home.com or +90 505 808 97 24.
5.3. The Obligation to Provide Security Within Personal Data
ELYSEE HOME, as Data Controllers are 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
ELYSEE HOME 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, ELYSEE HOME 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 an individual’s authorization in conformity to the 6th article of the Turkish KVKK Law.
As a Data Controller, ELYSEE HOME never requires Private Personal Data.
7. THE POLICY OF PERSONAL DATA PROCESSING
7.1. Data Processing Principles
All data collected by the ELYSEE HOME can be processed only in conformity to the 4th, 5th, and 6th articles of the KVKK Law
• ELYSEE HOME has an obligation to process the data by respecting the KVKK Law and other legal regulations.
• ELYSEE HOME has an obligation to be transparent, respect the code of honesty and keep users informed.
• ELYSEE HOME 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 ELYSEE HOME.
• ELYSEE HOME can store the data only within the necessary period (Read the 9th paragraph).
7.2. Data Processing Objectives
ELYSEE HOME doesn’t collect nor store the personal data from any customers sending any undesirable and unsolicited information (spam). ELYSEE HOME 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 ELYSEE HOME sites.
• Location data is collected only if the user permits it to their device during the browsing. This data is used by ELYSEE HOME in aim to show the most appropriate properties in the location.
The data is processed accordingly to another objective not previously stated:
• ELYSEE HOME sends hot offers and properties suggestions via newsletter format as an email.
• ELYSEE HOME answers any questions and queries by dealing with every customer individually according to communication data provided.
• ELYSEE HOME provides information concerning new services.
• ELYSEE HOME carries out direct marketing.
• ELYSEE HOME reserves the right to communicate directly with individuals if required.
7.3. Ensuring the Data to be Processed on Legal Grounds
ELYSEE HOME 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.
ELYSEE HOME takes the necessary legal precautions within the personal data processing for legal reasons:
• Informing and Educating the ELYSEE HOME 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 third-party processors.
8. THE POLICY REGULATING TRANSFER OF THE PERSONAL DATA
8.1. Transferring the Personal Data Inland
As Data Controllers, ELYSEE HOME has an obligation to act in conformity to KVKK Law. ELYSEE HOME never shares any personal information nor data with third-party companies without the authorization of the individual.
However, ELYSEE HOME 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 ELYSEE HOME under the condition that receiving country fulfills the obligations regulated by KVKK Board. In case if the safety measures are not enough, Turkish Data Controllers and Controllers from the 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 authorization: Public authorities can obtain the Data as they require in conformity to article number 8.1.
ELYSEE HOME and its customer program obtain the Personal Data, preserve it, and keep 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
Technical Precautions
• ELYSEE HOME 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 ELYSEE HOME authorized these data processors.
Executive Precautions
• ELYSEE HOME’s policies define in what purpose and how the data should be transferred. ELYSEE HOME 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
All information concerning a known or findable individual is personal data, in conformity to the KVKK Law. All the information such as telephone number and e-mail address are saved and protected by ELYSEE HOME.
Consequently, obtaining and keeping the data process is done in conformity to the laws by ELYSEE HOME. 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
Technical Precautions
• ELYSEE HOME creates the necessary mechanisms and systems to fulfill the requirements concerning the precautions in terms of Personal Data processing.
Executive Precautions
• ELYSEE HOME employees are taking place in the training concerning the preservation of Personal Data
• ELYSEE HOME is in charge of controlling these precautions measures for preserving personal data.
10. SAFETY POLICY OF THE PERSONAL DATA
10.1. Obligations of ELYSEE HOME about the Safety of Data
ELYSEE HOME has obligations to protect Personal Data and keep it safe according to the Law on the Protection of Personal Data, 12th Article. ELYSEE HOME is responsible for:
• prevention of the Personal Data being processed in an 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
ELYSEE HOME takes the necessary safety measures in times of security risk with the purpose of ensuring the Personal Data is 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. ELYSEE HOME has an obligation to take security measures for the protection of the individuals, in case of 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 ELYSEE HOME. 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
ELYSEE HOME 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, ELYSEE HOME 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 the 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 the 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: +90 505 808 97 24
via e-mail: contact@elysee-home.com
via letter or Personal meeting: Kızlar Pınarı, Derya Sk. No:3C, 07460 Alanya/Antalya
11.4. Individuals Requests and Evaluation
Individuals can require to reach their processed Data and use their rights in accordance with the policy. ELYSEE HOME 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 the Data Controllers Registry. Data Controller Representative will answer those applications within a maximum of 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 another option.
Kızlar Pınarı, Derya Sk. No:3C, 07460 Alanya/Antalya
Data Controller Representative may accept or decline 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 ELYSEE HOME. In case if the error belongs to ELYSEE HOME, the company agrees to make a payment to the individuals.
In case if the application is declined, the individual may request more information or write a complaint letter within 30 days.
12. COOKIE POLICY
The Cookie Policy applies to mobile and desktop website versions provided by ELYSEE HOME.
ELYSEE HOME uses Cookies for a better experience of navigation and to present the visitors with a better mobile and web service. The visitors have always an option to block the cookies by setting their browser parameters. However, limiting or blocking the Cookies can disturb the web user’s experience.
Web users are accepting the Cookies unless they don’t block or limit the Cookies.
13. PRESERVING AND PUBLISHING THE POLICY
Privacy Policy published on the website of ELYSEE HOME will be always the current and valid version. In case of any modifications to the Privacy Policy and Data, we will send a notification about it via email or post information before the new policy enters into force. If you continue to access the Website after the modifications are entered into force, we consider that you accept the redefined Privacy Policy.
14. THE PERIOD OF UPDATING THE POLICY
ELYSEE HOME may make some modifications to the Privacy Policy in accordance with the demands of information practices. We will send a notification about the update via email or post information before the new policy enters into force. The new and updated Privacy Policy enters into force right after the publication on the website.
Last Updated on 01.04.2019. This Privacy Policy is entering into force after 01.04.2019.
15. PERIOD OF VALIDITY
The Privacy Policy enters into force just after the publication until it is deleted from the website.
16. SECURITY
We implemented organizational and technical precautions to protect your Personal Data from being accidentally accessed, used, or lost in an 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. ELYSEE HOME rejects such an obligation.
17. INTERNATIONAL DATA TRANSFER
Residents of the EEA and Switzerland please note that the personal data that we obtain from you can be stored, processed, and transferred outside the EEA and Switzerland for the aims defined in this Privacy Policy. ELYSEE HOME takes serious methods to safeguard your data and protects the data in accordance with standards implemented in European Union, including the Standard Contractual Clause. In case of personal information transfer within our group companies requiring data process from EEA, ELYSEE HOME carries out this process in conformity to E.U. data protection conditions. ELYSEE HOME put into effect similar safeguards methods together with our partners and service providers. More details can be shared upon request.