GENEL AYDINLATMA METNİ
Privacy Policy & Personal Data Protection Notice
Legal Notice: This document is an unofficial English translation of our Personal Data Protection Notice (KVKK Aydınlatma Metni), prepared in accordance with Turkish Law No. 6698 on the Protection of Personal Data ("KVKK"). It is provided for informational purposes only. In case of any discrepancy or conflict between this translation and the Turkish original, the Turkish version shall prevail and shall be legally binding. The original Turkish text is available at primedegerleme.com/tr/kurumsal/k-v-k-k.
As Prime Gayrimenkul Değerleme ve Danışmanlık A.Ş., acting in the capacity of data controller, and in line with the importance we attach to the security of your personal data, all personal data we hold is processed, stored and transferred in accordance with Turkish Law No. 6698 on the Protection of Personal Data ("KVKK").
Our Company places great importance on the lawful processing and protection of personal data belonging to service providers, suppliers and their employees, consultants, customers, business partners, visitors and other third parties, in full compliance with Law No. 6698 on the Protection of Personal Data.
This notice has been prepared pursuant to Article 10 of the Law on the Protection of Personal Data, titled "Obligation of the Data Controller to Inform", and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform (Official Gazette No. 30356, dated 10.03.2018), for the purpose of informing our customers, suppliers of goods and services and their employees, contracted consultants with whom we have business relationships, business partners, visitors and other third parties whose personal data is collected, stored and processed by our Company as data controller.
Data Controller Information
| Company Name | Prime Gayrimenkul Değerleme ve Danışmanlık A.Ş. |
| Phone | +90 (212) 214 60 60 |
| Address | Esentepe Mah. Büyükdere Cad. No:127 Astoria A Blok D:1303 Şişli – İSTANBUL / TURKEY |
| Registered E-mail (KEP) |
Purposes of Processing Your Personal Data
In accordance with the general principles set forth in Article 4 of the Law on the Protection of Personal Data — namely, being processed lawfully and fairly; being accurate and, where necessary, kept up to date; being processed for specified, explicit and legitimate purposes; being relevant, limited and proportionate to the purposes for which they are processed; and being retained only for the period required by the relevant legislation or the purpose of processing — your categorized personal data is processed for the following purposes:
Your identity information (name, surname, date of birth, Turkish ID card information, Turkish ID number, photograph) and your contact information (residential address, business address, phone number, mobile phone number, e-mail address, registered e-mail/KEP address) are processed for the purposes of:
Ensuring corporate communication; carrying out statistical work; performing the work and transactions arising from signed contracts and protocols; managing customer relations; fulfilling legal obligations required or mandated by applicable legislation; maintaining contact with natural and legal persons with whom the Company has business relationships; preparing legal reports; managing the sale of goods and services; conducting promotional activities; managing storage and archiving activities; ensuring business continuity; planning and executing corporate communication and management activities; managing relationships with business partners and suppliers; creating visitor records; ensuring the physical security of premises; fulfilling obligations arising from legislation; fulfilling other legal obligations towards competent and authorized public institutions and bodies; resolving reported issues and complaints; conducting customer relationship management processes; and carrying out customer-satisfaction-oriented activities.
Your financial information (tax number, tax office, bank account number, IBAN and invoice details), together with your identity and contact information, is processed for the purposes of maintaining accounting records, opening current accounts, carrying out finance and accounting operations, and communicating with you on these matters.
Your visual records captured via security cameras are processed for the purposes of ensuring the physical security of our premises and creating and monitoring visitor records.
Your legal transaction information is processed and stored for the purposes of fulfilling our other legal obligations towards competent and authorized public institutions and bodies, and for use as evidence in any disputes that may arise between us.
Transfer of Your Personal Data to Third Parties and Purposes
The Company acts in accordance with Article 5 of the Law, the provisions on the processing of special categories of personal data in Article 6, and the rules on the transfer of personal data in Articles 8 and 9, as well as the principles published by the Personal Data Protection Authority. Special categories of personal data are not transferred without the explicit consent of the data subject.
Your personal data may be transferred, within the framework of the Law and other applicable legislation, to: competent and authorized public institutions and bodies in order to fulfill obligations arising from legislation; regulatory and supervisory authorities for the purpose of providing information to authorized persons, institutions and bodies; all judicial authorities for use as evidence in any legal disputes between us; your authorized representatives and attorneys; third parties from whom we receive consulting services, including tax and financial advisors, for the purpose of conducting and auditing business activities in compliance with legislation; contracted professional experts and assistants, consultants and advisors; service suppliers; courier companies; other public institutions and banks within the scope of legal obligations arising from our activities; and to the Capital Markets Board (CMB / SPK) and the Association of Appraisal Experts of Turkey, in accordance with the legislation applicable to our operations.
Method and Legal Basis of Collection
The "legal basis" referred to in Article 10(1)(ç) of the Law refers to which of the processing conditions set forth in Articles 5 and 6 of the Law serves as the basis for processing personal data within the scope of the obligation to inform.
Personal data is collected in electronic and physical media, based on legitimate interest, through information we request directly from you; personal data shared with us physically or digitally within the scope of a business relationship; contract information; financial data and invoice information you provide; digital applications submitted through our websites; information you transmit by e-mail and KEP; petitions and applications; legal notifications; correspondence with our Company; and applications made to our Company under Article 11 of the KVKK. Such data is retained in accordance with legal retention periods and the requirements of the business.
Your personal data is collected and processed on the basis of at least one of the following legal grounds set forth in the Law on the Protection of Personal Data, and where necessary, with your explicit consent: Article 5/2(c) — "processing of personal data of parties to a contract is necessary, provided it is directly related to the establishment or performance of the contract"; Article 5/2(ç) — "processing is mandatory for the data controller to fulfill its legal obligations"; Article 5/2(e) — "data processing is mandatory for the establishment, exercise or protection of a right"; and Article 5/2(f) — "processing is mandatory for the legitimate interests of the data controller, provided that this does not harm the fundamental rights and freedoms of the data subject".
Our Company does not collect personal data without a valid purpose and a valid legal basis or explicit consent.
Your Rights
In accordance with Article 10 of the KVKK, the Company informs data subjects of their rights and guides them on how to exercise these rights. Pursuant to Article 11 of the KVKK, by applying to the Company, you have the right to:
- Learn whether your personal data is being processed
- Request information regarding the processing of your personal data, if any
- Learn the purpose of processing and whether your data is used in line with that purpose
- Know the third parties, in Turkey or abroad, to whom your personal data is transferred
- Request the correction of your personal data if it has been processed incompletely or inaccurately
- Request the deletion or destruction of your personal data within the framework of Article 7 of the KVKK, without prejudice to our Company's legal obligations
- Request that the corrections and deletions carried out under the above items be notified to third parties to whom your data has been transferred
- Object to any adverse outcome resulting from the analysis of your personal data exclusively through automated systems
- Request compensation for damages you suffer due to the unlawful processing of your personal data
You may submit your written and wet-signed application under Article 11 of the Law in person to Esentepe Mah. Büyükdere Cad. No:127 Astoria A Blok D:1303 Şişli – İSTANBUL / TURKEY, by notary public, to our registered e-mail address
Requests contained in your application will be concluded free of charge within a maximum period of thirty (30) days, depending on the nature of the request. However, where the processing of the request requires an additional cost for the Company, the fee set by the Personal Data Protection Board may be charged.