PERSONAL DATA PROTECTION, PRIVACY AND COOKIES POLICY
Protection of personal data is an important issue for Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi ("Company") (https://www.kolektifhouse.co/). As a data controller, the Company adopts the principles stipulated by the PDPL in order to comply with the Personal Data Protection Law No. 6698 (the "PDPL"), and fulfils its obligations regarding the processing, deletion, destruction, anonymization, transfer of personal data, informing the data subject and ensuring data security. The Privacy and Personal Data Protection Policy prepared within this scope is made available to the real persons ("Data Subjects") whose personal data are processed.
This Privacy and Personal Data Protection Policy sets out:
- methods and legal grounds for collecting personal data;
- principles to be applied to the processing of personal data;
- which groups of persons' personal data are processed and which categories of personal data are processed in relation to these groups of persons (Data Categories) and sample data types;
- in which business processes and for what purposes these personal data are used;
- technical and administrative measures taken to ensure the security of personal data;
- to whom and for what purpose personal data may be transferred;
- retention periods for personal data,
- profiling and segmentation;
- what are the rights of the Data Subjects on their personal data and how they can exercise these rights;
- how the Data Subjects can change their positive or negative preferences for receiving electronic commercial messages;
- sharing personal data with public authorities;
- cookie usage and management.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi collects personal data through websites, mobile applications of the websites, social media accounts, cookies, call centres, notifications received from administrative and judicial authorities, and other communication channels in audio, electronic or written form in compliance with the legal grounds specified in Article 5 of the Personal Data Protection Law No. 6698. These legal grounds include:
- explicit provision in the laws;
- necessity of processing personal data directly related to the establishment or performance of a contract, provided that it is limited to the parties to the contract;
- personal data made public by the data subject themselves;
- necessity of processing personal data for the legitimate interests of the data controller, provided that it does not prejudice to the fundamental rights and freedoms of the data subject;
- necessity of processing personal data for the establishment, exercise, or protection of a legal right.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi adheres to the following principles in the collection, processing, and analysis of personal data:
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi will collect and process personal data in a lawful and fair manner, ensuring the protection of data subjects' rights. The principles of proportionality and necessity will be taken into account in carrying out these activities.
Personal data may only be processed for the purposes defined before its collection. Additional changes to the purpose can only be made to a limited extent and with justification.
Data subjects should be informed in detail before collection and processing of their personal data. Prior to data collection, data subjects should be informed about the following:
- identity of data controller and its representative, if any;
- purpose of processing personal data;
- recipients of the processed personal data and the purpose of such transfers;
- method and legal ground for collection of personal data;
- rights of the data subject under Article 11 of the PDPL.
Before the processing of personal data, it should be determined whether the transaction is necessary to achieve the purpose and to what extent it is necessary. If the purpose is acceptable and proportionate, anonymous or statistical data may be used.
Personal data that is no longer necessary is deleted, destroyed, or anonymized after the expiration of the retention periods stipulated by relevant laws and for the purposes of evidence.
Personal data must be accurate, complete, and up-to-date if it is is correct, complete and known. Inaccurate or incomplete data should be deleted, corrected, completed or updated.
Personal data should be stored and kept as confidential information. Personal Data should be protected and kept confidential on a personal level by taking necessary administrative and technical measures to prevent unauthorized access, illegal transactions, sharing, accidental loss, alteration or destruction.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi categorizes the data subject groups whose personal data are processed in its personal data processing processes and related activities as follows. However, personal data of other groups may also be processed in accordance with the personal data processing requirements stipulated in Articles 5 and 6 of the Personal Data Protection Law (the ''PDPL'') and within the legal grounds specified in this Personal Data Protection, Privacy, and Cookies Policy.
- First name, last name, date of birth, national identification number,
- City, district related to residence and purchased product, notification address, if necessary, current location information
- Mobile phone number, landline phone number, email address, company's notification address (if applicable), individual's residential address, postal code
- Tax office and number, invoice details, payment card information
- Membership information, membership ID number, specific current code assigned to the member in the company's billing system
- Purchased product(s), purchase amount, purchase date, call centre conversation records, consent for commercial electronic communication, campaigns/contests utilized, coupons used, order-related information
- IP address
- Password information
- Cookie records, targeting information, evaluations indicating preferences and interests
- Call centre conversation records, camera recordings obtained in mandatory areas owned by the company
- Start and end time of the service provided, type of the service utilized, transferred data amount, consent for commercial electronic communication given by the Data Subject, membership agreement approved , corporate membership agreement, other legal texts and contracts enabling the use of services provided by Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi
- Marketing-related SMS, email messages, or calls made by the call centre based on the consent for commercial electronic communication given by the Data Subject
- Records related to complaints and/or requests submitted by the Data Subject regarding the product or service purchased via the website, mobile application, social media accounts, or call centre, and the processes of evaluation or management of these requests
- First name, last name, date of birth, national identification number,
- City, district of residence (delivery address for the purchased product made through [kolektifhouse.co]
- Mobile phone number, email address, address, postal code, landline phone number
- Tax office, invoice details
- Purchased product(s), purchase amount, purchase date, call enter conversation records, consent for commercial communication, campaigns utilized, order-related information
- IP address
- Password information
- Cookie records, targeting information, evaluations indicating preferences and interests
- Call centre conversation records
- Start and end time of the service provided, type of the service utilized, amount of data transferred, consent for commercial electronic communication given by the Data Subject, other legal texts and contracts enabling the use of services provided by [kolektifhouse.co]
- Marketing-related SMS, email messages, or calls made by the call centre based on the consent for commercial electronic communication given by the Data Subject
- Records related to complaints and/or requests submitted by the Data Subject regarding the product or service purchased via the website, mobile application, social media accounts, or call centre, and the processes of evaluation or management of these requests
- Password, mobile phone, e-mail password information
- IP address
- Start and end time of the service provided, type of the service utilized, amount of data transferred
- First name, last name, date of birth, national identification number,
- City, district of residence (delivery address for the purchased product made through [kolektifhouse.co]
- Mobile phone number, e-mail address, address, postal code, landline phone number
- Tax office, invoice details
- National identification number, first name, last name
- E-mail address, landline phone number, REM address, address, mobile phone number
- Account Number, Tax Office, Tax Identification Number, tax board, IBAN Number
- Circular of signature, certificate of activity,
- Signature
- Carrying out membership procedures;
- Improving the services offered through the e-commerce platforms "https://www.kolektifhouse.co/" and "https://koplanet.kolektifhouse.co/marketplace'' [the ''platform''] operated by Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi, developing new services, and providing information related thereto;
- For the purpose of the performance of the Membership Agreement entered into with the Member Customer, analysing the preferences, interests and needs of the Member Customers and providing special promotions, opportunities and benefits to the Member Customers who have given their consents to receive commercial electronic messages;
- Conducting re-marketing, targeting, profiling, and analysis based on the express consents of the Member Customers, promoting and marketing applications, goods/products, and services according to the preferences and likes of the Member Customers;
- Resolving Member Customer issues and complaints;
- Improving the Member Customer experience on both the platform and mobile application;
- Tracking accounting and purchasing transactions;
- Ensuring compliance with legal processes and regulations;
- Responding to information requests from administrative and judicial authorities;
- Ensuring information and transaction security and preventing misuse;
- Making necessary arrangements to ensure that the data processed is up-to-date and accurate.
- Processing of online visitors data as per the Law No. 5651;
- Ensuring compliance with legal processes and regulations;
- Responding to information requests from administrative and judicial authorities;
- Ensuring information and transaction security and preventing misuse;
- Fulfilling legal obligations.
- Carrying out product-delivery processes;
- Tracking accounting and purchasing transactions;
- Ensuring compliance with legal processes and regulations;
- Responding to information requests from administrative and judicial authorities;
- Ensuring information and transaction security and preventing misuse;
- Making necessary arrangements to ensure that the data processed is up-to-date and accurate,
- Fulfilling legal obligations.
- Conducting contract processes;
- Tracking accounting and purchasing transactions;
- Ensuring compliance with legal processes and regulations;
- Responding to information requests from administrative and judicial authorities;
- Ensuring information and transaction security and preventing misuse;
- Making necessary arrangements to ensure that the data processed is up-to-date and accurate,
- Fulfilling legal obligations.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi is committed to taking all necessary technical and administrative measures to ensure the privacy, integrity, and security of personal data.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi takes necessary precautions to prevent unauthorized access to, misuse, unlawful processing, disclosure, alteration, or destruction of, personal data. Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi uses generally accepted security technology standards such as security firewalls and Secure Socket Layer (SSL) encryption when processing personal data. Additionally, when you send your personal data through the website, mobile application, or mobile site of Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi, these data are transferred using SSL.
To ensure the prevention of unauthorized access to, unlawful processing of, personal data, and the preservation of personal data, Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi:
- protects all areas on the website or mobile application where personal data are received with SSL;
- establishes and implements access authorization and control matrices for its employees to prevent the unlawful processing of personal data collected through the website or mobile application;
- conducts penetration tests and tests the system's resilience to unauthorized access to ensure that personal data are not accessed unlawfully;
- ensures that personal data in paper form is stored in locked cabinets and accessed only by authorized individuals;
- Personal data processed through cookies owned by third-parties from which services are received are deleted from the systems of these third-parties when the membership ends.
Although Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi has taken the necessary information security measures, in the event that personal data are damaged as a result of attacks on the platforms operated by the Company or the Company's system or in the hands of unauthorised third-parties, the Company shall immediately notify you and the Personal Data Protection Board and take the necessary measures.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi only transfers personal data to third-parties in accordance with the purposes stated in this Personal Data Protection, Privacy, and Cookies Policy and in compliance with Articles 8 and 9 of the Personal Data Protection Law. In this context, Member Customer/Guest Customer data processed and the information about the person to whom the product purchased will be delivered are shared with the seller and the shipping company, and these data can also be accessed by the call centre if necessary. The information about the person to whom an invoice will be issued is shared with the shipping company for the purpose of delivering the invoice to the relevant person.
The mobile phone number and/or email address details of Member Customers/Guest Customers are shared with the commercial electronic communication infrastructure service provider based on the consent for commercial electronic communication, in order to promote and advertise based on shopping preferences, likes, and habits and to provide benefits and opportunities through commercial electronic communication.
Website or mobile application usage preferences and browsing history are shared with domestic and international business partners providing cookie services for segmentation purposes and for contacting Member Customers/Guest Customers based on their preferences and likes. Personal data transfers carried out within this scope take place through secure environments and channels provided by the relevant third-party.
Data related to Member Customers/Guest Customers are shared with research companies to enhance Member Customer/Guest Customer satisfaction and loyalty.
In addition, your personal data will be shared with our international business partners for the provision of business development services, statistical and technical services, and the conduct of customer relations.
If Member Customers/Guest Customers/Online Visitors contact Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi via the corporate Whatsapp line, since the Whatsapp platform is a service provided from abroad, they will have sent their personal data abroad. If Member Customers/Guest Customers/Online Visitors do not want to send their personal data abroad using Whatsapp, they can use other communication channels provided by Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi.
The personal data transferred domestically and abroad as mentioned above are legally protected through provisions in compliance with the PDPL in our contracts, taking into account the fact that the counterparty of the legal relationship is the data controller or data processor.
When transferring personal information to countries outside of Turkey during information sharing as mentioned above, the data are transferred in accordance with this policy and as permitted by the applicable data protection laws.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi retains the personal data it processes in compliance with the Personal Data Protection Law (the ''PDPL'') for the periods prescribed in the relevant legislation or as required by the processing purpose. Additionally, your personal data may be retained to the extent necessary for the implementation of the necessary defences in case of any disputes between you and the Company.
You can review our Cookies Policy for the retention periods of personal data obtained through cookies.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi processes the personal data related to Member Customers/Guest Customers in order to:
- carry out profiling and segmentation for Member Customers/Guest Customers who have given their consents for receiving commercial electronic messages, in order to prepare more suitable contents, advertisements, promotions, and discounts according to their preferences.
-
carry out profiling and segmentation for Member Customers/Guest Customers who have not given their consents for receiving commercial electronic messages, in order to:
- improve products (determining the most sold or unsold product categories);
- organise campaigns for customer groups that have the potential to buy a certain product by making modelling by analysing their shopping preferences and uploading them to the system;
- take actions to increase sales potential.
Within the scope of profiling and segmentation activities, the personal data of Member Customers/Guest Customers, such as name, surname, mobile phone, email, or address information, are not directly used. Instead, they are processed with Member Customer/Guest Customer IDs assigned to them. The use of Member Customer/Guest Customer IDs, or in other words, pseudonymized data, ensures the protection of the personal data of the Customer/Member. Member Customer/Guest Customer IDs are accessible only to the relevant individuals or departments within https://koplanet.kolektifhouse.co/. These IDs assigned to Member Customers/Guest Customers are stored encrypted in the system by Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi, and access to this section is limited to authorized individuals.
The rights that the data subjects have under Article 11 of the PDPL regarding their personal data processed by Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi are listed below:
- right to know whether their personal data are being processed;
- right to request information if their personal data have been processed;
- right to know the purpose of processing their personal data and whether they are used for their intended purpose;
- right to know about the third-parties to whom their personal data are transferred home or abroad;
- right to request the correction of their personal data if it has been processed in an incomplete and incorrect manner;
- right to request the deletion or destruction of their personal data within the framework of the requirements stipulated in Article 7 of the PDPL;
- right to request that the actions taken under sub-paragraphs (d) and (e) be notified to the third-parties to whom their personal data have been transferred;
- right to object to any result against them that arises from the analysis of personal data exclusively through automated systems;
- right to demand compensation in case of damages due to the unlawful processing of their personal data.
By accessing the "Communication Preferences" section at any time, you can change or update your preferences you have made regarding receiving commercial electronic communications when you became a member to the website or mobile application of the electronic commerce platforms operated by Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi, or at any later time.
Terminating your membership does not mean revoking your consent to receive commercial electronic communications. Therefore, please ensure that you have completed all the procedures to revoke your consent.
Regarding cookie management, you can follow the steps specified in our Cookies Policy.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi may share your personal data related to your visits or membership to the electronic commerce platforms and mobile applications operated by it, as well as your traffic information such as browsing data, with public institutions and organizations authorized to legally request such information, to fulfil its obligations under company laws (in cases where there is a legal or administrative obligation to notify or provide information, including but not limited to combating crime, threat to state and public security).
We use cookies on our website to monitor users' preferences. Cookies are small files that are left on your computer's hard drive. They simplify navigation and make the website much more convenient to use. Cookies also help us identify the most popular areas on our website. In this way, we can create the content of our websites to better meet your needs, so we can improve the service we provide to you. Cookies can also be used to determine if our website has been accessed from your computer before.
You can also use our website without cookies, you can prevent the storage of cookies on your computer's hard disk by selecting the * block cookies * setting in your browser settings. However, we would like to draw your attention to the fact that many browsers automatically accept cookies and if you do not accept cookies, your use of our website may be limited.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi retains the personal data processed through its website, mobile application, or mobile site in accordance with Article 7, 17 of the Personal Data Protection Law (the ''PDPL'') and Article 138 of the Turkish Penal Code, as well as for the periods required by the processing purpose. After the expiration of these periods, the Company will delete, destroy, or anonymize personal data in accordance with the Regulation on Deletion, Destruction, or Anonymization of Personal Data.
Deleting personal data by Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi refers to making personal data inaccessible and unusable for the respective users. Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi establishes and implements an access authorization and control matrix at the user level for this purpose and takes necessary measures for the deletion process in the database.
Destroying personal data by Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi refers to making personal data inaccessible, irretrievable, and unusable by anyone in any way.
KAnonymizing personal data by Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi refers to rendering personal data unattributable or non-identifiable to any real person, even if it is matched with other data.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi provides detailed information on the methods, technical and administrative measures taken for deletion, destruction, and anonymization within the scope of the Personal Data Storage and Destruction Policy prepared in accordance with the Regulation. In this policy, the time interval for periodic destruction required by the Regulation is six (6) months.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi may make changes to this Privacy/Personal Data Protection Policy at any time. These changes will take effect immediately upon the publication of the modified Privacy/Personal Data Protection Policy. In order to be aware of the changes in this Privacy/Personal Data Protection Policy, necessary notifications will be provided to our members.
Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi has registered with the Data Controllers Registry as specified in Article 16 of the Turkish Personal Data Protection Law (the ''PDPL''). Accordingly, the information and documents submitted to the Board for registration are as follows:
- Identity and address information of Kolektif House Gayrimenkul İşletmeciliği ve Hizmetleri Ticaret Anonim Şirketi as the data controller and, if any, its representative;
- Descriptions regarding the purpose of processing personal data;
- Explanations about the groups of data subjects and their data categories;
- Recipients or recipient groups to whom personal data may be transferred;
- Personal data allowed to be transferred to foreign countries
- Measures taken for personal data security;
- Maximum time period required for the purpose for which personal data are processed.
