PROTECTION OF PERSONAL DATA
DAP GAYRİMENKUL GELİŞTİRME ANONİM ŞİRKETİ CLARIFICATION TEXT WITHIN THE SCOPE OF THE PERSONAL DATA PROTECTION LAW
Pursuant to Law No. 6698 on the Protection of Personal Data (“KVKK”), this clarification text has been prepared by Dap
Gayrimenkul Geliştirme Anonim Şirketi to inform third parties whose data is processed, excluding employees, in the
capacity of data controller. As the data controller, our company may process, store, classify, update, and, where
permitted by law, transfer to third parties the personal and sensitive personal data of third parties, within the scope
of the purposes listed below, in accordance with the law.
1. Definitions
Law: Law No. 6698 on the Protection of Personal Data (KVKK).
Personal Data: Any information relating to an identified or identifiable natural person.
Sensitive Personal Data: Data related to race, ethnic origin, political opinions, philosophical beliefs, religion, sect
or other beliefs, clothing, association/foundation/union membership, health, sexual life, criminal convictions and
security measures, biometric and genetic data, etc.
Processing of Personal Data: Any operation performed on personal data by automated or non-automated means, provided that
it is part of a data recording system, such as collection, recording, storage, preservation, alteration, reorganization,
disclosure, transfer, acquisition, making available, classification, or prevention of use.
Data Subject: The natural person whose personal data is being processed.
Data Processor: The real or legal person who processes personal data on behalf of the data controller with given
authority.
Data Controller: The real or legal person who determines the purposes and means of processing personal data and is
responsible for the establishment and management of the data recording system.
2. Purpose of Processing Your Personal / Sensitive Personal Data
Personal and/or sensitive personal data obtained by Dap Gayrimenkul Geliştirme Anonim Şirketi may be processed within
the following scope: execution of emergency management processes, information security processes,
recruitment/internship/student selection and placement processes, management of application processes of employee
candidates, audit/ethical activities, execution of training activities, management of access authorizations, execution
of activities in accordance with legislation, financial and accounting processes, customer loyalty programs, ensuring
physical space security, assignment processes, legal affairs management, internal audit/investigation/intelligence
activities, communication activities, planning of human resources processes, recruitment and evaluation processes,
business activity management/auditing, occupational health and safety activities, contract negotiations and signings,
collection and evaluation of suggestions for improvement, business continuity, logistics operations, purchasing
processes, after-sales support services, sales processes, production and operational processes, customer relationship
management, customer satisfaction activities, organization and event management, marketing analysis, performance
evaluation, advertising/campaign/promotion processes, risk management, data storage and archiving, contract processes,
sponsorship activities, strategic planning, tracking of requests and complaints, ensuring the security of movable
property and resources, supply chain management, wage policy management, product/service marketing processes, proxy and
signature circular processes, ensuring operational security, management of investment processes, career development,
providing information to authorized institutions and organizations, and management activities.
3. Transfer of Your Personal / Sensitive Personal Data
Your personal data processed within the scope of the purposes mentioned above may be transferred in accordance with the
principles set out in KVKK and under Articles 8 and 9, to our business partners, shareholders, affiliates, suppliers,
group companies, authorized public institutions and organizations, service providers and real persons we work with to
conduct our activities, and to independent audit companies, provided it is legally required and limited to the purposes
stated.
4. Transfer of Your Personal / Sensitive Personal Data Abroad
Dap Gayrimenkul Geliştirme Anonim Şirketi does not currently transfer your data abroad. If such transfer is required in
the future, necessary notifications will be made by our company, and your explicit consent will be obtained as required
by law following proper disclosure.
5. Method of Collecting Personal / Sensitive Personal Data
Your personal data is collected by Dap Gayrimenkul Geliştirme Anonim Şirketi through applications, emails, and various
channels to carry out our activities and based on the legal reasons specified below.
6. Legal Grounds for Processing Personal / Sensitive Personal Data
Your personal data is collected, used, recorded, stored, and processed in a lawful and honest manner, by providing clear
and understandable written information and obtaining explicit consent where necessary. It is processed in connection
with and limited to the legitimate purposes stated above, for the establishment of a contract, to exercise legal rights
arising from laws and contracts, to fulfill the company’s legitimate interests or legal obligations, and in accordance
with the principle of proportionality. These data are securely collected both physically and electronically throughout
the beginning and continuation of the contractual relationship. If a specific retention period is stipulated by law for
any data, they will be stored securely for that period in both physical and electronic environments. Accordingly, your
personal/sensitive personal data may be processed and transferred based on your explicit consent or without consent in
cases stated in Articles 5(2) and 6(3) of the KVKK.
7. Ensuring the Security of Personal Data
Our company takes necessary measures to ensure an appropriate level of security for the protection of personal data in
line with Article 12(1) of KVKK.
8. Your Rights as a Data Subject Under KVKK
According to Article 11 of KVKK, you have the following rights:
To learn whether your personal data is being processed,
To request information if your data has been processed,
To learn the purpose of processing and whether it is being used in accordance with its purpose,
To know the third parties to whom data is transferred domestically or abroad,
To request correction if your data is incomplete or incorrectly processed,
To request deletion or destruction of data under the conditions set forth in Article 7,
To request that correction or deletion operations be notified to third parties to whom data was transferred,
To object to any result that is against you and arises from analysis through automated systems exclusively,
To claim compensation in case of damage due to unlawful processing of personal data.
9. Questions and Requests
You may submit your requests regarding your rights mentioned above to our company’s address at Altayçeşme Mahallesi,
Zeytindalı Sokak, No:16 B Blok Maltepe / İstanbul, or to the registered email address dapgayrimenkul@hs01.kep.tr. Your
request will be finalized within thirty (30) days free of charge. However, if the process requires an additional cost, a
fee may be charged based on the tariff set by the Board.
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