PRIVACY AND COOKIE POLICY

1. Important information and who we are

Purpose of this privacy policy

aims to inform you about how Avla Real Estate collects and processes your personal data through your use of this website.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide in specific situations where we collect or process personal data about you so that you are fully aware of how and why we use your data. . This privacy policy supplements and is not intended to override any other policies and notices.

Controller

Avla Real Estate Gayrimenkul A.Ş. is the controller and responsible for your personal data (collectively referred to as "Avla Real Estate", "we", "us" or "our" in this privacy policy).

We have appointed a Compliance Manager who is responsible for overseeing questions regarding this privacy policy. If you have any questions about this privacy policy, including requests to exercise your legal rights, please contact the Compliance Manager using the information provided below.

Contact details

Full name of the legal entity: Avla Real Estate Gayrimenkul A.Ş. (Avla Real Estate )

Name of Compliance Manager: M. Sami Akbeniz

Email address: realestate @ avla.com.tr

Postal address: Örnek Mah. Ercüment Batanay Sk. No:14B Dumankaya İkon Sitesi A2 Block Flat: 197 Ataşehir 34704 İSTANBUL, Istanbul,Türkiye

 

This version is the latest 1 0 Updated on April 2024 .

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes during your relationship with us.

Third party links

This website may contain links to third-party websites, plug-ins and applications. Clicking or enabling these links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2. Data we collect about you

Personal data or personal information means any information about an individual from which that individual can be identified. It does not include data from which identity has been removed (anonymous data).

We may collect, use, store and transfer different types of personal data about you as follows:

Identity Data includes full name, username or similar identifying information, marital status, title, date of birth, and gender.

Contact Data includes address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details of payments to and from you and other details of services you have purchased from us.

Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data includes your username and password, orders placed by you, your interests, preferences

Usage Data includes information about how you use our website and services.

Marketing and Communications Data includes your preferences in receiving marketing and communication preferences from us and our third parties.

We also collect, use and share Aggregate Data, such as statistical or demographic data, for any purpose. Aggregate Data may be derived from your personal data, but is not legally considered personal data as it does not directly or indirectly reveal your identity. For example, we may collect your Usage Data to calculate the percentage of users who access a particular website feature. However, if we combine or link Aggregated Data with your personal data so that we can directly or indirectly identify you, we will treat the combined data as personal data.

 

3. How is your personal data collected?

We use different methods to collect data from and about you, including:

Direct interactions. You may provide us with your Identity, Contact and Financial Data by filling in forms or by contacting us by post, telephone, email or other means. This includes personal data you provide in the following cases:

when you contract with us to provide property services ;

when you request marketing to be sent to you ; or

When you participate in a survey .

Automated technologies or interactions. When you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookies policy for more details.

Third parties or publicly available sources. We may send or receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU;

(b) advertising networks located outside the EU, such as the Facebook Advertising Platform; And

(c) search information providers such as Google based outside the EU.

Identity and Contact Data of the following parties:

(a) Enforcement bodies within the EU and Turkey , such as the Land Registry; And

(b) Real estate portals within the EU and Turkey .

 

4. How do we use your personal data?

We will only use your personal data where we are permitted by law. We will most commonly use your personal data in the following situations:

a) When we need to fulfill the contract we are about to enter into or have signed with you.

b) It is necessary for our legitimate interests (or those of a third party) and these interests are not overridden by your interests and fundamental rights. Legitimate interest means our business's interest in operating and managing our business in a way that enables us to provide you with the best service and the best and safest experience. Before processing your personal data for our legitimate interests, we ensure that we consider and balance the potential impact on you (both positive and negative) and your rights. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are required or permitted to do so by law). You can learn more about how we weigh our legitimate interests against the potential impact on you in relation to certain activities by contacting us.

c) Where we are required to comply with legal and regulatory requirements.

Generally, we do not rely on consent as a legal basis for processing your personal data, other than to send you direct marketing communications by telephone, post, email or other electronic means. You have the right to withdraw your consent to marketing at any time by contacting us.

​

For what purposes we will use your personal data

Below we have provided in tabular format a description of all the ways we plan to use your personal data and the legal basis on which we do so.

Note that we may process your personal data on more than one legal basis, depending on the specific purpose for which we use your data. Where more than one ground is set out in the table below, please contact us if you need details of the specific legal ground we are relying on to process your personal data.

Purpose/Activity

To register you as a new customer

Data type

(a) Identity

(b) Communication

Legal basis for processing, including the basis of legitimate interest

Performance of a contract with you

Purpose/Activity

To provide you with services including:

(a) Managing payments, fees and expenses

(b) Collect and recover money owed to us

Data type

(a) Identity

(b) Communication

(c) Financial

(d) Transaction

(e) Marketing and Communications

Legal basis for processing, including the basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to collect debts owed to us)

Purpose/Activity

To manage our relationship with you this will include:

(a) To notify you about changes to our services, terms or privacy policy

(b) Asking you to leave a comment or participate in a survey

Data type

(a) Identity

(b) Communication

(c) Profile

(d) Marketing and Communications

Legal basis for processing, including the basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records up to date and to review how our customers use our property services)

Purpose/Activity

To enable you to complete a survey or provide us feedback

Data type

(a) Identity

(b) Communication

(c) Profile

(d) Use

(e) Marketing and Communications

Legal basis for processing, including the basis of legitimate interest

(a) Necessary for our legitimate interests (to research how customers use our property services, improve them and grow our business)

Purpose/Activity

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Data type

(a) Identity

(b) Communication

(c) Technical

Legal basis for processing, including the basis of legitimate interest

(a) Necessary for our legitimate interests (operating our business, provision of administration and IT services, network security, fraud prevention and in the context of implementing a business reorganization or group restructuring)

( b) Necessary to comply with a legal obligation

Purpose/Activity

To deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertisements we serve to you

Data type

(a) Identity

(b) Communication

(c) Profile

(d) Use

(e) Marketing and Communications

(f) Technical

Legal basis for processing, including the basis of legitimate interest

Necessary for our legitimate interests (to research how customers use our services, improve them, grow our business and inform our marketing strategy)

Purpose/Activity

Using data analytics to improve our website, property services, marketing, customer relationships and experiences

Data type

(a) Technical

(b) Use

Legal basis for processing, including the basis of legitimate interest

Necessary for our legitimate interests (to identify types of customers for our property services, keep our website up to date and relevant, develop our business and inform our marketing strategy)

Purpose/Activity

To provide you with suggestions and suggestions about real estate services that may interest you.

Data type

(a) Identity

(b) Communication

(c) Technical

Legal basis for processing, including the basis of legitimate interest

Necessary for our legitimate interests (to improve our services and grow our business)

Purpose/Activity

Previous/current landlords/agents/employers etc. To contact! For the purpose of providing reference services to our customers. This information can be provided directly by you or through our reference company.

Data type

( a ) Communication

(b) Profile

(c) Financial

Legal basis for processing, including the basis of legitimate interest

Necessary for our legitimate interests (to maintain our reference due diligence and improve our customer service offer)

Purpose/Activity

Share email data with third-party social media providers to create lookalike audiences.

Data type

(a) Identity

Legal basis for processing, including the basis of legitimate interest

Necessary for our legitimate interests (to develop our services, grow our business and improve our customer service)

 

 

 

Marketing

We strive to provide you with choices regarding certain uses of personal data, particularly for marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form an opinion about what we think you might want, need or be interested in. This is how we decide which services and offers might be suitable for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or provided us with your information when you signed up for a promotion and in each case you have not opted out of receiving such marketing communications.

Third party marketing

We will not share your personal data with any company outside Douglas & Gordon for marketing purposes.

Deactivation

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

When you opt out of receiving these marketing messages it will not apply to personal data provided to us as a result of a service purchase, service experience or other transaction.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or reject cookies, please note that some parts of this website may become inaccessible or may not function properly. For more information about the cookies we use, please see our Cookie Policy. You can review your cookie preferences at any time by clicking here.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose. If you would like to receive clarification on how compatible the processing for the new purpose is with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose we will inform you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent in accordance with the above rules, where this is required or permitted by law.

 

5. Disclosure of your personal data

We may have to share your personal data with the parties listed below for the purposes specified in the table in paragraph 4 above.

Avla Real Estate offices in different locations than the office you initially contacted or visited ;

Contractors;

Mortgage brokers;

Lawyers;

Cartographers;

Photographer/Spatial Planner/EPC engineers;

Board of Directors Companies for Sale/Rent;

Zero Deposit, rental deposit guarantee provider;

Inventory Officers;

Tenant/Guarantor Reference Companies;

Service providers – Tenants of managed properties will have their contact information sent to the providers so that an account can be created in their name;

Third parties involved in your transaction; Landlords, Sellers, Tenants or Buyers;

Third parties with whom we need to work to perform our contract with you;

If we introduce you to a property, they and other agents then in order to receive the required commission; And

Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire or merge with other businesses. In the event of a change to our business, the new owners may use your personal data as set out in this privacy policy;

We require all third parties we deal with to respect the security of your personal data and process it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for stated purposes and in accordance with our instructions.

 

6. International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so processing of your personal data will involve the transfer of data outside the EEA.

When we transfer your personal data outside the EEA, we ensure that a similar level of protection is provided by ensuring that at least one of the following security measures is implemented:

Where we use certain service providers, we may use contracts that give personal data the same protection that it has in Europe; And

When we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For more details, see European Commission: EU-US Privacy Shield.

If you would like to learn more about the specific mechanism we use when transferring your personal data outside the EEA, please contact us.

 

7. Data security

We have taken appropriate security measures

 

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

To request correction of the personal data we hold about you. This enables incomplete or inaccurate data we hold about you to be corrected, although we may need to verify the accuracy of any new data you provide to us.

Request deletion of your personal data. This allows you to ask us to erase or remove personal data when there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we are required to erase your personal data. comply with local laws. However, please note that we may not always be able to comply with your erasure request for specific legal reasons, which will be notified to you at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or the legitimate interests of a third party) and there is something about your particular situation that makes you want to object to processing on this ground because you consider that it affects your fundamental rights and freedoms. You also have the right to object that we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds for processing your information that override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to determine the accuracy of the data; (b) where our use of the data is unlawful but you do not want us to delete it; (c) where you want us to retain data even if we no longer need it, such as where you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or a third party. We will provide your personal data to you or a third party of your choosing in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially gave us permission to use or where we use the information to perform a contract with you.

Where we rely on consent to process your personal data, you can withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with some services. We will let you know if this is the case when you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

Usually no fee required

You will not have to pay any fees to access your personal data (or to exercise any of our other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these cases.

What might we need from you?

We may need to request certain information from you to help us verify your identity and secure your right to access your personal data (or your right to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to request further information regarding your request to expedite our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Sometimes this can take longer than a month if your request is particularly complex or you make a large number of requests. In this case we will inform you and keep you updated.

 

9. Cookies ("Cookies"), Pixels, and similar technologies

This website uses cookies and similar technologies. Cookies are small units of data that are required to use our website and are temporarily stored on your hard drive by your browser. A cookie usually contains a unique identifier, which consists of a randomly generated number and is stored on your device. Some of these identifiers expire when your website session ends, while others may remain on your device for longer periods of time. Technically necessary cookies will be used automatically. Other cookies (or similar technologies) will only be applied with your prior consent.
 

There are different types of cookies. First-party cookies are placed by the visited website and can only be read by that website. Third party cookies are placed by other organizations from which we receive service for various services we use. As an example, we use external analytics service providers who set cookies on our behalf to identify liked or disliked content on our website. In addition, the website you are visiting may contain embedded content from a source, for example YouTube, and cookies may also be set by this source.
 

A pixel is generally a transparent image measuring just 1 pixel x 1 pixel that is placed on a website for the purpose of personalizing content or making the browser experience more efficient and easier and collects certain data such as IP address, browser type, access time or cookies previously set. . They are often used in conjunction with cookies because pixels create and manage cookies.

If you consent, the website will collect detailed information about the device's operating system, browser, installed fonts, IP address, plug-ins and more. In this way, the device can be re-identified for user-related marketing purposes.