As Erra Proptech Real Estate Development Inc. (ERRAHOME), we take the utmost care to ensure the confidentiality of your personal data and process your data in accordance with the legislation while providing the services we offer to you. As the data controller within the framework of the Personal Data Protection Law No. 6698 (KVKK), we are responsible for protecting your personal data managed by Errahome. https://errahome.com/ We inform you about the processing of your personal data through the website.
In accordance with the Law on the Protection of Personal Data No. 6698 and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Disclose, this disclosure text has been prepared to inform users about the procedures and principles to be followed in protecting their personal data in their relations with ERRAHOME.

BASIC DEFINITIONS IN KVKK

Personal Data	: Any information relating to an identified or identifiable natural person.
Processing of Personal Data	: Any operation performed on personal data, such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, either fully or partially by automatic means or non-automatic means provided that it is part of any data recording system.
Data Controller	: The natural or legal person responsible for determining the purposes and means of processing personal data and for establishing and managing the data recording system. Within the scope of this text, the data controller is "Erra Proptech Gayrimenkul Geliştirme A.Ş."
Data recording system (VERBIS)	: It is a recording system in which personal data is structured and processed according to certain criteria.
Explicit Consent	Consent: Consent based on information and expressed with free will regarding a specific subject.
Board	: Refers to the Personal Data Protection Board.
Cookies	Cookies are small files that are saved on users' computers or mobile devices and help store preferences and other information about the web pages they visit.
Contact Person	: The real person whose personal data is processed.

PERSONAL DATA ABOUT USERS
At ERRAHOME, we may process your personal data in accordance with the purposes and processing conditions specified in this text. The personal data subject to processing are as follows:

a. Identity Data
Name, surname, Turkish ID Number, Passport Number, Date of Birth, Place of Birth.

b. Communication Data
Phone number, email address, internal company contact information (company phone number, extension phone number, corporate email address)

c. Payment Information
Redirection to card payment system.

d. Customer Transaction Data
Website usage data, statistical data.

e. Location Information
Your country, city and address information entered manually.

f. User Transaction Records, Login Methods

h. Other Data

If the accommodation is sponsored by a company; company name, company tax identification number, company address, Invoice-Bills-Cheque Information, Order Information, reservation history information, IP address information, website login-logout records, request-complaint information.

PURPOSE OF PROCESSING PERSONAL DATA
Within the scope of Article 10 of the KVKK and Article 5 of the Communiqué, personal data of customers can be processed for the following purposes in accordance with the processing conditions specified in Article 4 of the KVKK:

• Fulfillment of service obligations in accordance with the service contract.
• Carrying out contract processes regarding reservations made through the website.
• In order to fulfill the requirements of the services we provide to our customers in accordance with the requirements of the contract and technology and to improve the services we offer;
• To provide information to prosecutors, courts and relevant public officials on matters related to public security and legal disputes, upon request and in accordance with the legislation;
• To be able to offer a wide range of opportunities to our members or to share these opportunities with individuals or institutions that can offer them within the legal framework;
• Carrying out the reservation process, payment process and issuing invoices.
• To be able to communicate during the contract process.
• Creating your membership registration and logging into your account.
• Providing information about possible changes in the terms of service,
• Preparing all records and documents that will form the basis of the transaction in electronic (internet/mobile etc.) or paper format,
• Fulfilling legal obligations and exercising rights arising from current legislation,
• Providing information to authorized persons, institutions and organizations
• Execution of emergency management processes
• Carrying out communication activities
• Carrying out accounting and financial affairs
• Carrying out storage and archive activities
• Conducting analyses, reporting and auditing activities to improve products and services.
• To be able to provide information regarding complaints/suggestions.

METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA
Personal data may be obtained directly from the relevant person, third parties, and legal authorities during the establishment of a legal relationship. In this context, personal data is collected verbally, in writing, or electronically through written or verbal communication channels with our Company, such as through tools such as email, as required by the user agreement.
According to Article 5 of the Personal Data Protection Law (KVKK), personal data cannot be processed without the explicit consent of the data subject. The law specifies exceptions where explicit consent is not required. Personal data may be processed by our company without explicit consent, provided that there is an explicit provision in the law, it is directly related to the establishment or performance of a contract, processing personal data belonging to the parties to the contract is necessary, it is necessary for the company to fulfill its legal obligation, it has been made public by the data subject, data processing is necessary for the establishment, exercise, or protection of a right, and processing is necessary for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the data subject.
In order for ERRAHOME to continue its activities, personal data is processed within the scope of the conditions and purposes of processing specified in Articles 5 and 6 of the KVKK and in line with the principles and procedures stipulated by other relevant legislation, in order to achieve the purposes specified in this Disclosure Text and to fulfill legal obligations, for the legal reasons stated above.
In this context, your name, surname, contact information, address, Turkish ID Number, date of birth, place of birth, payment information, customer transaction information obtained from the website; and if the accommodation is sponsored by a company; company name, company tax identification number, company address, Invoice-Bills-Cheque Information, Order Information, reservation history information, IP address information, website login-logout records, request-complaint information are processed automatically through the website because they are necessary for the establishment and performance of the contract established with ERRAHOME, the processing of personal data to fulfill our legal obligations, and is mandatory for our legitimate interests.
In addition, your name, surname and contact information are processed, with your explicit consent, during the conduct of promotions, campaigns and advertising activities within the scope of products and services provided by ERRAHOME, within the scope of advertising, promotion and information in the areas where ERRAHOME operates commercially.
TO WHOM AND FOR WHAT PURPOSE PERSONAL DATA MAY BE TRANSFERRED
Customers' personal data may be shared and transferred with our shareholders, direct or indirect domestic/international affiliates; member companies using the errahome.com infrastructure, including but not limited to persons and organizations related to the services provided; program partner organizations from whom we receive services, cooperate, domestic/international organizations, and private legal entities from whom we receive services (in matters of audit, law, etc.); independent auditing firms; financial institutions; business partners at home and abroad, primarily direct and indirect affiliates; companies located at home and abroad that provide storage, archiving, and information technology support (servers, hosting, programs, cloud computing); and legally authorized public institutions, provided that adequate and effective measures are taken in accordance with the security and confidentiality principles set forth in the legislation in order to achieve the above-mentioned purposes.

SHARED PARTIES	SHARING EXAMPLES
Legally Authorized Public/Private Institution or Organization	Data can be shared with official institutions and organizations such as the Ministry of Treasury and Finance, Internal Audit Coordination Board, Court of Accounts, Judiciary and Execution authorities, other public and foundation companies, companies located abroad for international programs, and notaries.
Supplier/Business Partner/Consultant	Data may be shared with consultants, organizations and parties from which the company receives services complementary to its activities and with which it cooperates, limited to the purposes of their activities.

The Company does not transfer any data that is not related to its purposes. The exception to this requirement is when the transfer of the data in question is required by law, or is necessary for a criminal investigation, or is requested by an official authority based on legislation and with a justified reason.

STORAGE PERIOD OF PERSONAL DATA
In accordance with the provisions of the Personal Data Protection Law, when the purpose requiring processing of your personal data as per Article 7/f.1 of the Personal Data Protection Law is eliminated and/or the limitation periods required for processing your data pursuant to the legislation expire, your personal data will be deleted, destroyed or anonymized and will continue to be used by us, taking into account the Personal Data Storage and Destruction Policy.

RIGHTS OF THE RELATED PERSON

• To learn whether your Personal Data is being processed,
• To request information regarding the processing of personal data,
• To learn the purpose of processing your Personal Data and whether they are used in accordance with their purpose,
• To know the third parties to whom Personal Data is transferred, either domestically or abroad,
• To request correction of your Personal Data if it is processed incompletely or incorrectly,
• To request the deletion/destruction of your Personal Data within the framework of the conditions stipulated in Article 7 of the KVKK and to request notification to third parties to whom your Personal Data has been transferred,
• To object to any adverse results arising from the analysis of processed data exclusively through automated systems,
• To request compensation in case they suffer damage due to processing of their Personal Data in violation of KVKK.

As personal data owners, you can submit your requests regarding these rights to us. bilgi@errahome.com You can submit your requests using the address. Your requests will be evaluated and finalized by ERRAHOME as soon as possible and in any case within 30 (thirty) days.

EXCEPTIONS TO THE RIGHT TO APPLY
In accordance with Article 28/2 of the KVKK, it will not be possible for the relevant persons to benefit from the rights specified in Article 11 of the KVKK, except for the right to request compensation for damages in the following cases.

• Personal data processing is necessary for the prevention of crime or criminal investigation,
• Processing of personal data made public by the relevant person.
• Personal data processing is necessary for the execution of supervisory or regulatory duties or disciplinary investigation or prosecution by authorized public institutions and organizations and professional organizations with public institution status, based on the authority granted by law.
• Processing of personal data is necessary to protect the economic and financial interests of the state regarding budgetary, tax and financial matters.
  
  

APPLICATION METHOD The relevant person may apply for the above-mentioned rights. Applications to the Data Controller may be made in accordance with the application procedures stipulated in the Communiqué on Procedures and Principles .
Requests within the scope of the rights listed in Article 11 of the Personal Data Protection Law No. 6698 may be made through one of the methods explained below, in accordance with Article 13 of the KVKK and Article 5 of the Communiqué on the Procedures and Principles of Application to the Data Controller.
Applications submitted to the Company will be responded to within 30 days of the date the request is received by the Company, depending on the nature of the request, in accordance with Article 13/2 of the Personal Data Protection Law. Responses to the application will be delivered to the applicant in writing and electronically, in accordance with Article 13 of the Personal Data Protection Law.

APPLICATION METHOD	APPLICATION ADDRESS	INFORMATION TO BE INCLUDED IN THE APPLICATION
1. Written Application Application in person with wet signature or through Notary	Hamidiye Neighborhood, Cendere Street, No: 103/1, Porta Vadi T2 Block Floor: 1 Flat: 5, Kağıthane/Istanbul	"Request for Information Within the Scope of the Personal Data Protection Law" will be written on the envelope/notification.
2. With Registered Electronic Mail (KEP) address With Registered Electronic Mail (KEP) address	erraproptech@hs01.kep.tr	The subject of the e-mail will be "Personal Data Protection Law Information Request".
3. Application via the e-mail address in the company system using the e-mail address	bilgi@errahome.com	The subject of the e-mail will be "Personal Data Protection Law Information Request".

If the request is accepted or rejected with an explanation of the reason, the requester will be notified electronically or in writing. If the request is accepted, our company will take action without delay.

DATA CONTROLLER : ERRA PROPTECH REAL ESTATE DEVELOPMENT JOINT STOCK COMPANY Tel: (0212) 272 37 72
Website: https://errahome.com/
Email Address: bilgi@errahome.com
Central Registry Number: 0368053113900001
Updated Date: 04.12.2023