Privacy and Personal Data Protection Policy

This policy explains what Zingat’s principles are for the processing of personal data, which should be known to the natural persons such as suppliers, visitors and users of the Website (https://www.zingat.com/ ) whose personal data we process..

I. Definitions

For the purpose of this Policy, the following terms shall have the meanings set forth below:

Zingat shall mean Zingat Gayrimenkul Bilgi Sistemleri A.Ş., which is the owner of the Website.

Data Subject or Natural Person shall mean the owner of the personal data.

Recording Medium shall mean any environment where personal data is processed by automated means in full or in part or by non-automated means as a part of any data recording system.

Website shall mean the website at https://www.zingat.com/

Data Processor shall mean a natural or legal person who processes the personal data in the name of and under the authority granted by the data controller.

Data Controller shall mean a natural or legal person who determines the purposes of and means of personal data processing, and who is responsible for setting up and managing the data recording system.

Law No. 5651 shall mean the Law on Regulation of Publications on the Internet and Combating Crimes Committed by these Publications.

Law No. 6698 or LPPD shall mean the Law on the Protection of Personal Data.

II. Collection and Processing of Your Personal Data

1. Processing of the Personal Data of Website Users and Online Visitors

1.1. Processing of the Personal Data of Website Users

The usernames, names, surnames, e-mails and user activity of the Website users are processed. Users of the Website may, for the purposes of giving feedback and making suggestions, fill in the form at https://www.zingat.com/iletisim by entering their personal data, i.e. name, surname, e-mail address, phone number and message.

Users agree that the personal data are required for the express purpose of addressing their feedback and suggestions, and that they share their personal data with the Website by their own will.

1.2. Processing of the Personal Data of Online Visitors

User traffic information about the visitors of the Website may be processed in accordance with the provisions of the Law No. 5651.

2. Processing of the Personal Data of Suppliers

Zingat processes the personal data of natural person suppliers, supplier employees and/or officers in order to supervise and manage the supply process of its products, services and goods.

2.1. Personal Data Processed in Supply Processes

Zingat processes the following personal data in the course of its supply processes:

• For natural person suppliers, identification details including name, surname and personal ID and tax ID numbers; financial information such as bank account; and contact information such as mailing address, e-mail address and mobile phone number;
• For the authorized officers of suppliers, identification details including name, surname and personal ID number; other personal information such as signatures on deeds of power of attorney or statements of signature; and contact information such as mailing address, e-mail address and mobile phone number; and
• For the employees of suppliers, identification details including name, surname and personal ID number; and contact information such as mailing address, e-mail address and mobile phone number.

2.2. Purpose of Processing the Personal Data in Supply Processes

• Monitoring and execution of contracts related to the supply or procurement of goods, products or services; and
• Ensuring the fulfilment of financial and accounting obligations and compliance with legal procedures.

2.3. Methods of Collection and Processing of Personal Data of Suppliers

• Supplier, supplier managers and employees;
• Documents such as statements of signature and deeds of power of attorney;
• Means of communication including e-mail, phone; and,
• Contracts.

3. Processing of the Personal Data of Zingat Website Members

3.1. Processed Personal Data of Corporate Members

• For the Corporate Members, identification details including name, surname and personal ID and tax ID numbers; financial information such as bank details; contact information such as mailing address, e-mail address and mobile phone number; audio records such as call centre call records; visual records such as photos; and other specific personal information such as signatures on the deeds of power of attorney or statements of signature; and
• For the employees of Corporate Members, identification details including name and surname; contact information such as mailing address, e-mail address and mobile phone number; and audio records such as call centre call records.

3.2. Processed Personal Data of Individual Members

• For the Individual Members, identification details including name and surname; financial information such as bank details; contact information such as e-mail address and mobile phone number; location data such as province, district and quarter; audio records such as call centre call records, and visual data such as photos.
• You can change or update your preference to receive commercial electronic message you set when you become a member of the Zingat.com website or Zingat mobile app at any time at the My Profile Settings page.
• Termination of membership does not mean the revocation of your consent to receiving commercial electronic communications. Therefore, please also make sure that you have completed all the procedures to revoke your consent.

3.3. Purpose of Processing the Personal Data of Individual and Corporate Members

• Monitoring and managing corporate members and individual members through CRM;
• Developing new products or developing existing processes in line with the needs of the members by gathering member behaviours;
• Bringing individual and corporate members together on a common platform;
• Obtaining location data for the purpose of calculating the life score based on the needs of individual members;
• Obtaining identity and contact information to create a potential customer portfolio for corporate members; and
• Direct marketing.

3.4. Methods of Collection and Processing of Personal Data of Individual and Corporate Members

• Personal data are collected and processed based on the data provided by the corporate members during the membership talks and through the Website; and
• Personal data are collected and processed based on the data provided by the individual member through the Website.

4. Processing of Personal Data of R&D Supervisors

4.1. Processed personal data of R&D Supervisors

• Identification details such as name and surname; contact details such as address, e-mail and mobile phone; name of the affiliated institution and its name; and specific personal data such as signature on documents issued for supervision purposes.

4.2. Purpose of Processing of Personal Data of R&D Supervisors

• • Carrying out R&D projects, maintaining the R&D license.

4.3. Methods of Collection and Processing of Personal Data of R&D Supervisors

• • Data of supervisors are collected and processed through the organisation that assigns the supervisor (assignment).

5. Processing of Personal Data of Consultants

5.1. Processed Personal Data of Consultants

• • Identification details such as name and surname; contact details such as address, e-mail and mobile phone; specific personal data such as signature on documents issued for supervision purposes; name of the affiliated institution and its name; and details regarding the field of expertise.

5.2. Purpose of Processing of Personal Data of Consultants

• • Carrying out R&D projects, maintaining the R&D license;
• • Issuing accounting forms, invoices, payment, expense vouchers and self-employment receipts;
• • In line with the needs of the company, providing the necessary consultancy services where necessary, carrying out the contract processes related thereto; and
• • Bringing theoretical information to the company, carrying out R&D projects, and maintaining the R&D licenses.

5.3. Methods of Collection and Processing of Processing of Personal Data of Consultants

Personal data of consultants are collected and processed based on data provided by the person and through e-mail and contract.

6. Processing of Personal Data of Customers

6.1. Processed Personal Data of Customers

• • Identification details such as name and surname; contact details such as address, e-mail and mobile phone; name of the affiliated institution and its name; and specific personal data such as signature on documents issued for supervision purposes.

6.2. Purpose of Processing of Personal Data of Customers

• • Finding the right solution in line with the needs of the customer and presenting the marketing strategy.

6.3. Methods of Collection and Processing of Processing of Personal Data of Customers

Personal data of consultants are collected and processed on the basis of the data provided by the person itself, through Gyoder lists, e-mail, contract and Website.

7. Processing of Personal Data of Education Partners

7.1. Processed Data of Education Partners

• • Identification details such as name and surname; contact details such as address, e-mail and mobile phone; educational background and qualifications.

7.2. Purpose of Processing of Personal Data of Education Partners

• • Personal data of education partners are processed for improving employee career and performance development, loyalty and satisfaction.

7.3. Methods of Collection and Processing of Processing of Personal Data of Education Partners

The personal data of education partners are collected and processed based on the data provided by the person concerned and through e-mail.

III. Security of Your Personal Data, Transferring of Personal Data, and Exercising Your Rights Pertaining to Your Personal Data

The personal data you share with us are kept strictly confidential in Zingat’s databases pursuant to the provisions of Article 12 of Law No. 6698 on the Protection of Personal Data, and are not shared with third parties for commercial purposes.

Zingat transfers personal data to third parties only for the purposes specified in this Personal Data Protection Policy and in accordance with Articles 8 and 9 of the Law on the Protection of Personal Data. Zingat shall store personal data related to online and on-site visitors in accordance with the legislation and may share such data with the relevant governmental authorities upon request. The personal data of the suppliers with respect to the goods, products or services may be shared with Zingat affiliates and also with relevant governmental authorities.

Personal data of individual members and Website users are also transferred to third persons in line with the consent to commercial electronic messages for the purposes of sending them advertisements, and offering them with benefits and opportunities in accordance with their preferences and behaviours in accordance with Articles 8 and 9 of the Law on the Protection of Personal Data.

Zingat takes the following measures in order to ensure the security of personal data it processes to prevent unauthorised access and to prevent unauthorised data processing:

• • All pages on which personal data are received through the Website are protected by SSL certificates.
• • Encryption, transaction registration, access management and physical security measures are taken to ensure that information systems that contain personal data are protected against unauthorised access and unauthorised data processing.
• • The Website and personal data are protected by the network firewall installed on all systems.
• • Cookies are used on our Website to monitor the Website usage behaviours of online visitors.

With regard to the personal data you share with us for the purposes and through the methods outlined herein, under Article 11 of Law No. 6698, you are entitled to:

a) Inquire about whether your personal data has been processed;

b) If so, request information on the processing;

c) Learn the purpose of processing of the personal data and whether your data is used in accordance with their purpose;

d) Receive information on domestic and foreign third parties with whom your data has been shared;

e) Request correction in case personal data is inaccurate or incomplete;

f) Request deletion or destruction of personal data in case the reasons necessitating its processing cease to exist, even if such data has been processed in compliance with the provisions of Law No. 6698 or other applicable legislation;

g) Request that the actions taken within the framework of paragraphs (d) and (e) be notified to the third parties to whom the personal data is transferred;

h) Object to any result that is to your detriment as a result of an exclusively automated analysis of your personal data; and

i) Claim compensation for the damages you might suffer in the event your personal data is processed in an unlawful manner.

You may contact us at any time to exercise these rights by using the “Application Form” on our Website or through other methods specified in this policy.

IV. Accurate and Up-to-Date Storage of Personal Data

Individuals whose personal data we process hereby accept and agree that the accuracy and validity of the personal data, which were submitted by them through the Website and/or in person or obtained for contractual purposes, are instrumental for their ability to exercise their rights regarding the personal data under the LPPD and other applicable legislation; and that they shall take full responsibility for inaccurate data. You may make changes and/or revisions to your personal data by contacting us at [email protected]or by using one of the methods available on the application form at https://www.zingat.com/basvuru-formu

In order to ensure the security of personal data and prevent unlawful data sharing, Zingat.com may request information from the applicant for the purpose of authenticating the applicant to determine whether the applicant is the owner of the personal data submitted in the application. Zingat.com may also raise questions to the data subject about the application of the data subject to ensure that the application is concluded in accordance with the request. If the request is subject to a fee, the standard fee determined by the Board may be charged to the person concerned. The person concerned hereby acknowledges that Zingat.com shall have no responsibility for the claims arising from misinformation or unauthorised application due to inaccurate and out-of-date information submitted in relation to the request in this form or due to unauthorised application.

V. Duration of Storage of Personal Data

Zingat utilizes CCTV systems with cameras both inside and outside of the premises in order to ensure the security of Zingat employees and on-site visitors. Visitors are informed of the video surveillance upon their entrance to the building.

CCTV footage of visitors are stored in secure systems accessible only by authorised personnel. Such information may be shared with public authorities upon request.

Personal data collected during online visits are kept for a period of two years as per Law No. 5651. CCTV footage of on-site visits is kept for two years. Personal identity data are stored for the period of time as prescribed by the applicable legislation. Personal data of Suppliers, Consultants, Education Partners, Supervisors, Corporate Members and Corporate Clients are Personal data collected during online visits are kept for a period of two years as per Law No. 5651. CCTV footage of on-site visits is kept for two years. Personal identity data are stored for the period of time as prescribed by the applicable legislation. Personal data of Suppliers, Consultants, Education Partners, Supervisors, Corporate Members and Corporate Clients are kept for a period of 10 years following the termination of legal relationship; personal data of individual members are kept for a period of five years following the termination of customer relationship; call centre audio records are kept for a period of two years; all accounting and financial transaction records are kept for a period of 10 years; and the consent records for commercial electronic mails are kept for a period of one year from the date consent is withdrawn.

You can review our Cookie Policy on the retention period of personal data obtained through cookies.

VI. Deletion, Destruction and Pseudonymisation of Personal Data

The data processed for the purposes specified in this Personal Data Protection Policy shall be pseudonymised and remain in use when the initial condition for processing of the personal data set out in Article 7(f)(1) of Law No. 6698 is no longer valid, and respective legal periods expire as per Article 138 of the Turkish Penal Code.

Upon the end of the prescribed time period as specified in the relevant legislation or as required by the purpose of processing, Zingat shall, within the period of six months stipulated for the periodical destruction of data, use any one or more of the methods described in the Guidelines for the Deletion, Destruction and Pseudonymisation of Personal Data published by the Personal Data Protection Board as it deems suitable for its business processes and operations to pseudonymise the data, and may continue to use the pseudonymised data for further purposes.

VII. Amendments and Revisions to the Policy

Zingat may amend, revise and modify this Policy in line with the Company Policy. Data Subject shall be notified through the Website of the new Policy document containing such amendments and revisions.