Data Controller: Kalme Kurumsal Gayrimenkul Değerleme ve Danışmanlık A.Ş.

Contact Person: Esra Demirhan,

According to the 3^rd paragraph of the 20^th article of the Constitution of the Republic of Turkey “Everyone has the right to claim the protection of their personal data. This right also includes being informed about personal data about the person him/herself, accessing these data, requesting their correction or deletion, and learning whether they have been used for their intended purposes. Personal data can only be processed in cases stipulated by law or with the explicit consent of the person. The procedures and principles regarding the protection of personal data are regulated by law”. With regard to the processing of personal data, which has a constitutional basis, many legislations have been drawn up in order to protect the fundamental rights and freedoms of individuals, especially the privacy of private life, and to regulate the obligations of natural and legal persons who process personal data and the procedures and principles to be followed. The Law No 6698 on the Protection of Personal Data and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Clarification Obligation, which regulates the procedures and principles to be complied with within the scope of the clarification obligation to be fulfilled by the data controllers or authorized persons pursuant to the Article 10 of the Law above are among these regulations. As Kalme Kurumsal Gayrimenkul Değerleme ve Danışmanlık A.Ş. (hereinafter referred to as KALME), we pay strict and accurate attention regarding the security and privacy of your personal data in line with the applicable legislation and other communiqués and decisions of the KVK Institution. With this awareness, as a legal entity company, we attach great importance to processing and recording all kinds of personal data belonging to all persons related to the company in compliance with the Constitution of the Republic of Turkey, the Law on the Protection of Personal Data No. 6698, other communiqués and decisions and the Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Clarification Obligation and taking the necessary technical measures. As Kalme Kurumsal Gayrimenkul Değerleme ve Danışmanlık A.Ş., our company processes your personal data in its capacity as “Data Controller” defined within the scope of KVKK, as explained below and within the limits determined in accordance with the legislation, and transfers them in accordance with the law in the procedures specified in the Policy; necessary protective and preventive measures are taken in case of processing, storage and transfer. Our aim is to make explanations about the personal data processing and transfer activities carried out by our company in accordance with the “Law on Protection of Personal Data” No. 6698 and the systems adopted for the protection of personal data, and to provide transparency by informing the relevant persons whose data is processed by our company.

1. Collection, Processing and Processing Purposes of Personal Data

All personal data of our shareholders, representatives, real estate appraisers, assistant real estate appraisers, housing appraisers, other insured employees, interns, guests, customers, employees of banks and other legal entities we work with may be collected orally, in writing or electronically, directly or indirectly, through our company’s units, website, social media, mobile applications and similar means. As long as the person’s relationship with our company continues, in order to identify the data owner and determine the working areas, provide information about the offers and business process, ensure the continuity of the business and carry out work safety quickly and accurately within the scope of the personal data processing conditions and purposes specified in the 5th and 6th articles of the KVK Law; some or all of the data regarding the name, surname, date of birth, address, mobile phone, e-mail address, status of the person, educational background, field of activity, period of experience, educational documents, license document information (CMB license and TDUB experience certificate, etc.), health reports, bank and bank account information (Iban No) and data regarding criminal convictions and security measures may be processed by the relevant units of the company.

On the one hand, personal data of our shareholders, representatives, real estate appraisers, assistant real estate appraisers, housing appraisers, other insured employees, interns, guests, customers, employees of banks and other legal entities we work with may be processed within the scope of the law, with their explicit consent; on the other hand, some or all of the data regarding the name, surname, date of birth, address, mobile phone, e-mail address, status of the person, educational background and educational documents, license document information (SPK license and TDUB experience certificate, etc.), health reports, bank and bank account information (Iban No) and criminal convictions and security measures may be processed, without explicit consent, by the relevant units of the company in order to provide information for identification and work areas, offers and business process, to ensure the continuity of the business and carry out work safety quickly and accurately if one of the conditions specified in the article 5/2 of the KVK Law realizes.

Your personal data is collected in order to comply with the obligation to store and report data and inform required by the legislation, relevant regulatory institutions and other authorities, to fulfill our legal obligations as per applicable legislation, to arrange all records and documents for the purpose of processing in electronic or paper environment (physical) in order to carry out the activities involving the subject of business in accordance with the rules of the legislation.

Some or all of the personal data of our company and its shareholders, representatives, real estate appraisers, assistant real estate appraisers, housing appraisers, other insured employees, interns, guests, customers, employees of banks and other legal entities we work with, may be processed by the relevant units of the company in accordance with the personal data processing conditions specified in the articles 5 and 6 of the KVK Law in order to carry out business activities in accordance with the objectives and subject set out in the articles of association of the company, to continue its activities within the scope of its objectives and subject in accordance with the articles of association, to act in accordance with the regulatory rules of relevant institutions and organizations (public-private) on the basis of business activities carried out in accordance with its objectives and subject in accordance with the articles of association, to operate in accordance with the applicable legislation, to ensure legal and physical security, to provide administrative operations carried out by our company for communication, to operate our company’s locations, to carry out financial and accounting transactitons, administrative personnel transactions, customer information transactions continuously and in accordance with the law, to act together in the works carried out jointly with the banks and other institutions, to carry out the legal compliance process, to determine the strategies of our company, to implement the determined strategies and to follow human resources policies.

2. To Whom and What Purpose the Processed Personal Data Can be Transferred

Persons/organizations to whom personal data can be transferred for the above-mentioned purposes;

• Organizations and institutions permitted by the Turkish Appraisal Experts Association Regulations, the Real Estate Appraisal Minimum Wage Tariff and Implementation Principles Regarding the Valuation Services Provided by TDUB Members to their Customers, the Capital Markets Board Regulations, the Banking Regulation and Supervision Agency Regulations, the Capital Markets Law No. 6362, which includes Expertise Regulations, Expertise Law, the Regulation on Valuation Services for Banks and Authorization and Activities of Institutions to Provide Valuation Services to Banks,

• The Expropriation Law No. 2942, the Banking Law No. 5411, the Zoning Law No. 3194, the Settlement Law No. 5543, the Cadastre Law No. 3402, the Forest Law No. 6831, the Public Procurement Law No. 4734, the Social Insurance and Universal Health Insurance Law No. 5510, the Occupational Health and Safety Law No. 6331, the Law No. 4982 on Access to Information, the Retirement Fund Law No. 5434, the Social Services Law No. 2828, the Law No. 5366 on the Renewal, Protection and Use of Damaged Historical and Cultural Immovable Assets, the Law No. 2863 on the Protection of Cultural and Natural Assets, the Law No. 4706 on Amendment to Appraisal of Immovable Property Owned by the Treasury and Value Added Tax Law, the Turkish Commercial Code, the Tax Procedure Law, the Law on Regulation of Electronic Commerce, the Law on the Regulation of Publications through Internet and Combating Crimes Committed through these Publications, the Law on Protection of Consumers, the Enforcement and Bankruptcy Law No. 2004, the Labor Law No. 4857, the Regulation on Data Controllers Registry, the Regulation on Deletion, Destruction or Anonymization of Personal Data,
• The Communiqué on the Procedures and Principles of Application to the Data Controller, the Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Obligation of Clarification, the application form regarding the applications to be made by the person concerned (personal data owner) in accordance with the Law on the Protection of Personal Data No. 6698, the Law on the Protection of Personal Data No. 6698, the Regulation on Archive Services, the Regulation on Health and Safety Measures to be Taken in Workplaces and Premises, and other legislation and communiqué provisions,
• Public legal entities such as the Personal Data Protection Board, the Valuation Experts Association of Turkey, the Ministry of Finance, the Ministry of Commerce, Information Technologies and Communications Authority,
• Domestic/foreign partner organizations and other third parties who are jointly and severally responsible for taking data security measures such as protecting all kinds of personal data, preventing unauthorized access and illegal processing, from which we receive contracted services and cooperate with to carry out our activities As Kalme Kurumsal Gayrimenkul Değerleme ve Danışmanlık A.Ş.

3. Method and Legal Background of Collecting Personal Data

The personal data of our company’s shareholders, representatives, real estate appraisers, assistant real estate appraisers, housing appraisers, other insured employees, interns, guests, customers, employees of banks and other legal entities we work with, may vary depending on their relationship with our company. It is obtained for the purpose of providing our services in all kinds of verbal, written or electronic media in line with the purposes above and in this context, for fulfilling our contractual and legal responsibilities fully and accurately. These personal data collected due to such legal reason may also be processed and transferred for the purposes specified in articles (1) and (2) of this text within the scope of the processing conditions and purposes of personal data set out in Articles 5 and 6 of the KVK Law.

4. Rights of Personal Data Owner set out in Article 11 of KVK Law

In case personal data owners submit their requests regarding their rights to our company through the methods stated below, our company will conclude the request free of charge as soon as possible and within thirty days at the latest, taking into account the nature of the request. In this context, personal data owners have the rights;

• to learn whether the personal data have been processed or not,
• to request information if their personal data has been processed,
• to learn the purpose of processing personal data and whether they are used in line with their purpose,
• to be informed about the third parties to whom personal data are transferred domestically or abroad,
• to request correction and claim the notification of the transaction performed to the third persons to whom the personal data have been transferred, if the personal data is processed incompletely or incorrectly,
• to request the deletion or destruction of personal data and to claim the notification of the transaction performed to the third persons to whom the personal data have been transferred if the reasons requiring personal data to be processed within the framework of the provisions specified in Article 7 of the KVK Law are eliminated despite the fact that the data has been processed in accordance with the provisions of the KVK Law and other applicable laws,
• to object to any adverse consequences arising as a result of processed data being analyzed solely by automatic systems,
• to claim compensation in case of loss due to unlawful processing of personal data.

Pursuant to paragraph 1 of Article 13 of the KVK Law, you can send your application regarding the exercise of the above-mentioned (article 11 of the Law) rights, in writing, to our company’s data controller through our company’s address given below or electronic mail address: info@kalme.com.tr via secure electronic signature, mobile signature or by using the e-mail address previously reported to the data controller by the relevant person and registered in the data controller’s system.

Applications of personal data owners who want to exercise their rights above should include;

• Name, surname and signature, if application is written,
• TR identification number for Turkish Citizens and nationality, passport number or identification number for foreigners,
• Residential address or workplace address for notification,
• E-mail address, telephone and fax number, if any, for notices,
• Content related to the subject of the request.
• Information and documents related to the subject.

Action will be taken pursuant to the Article 6 (response to the application) of the “Communiqué on the Procedures and Principles of Application to the Data Controller” published in the Official Gazette dated 10.3.2018 and numbered 30356.

Internet address: info@kalme.com.tr

Address: Ümit Mahallesi, 2509 Sokak No:10 Çankaya/ANKARA

You can personally send your request to the address above, send it via a notary public or other methods specified in the KVK Law, or convey the relevant form via secure electronic signature.