PRIVACY AND PERSONAL DATA PROCESSING POLICY (KVKK)

1. General Provisions

1.1.

This Privacy and Personal Data Processing Policy (“Policy”) regulates the procedures for the collection, use, storage, transfer, and protection of personal data belonging to users (“Users”) of the ExamplePlatform platform (“Platform”).

1.2.

This Policy has been prepared in consideration of the Law on the Protection of Personal Data No. 6698 (“KVKK”) in force in the Republic of Türkiye, the European Union General Data Protection Regulation (“GDPR”), and other relevant legislation.

1.3.

Every User who uses the Platform declares that they have read and accepted the terms of this Policy. A User who does not accept any provision of the Policy must immediately cease using the Platform.

2. Data Controller

2.1.

Pursuant to the KVKK and other relevant legislation, the data controller for personal data is the organization whose details are provided below:

TOPLI, UNIPESSOAL LDA (ZONA FRANCA DA MADEIRA)
CENTRAL PORTUGAL ISTANBUL HEAD BRANCH
TCKN / VKN: 343434343
Address: Example City, Example Street 1
Phone: +90 000 000 0000
E-mail: test@example.com

2.2.

There is no dedicated department (Data Protection Officer) responsible for the protection of personal data within the Company. For any matters related to personal data, you may send an e-mail to test@example.com.

3. Personal Data Collected

3.1. Data provided directly by the User

Name and Surname
Contact Phone Number
E-mail Address

3.2. Data collected automatically

Cookies
IP Address
Activity data on the site (e.g., visit logs, session duration, etc.)

3.3. Sensitive Data

ExamplePlatform, does not collect sensitive personal data such as biometric data, racial/ethnic origin, or religious belief.

4. Methods and Sources of Data Collection

Forms on the site: Forms completed by the User during registration to the Platform or during contracts/transactions.
Analytics and advertising tools (e.g., Google Analytics, Meta (Facebook) Pixel, Microsoft Clarity): Help analyze user activities and manage marketing campaigns. Data is processed in accordance with the privacy policies of the respective service providers.
Other channels: Information voluntarily provided by the User via e‑mail (test@example.com), phone, messaging apps, etc.

5. Purposes and Legal Bases for Processing Personal Data

5.1. Purposes of Processing

Creation and management of the user account
Entering into and performance of contracts (e.g., with construction companies, agencies, intermediaries)
Marketing communications (with User consent)
Service improvement and analytics

5.2. Legal Bases

Necessity for the performance of a contract (KVKK Art. 5/2‑c)
Explicit consent of the User (KVKK Art. 5/1)
Fulfillment of legal obligations (KVKK Art. 5/2‑ç)

6. Transfer of Personal Data to Third Parties

6.1. Data Transfer to Construction Companies

Customer’s Name and Surname
A portion of the phone number

6.2. Use of Cloud Services

Data is stored on Google’s cloud infrastructure and protected with technical and organizational security measures.

6.3. Other Third Parties

Outsourcing companies, payment providers, IT services, etc.

6.4. Cross‑Border Data Transfer

Performed by taking necessary measures under the KVKK and GDPR.

7. Data Retention Period and Destruction Procedures

7.1. Analytics Data

Data such as Google Analytics and Meta Pixel is retained for 6 months.

7.2. Registration Data

User data is retained until a deletion request is made.

7.3. Deletion and Anonymization

At the end of the period, data is permanently deleted or anonymized.

8. Measures for Data Security and Protection

8.1. Technical Measures

Encryption of data
Use of HTTPS, SSL/TLS
Role‑based access
Regular software updates

8.2. Administrative Measures

Access is granted only to relevant personnel
Log records are kept
Information security policies are implemented

8.3. Incident Response Plans

In the event of a data breach, the relevant authorities and data subjects are informed.

9. User Rights

9.1. Right of Access

The User may request information about their data.

9.2. Right to Rectification

The User may request correction of incomplete/incorrect data.

9.3. Right to Erasure

The User may request deletion of their data.

9.4. Right to Restriction of Processing

The User may request suspension of processing.

9.5. Right to Data Portability

The User may request transfer of their data to another data controller.

9.6. Right to Withdraw Consent

The User may withdraw consent at any time.

Exercising the Rights:

Via account settings
By sending an e‑mail to test@example.com

10. Consent for Marketing Communications

10.1.

The User may give consent to receive marketing communications during registration.

10.2.

They may unsubscribe using the “Unsubscribe” link in each marketing e‑mail.

10.3.

The General Terms of Use also include provisions regarding marketing messages.

11. Cookie Policy

11.1.

The Platform uses cookies to improve user experience and manage advertising.

11.2.

Types of cookies and details may be provided separately in the “Cookie Policy” section.

12. Interaction with Agencies, Intermediaries, and Construction Companies

12.1.

Customer data may be transferred to the relevant construction company.

12.2.

Confidentiality provisions are additionally regulated in agreements with the companies.

12.3.

Agencies and intermediaries are included in the system by accepting the privacy provisions in the publicly available offer text.

13. Compliance with International Legislation (GDPR)

13.1.

ExamplePlatform takes the necessary measures within the scope of the GDPR.

13.2.

If the KVKK conflicts with the GDPR, the applicable legislation is determined in accordance with the User’s nationality and the rules of international law.

14. Contact Information

E‑mail: test@example.com
Phone: +90 000 000 0000

15. Changes and Updates to the Policy

15.1.

ExamplePlatform reserves the right to make changes to the Policy.

15.2.

By continuing to use the Platform after changes, the User is deemed to have accepted the updated Policy.

16. Entry into Force

16.1.

The Policy enters into force upon publication and remains valid until a new version is issued.# PRIVACY AND PERSONAL DATA PROCESSING POLICY (KVKK)