Clarification Text on Protection and Processing of Personal Data

The purpose of this Information on the Protection and Processing of Personal Data (Information), CAKALOZ CONSULTANCY DOMESTIC AND FOREIGN TRADE INDUSTRY ANONİM ŞİRKETİ (TEXPERA), which is managed by 
https://www.TEXPERA.com/
  10 of the Law No. 6698 on the Protection of Personal Data (Personal Data Protection Law) regarding the use of personal data obtained during the use of the website located at the address (Portal) and / or received from third parties. is the fulfillment of the obligation of disclosure imposed by the article. In addition, it is to transparently inform the Users about the collection methods, purposes of processing, legal reasons and rights of the personal data collected by TEXPERA regarding the use of the Portal by the Users or entered into the Portal by the Users themselves with their positive actions.

Providers of products and services in various categories and potential buyers meet and exchange through the secure environment offered by TEXPERA. Within this activity, personal data are processed as stated in this Information Text as a requirement for the use of TEXPERA functions.

TEXPERA continuously renews itself in order to provide better service to its Users in the internet field with innovative product and service applications by investing in technology and strives to provide the best service, takes the highest possible security measures to ensure that personal data is collected, stored and shared in accordance with the law and to protect its confidentiality. In order to realize this purpose, the personal data of the Users are processed within the scope and conditions detailed below.

TEXPERA may update and change the provisions of this Disclosure at any time by publishing them on the Portal. Updates and changes made by TEXPERA shall be effective from the date of publication on the Portal.

a) Data Controller

In accordance with the Law on the Protection of Personal Data, your personal data will be collected and processed by TEXPERA as the data controller within the scope described below.

b) Personal Data Collected

TEXPERA collects various static (fixed) and dynamic (variable) data from Users using the following methods. The data TEXPERA collects depends on the services and features Users use.

Under this heading, the data processed within the scope of the Services offered by TEXPERA and which are considered personal data in accordance with the Personal Data Protection Law are listed in groups below. Unless otherwise explicitly stated, the terms “personal data” and “sensitive personal data” within the scope of the terms and conditions provided in this Information include the following information:

Name and Contact Information:
 Name, surname, mobile phone, home phone, work phone, address, e-mail address, billing information, Turkish ID number (national ID number), photocopy of the front side of the ID and other similar documents.

Authentication Information:
 Users’ account information, passwords used to authenticate and access the account, User Name, contact information, User numbers, advertisement numbers, identity card front side information, new ID front side information, new driver’s license front side information, user selfie video, ID hologram video, billing information.

Demographic Data:
 Date of birth, gender, marital status, education, occupation, interests, preferred language.

Usage Data and Favorites: Data collected from your devices by means of various software and technological tools Your reasons for calling TEXPERA or Call Centers, voice recordings, real estate index, expertise, date and time data when the product is used, province, district, neighborhood where the index query is created, chassis for receiving the damage query report generated by the Insurance Association and Surveillance Center system if the payment transaction is successful  and license plate number, products viewed through the portal, square meter prices, data specified in the relevant survey or banner so that users can be directed to the relevant product through modules such as surveys and banners of domestic or foreign companies, and so that product supplier companies can contact the user, information requested by the bank regarding the offer that banks want to receive for the real estate they put up for sale through the real estate module from the bank, Data entered through the Portal for real estate projects in order to receive information about the projects of contractor companies through the Portal, usage habits (prioritization options, preferred return method and date, channels responded to, last date of entry to the Portal, type of Doping advertisement used, type of post, websites visited) in order to develop and customize services for you, the number of pages viewed, visit duration and target completion number, user actions performed while using the services, search terms entered, categories of products and advertisements visited,) errors and similar problems that occur during the use of the service in order to ensure the smooth provision of services.

Location Data: It covers data related to the precise or approximate location of users. GPS data and location data extracted from IP and port addresses are used when the user uses TEXPERA’s mobile applications to search for and place advertisements in the vicinity of his/her current location and if the user gives his/her consent.

Payment Data:
 Agency and customer invoice and payment information (name, surname, billing address, Turkish ID number, tax ID number), invoices sent to the account holder and receipt samples of payments received from account holders, payment number, invoice number, invoice amount, invoice cut-off date.

Content Data: Documents requested to prove that the trademark is not counterfeit (invoice, warranty certificate, etc.), documents showing that the product belongs to the person or his/her authority over the product (such as title deed, license, trademark registration certificate, relevant parts of the authorization agreement), advertisement information, authorization certificate, account information, notification description, solution description, satisfaction, reason for notification, customer note, renewal date, reason for rejection of the advertisement, feedback, reason for document submission, error content specified during the use of the Service, interim information status, interim information, search reason.

S- My Vehicle Information:
 Vehicle photo, make, model, body type, year, fuel, gear, package and equipment information, vehicle mileage, vehicle inspection and maintenance information, license plate, tire change date, vehicle color, city where the vehicle is located, painted and changed parts information, registration certificate, traffic insurance certificate, insurance certificate and inspection certificate data.

Survey Answers:
 Responses to periodic surveys organized by TEXPERA within the Portal and responses to surveys conducted by natural and legal persons with whom TEXPERA cooperates.

Fingerprint In the mobile application, you can prefer fingerprint login instead of using a password. Your fingerprint will not be transmitted to TEXPERA in any way within the scope of the process to be realized with the fingerprint identification you will make from the settings section of the mobile device. On the mobile device, TEXPERA only receives a verification or error warning and you can log in to the application accordingly. If no confirmation is received, you will be prompted to repeat the process or log in another way. You can always turn off the fingerprint login option in the settings of your device.

In-site messages caught in the filters or with content contrary to the Terms of Use: 
In order to ensure secure communication and trade between users, in-site messages sent by users to each other are only those that are caught in the filters or in-site messages that are detected in content contrary to the terms of use upon complaint / notification.

Where is Personal Data Stored and Processed?

Your personal data we obtain may be stored at home or abroad in another country where TEXPERA or its affiliates, subsidiaries or service service providers with which it cooperates have facilities and may be processed in line with and proportionate to the purposes in this Information.

Your personal data collected within the scope of this Information will be processed in accordance with the provisions contained herein and within the scope of the legislation in force in the country where the data is stored and processed and within the prescribed security measures.

c) Purpose for which Personal Data will be Processed

In line with the purposes set out in this Information and the Account Agreement, your personal data will be processed in accordance with the Principles and Processing Conditions regulated by the Personal Data Protection Law No. 6698 and for the purposes detailed below:

Name and Contact Information: Internal evaluation, communication, user registration, obtaining potential customer information, development of after-sales processes, business development, collection, customer portfolio management, promotion,  analysis, complaint management, managing customer satisfaction processes, marketing, advertising, research, billing, event information, conducting operational activities, measuring and improving service quality, audit, control, optimization, customer verification, sales, after-sales services, fraud detection and prevention, participation in online training meetings;

Authentication Information:
 User registration, problem/error reporting, control, development and execution of operational activities, development of after-sales processes, business development, collection, internal evaluation, customer portfolio management, measurement of service quality, communication, optimization, moderation, audit, risk management, digital authentication, customer verification, fraud detection and prevention;

Demographic Data: Promotion, internal evaluation, analysis, communication, development of after-sales processes, business development, collection, usage data and interests, favorites, marketing, sales, advertising, audit and control, risk management, internal evaluation, customer portfolio management, after-sales services, measuring and improving service quality, conducting complaint management processes, conducting and improving operational activities, registration, problem/error reporting;

Usage Data and Favorites: User registration, problem/error reporting, control, inquiry, execution and development of operational activities, after-sales services and development of after-sales processes, business development, collection, internal evaluation, online behavioral advertising and marketing, customer portfolio management, measurement and development of service quality, communication,  optimization, audit, risk management and control, promotion, analysis, interest identification, scoring, profiling, marketing, sales, advertising, complaint management processes, registration, problem/error reporting;

Location data:
 Use of location-dependent or location-related Portal functions, audit and control, risk management;

Payment Data:
 Managing the billing process, accounting, development of after-sales processes, business development, collection, internal evaluation, scoring, profiling, customer portfolio management, after-sales services, communication, marketing, audit, control, processes with payment service providers;

Content: Business development, optimization, customer portfolio management, audit, control, execution and development of operational activities, Planning the business process to access vehicle information from the license plate information in the advertisement photos in order to facilitate the advertisement processes, to prevent fraud and abuse that may occur during the advertisement process, and to understand the history of the vehicle on the platform, and to collect data in this direction, execution of advertisement operations, promotion, internal evaluation, customer management, analysis, scoring, profiling, development of after-sales processes, collection, after-sales services, communication, measurement and development of service quality, fulfillment of regulatory compliance requirements, execution of complaint management processes;

Survey and Test Answers: Information requested from users who respond to periodic surveys or tests organized by TEXPERA within the Portal, direct marketing to these users, statistical analysis, improvement of processes and database creation by real and/or legal persons with whom TEXPERA cooperates for the use of Portal functions and the fulfillment of these functions by TEXPERA and third real and legal persons with whom TEXPERA cooperates within the scope of all processing activities mentioned above in accordance with the purposes of use of the Portal;

Performing the obligations arising from the contracts made by TEXPERA with its business partners/customers/suppliers, establishing rights, protecting rights in order to fulfill legal and commercial obligations within the framework of the contracts made with third real or legal persons who are in business relationship with TEXPERA or the activities carried out and the obligations arising from legal regulations, to carry out commercial and legal evaluation processes, to conduct legal and commercial risk analyses, to carry out the legal compliance process, to finalize the tests for whether the user can receive the documents specified in the relevant legal regulations, to carry out financial affairs, to fulfill legal requirements, to fulfill the decisions of competent institutions, organizations and authorities, to respond to their requests. 5. and 6. will be processed within the scope of the personal data processing conditions and purposes specified in Articles 6.

In-site Messages that are caught in filters or Contrary to the Terms of Use: Our messaging service is provided to facilitate our users to communicate with the counterparty in buying, selling and leasing transactions. In messages within this scope; 5. Based on the legitimate interest in the article, messages that contain insults, violate public morality, raise suspicion of fraudulent advertisements, may cause unfair competition, violate personal rights, intellectual and industrial property rights and otherwise violate the law are filtered and moderated, and in-site messages with content contrary to the terms of use of  can be examined and blocked.

Personal Data Retention Period

TEXPERA shall retain the personal data it obtains for the period necessary for the purpose for which they are processed in order to enable the Users to make the best use of the Service and to fulfill the obligations arising from the nature of the Account Agreement within the framework of the conditions specified in this Information and the Account Agreement.

In addition, TEXPERA will retain personal data in the event of any dispute that may arise from the Account Agreement, limited to the purpose of conducting administrative or judicial proceedings within the scope of the dispute and during the limitation periods determined in accordance with the relevant legislation.

ç) To whom and for what purpose the processed personal data can be transferred

TEXPERA may use the User’s personal data and any new data obtained by using such personal data or any personal data entered into the Portal by Users through their own positive actions, in particular to fulfill the requirements of the Account Agreement and the Services, improve the User experience (including improvement and personalization), ensure the security of Users, detect and prevent fraud, improve the Services, Outsourcing service providers, business partners, suppliers, appraisal and real estate consultancy firms in order to perform any of the purposes specified in the processing purposes section above, including performing query activities that may be important for the Services, conducting operational evaluation research, resolving errors, verifying User identities, improving system performance, providing online training activities; corporate account holders to the extent required by the transfer in the course of performing the Services,  shipping companies, law offices, research companies, call centers, TEXPERA Academy and similar online training platforms, software companies, agencies, consulting companies, companies in the printing sector, banks for real estate sales of banks, contracting companies for real estate projects, social media channels, third real and/or legal persons including certification bodies, and authorized institutions, organizations, authorities, administrative, judicial bodies and independent audit companies within the scope of legal obligations.

In addition, the User’s Name and Contact Information will be shared with payment institutions for the purpose of identity verification in accordance with the payment institution framework agreement that the User will approve during the payment phase and in accordance with the Regulation on Measures to Prevent Laundering of Proceeds of Crime and Financing of Terrorism published in the Official Gazette dated January 9, 2008 and numbered 26751 .

Your personal data obtained through cookies placed on your device may be shared with third parties for the scope and purposes specified in this Information.

TEXPERA may transfer personal data to third parties within the above-mentioned categories and purposes, limited and proportionate to these purposes, as well as abroad.

d) Method and Legal Grounds for Collecting Personal Data

TEXPERA collects your personal data to work more effectively and provide you with the best experience. TEXPERA collects your personal data directly from you (the data subject), your proxy acting on your behalf and/or persons authorized to act on your behalf by using the following methods:

Data You Provide Directly to TEXPERA: Personal data provided to TEXPERA by Users on their own initiative for the performance of the Service and before or during the use of the Portal. This personal data includes all personal data provided directly by Users to TEXPERA as a result of their positive actions. For example, name-surname, contact information, identity information, answers to surveys, demographic data and content information are included in this type of data.

Data We Obtain When You Use Our Platform: It includes personal data relating to the usage habits of Users received through certain software or technological tools during the service provided by TEXPERA. For example, this includes location data and favorites, as well as interests and usage data.

TEXPERA collects usage data such as the number of pages viewed, duration of visit and number of target completions by associating the behavior of the user coming to the site with a cookie in the browser, even if they do not have an account, in order to enable online behavioral advertising and marketing. How to manage cookies is also set out in our Cookie Policy.

Your personal data collected by these methods are subject to the provisions of Law No. 6698 5. and Article 6 of the Convention;

1. It is clearly stipulated in the law,
2. It is mandatory to fulfill its legal obligation (legal regulations regulating electronic commerce activities, financial and tax issues, consumer protection and other issues),
3. The processing is directly related to the conclusion or performance of the contract and is necessary (Account Agreement, Terms of Use and the performance of the contract based on them, establishment and protection of the right),
4. Processing is mandatory for its legitimate interest (collection of data necessary for TEXPERA to carry out services, in particular to prevent fraud, in its activities related to the Portal),
5. The fact that it has been made public by you,
6. Processing is necessary for the establishment, exercise or protection of a right,
7. Explicit consent

the legal grounds for the imposition of sanctions.

Your personal data collected by these methods are subject to the provisions of Law No. 6698 5. and 6. personal data may be processed and transferred for the purposes specified in this Information within the scope of the personal data processing conditions and purposes specified in Articles 6.

Legal grounds for collecting personal data;

1. Account Agreement, Terms of Use and the performance of the contract, establishment and protection of the right based on them
2. Legal regulations governing electronic commerce activities, financial and tax matters, consumer protection and other issues
3. It is based on TEXPERA’s legitimate interest in collecting the data necessary for TEXPERA to carry out its services, in particular to prevent fraud, in its activities related to the Portal.

e) Our Measures and Commitments Regarding Data Security

TEXPERA is committed to securely protecting personal data. It carries out technical and administrative measures to ensure the appropriate level of security in order to prevent unlawful processing and access to personal data and to ensure the protection of personal data by using various methods and security technologies.

TEXPERA will not disclose the personal data it obtains to anyone else in violation of the provisions of this Information and the Law No. 6698 on the Protection of Personal Data and will not use it for purposes other than processing. TEXPERA declares that in the event that personal data belonging to Users are shared with outsourcing service providers in accordance with this Information, TEXPERA will carry out the necessary warning and audit activities to ensure that such outsourcing suppliers also comply with the commitments under this article.

In case of linking to other applications through the portal, TEXPERA does not bear any responsibility for the privacy policies and contents of the linked applications.

The User agrees that the information subject to this Information is complete, accurate and up to date, and in case of any changes in this information, they shall immediately 
https://banaozel.TEXPERA.com/
 will be updated at the following address. TEXPERA shall not be liable if the User fails to provide updated information.

f) The Personal Data Owner is required to comply with Article 11 of Law No. 6698. Rights enumerated in the article

As personal data owners, if you submit your requests regarding your rights to TEXPERA by the methods set out below, TEXPERA will finalize the request as soon as possible and within thirty days at the latest, depending on the nature of the request. There will be no charge for up to ten pages in the response. A transaction fee of 1 Turkish Lira will be charged for each page over ten pages. If the response to the application is provided on a recording medium such as CD, flash memory, the fee that TEXPERA may charge will not exceed the cost of the recording medium.

In this context, personal data owners;

1. Learn whether their personal data is being processed,
2. Request information if their personal data has been processed,
3. To learn the purpose of processing personal data and whether they are used for their intended purpose,
4. To know the third parties to whom personal data are transferred domestically or abroad,
5. To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
6. Although it has been processed in accordance with the provisions of Law No. 6698 and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
7. To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
8. In case of damage due to unlawful processing of personal data, it has the right to demand compensation for the damage.

You may submit your request to exercise your above-mentioned rights in accordance with Article 5 of the Communiqué on the Procedures and Principles of Application to the Data Controller. Pursuant to the article, in Turkish; TEXPERA, as the data controller, has been appointed as the data controller at Değirmen Yolu Cad. No:28 Asia OfisPark A Blok Kat:2 34752 Ataşehir/İstanbul/Turkey in writing with information and documents certifying your identity.

TEXPERA reserves the right to verify your identity in order to prevent unlawful sharing of your personal data.

In your application;

1. Your name, your surname and your signature if the application is in writing,
2. For citizens of the Republic of Turkey, your Turkish ID number; if you are a foreigner, your nationality, passport number or ID number, if any,
3. Your residential or workplace address for notification,
4. Your e-mail address, telephone and fax numbers, if any,
5. Your request subject,

 is mandatory and relevant information and documents, if any, must be attached to the application.