INFORMING TEXT IN THE SCOPE OF PERSONAL DATA PROTECTION

As Watergarden Gayrimenkul Yatırım A.Ş. (“Watergarden”); we give great importance to the confidentiality and security of your personal data and we treat it with sensitivity. Within this framework, it is our priority to process and store any personal data belonging to all persons related to Watergarden in accordance with the Personal Data Protection Law No. 6698 (Kişisel Verilerin Korunması Kanunu “KVKK”) including our customers who benefit from our services and products and our business contacts. Pursuant to KVKK with the title of “Data Officer” and the awareness of this responsibility, we would like to inform you about the purposes of processing your personal data, the methods and reasons for collecting your data, your rights regarding the processing of your personal data and the application procedures and principles of using these rights as follows.

1. What personal data do we collect?

When necessary, Watergarden collects personal data of our customers (real people who are visiting / have visited our shopping centers), visitors (real persons who are visiting / have visited our company’s electronic platforms – Watergarden website, mobile site, etc.- and / or the physical locations of our company), business contacts (to all shareholders, officers and employees of the institution with whom we have business relations like suppliers, subcontractors), shareholders, authorities and employees of the tenant stores and other third parties in accordance with KVKK. We can list the personal data we collect as follows:

 

  • Identity Data:Data on the identity of the person like the name, surname T.C. number, identification number, nationality, license plate information, photocopy of the identity of the person that we collect from our customers, visitors, business contacts, tenant stores, shareholders, officials, employees and other third parties.

 

  • Contact Data: Data that enables communication with the person like phone number, address, e- mail address that we collect from our customers, visitors, business contacts, tenant stores, shareholders, officials, employees and other third parties.

 

  • Financial Data: Data such as wage information, expenditure amount, payment information, bank account number that we collect from our customers, business contacts and store tenants according to the legal relationship established by our company.

 

  • Personal Data: It is any kind of personal data that may include the professional experience and the foundation of the personal rights of real persons in working relationship with our company that we collect from institutions we have business relationship such as subcontractor and similar businesses and the tenants’ stores managers and employees.

 

  • Physical Space Security Data:Personal data such as security and camera recordings that are received at the entrance to the physical space and during the stay within the space that we collect from our customers, visitors, business contacts, tenant stores, shareholders, officials, employees and other third parties.

 

  • Audio / Visual Data: Personal data such as photography, audio and video recording that are not covered by security information that we collect from our customers, business contacts and managers and employees of the tenant stores.

 

  • Special Qualified Personal Data: As stated in Article 6 of KVKK, the health data or information on criminal conviction data that w emay collect from our customers, visitors, business contacts, tenant stores, shareholders, officials, employees and other third parties.

 

  • Other Data: Risk management information, data belonging to family members and relatives, customer transaction data, marketing data, cookies and other means are collected by automated means collected from our customers, visitors, business contacts, tenant stores, shareholders, officials, employees and other third parties.

2.What methods and legal reasons do we collect / process your personal data?

Your personal data,

  • Through other communication methods, including printed and electronic forms that you make use of during your visit to our shopping center,
  • Our Internet and mobile sites, through our social media accounts operated on behalf of Watergarden in various social media channels,
  • Through other communication methods including e-mail, telephone, short messages (“SMS”) or multimedia messages (”MMS”), printed and electronic forms that we use within the scope of sales and marketing activities
  • Through closed circuit camera and access control systems placed in the Watergarden administrative and administrative offices and shopping center,
  • Through contracts, commercial offers, printed and electronic forms, documents, correspondence, applications made with us, which we have signed with you or your company within the scope of our business activities,
  • By means of business cards and other documents provided by you within the scope of our business meetings and events,
  • Through third parties, such as Watergarden Grups’ group companies, subsidiaries and affiliates, companies in which it is an organic affiliate (associated company), business contacts or companies that provide services / products;

 

collected in a variety of ways, whether fully or partially automated or as part of any data recording system, whether verbal, written or electronic.

We process your personal data collected in accordance with the above methods for one or more of the following legal reasons:

  • Having your consent,
  • Require the processing of the provisions of the laws and regulations in force in the Republic of Turkey,
  • Mandatory for the protection of the life or the integrity of the person or someone else when he or she is unable to disclose your consent due to actual impossibility,
  • When it is necessary for the execution of the contract concluded with you or your company,
  • When it is necessary to process your personal data in order to fulfill our legal obligations,
  • When your personal data is publicized by you,
  • When it is necessary usage or protection of our legal or contractual rights as a company,
  • The processing of your personal data is necessary for our legitimate interest, provided that it does not harm your fundamental rights and freedoms.

We maintain all personal data we process in accordance with the periods stipulated in KVKK and other legislation, and in any case by taking all necessary administrative and technical measures unless the above-mentioned legitimate aims are eliminated.

3. For what purposes do we process your Personal Data?

  • We process the Personal Data we collect according to its nature for the following purposes:
    • Our business units carry out the necessary planning, evaluation and studies in order to benefit our customers from our products and services offered by Watergarden;
    • Conducting advertising and marketing activities for the products and services we provide, providing information on promotions, campaigns, offers, bulletins, events and similar issues, conducting corporate communication activities, and offering products and services in accordance with the tastes, usage habits and needs of the relevant customer;
    • Conducting marketing and customer relationship management activities;
    • Organizing and informing about corporate communication and other activities, campaigns and invitations within this scope, conducting market research studies;
    • In order to improve the digital platforms we offer to our customers and to provide efficient and personalized experience to platform users, to provide statistics on the number, type, frequency of visits, behaviors, geographical locations, etc., to provide personalized content, campaigns and advertisements according to the interests and needs of the platform users, usage of cookies for this purpose;
    • Follow-up evaluation of customer requests, suggestions and complaints, management of customer satisfaction and implementation of planning, statistics and satisfaction evaluation studies within this scope;
    • Carrying out improvement works in order to provide better and more reliable products and services and ensuring sustainability, supervision of suppliers, subcontractors and similar business contacts;
    • Management of business contacts, suppliers, subcontractors, and maintaining similar business relationships, conducting business and commercial relations; implementation of human resources policies;
    • Ensuring the legal and commercial security of Watergarden and persons in contact with Watergarden(Planning of administrative operations for the services provided by our company, business partner / customer / supplier (authorized or employees) evaluation processes, legal compliance process);
    • Ensuring the physical safety and control of the facilities operated by Watergarden;
    • Planning and applying of occupational health and safety processes;
    • Exercise of legal rights, use of information about transaction history after the termination of legal relationship as evidence in case of dispute;
    • Determining and implementing commercial, legal and business strategies;
    • Carrying out financial policies; e-invoice management;
    • Planning, auditing and conducting information security processes, management of information technology infrastructure;
    • Conducting planning, reporting, visitor / customer statistics and similar investigations within the scope of our company’s activities and/or
    • Compliance with domestic legislation, provision of information requested by public institutions and organizations, fulfillment of reporting obligations.

4. Do we transfer your Personal Data to third parties and / or abroad?

We collect your personal data in the presence of the above-mentioned legal reasons and in line with the stated purposes; In order to continue its activities and business processes, our company provides services to our group companies, subsidiaries and affiliates, companies with which we are organic (related companies), business partners, business contacts, suppliers, insurance companies, banks and financial institutions that provide services to our Company in Turkey and abroad, law, tax and so on. support to our consulting firms, company officials, shareholders, legally authorized public institutions and private individuals, in which we receive support in similar fields; storage, archiving, information technology support (server, hosting, software, cloud computing, etc.) that may process personal data on behalf of our company in accordance with the provisions of the KVKK. At Watergarden, we undertake that your personal data will be stored securely and will not be processed illegally.

5. Rights and Personal Procedures of Application and Principles of Personal Data Holder

i. Your rights to your personal data we would like to inform you that you have the following rights with respect to your data being processed within the Company:

  • To learn whether your personal data is processed,
  • To obtain information about it if your personal data is being processed,
  • To learn what the purpose of your personal data is processed and whether your personal data is used for its purpose,
  • To know who the third parties to whom the data are transferred at home or abroad, if any, and which data are transferred,
  • Request the correction of the processed personal data if it is incomplete or incorrect,
  • In case of correcting, deleting or destroying your personal data, requesting that these transactions be notified to the third parties to whom your personal data have been transferred,
  • Requesting destroying or deletion of your processed personal data if the reasons that require the processing of your personal data disappear or if your personal data becomes out of date,
  • Object to the occurrence of a disadvantage by analyzing your processed personal data exclusively through automated systems,
  • You have the right to claim damages if you suffer damage due to unlawful processing of your personal data.

 

ii.Application

You may fill in the application form below in writing or with your registered e-mail address, secure electronic signature, mobile signature or your e-mail address that you have previously informed us and registered in our system. Please click here for the application form.

As Watergarden, we will finalize your requests free of charge within the shortest time and within thirty days at the latest according to the nature of the request. Depending on the nature of your request and the method of application, we may require additional verifications (sending messages to your registered phone, calling, etc.) to determine whether the application belongs to you and thus protect your rights. If there is a cost due to the fulfillment of your requests, we may only charge you the fees that set by the Personal Data Protection Board.

We may accept or reject any request made to Watergarden by giving reasons and forward this reply in writing or electronically to the requesting person. If the request is accepted, as Watergarden we are obliged to fulfill the request immediately.

iii. Complaint

You may file a complaint with the Personal Data Protection Board within 30 days of the date on which the response was notified to you, if the request is not rejected by the Company, if you are dissatisfied or not answered by the Company, and if the response is not answered within 30 days.

6. Data Responsible Identity and Contact Information

This informing text edited by Watergarden Gayrimenkul Yatırım A.Ş. established in Turkey and given the information below addressed to persons named as “Data Officer”.

 

Commercial title: Watergarden Gayrimenkul Yatırım A.Ş.

Address: Mahmutbey Neighborhood, Taşocağı Yolu St. No:24/41 Bağcılar / İstanbul

Mersis no: 0800091240000001

Phone number: +90216 504 75 25

Fax: +90 216 504 75 30

KEP address: watergardengayrimenkul@hs01.kep.tr

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