WATERGARDEN PRIVACY POLICY

WATERGARDEN has agreed to ensure the confidentiality of the information shared by you who visit the website. For this reason, this “Privacy Policy” was created with the aim of informing you, site users (“Data Owner”), by explaining the terms and conditions related to the use of personal data generated during use of the website “www.watergarden.com.tr” and "www.cinehall.com.tr (“Site”) operated by Watergarden Gayrimenkul Yatırım A.Ş. (“The Company”). The service offered by WATERGARDEN will be referred to as “Service”.

WHAT IS PERSONAL DATA AND DATA PROCESSING?

Personal data refers to personal information (name, surname, Turkish identity number, etc.), address and telephone information, professional information, IP address, bank account information within the framework of the, Privacy Policy. Special Personal Data includes data on race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, disguise and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, sensitive personal data such as your genetic data. These Personal and Special Personal Data constitutes the subject of this “Privacy Policy”.

With the processing of Personal Data; the acquisition, storage, modification, reorganization, disclosure, transfer, takeover, availability, classification, or use of personal data, whether fully or partially automated or as part of any data recording system refers to any operation performed on such data.

SCOPE OF PRIVACY POLICY

As part of the service provided, WATERGARDEN may collect, maintain and / or transmit personal information about you receiving services under this “Privacy Policy”. Such personal data processing activities are carried out in accordance with the Law No. 6698 on the Protection of Personal Data(“KVKK”).

This “Privacy Policy” does not cover the applications collected outside WATERGARDEN’s own control, information collected by third parties’ websites and / or platforms, information collected by third parties through links on the WATERGARDEN website, or any third party websites WATERGARDEN sponsors and / or participates in. headlines, campaigns, and other advertising or promotions. WATERGARDEN is not responsible for the processing of personal data collected, stored and used by third parties through their own web sites, and if you provide personal information and / or use / visit these sites, the privacy policy and terms of use of those sites apply.

WHICH PERSONAL DATA ARE PROCESSED?

Some personal information is processed by the Company within the scope of the Services provided on the Site. This personal information may include: Your personal information, contact information, records of your marketing and contact preferences, your IP address, the pages you view on our site, the data that identifies your mobile device if you visit our site with your mobile device, and the information that you explicitly choose to give and any other information that we may obtain with your consent may be collected, processed and recorded by us.

In addition, cookies are used on the Site to improve the user experience, to ensure efficient operation of the website and to monitor statistical data. Some of the personal data mentioned above can be obtained using cookies and users agree to the use of these cookies using the Site. You can review our WATERGARDEN Cookie Policy to get detailed information about the function of cookies, what kind of cookies are used, the intended use and data transfers to third parties and to change your cookie preferences.

WHAT PURPOSE IS YOUR PERSONAL DATA PROCESSED?

Your personal information can be processed to provide the best service you requested from WATERGARDEN, the products and services offered to you with your demands and expectations to be realized and to provide personal experience, to benefit our customers from our products and services, planning and evaluation of the products and services by our business units, products and services customized and presented according to the tastes, usage habits and needs of the persons concerned; follow-up, evaluation of customer requests, suggestions and complaints, customer satisfaction management and implementation of planning, statistics and satisfaction evaluation studies within this scope; determination of commercial, legal and business strategies and implementation, legal and technical and commercial-business security of the Company and the related persons in the business relationship with the Company.

Your personal information may also be processed for the purpose of providing improvement and sustainability to provide better and more reliable products and services, and to ensure that third parties fulfill their technical and other functions (maintenance, support, backup services, etc.) as a service provider on our behalf.

In addition, your personal information can be used for advertising and marketing activities for our products and services provided that you have explicit consent, to provide information on promotions, campaigns, offers, newsletters, events and other marketing communications.

For the purposes above, we process your personal data for one or more of the following legal reasons:

Having your express consent,

Processing needed to make the provisions of the applicable laws and regulations of the Republic of Turkey,

Being obliged to protect the life or body integrity of the person or someone else when he or she cannot disclose their consent due to the actual impossibility,

Required for the performance of the contract we have 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,

To be required for the exercise or protection of our legal or contractual rights as a company,

Providing the processing of your personal data is necessary for our legitimate interest, without prejudice to 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.

WHO IS YOUR PERSONAL DATA SHARED WITH?

The Company may transfer the personal data of the Data Owner to a limited number of domestic and overseas third parties providing services to the Company in order to achieve the purposes set forth in this Privacy Policy.

The Company may use your personal data to improve the Data Owner experience (including improvement and personalization), to ensure the Data Owner’s security, to detect fraudulent or unauthorized use, to perform operational evaluation, to correct support for outsourcing service providers including lawyers, authorized institutions and organizations, research companies, storage, archiving, information technology support (server, hosting, software, cloud computing, etc.) service providers and consulting firms that we receive.

In addition, some of the personal data obtained by WATERGARDEN as set out in this “Privacy Policy” may be shared with advertisers in aggregate with other users’ information only to ensure that the ads can be adapted to the target audience. In this context, no personal information is provided in any way, it is used only for the purpose of conducting some analyzes about user tendencies as a group, performing statistical studies by anonymizing the information and for segmentation purposes.

WATERGARDEN may also disclose your Personal Data for any of the following reasons: (i) in accordance with legal requirements; (ii) to comply with administrative and judicial proceedings and the demands of administrative or judicial authorities; (iii) in order to carry out the Terms of Service; (iv) in order to protect its activities; (v) to take reasonable steps to protect the rights, privacy, security or property of WATERGARDEN, you or third parties, or to make it possible to limit damages that may be incurred.

WHAT ARE YOUR RIGHTS AS THE DATA OWNER?

Please note 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.

Please refer to the WATERGARDEN Informing Text on Pretection of Personal Data for the application procedures related to the above requests. You can fill in the Application Form within the scope of KVKK and send it in writing or via your registered e-mail address, secure electronic signature, mobile signature or e-mail address that you have previously informed us and registered in our system.

Your requests will be evaluated 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 set by the Personal Data Protection Board.

We may accept requests made to the Company or reject them by explaining the reasons and forward this reply in writing or electronically to the requesting person. If the request is accepted, we, as the Company, are obliged to fulfill the request immediately. You may file a complaint with the Personal Data Protection Board within 30 days from the date on which you are notified of the response, and 30 days from the end of the 30-day period if the response is rejected by the Company, if you are dissatisfied or not answered by the Company.

HOW LONG IS YOUR PERSONAL DATA STORED?

WATERGARDEN will store your Personal Data for the period required by the processing purposes set forth in this “Privacy Policy” unless a longer retention period is required or permitted under applicable legislation. It will destroy such data if the purpose of data processing is lost or if requested by the data owner. (erase, destroy or anonymize.)

In addition, in the event of any dispute between the Data Owner and the Company, the Company will be able to store personal data for a limited period and in accordance with the applicable legislation, for the purpose of making the necessary defenses under the dispute.

PROVIDING DATA SECURITY

WATERGARDEN is committed to keeping personal information strictly confidential, to treat it as a confidentiality obligation, and to provide the necessary and reasonable protection to protect the confidentiality, security and integrity of personal data; is committed to taking all necessary measures to ensure that all or any part of it, without prejudice to its legal obligations, enters into the public domain or unauthorized use or disclosure to a third party and takes due care.

In case of linking to other applications through the Site, the Company has no responsibility for the privacy policies and content of the applications.

POLICY UPDATE

WATERGARDEN may change the content of this Privacy Policy at any time to keep the privacy and data protection principles up to date and to comply with applicable legislation. The changed Privacy Policy will be posted on the WATERGARDEN website. We therefore recommend that you periodically review our Privacy Policy. The provisions of the Privacy Policy that WATERGARDEN makes changes will be effective on the date of publication on the Site. If you continue to use the Site even after the change has been made, it means that you have accepted the changes.

CONTACT US

If you have any questions, concerns or complaints regarding the interpretation or implementation of this Policy, you may forward them to the following contact addresses.

Contact information: Watergarden Gayrimenkul Yatırım A.Ş.

Email: kvkk@watergarden.com.tr

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

Last updated: 22/02/2019