Office Rental

COMMERCIAL ELECTRONIC MESSAGE PERMISSION

This text indicates that, within the scope of the Law No. 6563 on the Regulation of Electronic Commerce, Office Rental Systems İnşaat Sanayi Ve Ticaret Anonim Şirketi (“Plaza Cubes”) sends me commercial electronic messages and other messages in accordance with the relevant laws, and that my contact information stated below has been received for these purposes and that I have preferred it. Messages will be sent to me through the channel I specified; that my contact information may be shared with third parties for the above-mentioned purposes in accordance with the legal principles regarding the processing of my contact information by taking the necessary measures to protect their confidentiality, and that it will be processed in other ways specified in the law, that I can change my communication preferences at any time or stop the communication by exercising my right to reject this communication permission I have given without giving any reason, and in all other relevant matters. informed/informed by the explanations herein and/or my agreement; Survey applications carried out within the scope of various information, publicity, advertising, promotion, sales and marketing activities regarding the products and services offered by Plaza Cubes, including sending newsletters, are carried out by Plaza Cubes in accordance with the law via SMS/text message, automatic call, telephone call, social media, etc. It includes my consent to send commercial electronic messages and other messages to me through the communication channels I have chosen below, among media and online advertising networks, e-mail/mail and other electronic communication tools-channels.

INFORMATION TEXT ON THE PROCESSING OF PERSONAL DATA FOR CUSTOMERS

This Document is designed to inform you about the processing of your personal data as per the Article 10 of the Law no. 6698 on Personal Data Protection Law (“Law”).  

Ofis Kiralama Sistemleri İnşaat Sanayi Ve Ticaret Anonim Şirketi and Ofis Gayrimenkul Turizm Pazarlama Ticaret Limited Şirketi (“Plaza Cubes”), shall be the Data Controller as per the Law with respect to the personal data collected from its customers. There is a partnership relationship between the companies, and the same database is being used.

Purposes of Processing Your Personal Data

Plaza Cubes may process your personal data forthe purposes listed below, in accordance with theconditions for personal data processing specifiedin Articles 5 and 6 of Law No. 6698.

Your personal data related to identity information, contact information, financial information, andcustomer transaction information are processedbased on the legal grounds stipulated under Article5/2(c) of Law No. 6698, which allows for theprocessing of personal data belonging to theparties of a contract, provided that it is directlyrelated to the establishment or performance of thecontract. These data are processed for fulfillingcontractual obligations, establish and perform a lease contract, managing customer relations, providing services tailored to your needs, ensuringdata accuracy and currency, handling requests orcomplaints, and fulfilling our legal obligations.

When you use the Online Customer Service

Representative channel on the company’scorporate website, your personal data, includingyour name, surname, phone number, and anyinformation shared during your communicationwith our representative, are processed to provideservice and resolve issues. This data is collectedand processed in accordance with Articles 5(2)(c) and 5(2)(f) of the PDPL, for the performance of the contract and based on the legitimate interestsof the data controller, in compliance with alladministrative and technical measures set forth in the PDPL.

In the event that you wish for us to contact you, your personal data such as your first name, lastname, phone number, email address, companyname, how many people are in your team, yourworking style, location preferencei and your voicerecord will be collected when you fill out the form available under theRequest a Callback‘ link on our website https://www.plazacubes.com/. Yourcollected personal data is processed to respond toyour requests, connect you with an appropriaterepresentative, promote our services, and shapeour services according to your needs, as well as toensure the provision of related services. Thisprocessing is based on the following legal groundsunder the PDPL Art. 5/2(c): where processing of personal data belonging to the parties to a contract is necessary, provided that it is directlyrelated to the conclusion or performance of thatcontract”, PDPL Art. 5/2(d): where the data concerned has been made public by the data subject”, and PDPL Art. 5/2(f): where processingis mandatory for the legitimate interests of thedata controller, provided that it does not harm thefundamental rights and freedoms of the data subject”.

Your identity and contact information areprocessed with your explicit consent based on theprovision in Article 5(1) of the PDPL, whichstates, “Personal data cannot be processed withoutthe explicit consent of the data subject.” This data is processed for the purpose of sending youinformative content about campaigns and offers, newsletters, promotional materials, planningcustomer satisfaction processes, and for theplanning and execution of marketing activities.

Your image and access data are processed by Plaza Cubes under Article 5(2)(f) of the TurkishPersonal Data Protection Law (KVKK) based on the legitimate interests of the data controller, provided that the processing does not harm thefundamental rights and freedoms of the data subject, and solely for the purpose of ensuringsecurity in Plaza Cubes premises.

Additionally, in accordance with the secondaryrights and obligations arising from the contractbetween us, your personal data is processed byPlaza Cubes under Article 5(2)(ç) of KVKK tofulfill our legal obligations.

Your MAC address, IP address, and computer log information are processed under Article 5(2)(a) of KVKK for the purpose of fulfilling our legal obligations in connection with the internet servicesyou use at our locations.

Method and Legal Ground for Collecting Your Personal Data

Your personal data may be collected by Plaza Cubes physically, CCTV and call centers, orally, in writing or in electronic media.

Disclosure of Your Personal Data

Plaza Disclose shall, in order to achieve the data processing purposes specified above, disclose and share your personal data to public bodies and organizations, business partners, third parties and vendors providing support and services to Plaza Cubes.

Your Rights as a “Data Subject” with regard to Your Personal Data

By applying to our company you are entitled to;

Learn whether your personal data is processed or not
If your personal data is processed, request information,
Learn the purpose of processing your personal data and whether your personal data is used in accordance with the purpose of processing,
Learn third parties to whom your personal data is transferred at home or abroad,
Request correction if and when your personal data is processed incompletely or incorrectly,
Request the deletion or destruction of your personal data as per the conditions prescribed in the applicable legislation,
Request the notification to third parties to whom your personal data is transferred, about the correction, deletion and destruction of your personal data as per the applicable legislation,
Raise objections to any negative consequence on your side as a result of analyzing your personal data exclusively via automatic systems,
Claim damages if you suffer damages and losses due the processing of your personal in contradiction with the law

. In accordance with the principles and procedures specified in the Communiqué no. 30356, dated 10.03.2018 on the Principles and Procedures for Applying to the Data Controller, you can, with original signed documents, apply to the address Maslak Mah. Bilim Sok.No.5 Sun Plaza Kat 13-15 Şişli/İstanbul together with the documents showing your identity; or to ofiskiralama@hs01.kep.tr using the registered electronic mail (KEP) address, secure electronic signature, mobile signature or using your electronic mail address notified to our company before and registered in our system. The requests in your application shall be finalized free of charge within maximum 30 days depending on the nature of the request.

PERSONAL DATA PROTECTION AND PRIVACY POLICY

1. SCOPE

Personal Data Protection and Privacy Policy has been prepared in order to provide the necessary information by explaining the set of rules for the processing of personal data, and it was approved by the Board of Directors of Ofis Kiralama Sistemleri İnşaat Sanayi ve Ticaret Anonim Şirketi (“Plaza Cubes” or “Company”) and came into force on .

The policy covers everyone whose personal data is processed by the company, except Plaza Cubes employees. There is also an “Employee Policy” for our company employees, Office Rental Systems Construction Industry and Trade Joint Stock Company Employees Personal Data Protection and Privacy Policy.

2. DEFINITIONS
Explicit consent:It refers to consent regarding a specific subject, based on informed consent and expressed with free will.
Anonymization:It refers to making personal data impossible to associate with an identified or identifiable natural person in any way, even by matching it with other data.
Contact personRepresents the real person whose personal data is processed.
LawPersonal Data Protection Law
Personal data:It refers to all kinds of information regarding an identified or identifiable natural person.
Processing of personal data:Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, obtaining personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. It refers to any operation performed on data such as making it accessible, classifying it or preventing its use.
Personal Data Protection Law (‘KVKK’):Although it is the subject of this Policy, Law No. 6698 dated 24 March 2016 published in the Official Gazette No. 29677 dated 7 April 2016
BoardPersonal Data Protection Board
InstitutionPersonal Data Protection Authority
Data processor:Natural or legal person who processes personal data on behalf of the data controller based on the authority given by him/her
Data recording system:Recording system where personal data is structured and processed according to certain criteria
Data controller:The natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system
Special personal data:Data regarding race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data. .
Policy:Personal Data Protection and Privacy Policy
3. CHANGES

Changes to be made to this Policy with the entry into force of additional legislation within the scope of the Law or from time to time will be available on Plaza Cubes’ corporate website www.plazacubes.com. The current version of this Policy can also be accessed from this corporate site.

4. BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA

Plaza Cubes processes personal data in accordance with the following principles, in accordance with the 2nd paragraph of Article 4 of the Law and within the scope of the purposes exemplified in the ‘Purposes of Processing Personal Data’ section of this Policy:

  • Being in compliance with the law and the rules of honesty
  • Accurate and up-to-date when necessary
  • Processing for specific, clear and legitimate purposes
  • Being related to the purpose for which they are processed, limited and proportionate
  • Keeping for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed
5. CLARIFICATION AND INFORMATION OF THE PERSONAL DATA OWNER

In accordance with Article 10 of the Law, Plaza Cubes informs personal data owners during the acquisition of personal data. In this context, during the acquisition of personal data by our Company to personal data owners, the identity of our Company, the purpose for which the personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method and legal reason of collecting personal data, and the personal data owner’s possession within the scope of Article 11 of the Law. Clarification regarding rights is provided.

  1. REASONS FOR COMPLIANCE WITH THE LAW IN THE PROCESSING OF PERSONAL DATA

Explicit consent of the personal data owner is only one of the legal bases that enable the lawful processing of personal data. Apart from explicit consent, personal data may also be processed if one of the other conditions listed below is met. The basis for personal data processing may be only one of the conditions listed below, or more than one of these conditions may be the basis for the same personal data processing activity. If the data processed is personal data of special nature; The following conditions apply.

  • Explicit Consent of the Personal Data Owner
  • Clearly Provided in Laws
  • Failure to Obtain Explicit Consent of the Person Relevant Due to Actual Impossibility
  • Directly Involved in the Establishment or Performance of the Contract
  • Plaza Cubes Fulfills Its Legal Obligations
  • Personal Data Owner’s Publicization of Personal Data
  • Data Processing is Necessary for the Establishment or Protection of a Right
  • Data Processing is Necessary for the Legitimate Interests of Plaza Cubes

Although the legal basis for processing personal data by our company varies, all kinds of personal data processing activities are carried out in accordance with the general principles specified in Article 4 of Law No. 6698.

7. REASONS FOR COMPLIANCE WITH THE LAW IN THE PROCESSING OF SPECIAL PERSONAL DATA

In Article 6 of the Law, some personal data that poses the risk of causing victimization or discrimination when processed unlawfully are designated as “special nature”. These data; Data regarding race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, appearance and clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data.

By Plaza Cubes in accordance with the law; Special categories of personal data are processed in the following cases, provided that adequate measures are taken to be determined by the KVK Board:

  • If there is explicit consent of the personal data owner, or
  • If there is no explicit consent of the personal data owner;
  • Special categories of personal data, other than the health and sexual life of the personal data owner, in cases stipulated by law,
  • Special personal data regarding the personal data owner’s health and sexual life can only be used by persons or authorized persons under the obligation of confidentiality for the purpose of protecting public health, preventive medicine, medical diagnosis, execution of treatment and care services, planning and management of health services and their financing. It is processed by institutions and organizations.
8. PERSONAL DATA PROCESSED BY PLAZA CUBES

Plaza Cubes processes the following personal data it obtains, in accordance with the above-mentioned principles and legal compliance reasons, by informing the relevant persons in accordance with Article 10 of the Law. Owners of personal data belonging to the data categories specified below are specified in Section 9 of the Policy.

Identity InformationInformation contained in identity cards, driver’s licenses and passport documents pertaining to an identified or identifiable natural person.
Contact InformationE-mail, telephone number, address information related to an identified or identifiable natural person.
Customer InformationInvoices, bank information, etc. obtained, provided that they are limited to the scope of commercial activities related to an identified or identifiable natural person. information.
Employee Candidate InformationPersonal information, educational information, work experience, etc. obtained, provided that it is limited to the scope of recruitment to our company, related to an identified or identifiable real person. information.
Benefits InformationInformation obtained, provided that it is limited to the side rights and benefits offered by our company, regarding an identified or identifiable natural person.
Facility Security InformationRecords, documents, camera images, fingerprint information obtained during logins to our company regarding an identified or identifiable natural person.
Legal Transaction InformationInformation obtained regarding an identified or identifiable natural person, provided that it is limited to fulfilling our company’s legal obligations.
Information Technologies KnowledgeIP address, Mac address, Log records, etc. obtained regarding an identified or identifiable natural person. information.
Financial InformationBank account number, IBAN number, asset information, etc., limited to documents showing the financial result of an identified or identifiable real person. information.
9. CATEGORIZATION REGARDING THE OWNERS OF PERSONAL DATA PROCESSED BY PLAZA CUBES

Real persons whose personal data is processed by Plaza Cubes; It is limited to customers, potential customers, third parties with whom our customers work, employee candidates, visitors, supplier/business partner employees, company officials and third parties. The persons included in the data subject categories in question are detailed in the table below; Our company employees are evaluated in the Employee Policy.

CustomerReal persons who benefit from our company’s products and services.
Potential CustomerReal persons who are or may be interested in our company’s products and services.
Third Parties Our Customers Work WithReal persons who benefit from our company’s products and services and who contact them through our company by any means.
Employee CandidateReal persons who have applied for a job to our company by any means and sent a resume.
VisitorReal persons who have entered our company’s premises or visited our website in any way.
Supplier/Partner EmployeesEmployees and authorities of the institutions with which our company has any business relationship, receives service or cooperates.
Company OfficialMembers of the Board of Directors and shareholders of our company.
With Third PartiesReal persons (guarantors, family members, relatives, etc.) whose personal data our company processes in accordance with its legal obligations or company procedures.
10. PRECAUTIONS TAKEN REGARDING THE PROTECTION OF PERSONAL DATA

In accordance with Article 12 of the Law, Plaza Cubes takes the necessary technical and administrative measures to ensure the appropriate level of security to prevent unlawful processing and access of the personal data it processes and to ensure the preservation of the data, and carries out the necessary inspections or has them carried out in this context.

In this context, Plaza Cubes; Personal data is of special nature; The degree to which it requires confidentiality due to its nature; It carries out its activities by taking into account the extent to which it may affect the rights and freedoms of the data owner in the event of a security breach.

Administrative Measures Taken by Plaza Cubes

  • Employees were trained to raise awareness about the protection of personal data.
  • A personal data security policy has been created; Necessary efforts have been made to comply with this policy.
  • It has been ensured that personal data that is not needed for the processing purposes is no longer retained.
  • Additional protocols regarding data security and transfer have been signed with data processors.
  • A personal data processing inventory has been prepared.

Technical Measures Taken by Plaza Cubes

  • Measures such as firewalls and gateways have been taken against unauthorized access over the Internet.
  • Physical environments containing personal data are protected against external risks with appropriate methods, and entries and exits to these areas are controlled.
  • A commitment has been received that the security measures taken by the cloud storage service provider are sufficient and appropriate.
  • Data backup work is being carried out.
11. RIGHTS OF THE “RELATED PERSON” REGARDING PERSONAL DATA AND APPLICATION METHOD

Within the framework of Article 11 of the Law, the relevant person can apply to Plaza Cubes at any time. The person concerned;

  • Learning whether your personal data is being processed,
  • If your personal data has been processed, requesting information about it,
  • Learning the purpose of processing your personal data and whether your personal data is used in accordance with the purpose of processing,
  • Knowing the third parties to whom your personal data is transferred at home or abroad,
  • Request correction of your personal data if they are incomplete or incorrectly processed,
  • Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
  • Requesting that correction, deletion and destruction operations carried out in accordance with the relevant legislation be notified to third parties with whom your personal data has been shared,
  • To object to the emergence of a result unfavorable to you by analyzing your processed personal data exclusively through automatic systems,
  • If you suffer damage due to unlawful processing of your personal data, request compensation for the damage,

They have rights.

In accordance with the procedures and principles in the Communiqué on the Procedures and Principles of Application to the Data Controller dated 10.03.2018 and numbered 30356, together with the documents showing your identity, with a wet signature to the address ………………………………; or ………….…….. You can apply by using your registered e-mail (KEP) address, secure electronic signature, mobile signature or your e-mail address previously notified to our company and registered in our system. Requests in the application will be answered free of charge within 30 days at the latest, depending on the nature of the request.

12. PERSONAL DATA PROCESSED BY PLAZA CUBES AND THE PURPOSES OF PROCESSING

The data owners specified in Sections 8 and 9 of this policy and the personal data related to these data owners are processed for the following purposes;

  • Fulfillment of contractual obligations,
  • Conducting customer relations,
  • Providing the services offered by the company according to the needs,
  • Keeping data accurate and up-to-date,
  • Planning customer satisfaction processes,
  • Planning and execution of marketing activities,
  • Management of requests or complaints,
  • Creating and tracking visitor records,
  • Ensuring security for visitors in our company’s buildings and facilities,
  • Fulfillment of our legal obligations,
  • Workforce planning and new personnel selection
  • Management of human resources processes such as recruitment,
  • It is processed for the purposes of evaluating your job application and managing employee recruitment processes.
13. STORAGE OF PERSONAL DATA

Personal data processed by Plaza Cubes can be stored for the period required for the purposes of processing. If there is no legal reason to store it after the purpose of processing is eliminated; personal data is deleted, destroyed or anonymized.

In this context, Plaza Cubes takes the necessary technical and administrative measures within the Company in order to fulfill its relevant obligations; It has developed the necessary operating mechanisms in this regard; It trains, assigns and raises awareness of the relevant business units in order to comply with these obligations.

14. THIRD PARTIES TO WHICH PERSONAL DATA IS TRANSFERRED BY PLAZA CUBES

Our company can transfer the personal data and sensitive personal data of the personal data owner to third parties (Group Companies, business partners, shareholders, affiliates, insurance companies, public institutions and/or organizations and other third parties) by taking the necessary security measures in line with the legal personal data processing purposes. . In this regard, our company acts in accordance with the regulations stipulated in Article 8 of the KVK Law.

Plaza Cubes may transfer the personal data of data owners managed by the Policy to the categories of persons listed below in accordance with Articles 8 and 9 of the Law:

Supplier/Business PartnerPlaza Cubes shares limited services with outsourced services that are necessary for the continuity of our company’s business processes.
To official institutions and organizationsPlaza Cubes shares shares limited to fulfilling its legal obligations.
To legally authorized private legal personsPlaza Cubes shares shares limited to the purpose requested by private law persons within their legal authority.
15. PLAZA CUBES PERSONAL DATA PROTECTION AND PROCESSING POLICY GOVERNANCE STRUCTURE

The principles set forth by Plaza Cubes with this Policy; It ensures that the relevant principles are implemented within the Company with the policies, procedures and application guides it puts forward for the execution. By establishing a connection between the policies, procedures and application guides regarding the protection of personal data and the basic policies, procedures and application guides carried out by the Company in other areas, compatibility is also ensured between the processes operated by the Company with different policy principles for similar purposes.

Plaza Cubes subjects all procedures established for the implementation of this Policy to each audit internally or by an independent third-party consultant. In this context, when a change is made to this Policy, the approval of Plaza Cubes’ senior management is required for the updated policy to come into force. In addition, Plaza Cubes takes the necessary legal actions to ensure compliance with its obligations within the scope of the Law and secondary legislation and to complete them in case of deficiencies. Plaza Cubes employees have sufficient awareness about the protection of personal data and have completed training on this subject. As a company, within the scope of the importance given to this issue, measures are taken regarding the security of personal data; Data owners are informed about their rights in this regard.

Office Real Estate

COMMERCIAL ELECTRONIC MESSAGE PERMISSION

This text indicates that, within the scope of the Law No. 6563 on the Regulation of Electronic Commerce, Office Rental Systems İnşaat Sanayi Ve Ticaret Anonim Şirketi (“Plaza Cubes”) sends me commercial electronic messages and other messages in accordance with the relevant laws, and that my contact information stated below has been received for these purposes and that I have preferred it. Messages will be sent to me through the channel I specified; that my contact information may be shared with third parties for the above-mentioned purposes in accordance with the legal principles regarding the processing of my contact information by taking the necessary measures to protect their confidentiality, and that it will be processed in other ways specified in the law, that I can change my communication preferences at any time or stop the communication by exercising my right to reject this communication permission I have given without giving any reason, and in all other relevant matters. informed/informed by the explanations herein and/or my agreement; Survey applications carried out within the scope of various information, publicity, advertising, promotion, sales and marketing activities regarding the products and services offered by Plaza Cubes, including sending newsletters, are carried out by Plaza Cubes in accordance with the law via SMS/text message, automatic call, telephone call, social media, etc. It includes my consent to send commercial electronic messages and other messages to me through the communication channels I have chosen below, among media and online advertising networks, e-mail/mail and other electronic communication tools-channels.

INFORMATION TEXT ON THE PROCESSING OF PERSONAL DATA FOR CUSTOMERS

This document is based on the Personal Data Protection Law No. 6698 (“Law”) regarding the processing of your personal data. It has been prepared to ensure that you are enlightened within the framework of 10.

Ofis Gayrimenkul Turizm Pazarlama Ticaret Limited Şirketi (“Plaza Cubes”) has the title of Data Controller in accordance with the Law in terms of the personal data it obtains from you, our customers.

Purposes of Processing Your Personal Data

Plaza Cubes may use your personal data for the purposes listed below; It can be processed within the personal data processing conditions specified in Articles 5 and 6 of Law No. 6698;

Your identity information, contact information, camera images and other personal data declared by you during your visit to our company facility are processed for the purposes of creating and tracking visitor records and ensuring security for visitors in our company’s buildings and facilities.

Collection Method and Legal Reason of Your Personal Data

Your personal data can be collected by Plaza Cubes physically, verbally, in writing or electronically or via CCTV. Plaza Cubes processes and shares your personal data to fulfill its legal obligations, especially the establishment and execution of the contract, and for the reasons clearly stipulated by law.

Sharing of Your Personal Data

In this context, Plaza Cubes does not share your personal data with third parties.

Storage of Your Personal Data

Your personal data may be stored for the period required for the purposes of processing. After the purpose of processing ceases, your personal data is deleted, destroyed or anonymized if there is no legal reason to keep it.

Security of Your Personal Data

In order to ensure that your personal data is processed and stored securely in accordance with the law and to prevent unlawful access to your personal data, Plaza Cubes takes all necessary technical and administrative measures to ensure the appropriate level of security.

Your Rights as a “Relevant Person” Regarding Your Personal Data

By applying to our company;

  • Learning whether your personal data is being processed,
  • If your personal data has been processed, requesting information about it,
  • Learning the purpose of processing your personal data and whether your personal data is used in accordance with the purpose of processing,
  • Knowing the third parties to whom your personal data is transferred at home or abroad,
  • Request correction of your personal data if they are incomplete or incorrectly processed,
  • Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
  • Requesting that correction, deletion and destruction operations carried out in accordance with the relevant legislation be notified to third parties with whom your personal data has been shared,
  • To object to the emergence of a result unfavorable to you by analyzing your processed personal data exclusively through automatic systems,
  • If you suffer damage due to unlawful processing of your personal data, request compensation for the damage,

You do not have the rights. In accordance with the procedures and principles of the Communiqué on the Procedures and Principles of Application to the Data Controller dated 10.03.2018 and numbered 30356, together with the documents showing your identity, with a wet signature to the address ………………………………; or you can apply to ………….…….. by using your registered e-mail (KEP) address, secure electronic signature, mobile signature or your e-mail address previously notified to our company and registered in our system. The requests in your application will be terminated free of charge within 30 days at the latest, depending on the nature of the request.

PROTECTION OF PERSONAL DATA ANDPRIVACY POLICY

CONTENTS

  • SCOPE
  • DEFINITIONS
  • CHANGES
  • BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA
  • CLARIFICATION AND INFORMATION OF THE PERSONAL DATA OWNER
  • REASONS FOR LAW COMPLIANCE IN THE PROCESSING OF SPECIAL PERSONAL DATA
  • PERSONAL DATA PROCESSED BY PLAZA CUBES
  • CATEGORIZATION REGARDING THE OWNERS OF PERSONAL DATA PROCESSED BY PLAZA CUBES
  • PRECAUTIONS TAKEN REGARDING THE PROTECTION OF PERSONAL DATA
  • RIGHTS OF THE “RELATED PERSON” REGARDING PERSONAL DATA AND APPLICATION METHOD.
  • PERSONAL DATA PROCESSED BY PLAZA CUBES AND THE PURPOSES OF PROCESSING
  • STORAGE OF PERSONAL DATA.
  • THIRD PARTIES TO WHICH PERSONAL DATA IS TRANSFERRED BY PLAZA CUBES.
  • PLAZA CUBES PERSONAL DATA PROTECTION AND PROCESSING POLICY GOVERNANCE STRUCTURE.
1. SCOPE

Personal Data Protection and Privacy Policy has been prepared to provide the necessary information by explaining the set of rules for the processing of personal data, and it was approved by the Board of Directors of Ofis Gayrimenkul Turizm Pazarlama Ticaret Limited Şirketi (“Plaza Cubes” or “Company”) and came into force on .

The policy covers everyone whose personal data is processed by the company, except Plaza Cubes employees. There is also an “Employee Policy” for our company employees, Office Rental Systems Construction Industry and Trade Joint Stock Company Employees Personal Data Protection and Privacy Policy.

2. DEFINITIONS
Explicit consent:It refers to consent regarding a specific subject, based on informed consent and expressed with free will.
Anonymization:It refers to making personal data impossible to associate with an identified or identifiable natural person in any way, even by matching it with other data.
Contact personRepresents the real person whose personal data is processed.
LawPersonal Data Protection Law
Personal data:It refers to all kinds of information regarding an identified or identifiable natural person.
Processing of personal data:Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, obtaining personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. It refers to any operation performed on data such as making it accessible, classifying it or preventing its use.
Personal Data Protection Law (‘KVKK’):Although it is the subject of this Policy, Law No. 6698 dated 24 March 2016 published in the Official Gazette No. 29677 dated 7 April 2016
BoardPersonal Data Protection Board
InstitutionPersonal Data Protection Authority
Data processor:Natural or legal person who processes personal data on behalf of the data controller based on the authority given by him/her
Data recording system:Recording system where personal data is structured and processed according to certain criteria
Data controller:The natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system
Special personal data:Data regarding race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data. .
Policy:Personal Data Protection and Privacy Policy
3. CHANGES

Changes to be made to this Policy with the entry into force of additional legislation within the scope of the Law or from time to time will be available on Plaza Cubes’ corporate website www.plazacubes.com. The current version of this Policy can also be accessed from this corporate site.

4. BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA

Plaza Cubes processes personal data in accordance with the following principles, in accordance with the 2nd paragraph of Article 4 of the Law and within the scope of the purposes exemplified in the ‘Purposes of Processing Personal Data’ section of this Policy:

  • Being in compliance with the law and the rules of honesty
  • Accurate and up-to-date when necessary
  • Processing for specific, clear and legitimate purposes
  • Being related to the purpose for which they are processed, limited and proportionate
  • Keeping for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed
5. CLARIFICATION AND INFORMATION OF THE PERSONAL DATA OWNER

In accordance with Article 10 of the Law, Plaza Cubes informs personal data owners during the acquisition of personal data. In this context, during the acquisition of personal data by our Company to personal data owners, the identity of our Company, the purpose for which the personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method and legal reason of collecting personal data, and the personal data owner’s possession within the scope of Article 11 of the Law. Clarification regarding rights is provided.

5. REASONS FOR COMPLIANCE WITH THE LAW IN THE PROCESSING OF PERSONAL DATA

Explicit consent of the personal data owner is only one of the legal bases that enable the lawful processing of personal data. Apart from explicit consent, personal data may also be processed if one of the other conditions listed below is met. The basis for personal data processing may be only one of the conditions listed below, or more than one of these conditions may be the basis for the same personal data processing activity. If the data processed is personal data of special nature; The following conditions apply.

  • Explicit Consent of the Personal Data Owner
  • Clearly Provided in Laws
  • Failure to Obtain Explicit Consent of the Person Relevant Due to Actual Impossibility
  • Directly Involved in the Establishment or Performance of the Contract
  • Plaza Cubes Fulfills Its Legal Obligations
  • Personal Data Owner’s Publicization of Personal Data
  • Data Processing is Necessary for the Establishment or Protection of a Right
  • Data Processing is Necessary for the Legitimate Interests of Plaza Cubes

Although the legal basis for processing personal data by our company varies, all kinds of personal data processing activities are carried out in accordance with the general principles specified in Article 4 of Law No. 6698.

7. REASONS FOR COMPLIANCE WITH THE LAW IN THE PROCESSING OF SPECIAL PERSONAL DATA

In Article 6 of the Law, some personal data that poses the risk of causing victimization or discrimination when processed unlawfully are designated as “special nature”. These data; Data regarding race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, appearance and clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data.

By Plaza Cubes in accordance with the law; Special categories of personal data are processed in the following cases, provided that adequate measures are taken to be determined by the KVK Board:

  • If there is explicit consent of the personal data owner, or
  • If there is no explicit consent of the personal data owner;
  • Special categories of personal data, other than the health and sexual life of the personal data owner, in cases stipulated by law,
  • Special personal data regarding the personal data owner’s health and sexual life can only be used by persons or authorized persons under the obligation of confidentiality for the purpose of protecting public health, preventive medicine, medical diagnosis, execution of treatment and care services, planning and management of health services and their financing. It is processed by institutions and organizations.
8. PERSONAL DATA PROCESSED BY PLAZA CUBES

Plaza Cubes processes the following personal data it obtains, in accordance with the above-mentioned principles and legal compliance reasons, by informing the relevant persons in accordance with Article 10 of the Law. Owners of personal data belonging to the data categories specified below are specified in Section 9 of the Policy.

Identity InformationInformation contained in identity cards, driver’s licenses and passport documents pertaining to an identified or identifiable natural person.
Contact InformationE-mail, telephone number, address information related to an identified or identifiable natural person.
Customer InformationInvoices, bank information, etc. obtained, provided that they are limited to the scope of commercial activities related to an identified or identifiable natural person. information.
Employee Candidate InformationPersonal information, educational information, work experience, etc. obtained, provided that it is limited to the scope of recruitment to our company, related to an identified or identifiable real person. information.
Benefits InformationInformation obtained, provided that it is limited to the side rights and benefits offered by our company, regarding an identified or identifiable natural person.
Facility Security InformationRecords, documents, camera images, fingerprint information obtained during logins to our company regarding an identified or identifiable natural person.
Legal Transaction InformationInformation obtained regarding an identified or identifiable natural person, provided that it is limited to fulfilling our company’s legal obligations.
Information Technologies KnowledgeIP address, Mac address, Log records, etc. obtained regarding an identified or identifiable natural person. information.
Financial InformationBank account number, IBAN number, asset information, etc., limited to documents showing the financial result of an identified or identifiable real person. information.
9. CATEGORIZATION REGARDING THE OWNERS OF PERSONAL DATA PROCESSED BY PLAZA CUBES

Real persons whose personal data is processed by Plaza Cubes; It is limited to customers, potential customers, third parties with whom our customers work, employee candidates, visitors, supplier/business partner employees, company officials and third parties. The persons included in the data subject categories in question are detailed in the table below; Our company employees are evaluated in the Employee Policy.

CustomerReal persons who benefit from our company’s products and services.
Potential CustomerReal persons who are or may be interested in our company’s products and services.
Third Parties Our Customers Work WithReal persons who benefit from our company’s products and services and who contact them through our company by any means.
Employee CandidateReal persons who have applied for a job to our company by any means and sent a resume.
VisitorReal persons who have entered our company’s premises or visited our website in any way.
Supplier/Partner EmployeesEmployees and authorities of the institutions with which our company has any business relationship, receives service or cooperates.
Company OfficialMembers of the Board of Directors and shareholders of our company.
With Third PartiesReal persons (guarantors, family members, relatives, etc.) whose personal data our company processes in accordance with its legal obligations or company procedures.
10. PRECAUTIONS TAKEN REGARDING THE PROTECTION OF PERSONAL DATA

In accordance with Article 12 of the Law, Plaza Cubes takes the necessary technical and administrative measures to ensure the appropriate level of security to prevent unlawful processing and access of the personal data it processes and to ensure the preservation of the data, and carries out the necessary inspections or has them carried out in this context.

In this context, Plaza Cubes; Personal data is of special nature; The degree to which it requires confidentiality due to its nature; It carries out its activities by taking into account the extent to which it may affect the rights and freedoms of the data owner in the event of a security breach.

Administrative Measures Taken by Plaza Cubes

  • Employees were trained to raise awareness about the protection of personal data.
  • A personal data security policy has been created; Necessary efforts have been made to comply with this policy.
  • It has been ensured that personal data that is not needed for the processing purposes is no longer retained.
  • Additional protocols regarding data security and transfer have been signed with data processors.
  • A personal data processing inventory has been prepared.

Technical Measures Taken by Plaza Cubes

  • Measures such as firewalls and gateways have been taken against unauthorized access over the Internet.
  • Physical environments containing personal data are protected against external risks with appropriate methods, and entries and exits to these areas are controlled.
  • A commitment has been received that the security measures taken by the cloud storage service provider are sufficient and appropriate.
  • Data backup work is being carried out.
11. RIGHTS OF THE “RELATED PERSON” REGARDING PERSONAL DATA AND APPLICATION METHOD

Within the framework of Article 11 of the Law, the relevant person can apply to Plaza Cubes at any time. The person concerned;

  • Learning whether your personal data is being processed,
  • If your personal data has been processed, requesting information about it,
  • Learning the purpose of processing your personal data and whether your personal data is used in accordance with the purpose of processing,
  • Knowing the third parties to whom your personal data is transferred at home or abroad,
  • Request correction of your personal data if they are incomplete or incorrectly processed,
  • Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
  • Requesting that correction, deletion and destruction operations carried out in accordance with the relevant legislation be notified to third parties with whom your personal data has been shared,
  • To object to the emergence of a result unfavorable to you by analyzing your processed personal data exclusively through automatic systems,
  • If you suffer damage due to unlawful processing of your personal data, request compensation for the damage,

They have rights.

In accordance with the procedures and principles in the Communiqué on the Procedures and Principles of Application to the Data Controller dated 10.03.2018 and numbered 30356, together with the documents showing your identity, with a wet signature to the address ………………………………; or ………….…….. You can apply by using your registered e-mail (KEP) address, secure electronic signature, mobile signature or your e-mail address previously notified to our company and registered in our system. Requests in the application will be answered free of charge within 30 days at the latest, depending on the nature of the request.

12. PERSONAL DATA PROCESSED BY PLAZA CUBES AND THE PURPOSES OF PROCESSING

The data owners specified in Sections 8 and 9 of this policy and the personal data related to these data owners are processed for the following purposes;

  • Fulfillment of contractual obligations,
  • Conducting customer relations,
  • Providing the services offered by the company according to the needs,
  • Keeping data accurate and up-to-date,
  • Planning customer satisfaction processes,
  • Planning and execution of marketing activities,
  • Management of requests or complaints,
  • Creating and tracking visitor records,
  • Ensuring security for visitors in our company’s buildings and facilities,
  • Fulfillment of our legal obligations,
  • Workforce planning and new personnel selection
  • Management of human resources processes such as recruitment,
  • It is processed for the purposes of evaluating your job application and managing employee recruitment processes.
13. STORAGE OF PERSONAL DATA

Personal data processed by Plaza Cubes can be stored for the period required for the purposes of processing. If there is no legal reason to store it after the purpose of processing is eliminated; personal data is deleted, destroyed or anonymized.

In this context, Plaza Cubes takes the necessary technical and administrative measures within the Company in order to fulfill its relevant obligations; It has developed the necessary operating mechanisms in this regard; It trains, assigns and raises awareness of the relevant business units in order to comply with these obligations.

14. THIRD PARTIES TO WHICH PERSONAL DATA IS TRANSFERRED BY PLAZA CUBES

Our company can transfer the personal data and sensitive personal data of the personal data owner to third parties (Group Companies, business partners, shareholders, affiliates, insurance companies, public institutions and/or organizations and other third parties) by taking the necessary security measures in line with the legal personal data processing purposes. . In this regard, our company acts in accordance with the regulations stipulated in Article 8 of the KVK Law.

Plaza Cubes may transfer the personal data of data owners managed by the Policy to the categories of persons listed below in accordance with Articles 8 and 9 of the Law:

Supplier/Business PartnerPlaza Cubes shares limited services with outsourced services that are necessary for the continuity of our company’s business processes.
To official institutions and organizationsPlaza Cubes shares shares limited to fulfilling its legal obligation.
To legally authorized private legal personsPlaza Cubes shares shares limited to the purpose requested by private law persons within their legal authority.
15. PLAZA CUBES PERSONAL DATA PROTECTION AND PROCESSING POLICY GOVERNANCE STRUCTURE

The principles set forth by Plaza Cubes with this Policy; It ensures that the relevant principles are implemented within the Company with the policies, procedures and application guides it puts forward for the execution. By establishing a connection between the policies, procedures and application guides regarding the protection of personal data and the basic policies, procedures and application guides carried out by the Company in other areas, compatibility is also ensured between the processes operated by the Company with different policy principles for similar purposes.

Plaza Cubes subjects all procedures established for the implementation of this Policy to each audit internally or by an independent third-party consultant. In this context, when a change is made to this Policy, the approval of Plaza Cubes’ senior management is required for the updated policy to come into force. In addition, Plaza Cubes takes the necessary legal actions to ensure compliance with its obligations within the scope of the Law and secondary legislation and to complete them in case of deficiencies. Plaza Cubes employees have sufficient awareness about the protection of personal data and have completed training on this subject. As a company, within the scope of the importance given to this issue, measures are taken regarding the security of personal data; Data owners are informed about their rights in this regard.

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