Privacy Policy and Personal Data Protection Law (KVKK) Information Text

The purpose of this Information on the Protection and Processing of Personal Data (the Information) is to fulfill the information obligation brought by Article 10 of the Personal Data Protection Law No. 6698 regarding the use of personal data obtained during the use of the website located at www.digipilpass.com (the Portal) and/or received from third parties. It also aims to inform Users transparently about the collection methods, processing purposes, legal reasons, and rights regarding personal data collected by our company in relation to the use of the Portal or entered by Users themselves through their positive actions. Suppliers offering products and services in various categories and potential buyers meet and conduct their transactions through the secure environment provided by (DIGIPILPASS®). Within this activity, personal data is processed as required for the use of (DIGIPILPASS®) functions as specified in this Information text.

(DIGIPILPASS®) continuously renews itself to provide better service to its Users in the internet field with innovative product and service applications by investing in technology, and works to provide the best service, taking the highest level of security measures possible to ensure the lawful collection, storage and sharing of personal data and to protect their confidentiality. To achieve this purpose, the personal data of Users are processed within the scope and conditions detailed below.

(DIGIPILPASS®) may update and change the provisions of this Information at any time by publishing it on the Portal.

Updates and changes made by (DIGIPILPASS®) will be effective from the date they are published on the Portal.

a) Data Controller

In accordance with the Personal Data Protection Law, your personal data will be collected and processed by (DIGIPILPASS®) as the data controller within the scope explained below.

b) Personal Data Collected

(DIGIPILPASS®) collects various static (fixed) and dynamic (variable) data from Users through the methods specified below.

The data collected by (DIGIPILPASS®) depends on the services and features used by Users. Under this heading, the data processed within the scope of the Services provided by (DIGIPILPASS®) and considered as personal data in accordance with the Personal Data Protection Law are listed in groups below. Unless explicitly stated otherwise, the terms "personal data" and "special categories of personal data" within the scope of the provisions and conditions set forth in this Information include the information listed below:

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

Authentication Information: Users' membership information, passwords used to authenticate and provide account access, User Name, contact information, password hints, User numbers, listing numbers.

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

Usage Data and Favorites: Data collected from your devices through various software and technological tools, reasons for calling (DIGIPILPASS®) or Call Centers, voice recordings, real estate index, appraisal, date and time data of product use, province, district, neighborhood where index query is created, chassis and license plate number for obtaining damage inquiry report generated by the Insurance Association and Supervision Center system in case of successful payment transaction, products viewed on the Portal, square meter prices, data specified in the relevant survey or banner for users to be directed to the relevant product and for product supplier companies to contact the user through modules such as surveys and banner redirects of domestic or foreign companies, information requested by the bank for the offers they want to receive for the real estate put on sale by banks through the real estate module from the bank, data entered to obtain information about the projects of contractor companies through the Portal for real estate projects, usage habits for the development of services and customization for you (prioritization options, preferred return method and date, answered channels, last login date to the Portal, type of Doping listing used, type of post, visited websites, number of pages viewed, visit duration and number of goal completions, user actions performed while using services, entered search terms, categories of visited products and listings), errors and similar problems that occur during service use in order to ensure the smooth provision of services.

Location Data: Covers data about Users' precise or approximate locations. Location data derived from GPS data and IP and port addresses is used when the user wants to search for and post listings around their location while using (DIGIPILPASS®)'s mobile applications and with the user's permission.

Payment Data: Agency and customer invoice and payment information (name, surname, invoice address, Turkish ID number, tax ID number), invoices sent to members and receipt samples for payments received from members, data such as payment number, invoice number, invoice amount, invoice date.

Content Data: Documents requested to prove that the brand is not fake (invoice, warranty certificate, etc.), documents showing that the product belongs to the person or their authority over the product (such as title deed, license, brand registration certificate), listing information, membership information, notification description, solution description, satisfaction, notification reason, customer note, renewal date, listing rejection reason, feedback, document sending reason, error content specified during the use of the Service, interim information status, interim information, similar data such as search reason.

Survey Responses: Responses to periodic surveys organized within the Portal by (DIGIPILPASS®) and responses to surveys conducted by real and legal persons with whom (DIGIPILPASS®) cooperates.

Fingerprint: You can choose to use fingerprint login instead of password in the mobile application. Your fingerprint will not be transmitted to (DIGIPILPASS®) in any way within the scope of the transaction to be carried out with the fingerprint identification you will make from the settings section of the mobile device. Only verification or error warning comes to (DIGIPILPASS®) from the mobile device and accordingly your login to the application is provided. If approval is not received, you are directed to repeat the transaction or log in by another method. You can always turn off the fingerprint login option from the settings section of your device.

In-Site Messages Caught by Filters or with Content Contrary to Terms of Use: Only in-site messages caught by filters or detected to have content contrary to the terms of use upon incoming complaints/notifications from in-site messages sent by users to each other in order to enable safe communication and trade between users.

Where is Personal Data Stored and Processed? The personal data we obtain may be stored domestically or abroad in another country where (DIGIPILPASS®) or its affiliates, subsidiaries or service providers it cooperates with have facilities, and may be processed in accordance with the purposes in this Information and proportionate to these purposes. 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 foreseen security measures.

c) For What Purpose Will Personal Data Be Processed:

In accordance with the purposes set forth in this Information and the Membership 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 within the scope of the purposes detailed below:

Name and Contact Information: Internal evaluation, communication, User registration, obtaining potential customer information, improvement of after-sales processes, business development, collection, customer portfolio management, promotion, analysis, complaint management, managing customer satisfaction processes, marketing, advertising, research, invoicing, event notification, operational activities execution, measuring service quality, improvement, audit, control, optimization, customer verification, marketing, sales, advertising, after-sales services, fraud detection and prevention;

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

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

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

Location data: Providing location-based or location-related Portal functions, audit and control, risk management;

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

Content: Business development, optimization, customer portfolio management, audit, control, improvement of operational activities, business development, promotion, internal evaluation, customer management, analysis, scoring, profiling, improvement of after-sales processes, collection, after-sales services, communication, service quality measurement, improvement, executing complaint management processes;

Survey and Test Responses: Information requested from users who respond to periodic surveys or tests organized by (DIGIPILPASS®) within the Portal will be processed by third-party natural and legal persons with whom (DIGIPILPASS®) cooperates to use Portal functions and for these functions to be fulfilled by (DIGIPILPASS®), and third-party natural and legal persons with whom it cooperates within the scope of all processing activities specified above in accordance with the purposes of use of the Portal for direct marketing to these users, statistical analysis, improving their processes and creating databases; fulfilling obligations arising from contracts made with third-party natural or legal persons in business relationship with (DIGIPILPASS®) or activities carried out and legal regulations, in order to fulfill legal and commercial obligations, for performing contractual obligations arising from contracts made by (DIGIPILPASS®) with business partners/customers/suppliers, establishing rights, protecting rights, conducting commercial and legal evaluation processes, conducting legal and commercial risk analyses, conducting legal compliance process, concluding tests conducted regarding whether the user can obtain the documents specified in the relevant legal regulations, conducting financial affairs, fulfilling legal requirements, fulfilling the decisions of authorized institutions, organizations and authorities, responding to their requests, within the scope of personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

Filtered Messages or Messages with Content Contrary to Terms of Use: Our messaging service is provided to facilitate communication between our users and the other party in purchase, sale and rental transactions. In messages within this scope; based on the legitimate interest in Article 5 of the Law, messages containing insults, contrary to public morality, raising suspicion that fraudulent listings have been posted, that may cause unfair competition, violating personal rights, intellectual and industrial property rights, and otherwise containing illegality are filtered and subject to moderation, and on-site messages with content contrary to the terms of use can be reviewed and blocked.

Personal Data Retention Period: (DIGIPILPASS®) will retain the personal data it obtains for the period necessary for the purpose for which they are processed, within the framework of the conditions specified in this Information and the Membership Agreement, so that Users can benefit from the Service in the best way, and in order to fulfill the obligations arising from the nature of the Membership Agreement. In addition, (DIGIPILPASS®) will store personal data in case of any dispute arising from the Membership Agreement, limited to the purpose of conducting administrative or judicial processes within the scope of the dispute, and during the statute of limitations periods determined in accordance with the relevant legislation.

ç) To Whom and For What Purpose Processed Personal Data May Be Transferred:

(DIGIPILPASS®) shares personal data belonging to the User and new data obtained by using this personal data or personal information that Users enter into the Portal with their own positive actions primarily to fulfill the requirements of the Membership Agreement and Services, improve User experience (including improvement and personalization), ensure the security of Users, detect and prevent fraud, improve Services, perform inquiry activities that may be important for Services, conduct operational evaluation research, fix errors, verify User identities, improve system performance, with outsourced service providers, business partners, suppliers, appraisal and real estate consultancy firms, in order to achieve any of the purposes specified in the processing purposes section above; corporate members, cargo companies, law offices, research companies, call centers, software companies for complaint management and security, agencies, consultancy companies, companies in the printing sector, banks for real estate sales of banks, contracting firms for real estate projects, social media platforms, certification organizations, third-party natural and/or legal persons to the extent required by the transfer while providing Services, and with authorized institutions, organizations, authorities, administrative and judicial bodies within the scope of legal obligations. In addition, the User's Name and Contact Information will be shared with payment institutions for identity verification in accordance with the payment institution framework agreement that they will approve at the payment stage and in accordance with the Regulation on Measures Regarding the Prevention of Money Laundering 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 within the scope and purposes specified in this Information. (DIGIPILPASS®) may transfer personal data to third parties domestically as well as abroad within the categories and purposes specified above, limited and proportionate to these purposes.

d) Method and Legal Basis of Personal Data Collection:

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

Data You Have Provided Directly to (DIGIPILPASS®): Refers to personal data that Users provide to (DIGIPILPASS®) 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 (DIGIPILPASS®) as a result of their positive actions. For example, name-surname, contact information, identity information, answers given to surveys, demographic data and content information fall into this type of data.

Data We Obtain When You Use Our Platform: Includes personal data regarding Users' usage habits obtained through certain software or technological tools during the service provided by (DIGIPILPASS®). For example, location data and favorites along with interests and usage data fall into this type of data. (DIGIPILPASS®) collects usage data such as the number of pages viewed, visit duration and number of goal completions, and associates the behavior of the user coming to the site on the site with a cookie in the browser, even if they are not members, for the purpose of online behavioral advertising and marketing. How to manage cookies is also stated in our Cookie Policy. Your personal data collected by these methods is based on the legal grounds specified in Articles 5 and 6 of Law No. 6698; being explicitly provided in laws, being necessary to fulfill legal obligations (legal regulations regulating electronic commerce activities, matters related to cost and tax, consumer protection and other matters), being directly related to the establishment or performance of the contract and processing being necessary (Membership Agreement, Terms of Use and based on these, performance of the contract, establishment and protection of rights), processing being necessary for legitimate interest (collection of data necessary for (DIGIPILPASS®) to carry out services, especially to prevent fraud in its activities related to the Portal), being made public by you, processing being necessary for the establishment, exercise or protection of a right, having your explicit consent. Your personal data collected by these methods can be processed and transferred for the purposes specified in this Information within the scope of personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698. The legal basis for collecting personal data is based on; Membership Agreement, Terms of Use and based on these, performance of the contract, establishment and protection of rights, legal regulations regulating electronic commerce activities, matters related to cost and tax, consumer protection and other matters, (DIGIPILPASS®)'s legitimate interest in collecting data necessary to carry out services, especially to prevent fraud in its activities related to the Portal.

e) Our Measures and Commitments Regarding Data Security:

(DIGIPILPASS®) commits to protecting personal data securely. Technical and administrative measures aimed at ensuring an appropriate level of security are implemented using various methods and security technologies to prevent the unlawful processing and access of personal data and to ensure the preservation of personal data. (DIGIPILPASS®) will not disclose the personal data it obtains to others in violation of this Information and the provisions of the Personal Data Protection Law No. 6698, and will not use it for purposes other than processing. (DIGIPILPASS®) declares that in case of sharing personal data belonging to Users with outsourced service providers in accordance with this Information, it will carry out the necessary warning and supervision activities to ensure that the outsourced suppliers also comply with the commitments under this article. In case of linking to other applications through the Portal, (DIGIPILPASS®) does not bear any responsibility for the privacy policies and contents of the linked applications. The User undertakes that the information subject to this Information is complete, accurate and up-to-date, and that in case of any change in this information, they will immediately update it from www.digipilpass.com. In case the User has not provided up-to-date information, (DIGIPILPASS®) will not have any responsibility.

f) Rights of the Personal Data Subject Listed in Article 11 of Law No. 6698

As personal data subjects, if you submit your requests regarding your rights to (DIGIPILPASS®) through the methods regulated below, (DIGIPILPASS®) will conclude the request as soon as possible and within thirty days at the latest, depending on the nature of the request. No fee will be charged for responses up to one page. A processing fee of 10 Turkish Liras will be charged for each page over ten pages. In case the response to the application is provided in a recording medium such as CD, flash memory, the fee that may be requested by (DIGIPILPASS®) will not exceed the cost of the recording medium. In this context, personal data subjects;

• Learning whether their personal data is being processed,
• Requesting information about it if their personal data has been processed,
• Learning the purpose of processing personal data and whether they are used in accordance with their purpose,
• Knowing the third parties to whom personal data is transferred domestically or abroad,
• Requesting correction of personal data in case it has been processed incompletely or incorrectly, and requesting that the transaction made in this context be notified to third parties to whom personal data has been transferred,
• Requesting deletion or destruction of personal data in case the reasons requiring processing have disappeared, even though they have been processed in accordance with Law No. 6698 and other relevant legal provisions, and requesting that the transaction made in this context be notified to third parties to whom personal data has been transferred,
• Objecting to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,
• Have the right to request compensation for damage in case they suffer damage due to unlawful processing of personal data.

You can submit your request regarding the exercise of your rights stated above in Turkish; to [email protected] of (DIGIPILPASS®) as the data controller in writing with documents identifying you, via notary, as registered e-mail to the mail address, or by other methods determined by the Personal Data Protection Board. (DIGIPILPASS®) reserves the right to verify your identity before responding. In your application;

• Your name, surname and signature if the application is in writing,
• Your Turkish ID number for Turkish citizens, your nationality, passport number or ID number if you are a foreigner,
• Your residence or business address for notification,
• Your e-mail address, telephone and fax number for notification, if any,
• Your request subject must be included, and if any, information and documents related to the subject must also be added to the application.

g) Cookies and Similar Technologies

We use cookies and similar technologies on our website. These technologies help us understand how our website is used and improve user experience. You can disable cookies by changing your browser settings, but in this case some features of the website may not work properly.

h) Policy Changes

This Privacy Policy and GDPR Information Text may be updated from time to time. If we make significant changes to the policy, we will inform you by posting a notice on our website or by sending you a direct notification.

i) Contact

If you have any questions about our privacy policy or the processing of your personal data, please contact us: