Disclosure Statement

As Erra Proptech Real Estate Development Inc. (ERRAHOME), we place the utmost importance on ensuring the privacy of your personal data and processing your data in accordance with the legislation while providing the services we offer. We hereby inform you about the processing of your personal data through the website https://errahome.com/, managed by Errahome, as the data controller, within the framework of the Personal Data Protection Law No. 6698 (KVKK).
This disclosure statement is prepared to inform users about the principles and procedures to be followed in protecting their personal data in their relationship with ERRAHOME, in accordance with the Law on the Protection of Personal Data No. 6698 and the Regulation on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform under this Law.

BASIC DEFINITIONS IN KVKK

Personal Data	: Any information related to an identified or identifiable natural person.
Processing of Personal Data	: Any operation performed on personal data, whether fully or partially automated or non-automated, including obtaining, recording, storing, preserving, modifying, rearranging, disclosing, transferring, taking over, making available, classifying, or preventing the use of data.
Data Controller	: A natural or legal person responsible for determining the purposes and means of processing personal data and establishing and managing the data recording system. In this context, the data controller is "Erra Proptech Real Estate Development Inc."
Data Recording System (VERBIS)	: The record system where personal data is processed according to specific criteria.
Explicit Consent	: Consent based on information about a specific subject, declared with free will.
Board (Kurul)	: Refers to the Personal Data Protection Board.
Cookies	: Small files stored on users' computers or mobile devices that help store preferences and other information about the web pages they visit.	. td>
Data Subject	: The natural person whose personal data is processed.

PERSONAL DATA ABOUT USERS
As ERRAHOME, your personal data may be processed in line with the purposes and processing conditions specified in this text. Personal data subject to processing are as follows:

a. Identity Data
Name, surname, Turkish ID Number, Passport Number, Date of Birth, Place of Birth.

b. Contact Data
Telephone number, e-mail address, internal contact information (company telephone number, internal telephone number, corporate e-mail address)

c. Payment Information
Directing to the card payment system.

d. Customer Transaction Data
Website usage data, statistical data.

e. Location Information
Your manually entered country, city, address.

f. User Transaction Records, Login Methods

h. Other Data

If the accommodation is sponsored by a company; company name, company tax identification number, company address Invoice-Ticket-Check Information, Order Information, reservation history information, ip address information, website login - logout records, request-complaint information.

**PURPOSE OF PROCESSING PERSONAL DATA**
In accordance with Article 10 of the Law on the Protection of Personal Data (KVKK) and Article 5 of the Regulation, customers' personal data may be processed for the following purposes, in compliance with the processing conditions specified in Article 4 of the KVKK:

• Fulfillment of service obligations within the scope of the service contract.
• Execution of contract processes related to reservations made through the website.
• Performing the requirements of the services provided to our customers in accordance with the requirements of the contract and technology, and improving our offered services.
• Providing information to public authorities, prosecutors, courts, and relevant public officials in matters related to public security and legal disputes, upon request and in accordance with the legislation.
• Offering various opportunities to our members within the legal framework or sharing these opportunities with individuals or institutions that can provide them.
• Execution of the reservation and payment process and issuance of invoices.
• Communication during the contract process.< /li>
• Creation of your membership record and facilitation of access to your account.
• Notification of changes to the service terms.
• Preparation of all records and documents that will serve as a basis for processing, whether electronic (internet/mobile, etc.) or on paper.
• Fulfillment of legal obligations and exercise of rights arising from current legislation.
• Providing information to authorized individuals, institutions, and organizations.
• Execution of emergency management processes.
• Conducting communication activities.
• Conducting accounting and financial operations.
• Conducting storage and archive activities.
• Conducting analyses for the development of products and services, and carrying out reporting and auditing activities.
• Providing information regarding complaints/suggestions.

**METHOD OF PERSONAL DATA COLLECTION AND LEGAL BASIS**
Personal data may be obtained directly from the data subject, third parties, and legal authorities during the establishment of a legal relationship. Personal data is collected through various communication channels such as user agreements, electronic mail, etc., within the framework of legal requirements.
According to Article 5 of the KVKK, personal data cannot be processed without the explicit consent of the data subject. The law specifies exceptions where explicit consent is not required. These exceptions include situations where processing is necessary for the establishment or performance of a contract, compliance with legal obligations, publicized by the data subject, establishment, exercise, or protection of a right, processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject. In these cases, personal data can be processed by our company without explicit consent.
Within the scope of ERRAHOME's activities, personal data is processed in accordance with the purposes and processing conditions specified in Articles 5 and 6 of the KVKK, as well as the principles and procedures prescribed by other relevant legislation.
In this context, data such as name, surname, contact information, address, ID number, date of birth, birthplace, payment information, customer transaction information, company name, tax identification number, company address, invoice-check-promissory note information, order information, reservation history, IP address information, website login-logout records, and complaint/suggestion information may be processed by ERRAHOME for the establishment and performance of the contract, fulfillment of legal obligations, and legitimate interests.
**TRANSFER AND PROCESSING OF PERSONAL DATA**
Personal data of customers may be transferred to third parties within the framework of legal provisions and security measures, ensuring confidentiality, and taking effective measures. These transfers are made to shareholders, domestic/foreign subsidiaries, affiliate companies that use the errahome.com infrastructure, and other individuals or organizations involved in the provision of services. The data may also be shared with independent audit organizations, financial institutions, business partners, legal authorities, storage/archiving/IT support firms, and others.

SHARED PARTIES AND EXAMPLES OF SHARING
Legally Authorized Public/Private Institutions or Organizations	Data may be shared with official institutions such as the Ministry of Treasury and Finance, Internal Audit Coordination Board, Court of Accounts, judicial and enforcement authorities, other public and foundation companies, and international companies abroad for international programs.
Supplier/Business Partner/Consultant	Data may be shared with consultants, organizations, and parties with whom the company collaborates and from whom it receives complementary services for the purposes of the activities conducted.

**EXCEPTIONS TO DATA TRANSFER THAT DO NOT CONCERN COMPANY OBJECTIVES**

The company does not make any data transfers that do not relate to its objectives. The exception to this determination includes cases where the transfer of such data is made compulsory by legislation, or it is mandatory for a criminal investigation, or requested by an official authority based on legislation, with a specified justification.

 

STORAGE PERIOD OF PERSONAL DATA
In accordance with the provisions of the KVKK, your personal data processed for the purposes specified in this "Clarification Text on the Processing of Personal Data" will be deleted, destroyed or anonymized and will continue to be used by us, taking into account the Personal Data Retention and Destruction Policy, when the purpose requiring processing according to Article 7 / f.1. of the KVKK disappears and / or the statute of limitations that we are required to process your data in accordance with the legislation expires.

 

DATA SUBJECT RIGHTS

• As data subjects, you have the following rights under the Personal Data Protection Law:
• 1. The right to learn whether your personal data is being processed.< /li>
• 2. If your personal data is processed, the right to request information regarding this processing.
• 3. The right to learn the purpose of the processing of your personal data and whether it is used for its intended purpose.
• 4. The right to know the third parties, domestically or internationally, to whom your personal data is transferred.
• 5. The right to request correction if your personal data is incomplete or inaccurately processed.< /li>
• 6. The right, within the framework of the conditions stipulated in Article 7 of the Personal Data Protection Law, to request the deletion or destruction of your personal data and to request notification to third parties to whom your personal data has been transferred in this context.
• 7. The right to object to the emergence of a result against you through the analysis of processed data solely by automatic systems.
• 8. The right to request compensation if you suffer damages due to the processing of your personal data in violation of the Personal Data Protection Law.
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You can submit your requests related to these rights to us via the email address bilgi@errahome.com. Your requests will be evaluated and concluded by ERRAHOME as soon as possible, and in any case, within 30 (thirty) days.
 

**EXCEPTIONS TO THE RIGHT OF APPLICATION**
In accordance with Article 28/2 of the Personal Data Protection Law (KVKK), data subjects will not be able to benefit from the rights specified in Article 11 of the KVKK, except for the right to request the remedy of damages, in the following cases:

• 1. If personal data processing is necessary for the prevention of a crime or for the investigation of a crime,
• 2. Processing of personal data that has been made public by the data subject.
• 3. If personal data processing is necessary for the exercise of tasks and powers conferred by law on authorized public institutions and organizations, professional organizations with the characteristics of public institutions, for the conduct of disciplinary investigations or prosecutions, and for the exercise of regulatory or supervisory duties in the fields of audit or regulation,
• 4. If personal data processing is necessary for the protection of the state's economic and financial interests regarding budget, tax, and financial matters.
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**APPLICATION METHOD** The data subject can make applications regarding their rights specified under Article 11 of the KVKK in accordance with the application procedures stipulated in the Communique on the Principles and Procedures for Application to the Data Controller.
Requests falling within the scope of Article 11 of the Law No. 6698 can be submitted through one of the methods explained below, in accordance with Article 5 of the Communique on Application to the Data Controller within the Framework of the Personal Data Protection Law No. 6698.
Responses to applications sent to the company will be answered within 30 days from the date the request reaches the company, depending on the nature of the request, in accordance with Article 13/2 of the KVKK. Responses to the application will be sent to the applicant in writing and electronically, as required by Article 13 of the KVKK.

**APPLICATION METHODS:**
1. **Written Application:** - Applications with wet signature can be made in person or through a notary.	- Application Address: Hamidiye Mah. Cendere Cad. No:103/1, Porta Vadi T2 Blok Kat:1 Daire:5, Kağıthane/İstanbul.	- The expression "Request for Information under the Personal Data Protection Law" should be written on the envelope/notice.
2. **Registered Electronic Mail (KEP) Address:** - KEP Address: erraproptech@hs01.kep.tr		- The expression "Request for Information under the Personal Data Protection Law" should be written in the subject of the email.
3. **Application with the Company's System Email Address:** by using the e-mail address	- Email Address: bilgi@errahome.com	- The expression "Request for Information under the Personal Data Protection Law" should be written in the subject of the email.

**INFORMATION TO BE INCLUDED IN THE APPLICATION:**

For applications to be valid, the specified information must be included accurately and completely.

- **For Written Applications:**
- Name, surname, and contact information of the applicant,
- Information related to the subject of the request. - **For Electronic Mail (KEP and Company Email) Applications:**
- Name, surname, and contact information of the applicant,
- Information related to the subject of the request.
Applications must be notarized for written applications made by the relevant person or through a notary. Using the specified expression is important for the subject of the application.
In case the request is accepted or rejected with an explanation, the response will be communicated to the requester in electronic form or in writing. If the request is accepted, the necessary actions will be promptly taken by our company.