Protection of Personal Data

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INFORMATION ABOUT THE PROTECTION OF PERSONAL DATA BY PROPERTYNC

Personal data collected and processed by Printhouse Trade Ltd. (Propertync) is protected by Propertync. Propertync, using its technological and infrastructure capabilities, takes necessary technical and administrative measures to ensure the secure storage and lawful processing of personal data within the framework of Law No. 89/2007 on the Protection of Personal Data and relevant legislation.

I. WHAT ARE YOUR PERSONAL DATA?

Personal data refers to all information that describes a specific or identifiable individual. Your personal data that may be processed by Propertync, not limited to, is as follows:

Identity Information: This data category includes types of data such as identity or passport number, name, surname, place and date of birth, marital status, gender, identity document sample, photograph, etc.

Contact Information: This data category includes types of data such as address, telephone/fax number, email address, etc.

User Information: This data category includes types of data such as customer number, user type and status, tariff and package information, information related to the use of value-added services by the user, and products and services.

Information from Sales Channels: This data category includes information and documents provided during the sales processes; data obtained when contacted through electronic or physical means; voice call recordings kept in accordance with call center standards; your voice recording used as an identity verification method if requested; information about your requests and transactions in sales channels, etc.

Information on Product and Service Usage: This data category includes preferences, habits, and other usage information related to the use of products and services; behavioral information on websites and mobile applications created for the presentation, provision, or promotion of products and services, either by Propertync itself or in cooperation with third parties; device, network, application, location, and usage information that can be collected through mobile applications, etc.

Sensitive Personal Information: This data category includes (i) health data belonging to socially supported groups (disabled, disabled veterans, etc.) and (ii) information such as membership in associations, foundations, or unions.

II. PURPOSES OF PROCESSING PERSONAL DATA

Your personal data may be processed for the following purposes in compliance with the legislation on the protection of personal data:

Providing, pricing, and invoicing of products and services; ensuring the realization and follow-up of transactions requested by you regarding ordered, purchased, and/or used products and services; promotion and marketing of products and services, contacting you regarding issues such as campaigns, discounts, benefits, terms, pricing, etc.; providing opportunities such as membership, events, and economic benefits and performing necessary procedures for their use; offering you offers, gifts, and promotions; targeted promotion; transmitting contents such as special congratulations, wishes, rewards, sweepstakes, or similar events; using the information you provide in sweepstakes, contests, or similar events for the event; verifying your identity information and documents when necessary; conducting credit checks and reporting; conducting necessary processes to prevent abuses, losses, and frauds; performing network traffic management, connection, billing, fraud detection, and similar processes; resolving disputes such as consumer complaints related to connection and billing, etc.; developing, diversifying, measuring, auditing, and analyzing products, services, and networks and training employees, financial reporting, etc.; evaluating your interest in products and services, investigating customer satisfaction; providing call center service; responding to your questions, complaints, and notifications; providing products and services together with our business partners and ensuring financial reconciliation with these individuals; determining your location in emergency call situations and sharing it with authorized institutions; preserving your information that needs to be kept in accordance with relevant legislation; copying and backing up for the prevention of information losses; ensuring the consistency of your information; taking necessary technical and administrative measures for the security of our networks and your information; fulfilling legal obligations required by regulatory and supervisory institutions, fulfilling legal obligations required or mandatory by legal regulations, conducting legal proceedings and legal processes.

III. TRANSFER OF PERSONAL DATA

Propertync may transfer your personal data to the following domestic and international recipient categories within the scope of the Law and other legislation stated in this Policy:

Authorized persons acting on behalf of Propertync, Suppliers and business partners with whom we work for the procurement or delivery of products and services you want to buy or use, Our business partners with whom cooperation is made for the provision, promotion, and similar purposes of products and services, supplier companies, and banks, financial institutions, Authorized authorities that will determine your location in case of emergency call, Lawyers, auditors, consultants, and service provider companies, Authorized institutions or organizations authorized to request your personal data, and persons determined by them, Electronic communication services for the management of collection related risks and prevention of malicious uses.

Your device information, segment information in Propertync, and information about your product and service usage, Legal entities with phone numbers in the Propertync directory.

IV. METHOD AND LEGAL BASIS OF PERSONAL DATA COLLECTION

Your personal data can be collected, processed, and transferred for the purposes specified in this Policy, completely or partially, through verbal, written, user agreement, face-to-face channels such as dealers, call centers, physical or websites, mobile applications, short message, electronic mail, voice response system, and all kinds of voice recordings, written, and verbal electronic environments, by relying on your consent to the processing of your personal data, as specified in Articles 6 and 7 of the Law, or other legal bases specified in the legislation, and based on the following legal bases, by automatic or non-automatic methods or tools.

It being necessary to fulfill the legal obligation to which Propertync is subject, It being necessary for the performance of a contract to which you are a party or for pre-contractual measures taken upon your request, It being necessary to protect your vital interests, It being necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Propertync or the third party to whom the data is transferred.

It being compulsory for the legitimate interests pursued by Propertync or the third party to whom the data is transferred, provided that it does not harm your fundamental rights and freedoms.

V. YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA

According to Articles 14 and 15 of the Law or other legislation, by applying to Propertync through the methods specified in the "Contact" section of this Policy,

You have the right to learn whether your personal data is processed, To learn all your personal data processed and at the same time their source, The purpose of processing your personal data, the recipients or categories of recipients to whom the personal data is disclosed, and the categories of personal data that are processed or are intended to be processed, To obtain information about the progress recorded in processing since the notification about the processing of personal data, To request correction, deletion, or blocking of your personal data in case it is incomplete or incorrectly processed in accordance with the legislation rules, Unless it is impossible or requires disproportionate effort, to request the notification of these operations to third parties to whom your personal data has been transferred, To object to the processing of your personal data, which concerns you, on the basis of legitimate reasons arising from your particular situation, at any time, and To object to the processing of your personal data, which concerns you, for direct marketing purposes.

VI. CONTACT

You can send your requests under the Law and your questions regarding your personal data with a duly prepared and approved letter by the confirmation officer to the address Şht. Arif Salih Sokak, No:7, Lefkoşa.

VII. ABOUT THE POLICY

This Policy will be valid as of the date it is published by Propertync. Propertync may make changes to this Policy whenever deemed necessary. Changes made by Propertync will take effect immediately upon publication of the Policy on www.propertync.com. We recommend that you check our website at regular intervals to keep track of changes to the Policy. Information in the Policy may vary from person to person due to products and services used by individuals or requests and consents.

INFORMATION ABOUT PROPERTYNC PRIVACY POLICY

The Propertync website (www.propertync.com) belongs to Printhouse Trade Ltd. and the information security of our customers who visit this address is of great importance to Propertync. This text has been prepared to inform you about information security.

You can visit our website as often as you like without sharing your personal information. During your visit to our website, your personal information is only obtained by us with your knowledge. Personal information obtained by you is recorded and will continue to be protected by Propertync.

Your name, surname, postal address, date of birth, gender, phone number, and email address are recorded when you provide them to our website.

We would like to emphasize the necessity of not sharing your passwords with anyone to ensure your information security. We recommend that you read the 'Propertync User Agreement for Transactions via the Web' regarding the transactions you make on our website and/or Self-Service channels in order to better understand the importance of protecting your passwords. We especially request that you do not share your Super Password with anyone and do not write it down anywhere.

If the email message is not encrypted during email communication, we would like to remind you that the security of the message cannot be guaranteed, and you are responsible for the security of the emails you send.

We may provide links to other websites not operated by Propertync on our website. If you visit any of these websites, you should review the privacy and other policies of that site. We declare that Printhouse Trade Ltd. is not responsible for the policies and practices of other companies.

Propertync reserves the right to change its privacy policies, so we recommend that you regularly check our Security and Privacy pages. Please read the Propertync User Agreement for Transactions via the Web carefully for the terms of the contract for transactions made via the Propertync website. This agreement is an integral part of the 'User Agreement' signed by Propertync users in advance.

ARTICLE 1- DEFINITIONS:

USER: PROPERTYNC individual users and corporate line users PROPERTYNC: Printhouse Trade Ltd..

ARTICLE 2- SUBJECT OF THE CONTRACT:

The subject of this agreement is the determination and determination of the principles regarding the provision of USER services to the USER by PROPERTYNC via Self Service channels, and the determination of the rights and obligations of the parties.

ARTICLE 3- USER'S OBLIGATIONS

The USER hereby declares and undertakes that it will be fully authorized to act on its own behalf due to this agreement / during the performance of the agreement, that every transaction it performs within the limits determined and determined by PROPERTYNC will bind itself, that it will be responsible for all transactions and behaviors, and that it will abandon in advance the objection that transactions made through password usage are not made by itself, that Printhouse Trade Ltd.. (Hereinafter referred to as 'PROPERTYNC') does not have the obligation to investigate the identities of the persons who perform transactions using passwords, that the USER will take necessary care and attention for the secrecy of the password/passwords, that it will not disclose this password/passwords to any third party and will not allow the use of these passwords by any third party, that it will be personally responsible for any damages that may arise from the use of passwords by persons other than themselves, that PROPERTYNC cannot be held responsible in any way and that it releases PROPERTYNC in advance for any damages that may arise, and that it accepts and undertakes that all liabilities are with itself.

ARTICLE 4- PROVISIONS REGARDING TRANSACTIONS TO BE MADE OVER THE WEB

4.1. The fact that PROPERTYNC provides USER service to the USER via the Internet does not constitute a commitment by PROPERTYNC to provide hardware and software (hardware-software) to the USER.

4.2. The USER acknowledges and declares that it is not responsible for defects in goods and services received from third parties by benefiting from the USER services provided by PROPERTYNC over the Internet, and that it hereby releases PROPERTYNC in advance from any liability that may be attributed to PROPERTYNC within the scope of the Consumer Protection Law and relevant legislation.

4.3. PROPERTYNC does not guarantee the continuity of the services to be provided through Self Service channels and reserves the right to make changes, reduce or decrease the transactions to be made through these channels.

4.4. In case PROPERTYNC determines that the USER's lines at PROPERTYNC are closed, the USER violates its obligations under this Agreement, the Super passwords are used contrary to the provisions of the Agreement, the service is used incorrectly, against the laws and rules of honesty, and the security measures are violated, PROPERTYNC may cancel the USER's password without any notification, terminate the USER's access to this service immediately, without giving any reason and without making any notification, and the USER's obligations arising during the period until the service is terminated will continue after the service is terminated. The USER agrees and undertakes that it will not claim any compensation from PROPERTYNC under any title for the termination of the service in this way.

4.5. In accordance with the information provided by the USER to PROPERTYNC, PROPERTYNC has the right not to process any transactions and the USER cannot claim any rights or receivables from PROPERTYNC due to the information provided by the USER. The USER accepts and declares that it will immediately inform PROPERTYNC if passwords for lines registered in its name are learned by third parties or if there is a suspicion that they are learned; otherwise, it accepts and declares that it is responsible for the consequences that may arise.

4.6. PROPERTYNC shall not be responsible for any technical malfunctions or problems that may occur for any reason beyond the control of PROPERTYNC in connection with the services to be provided under this agreement. PROPERTYNC reserves the right to discontinue the provision of the services covered by this Agreement without giving any reason.

4.7. The courts and enforcement offices of the TRNC are authorized to settle any disputes that may arise between PROPERTYNC and the USER.

4.8. In case of any disputes arising from this Agreement between PROPERTYNC and the USER, PROPERTYNC's books, all kinds of documents, computer and voice recordings, and microfilms shall constitute conclusive evidence and be binding. The USER accepts and declares that it can only prove its objections to these records with a written document and that this is an evidence agreement. The USER hereby waives in advance its right to request an oath regarding the proper keeping of the books and records kept by PROPERTYNC.

4.9. The USER agrees and undertakes to provide PROPERTYNC with any documents and information requested by PROPERTYNC regarding this agreement immediately when requested by PROPERTYNC.

4.10. PROPERTYNC reserves the right to make any changes and innovations it deems necessary in this agreement.

COOKIE POLICY

The Propertync Cookie Policy has been prepared to provide information about cookies and similar technologies (collectively referred to as "cookies") that can be used on websites and applications within Printhouse Trade Ltd.. Since each Propertync website and application has different purposes and features, the following information may vary for each website and application.

If you use Propertync websites and applications, cookies and similar technologies may be used within the scope of the Propertync Cookie Policy, stored on your device, and your personal data may be processed in accordance with the purposes and methods specified in the Privacy Policy.

WHAT IS A COOKIE?

Cookies are files or pieces of information that can be stored on your computer (or other devices with internet capabilities such as smartphones and tablets) when you visit a website. A cookie usually contains the name of the website it was received from, the "lifetime" of the cookie (i.e., how long it will be stored on your device), and typically a randomly generated unique numerical value. Cookies save your actions and preferences during your browser session or for your next visit to our website. When you revisit our websites, this information will be sent back to the server. This allows your computer or mobile device to be automatically recognized, and, for example, your preferred settings to be automatically loaded for your convenience. Cookies offer the advantage that you do not have to adjust them every time you visit Propertync websites or applications.

WHAT ARE THE PURPOSES OF USING COOKIES?

Cookies are used for various purposes, including facilitating efficient navigation between web pages, making the use of websites easier, tracking your preferences to improve our offers, online visibility, and advertising in terms of content, graphics, and technology according to your needs, enriching and improving the overall user experience, evaluating usage data for our websites statistically, and assisting in improving the structure and content of our websites.

In addition, cookies can be used to customize our services better according to your interests and needs and/or to accelerate activities and experiences you will perform on our websites in the future.

WHAT ARE THE TYPES OF COOKIES?

In terms of cookie management:

First-Party Cookies: These are cookies created and placed on the website by us, under our control.

Third-Party Cookies: These are cookies created and managed by third-party companies we collaborate with.

In terms of storage duration:

Essential Cookies: These are necessary to ensure the proper functioning of websites, to provide various services through websites, and to access secure areas. Without these cookies, it would not be possible for us to provide certain services such as the shopping basket.

Performance Cookies: These aim to offer an enhanced and personalized experience to the user by saving user preferences such as language settings on the website.

Analytical Cookies: These are used to collect statistical information such as the time spent on the website, the pages visited, click information, and the duration of staying on a page through web analytics tools to analyze website usage and perform more effective marketing activities.

HOW TO CHANGE COOKIE PREFERENCES

Although many internet browsers accept cookies by default, you can reject or delete cookies from your browser settings section. For detailed information on how to adjust your browser settings, please refer to the help screen of your browser.

If you choose to reject or delete cookies, please note that this may prevent certain features or services of Propertync websites from functioning properly and may therefore affect your experience on Propertync websites. Since your cookie preferences are managed through the browser you use, you will need to refresh your rejection preferences when using a different browser or purchasing a new computer.

Propertync uses cookies within the scope of the Privacy and Security Policies and reserves the right to change the terms of use of cookies and the Cookie Policy.

COOKIE POLICY

The Propertync Cookie Policy has been prepared to provide information about cookies and similar technologies (collectively referred to as "cookies") that can be used on websites and applications within Printhouse Trade Ltd. Since each Propertync website and application has different purposes and features, the following information may vary for each website and application.

If you use Propertync websites and applications, cookies and similar technologies may be used within the scope of the Propertync Cookie Policy, stored on your device, and your personal data may be processed in accordance with the purposes and methods specified in the Privacy Policy.

WHAT IS A COOKIE?

Cookies are files or pieces of information that can be stored on your computer (or other devices with internet capabilities such as smartphones and tablets) when you visit a website. A cookie usually contains the name of the website it was received from, the "lifetime" of the cookie (i.e., how long it will be stored on your device), and typically a randomly generated unique numerical value. Cookies save your actions and preferences during your browser session or for your next visit to our website. When you revisit our websites, this information will be sent back to the server. This allows your computer or mobile device to be automatically recognized, and, for example, your preferred settings to be automatically loaded for your convenience. Cookies offer the advantage that you do not have to adjust them every time you visit Propertync websites or applications.

WHAT ARE THE PURPOSES OF COOKIES?

Cookies are used for various purposes including facilitating effective navigation between web pages; making the use of websites easier; tracking your preferences to tailor our offers, online visibility, and advertisements according to your content, graphic, and technological needs; enriching and improving the overall user experience; evaluating the usage data of our websites statistically; and assisting in the development of the structures and contents of our websites.

In addition to these, cookies can also be used to customize our services better according to your interests and needs, and/or to expedite activities and experiences you will undertake on our websites in the future.

WHAT ARE THE TYPES OF COOKIES?

In terms of cookie management:

First-Party Cookies: These refer to cookies created by us and placed on the website under our control.

Third-Party Cookies: These are cookies created and managed by third-party companies with which we collaborate.

Persistent Cookies: This type of cookie remains on your browser until a certain expiration date even after your browser is closed. They can be used by websites to recognize your computer when you reopen your browser and browse the internet again.

In terms of storage duration:

Essential Cookies: These are necessary to ensure the effective operation of websites, provide various services through websites, and perform some functions such as accessing secure areas. Without these cookies, it is not possible for us to provide some services such as the shopping cart.

Performance Cookies: They aim to provide an enhanced and personalized experience to users by recording user preferences such as language settings on the website.

Analytical Cookies: They are used to analyze website usage, collect statistical information such as time spent on the website, pages visited, click information, and time spent on a page, in order to conduct more effective marketing activities.

HOW TO CHANGE COOKIE PREFERENCES

Although many internet browsers accept cookies as default settings, you can refuse or delete cookies from your browser's settings section. Please refer to your browser's help screen for detailed information on how to adjust your browser settings.

If you choose to reject or delete cookies, please note that this may prevent some features or services of Propertync websites from functioning properly, and therefore may affect your experience on Propertync websites. Since your cookie preferences are managed through the browser you use, you will need to refresh your rejection preferences when using a different browser or purchasing a new computer.

Propertync reserves the right to use cookies within the scope of the Privacy and Security Policies and to change the terms of use and Cookie Policy related to cookies.

INFORMATION SECURITY POLICY

Although many internet browsers accept cookies as default settings, you can refuse or delete cookies from your browser's settings section. Please refer to your browser's help screen for detailed information on how to adjust your browser settings.

If you choose to reject or delete cookies, please note that this may prevent some features or services of Propertync websites from functioning properly, and therefore may affect your experience on Propertync websites. Since your cookie preferences are managed through the browser you use, you will need to refresh your rejection preferences when using a different browser or purchasing a new computer.

Propertync reserves the right to use cookies within the scope of the Privacy and Security Policies and to change the terms of use and Cookie Policy related to cookies.

INFORMATION SECURITY MANAGEMENT SYSTEM AND POLICIES

Propertync has an information security management system under the supervision of top management to ensure the security of information in line with business needs, laws, and regulations. Propertync Management provides support for the implementation of the information security management system at Propertync and makes necessary appointments and assignments when needed. The information security management system is provided with defined risk management approach and basic rules set out in information security policies. These policies are shared within the company so that all Propertync employees can access them. The purpose of information security policies is to manage Information Security risks and ensure adequate security of information. All Propertync employees are responsible for implementing the rules stated in these policies in the business processes and information assets they are responsible for.

The compliance, adequacy, and effectiveness of Propertync's information security management system are independently reviewed. Independent review results are reported to the management and relevant records are kept.

CONFIDENTIALITY AGREEMENTS

It is stated that every Propertync employee is responsible for maintaining confidentiality in their employment contract. A confidentiality agreement is signed before starting to work with suppliers. Depending on the content and scope of the service/product provided by the supplier to Propertync, appropriate security issues are added to the confidentiality agreement by foreseeing the risks Propertync will face. This confidentiality agreement reflects the requirements related to ensuring the security of information and includes commercial sanctions. The information to be protected and the sanctions related to breaches are defined in the contract. Suppliers and supplier employees are authorized to access information assets only to the extent necessary for their areas of responsibility and relevant tasks, for a minimum period and with minimum access rights.

LEGAL COMPLIANCE

Propertync determines and implements security requirements in accordance with legal regulations. All personal information belonging to Propertync USERS is protected in accordance with the laws and regulations of the Turkish Republic of Northern Cyprus. Compliance with the principle of data privacy is ensured in recording, processing, and sharing personal information in accordance with current laws and regulations. Significant records of Propertync are protected against loss and corruption. When determining the retention periods of records, obligations in legislation are taken into account.

INFORMATION SECURITY RISK MANAGEMENT

Risks and risks related to services are identified for effective management of information security risks at Propertync. Identified risks are evaluated, prioritized, and managed. Information security risk management typically includes risk assessment, risk processing, risk acceptance, and risk communication.

MANAGEMENT OF INFORMATION SECURITY INCIDENTS

To ensure the security of information assets at Propertync, technological solutions and measures are taken at the level of processes and services, and regular checks, tests, and monitoring are performed. Employees are informed and trained in this regard. It is determined how incidents related to Propertync information assets will be identified, to whom they will be reported, and how they will be handled. In addition, responsibilities for notifying relevant parties of identified security vulnerabilities, deficiencies leading to incidents, and assessing potential risks are defined.