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Last updated: (publishing date) 05/12/2021

PRIVACY POLICY

Welcome to ALBURSA E-TİCARET ANONİM ŞİRKETİ, albursa.com and our Privacy Policy.

As ALBURSA E-TİCARET ANONİM ŞİRKETİ (here-in-after referred to as “ALBURSA”, “Company” or “we/our”.) we collect personal information provided by users (which are; visitors and registered members), contributors and others who access our website, social media accounts or any other services for any purpose (as “Users”).

This website explains the terms by which you may use our website albursa.com, other social media accounts and software provided on or in connection with the service (collectively the “Service”).

Please be aware that our website is not designed for or directed at children. As ALBURSA, we comply with COPPA and other regulations to protect the children’s rights.

Also see our General Terms Of Use, Cookie Policy, GDPR and KVKK Compliance which are posted on our website. We recommend you to visit this page regularly to review the current Privacy Policy.

1-) Definitions
In addition to the above, the definitions of terms in this Privacy Policy are as follows:

a. Anonymization: Rendering personal data by no means identified or identifiable with a natural person even by linking with other data;

b. Cookies: Cookies are used to uniquely identify a device or the person using it, which are considered personal data under the GDPR and KVKK.

c. The Data subject (owner): The person whose data are to be processed.

d. Data controller: The natural or legal person who determines the ends and means of the processing of personal data and who is responsible for the establishment and management of the filing system.

e. Explicit Consent: Freely given specific and informed consent;

f. GDPR: The General Data Protection Regulation, is a regulation in European Law that sets a guidelines for the collection and processing of personal information from individuals.

g. Law or KVKK: Turkish Personal Data Protection Law No. 6698, as published in the Official Gazette No. 29677, dated April 7th, 2016.

h. Personal Data: Any information relating to an identified or identifiable natural person.

i. Private (Sensitive) Personal Data: Data on a person’s race, ethnic origin, political and philosophical opinions, religion, religious sect and other beliefs, apparel, membership information to associations, foundations or syndicates, sexual life, conviction, security measures, biometric and genetic information.

j. Processing of Personal Data: Any operation which is performed on personal data, wholly or partially by automated means or non-automated means which provided that form part of a data filing system, such as collection, recording, storage, protection, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization, preventing the use thereof,

k. Similar Tracking Technologies: Similar tracking technologies are known as web beacons, such as small graphic data, a clear GIF that recognize user activity and like cookies, which are also considered personal data under the GDPR and KVKK.


2-) About Privacy Policy
(i) In this Privacy Policy (or “Policy”) our users can find the types of information that we collect, use, protect, transfer, or otherwise handle with them. By using our website or subscribing; you read, understood, accept, and agree to this Privacy Policy in full. If you disagree with this Policy or any part of them, you do not have the right to use our website and benefit from our services and should cease using them immediately.

(ii) Also, our Site may contain links to third-party websites. Please be aware that we have no control over how your data is collected, stored, transferred, or used by other websites. We suggest you to check the privacy and other policies of any such third-party websites before providing any data to them.

3-) Consent
(i) As ALBURSA, we provide our users a Service which specialized in construction and real-estate area. Our registered users can find a forum section where they can share their experiences on industry-related issues or comment on an existing post. Also, our website presents a wide range of vendor information so they can directly communicate with them.

(ii) For this reason, as a user, you have given your explicit consent that your personal data including special categories of your personal data can be (including but not limited to) processed, collect, used, shared, transferred for the designated purposes in this Policy.

(iii) By using our website or subscribing (which is considered as your official consent to process, collect, use, transfer, and disclosure of your personal information as we describe further below); you read, understood, accept, and agree to this Policy in full. If you disagree with these terms or any part of them, you do not have the right to use our website and benefit from our services and should cease using them immediately.

4-) Collection of Personal Data
We collect personal information in different ways.

a. For Registered Users:
When registering on our site or using our services, users may be asked to enter their e-mail address, password, payment card details (name on card, billing address card type [Visa/Master], card number, expiration date, security code) or other information so that we can provide our services to them.
We collect this information when users first register an account with us or contact us for information about our services. The personal information we collect may include the following: ID-Pass information, gender, date of birth, address, email, phone numbers, and financial information for monthly fee plan.
Also, we may collect some additional personal information in connection with users’ participation in any promotion or survey offered by us.

b. Others:
As we may obtain the personal data directly from our users; We may obtain them from publicly available sources such as the internet, social media or suppliers and vendors (including third-party data providers). For instance, we may collect contact information on such publicly available sources to establish initial contact with our potential customer base.

c. Non-Personal Information:
This information is also classified as personal data and is subject to all legal restrictions about personal data. However, since it is technology-based data, we consider it under this heading.
(i) Cookies and Others: We may use cookies and other similar tracking technologies to improve users’ experience during their use or visit to our Service. In this way, we may also collect such non-personal information.

(ii) We may automatically collect non-personal information about visitors to our Service, such as the number of visitors, Internet protocol address, browser type, operating system, pages viewed and language, but we will not combine such information with any personal data that we explain above. We use this information as a whole to determine how visitors use our Service so we can improve their experience on our Service.

(iii) Also, users can set their browsers to decline some certain types of cookies or specific cookies or can remove them at any time. However, this may adversely affect some of the functionality and performance of the Site.

5-) The Personal Information Protection and Electronic Documents Act (PIPEDA)
(i) The Personal Information Protection and Electronic Documents Act (PIPEDA) is a Canadian law protecting the rights and privacy of consumers in Canada. Organizations covered by PIPEDA must obtain the consent of their consumers when collecting, using, and disseminating their personal data. On the other hand, customers have the right to access and even question the accuracy of any information held by the company.

(ii) PIPEDA defines personal information as information about an identifiable individual which may be the name, e-mail, phone number, and any other information that can identify users. For the law to be valid, the Company must collect Personally Identifiable Information and does not apply to anonymous information. As ALBURSA, we strive to work with anonymous information as much as possible.

6-) How We Use Personal Information
Unless specified otherwise, we may use such information for the following purposes and methods:

o To better serve our users in responding to their customer service requests,
o To process users’ transactions,
o To operate and expand our business activities,
o To personalize and enhance users’ experience on our Service, (with cookies and other similar technologies or surveys)
o To inform users about the fees, content, and product offerings,
o To send emails or SMS regarding to users’ orders or other services,
o To inform about the amendment of our Policies or other terms posted in the Site,

(With the email address or phone number that they provide us, or we provide from publicly available sources.)

Users can exercise their right to prevent communications to them by utilizing opt-out mechanisms in the emails we send to them or by following the steps in the “9- To Remove or Modify the Data” section below. Even In such cases, we may retain some personal data in order to avoid contacting with those users again.

7-) How Long Do We Keep Personal Data
We keep your personal data as long as necessary and as permitted by law. For instance, if the business relationship between us continues or your account is active or the service we provide to you as a user continues. We apply certain procedures to delete personal data after a reasonable period of time, according to the retention criteria.

8-) The Rights of Data Subject
As data owner/subject users are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in Personal Data Protection Law (KVKK)) to:

o Learn whether or not their personal data have been processed;
o Request information as to the processing if their data have been processed;
o Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose;
o Know the third parties in the country or abroad to whom personal data have been transferred;
o Request the rectification of the incomplete or inaccurate data, if any,
o Request the deletion or destruction of personal data and to notify third parties to whom personal data has been transferred.
o Object to occurrence of any result that is to their detriment by means of the analysis of personal data exclusively through automated systems;
o Claim compensation for the damage arising from the unlawful processing of their personal data.

9-) To Remove or Modify the Data
Users can have a request to remove or change their personal data

a. Right To Be Forgotten
(i) GDPR: The GDPR outlines the specific circumstances under which the right to be forgotten applies. According to that, an individual has the right to have their personal data/information erased if: “The personal data is no longer necessary for the purpose an organization originally collected or processed it.”

(ii) KVKK: On the other hand, the right to be forgotten has also been addressed in accordance with the decision of the Personal Data Protection Board dated 23.06.2020 and numbered 2020/481 and Article 20 of the Constitution of the Republic of Turkey.

b. Deletion Of The Data
The person whose personal data are processed can request to have their information removed or modified by sending an e-mail to us or by sending a letter to our address. (the information below)
In the application containing users’ requests regarding the right they want to use as a data owner; their request must be clearly stated, and the subject of their own request must be personal. In addition, the application must include identification and address details, along with supporting documents confirming the users’ identity. If the user is acting on behalf of another person, he/she must also attach a document containing his/her special authority.

Please note that this will not affect our right to process personal data obtained prior to withdrawing your consent or to continue certain limited parts of the processing based on other legal grounds other than your consent.

10-) Protection Of Personal Data
We cannot ensure or warrant the security of any information users transmit to us and also users understand and accept that any information they transmit to ALBURSA is at their own risk. On the other hand, we take the necessary measures to ensure that our users visit as safely as possible. The personal information of our users is protected, and their information can only be accessed by a limited number of people who have special access rights to such systems and are required to keep the information confidential.
In addition, all credit card information our users supply are encrypted via SSL technology.
All transactions are processed through a gateway provider and may not stored or processed on our servers. For this reason, users understand and accept that such third-party services may have their own terms and conditions, privacy and cookie policies or other policies and ALBURSA makes no representations or warranties with respect to such third parties.
11-) Children and Privacy
a. Children's Online Privacy Protection Act (COPPA)
COPPA is a law created to protect the privacy of children under the age of 13 and passed by the US Congress in 1998. The COPPA rules prohibit unfair and deceptive acts and practices in connection with the collection and use of personal information from and about children on the Internet. COPPA applies to a Company that collects personal information from kids under 13, even if it is optional.

b. Our Principle on Children's Data
As ALBURSA, we comply with COPPA, GDPR, KVKK and other regulations to protect children’s rights. We do not collect personal information from children under the age of 18 through our Service. If we become aware that we have unknowingly collected any personal information from a child under the age of 18, we will delete them and prevent access to our Services immediately.

12-) Cookies & Similar Technologies
As ALBURSA, we use cookies in our Service. For more information, please visit our “Cookie Policy” posted on our website.

a. About Cookies and Others
Cookies and other similar technologies are text files with small pieces of data that are stored on the user’s device when websites are loaded in a browser. They are generally used to identify the user and their preferences to improve users’ web browsing experience, either for a single visit or for multiple repeat visits. We collect cookies as stated in the “4-c; Non-Personal Information” section above

b. Our Purpose of Use
As ALBURSA, we use cookies in our Service for numerous reasons, among other things, to monitor traffic, to simplify the logging on process, and facilitate fee procedures. Cookies help us to understand how the Service is being used and improve users web browsing experiences.

c. Third-Party Cookies
We work with third-party companies, such as Azur, Google, Facebook, Twitter, LinkedIn, Instagram, and Twitter that use cookies and other similar tracking technologies, like web beacons, to collect anonymous information to enhance users experience and improve our content.

d. Turning Off and Deleting Cookies
In addition, users can turn-off those cookies by configuring their browser settings. With regard to Cookies installed by third parties, users can manage their preferences and withdrawal of their consent by clicking the related opt-out link (if provided) or by using the instrument provided in the third party's privacy policy, or by contacting the third party.

By using our Service without deleting or rejecting some or all cookies, you agree and accept that we can place the cookies and other similar tracking technologies that you have not deleted or rejected on your device.

13-) Third Party Disclosures
(i) As ALBURSA, we do not sell any of our users’ information that we store. Also, we do not trade, or otherwise transfer to outside parties our users’ personal data unless we provide them with advance notice.

(ii) However, this does not include website hosting partners, payment services and other parties who help us in running our Service, providing our business, or servicing our users, as long as the parties agree to keep this information confidential.

(iii) Also, we may share your personal data within the scope of the Privacy Policy with legally authorized public institutions, limited to the realization of the purposes set out in this Policy and in accordance with the legislation and regulations.

(iv) As ALBURSA, we reserve the right at our sole discretion, to refuse the service, terminate accounts, save, remove, transfer, or edit any content on the servers, or cancel the request with or without any notice and showing any reason.

14-) Third-Party Services
(i) ALBURSA is a platform that allows registered users, to offer and sell products and services, to communicate with each other, to join an open international tender, to enable all users (only this service) to share information about construction and real estate area. This platform gives third parties to find and meet each other in a variety of pricing formats and also locations.
For this reason, users accept that ALBURSA is not responsible for the risks that users take associated with these third-parties links, special offers, advertisers, or make connections to their applications or services or other events and activities.

(ii) Users understand and accept that, such third-party services may or may not have their own privacy terms and conditions. We do not accept any responsibility or liability for such third parties’ websites or programs or any other interactions. Please check such third parties’ terms and conditions, privacy and cookie or other policies before using and providing any information from them.

15-) Transfer Of Personal Data
Users’ personal data, but not limited to these, may be transferred directly or indirectly to any third party in the country or abroad for the above-mentioned purposes.
As ALBURSA, we take all necessary measures to transfer your personal data domestically or abroad. Your personal data may be shared with affiliated companies and affiliates, business partners, suppliers, company officials and shareholders, public institutions and organizations and legally authorized private persons within the framework of the provisions regarding the transfer of personal data specified in Articles 8 and 9 of the KVKK.

a. For Financial Transection: Our Company offers our registered users monthly payment fees in different plans. For that reason, we work with some payment service providers to perform those financial transactions. We share our registered users’ transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds.
We are using a secure payment service providers (third-party) to manage transactions and payment processing. Your payment information will be stored as long as this third-party is entitled to or obliged to store it pursuant to legislation.

b. Transection For Legal Obligation: In case of any legal obligation, we may share your personal data with the institution or organization specified by law or court in order to comply with the legal obligation.

c. ALBURSA reserves the right to refuse service, terminate accounts, save, remove, transfer or edit any content residing on the servers, or cancel requests in its sole discretion with or without any notice and showing any reason.


16-) Paid Services
Our website is a platform through which specialized in construction and real-estate area. In this platform that registered users can find construction materials, meet real-estate developers, and choose services all across the world. In addition, our website also provides a platform where registered users can find an open international tender. To benefit from our services, users need to subscribe and pay for them.

Subscription levels include monthly fees and different payment plans, for the use of the website and hosting features of the Service. If you prefer to use one of the paid aspects of the Service, you agree to the pricing and payment listed on the Service which we may update from time to time. The Company reserves the right to change or add new services for additional fees and charges, or amend fees and charges for existing services, at any time at its sole discretion; by updating the fees listed on the website.

17-) Sensitive Personal Data
The term "sensitive data” (in other words private personal data) refers to the data on a person’s race, ethnic origin, political and philosophical opinions, religion, religious sect and other beliefs, apparel, membership information to associations, foundations or syndicates, sexual life, conviction, security measures, biometric and genetic information and also requires explicit consent.

We do not collect or ask our users for sensitive data through this Service. In the limited circumstances where we may attempt to collect such data, we will do so in accordance with data privacy law requirements and/or seek your explicit consent.

18-) For California Residents
The Consumer Privacy Act in California provides protection of personal data-based rights for consumers who are natural persons and residing in California.

a. California Consumer Privacy Act (CCPA): The CCPA creates certain rights regarding personal data and data privacy. Although these rights are similar to those set by the GDPR and KVKK, they only apply to California residents.

b. Under the California Consumer Privacy Act of 2018 ("CCPA"), if you are a California resident, you have the following rights:

o To know what personal data is collected, used, shared, or sold,
o To delete personal data obtained by businesses and their vendors.
o To opt-out of the sale of their personal data and direct a company to stop selling their information. (Also, as a Company we do not sell any Personal Data and we do not collect personal information from children under the age of 18 compliant with CCPA.)
o To non-discrimination when a user whose personal data is processed wants to exercise their right to privacy under the CCPA.

Please note that, in case of violation, Companies have 30 days to comply with the law once regulators notify them of a violation.

c. Manner Of Application: In the application containing users requests regarding the right they want to use as a data owner; their request must be clearly stated, and the subject of their own request must be personal. In addition, the application must include identification and address details, along with supporting documents confirming users’ identity. If user is acting on behalf of another person, he/she must also attach a document containing his/her special authority.

19-) Severability
If any provisions of this Privacy Policy shall be held to be invalid or unenforceable for any reason, the remaining provisions shall continue to be valid and enforceable. If a court or other competent authority finds that any provision of this Policy is invalid or unenforceable, but that by limiting such provision it would become valid or enforceable, then such provision shall be deemed to be written, construed, and enforced as so limited.

20-) Amendment
We reserve all the rights, at our sole discretion, to change, amend, update, withdraw, modify, or replace these Policy and also other information, material and content provided in the Service at any time and without any prior notification, and revised Privacy Policy terms and other information shall be effective immediately on posting. By using our Service, you accept to receive notifications at any time, if you so desire, you may unsubscribe from receiving them.

Therefore, please visit this Privacy Policy regularly to stay informed about our use, protect, collect, transfer, and otherwise handle with personal data.

21-) In Case of Dispute
As a user, you may always contact us if you believe that your data protection rights have been impaired. Our Company will carefully examine your concern and take the possible precautions. ALBURSA is also obliged to protect the confidentiality of your other personal data obtained in connection with your request. For more information about arbitration and other dispute resolution methods, please visit our General Terms of Use on this website.

22-) Law and Jurisdiction
These Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Turkey, any disputes relating to these terms and conditions will be subject to the exclusive jurisdiction of the courts of Republic of Turkey.

23-) Contact Information
If you have any questions regarding these Privacy Policy, please contact us at [email protected]

The Data Controller:
ALBURSA E-TİCARET ANONİM ŞİRKETİ
Yakuplu Mah. Hürriyet Bulvarı No: 111
İç Kapı No: 4, 34524,
Beylikdüzü/ İstanbul