This Privacy Notice has been prepared to inform and enlighten you, in your capacity as the data subject ("relevant person"), regarding the following matters under Law No. 6698 on the Protection of Personal Data (KVKK): which of your personal data will be processed and for what purposes, to whom and for what purposes the processed personal data may be transferred, the method and legal basis for collecting your personal data, and your rights under Article 11 of the Law regarding the personal data processed by us. This Privacy Notice has been issued by Ram And Sons İnşaat ve Dış. Tic. A.Ş. (“RAMS” and/or “Company”), acting as the data controller, or by its affiliates and subsidiaries, to explain how personal data is processed during your visit to our company’s websites.

Identity of the Data Controller

Data Controller: Ram And Sons İnşaat ve Dış. Tic. A.Ş. (Tax Identification No: 7341504228)
Phone: 444 47 48
Website URL: www.ramsturkiye.com.tr
Email Address: info@ramsturkiye.com.tr
Address: Büyükdere Mah. Ahiler Çıkmazı Sk. Sarıyer Belediyesi Blok No: 19 Sarıyer / İstanbul
Definitions
Personal Data: Any information relating to an identified or identifiable natural person.
Processing of Personal Data:
Any operation performed on personal data: such as collection, recording, storage, retention, alteration, rearrangement, disclosure, transmission, retrieval, making available, classification, or restriction of use, including all actions on personal data, fully or partially automated, or as part of a non-automated data recording system.
Data Processor:
A natural or legal person who processes personal data on behalf of the data controller based on their authority.
Data Recording System:
The system in which personal data is structured and processed according to certain criteria.
Data Controller:
The natural or legal person who determines the purposes and means of personal data processing and is responsible for establishing and managing the data recording system.
Law/KVKK:
Law No. 6698 on the Protection of Personal Data, published on April 7, 2016, in the Official Gazette of the Republic of Turkey No. 29677.
Institution:
The Personal Data Protection Authority.
Board:
The Personal Data Protection Board.


B. Processed Personal Data and Purpose of Personal Data Processing Activities

During your visit to our website, your IP address, which qualifies as personal data, is processed. Additionally, in cases where you request information regarding our projects through our Company, your name, last name, email address, and country of residence, which also constitute personal data, are processed upon the completion and submission of the relevant form. RAMS processes personal data pursuant to Article 5/2 of the Turkish Code No. 6698 on the Protection of Personal Data (KVKK) on the grounds that processing is mandatory for the data controller to fulfill its legal obligations, that the relevant person has made their personal data public, that processing is necessary for the establishment, exercise, or protection of a legal right, or that processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject. Within the scope of the aforementioned conditions, your IP address is processed to fulfill requests made by official authorities and to provide legally required information to competent institutions, to carry out information security processes, to monitor and improve service-related activities, to implement cybersecurity and data protection measures, to manage and follow up on legal affairs, and to ensure the retention of website visit records for the general statute of limitations period so that they may serve as evidence in disputes between the data controller and data subjects or third parties. Furthermore, the processing of your IP address is carried out to ensure compliance with statutory retention obligations and to receive, evaluate, and respond to requests, inquiries, complaints, and suggestions.If you voluntarily complete and submit the application form, your name, last name, email address, and country of residence will be processed for the purpose of identifying potential customers who may be interested in purchasing or renting real estate within the Company's portfolio and carrying out targeted marketing activities in relation to such customers. Additionally, the data will be processed to determine the Company's commercial and business strategies, to plan and execute customer relationship management processes, to plan and implement customer satisfaction and corporate communication activities, and to organize sweepstakes, campaigns, competitions, promotions, or advertising activities. If you provide your consent, your identity, contact, customer transaction, and marketing data will be processed by our Company to personalize and recommend the products and services we offer based on your preferences, usage habits, and needs, and within this scope, your contact information may be used to send you commercial electronic messages, including advertisements, promotions, and campaigns. In order for the personal data you provide in the application form for the purpose of receiving information about our projects to also be used for notifying you of advertisements, campaigns, and announcements regarding all other projects of our Company, you must check the box stating, "I would like to receive electronic messages regarding advertisements, promotions, and campaigns." If you provide this consent, we will be able to inform you about updates concerning our projects. Otherwise, your personal data processed by our Company will be used strictly for the purpose for which you completed the application form.

B: To Whom and For What Purpose the Processed Personal Data Can Be Transferred

Your personal data may be transferred domestically to achieve the processing purposes listed above and to fulfill RAMS's obligations arising from its corporate policy, in accordance with the fundamental principles set forth in Articles 8 and 9 of the Personal Data Protection Law No. 6698 (KVKK). This includes sharing your data with Ram And Sons İnşaat ve Dış Ticaret A.Ş., its affiliates and subsidiaries, business partners, public institutions, and domestic service providers or consultancy firms that we cooperate with for the provision of services or the performance of contracts, provided that confidentiality obligations are respected. Additionally, if you grant communication consent, your personal data may be transferred to İleti Yönetim Sistemi A.Ş. for the management of communication consents in accordance with the Regulation on Commercial Communication and Commercial Electronic Messages and to our solution partners engaged in communication activities. Regarding the transfer of your personal data abroad, your collected personal data may be transferred to our service providers and business partners located outside Turkey for purposes such as information technology services, reporting, analysis, segmentation, advertising activities, or specialized consultancy, including support for software development, hosting, maintenance and infrastructure services. This is because the servers of our foreign suppliers (including communication applications, social media platforms, call centers, and customer relationship management applications) are located outside Turkey. In accordance with Article 9 of KVKK and the Regulation on Procedures and Principles for the Transfer of Personal Data Abroad, such data may be transferred if the conditions outlined therein are met. Under the relevant regulations, personal data may only be transferred to a foreign country if the conditions set out in Articles 5 and 6 of the KVKK are met, and if a “sufficiency decision” has been issued by the Board for the specific country to which the personal data is to be transferred. If a “sufficiency decision” has been issued by the Board, personal data may be transferred to the foreign country, its sectors, or international organizations specified in the sufficiency decision.In the absence of a “sufficiency decision” by the Board for the country to which the data is to be transferred, personal data may only be transferred if one of the requirements of Articles 5 and 6 of the Law is fulfilled, and if the individual can effectively exercise their rights and access effective legal remedies in the country of transfer. Additionally, the transfer may occur if an international agreement, not classified as a public international treaty, exists between public institutions or organizations in Turkey and foreign public institutions or organizations, and if the Board permits the transfer. Furthermore, the transfer can be made if the businesses within an economic enterprise group are required to comply with binding corporate rules related to personal data protection, and these rules are approved by the Board. Another condition is the existence of a standard contract issued by the Board, which includes the data categories, the purposes of data transfer, the recipients and recipient groups, the technical and administrative measures to be taken by the data recipient, and additional measures taken for sensitive personal data and written commitments containing provisions ensuring adequate protection. If any of these guarantees are in place, personal data can be transferred abroad. In the absence of a sufficiency decision by the Board and if no appropriate safeguards as required by KVKK are provided, personal data may still be transferred abroad, but only incidentally and under the following specific circumstances: if the individual gives explicit consent after being informed of the potential risks, if the transfer is necessary for the performance of a contract between the individual and the data controller or for pre-contractual measures requested by the individual, if the transfer is necessary for the establishment or performance of a contract between the data controller and another natural or legal person for the benefit of the individual, if the transfer is required for the public interest or for the establishment, exercise, or protection of a legal right, if the transfer is necessary due to factual impossibility where the individual is unable to provide consent or if their consent is not legally valid, and if it is necessary for the protection of the life or physical integrity of the individual or another person. Personal data may also be transferred if there is a public registry accessible to the public or persons with legitimate interests, provided that the conditions for accessing the registry are met, and the person with legitimate interest requests the transfer.

C. Rights of the Data Subject Under Article 11 of the KVKK

As Ram And Sons İnşaat ve Dış. Tic. A.Ş., we hereby inform you that you have the following rights under Article 11 of the KVKK: the right to learn whether your personal data is being processed, the right to request information if your personal data has been processed, the right to learn the purpose of the processing of your personal data and whether they are used in accordance with this purpose, the right to know the third parties to whom your personal data is transferred domestically or abroad, the right to request the correction of your personal data if it has been processed incompletely or inaccurately, the right to request the deletion, destruction, or anonymization of your personal data in accordance with Article 7 of the KVKK in cases where the reasons requiring its processing no longer exist, the right to request that third parties to whom the personal data has been transferred be informed of the correction, deletion, destruction, or anonymization of the data, the right to object to a decision resulting in an unfavorable outcome for you if the processed data has been analyzed exclusively through automated systems, and the right to request rectification of damages in the event that you suffer harm due to the unlawful processing of your personal data.

D. Rights of the Data Subject Under Article 11 of the KVKK

As Ram And Sons İnşaat ve Dış. Tic. A.Ş., we hereby inform you that you have the following rights under Article 11 of the KVKK: the right to learn whether your personal data is being processed, the right to request information if your personal data has been processed, the right to learn the purpose of the processing of your personal data and whether they are used in accordance with this purpose, the right to know the third parties to whom your personal data is transferred domestically or abroad, the right to request the correction of your personal data if it has been processed incompletely or inaccurately, the right to request the deletion, destruction, or anonymization of your personal data in accordance with Article 7 of the KVKK in cases where the reasons requiring its processing no longer exist, the right to request that third parties to whom the personal data has been transferred be informed of the correction, deletion, destruction, or anonymization of the data, the right to object to a decision resulting in an unfavorable outcome for you if the processed data has been analyzed exclusively through automated systems, and the right to request rectification of damages in the event that you suffer harm due to the unlawful processing of your personal data.

F. Application Procedure Pursuant to Article 5 of the Communiqué on the Procedures and Principles of Application to the Data Controller, dated March 10, 2018, in order to exercise the aforementioned rights, the requestor must submit a written request containing the necessary identifying information and explanations regarding the right they wish to exercise. This written request must be addressed to the relevant representative of Ram And Sons İnşaat ve Dış. Tic. A.Ş. using their official title and sent via registered mail with return receipt or through a notary to the address Büyükdere Mah., Ahiler Çıkmazı Sok., No:19 Sarıyer/İstanbul, or it must be sent to our email address kvkk@ramandsons.com.tr. Applications must be made in Turkish, and the request must clearly specify which of the rights listed above and in Article 11 of the KVKK the applicant is invoking. Additionally, the request must include identity information and any relevant documents and information related to the matter. In cases where an application is submitted on behalf of a third party, a power of attorney duly authorizing representation of the concerned individual must be provided. Applications submitted within this scope shall be concluded as soon as possible and no later than 30 days, free of charge. However, if the requested action incurs an additional cost, the fee determined by the Personal Data Protection Board tariff may be charged to the applicant. If the submitted information and documents are incomplete, the processing period will commence only upon the full submission of the required information and documents. Our company reserves the right to verify the applicant’s identity before responding. Responses to applications may be sent by Ram And Sons İnşaat ve Dış. Tic. A.Ş. to the applicant’s postal address via any type of mail or to the provided email address, at the company's discretion. Ram And Sons İnşaat ve Dış. Tic. A.Ş. reserves the right to amend this disclosure statement in accordance with any amendments to the KVKK and any new methods determined by the Personal Data Protection Board.