1. Data Controller: Pursuant to the Personal Data Protection Law No. 6698 (“KVKK”), your personal data; as the data controller, is processed by İlanpa Bilgi Teknolojileri Pazarlama Turizm ve Tic. Ltd. Şti. (“ILANPA”) within the scope explained below.
2. Your Processed Personal Data and Processing Purposes:
Identity and Contact Data: Creation of membership registration, identity verification in accordance with the Regulation on Real Estate Trade, and execution of communication activities.
Transaction Security Data (IP Address, Log Records): Ensuring system security and monitoring unlawful content in accordance with Laws No. 5651 and 6563.
Financial Data (Payment References): Technical tracking of top-ups made via digital wallet and virtual POS and management of reconciliation processes in accordance with Law No. 6493.
Listing and Portfolio Data: Publication of real estate listings and sharing with authorized offices within the scope of the MLS (Solution Partnership) system.
3. Legal Grounds for Processing Personal Data: Your personal data, pursuant to Article 5/2 of the KVKK;
Establishment and performance of a contract (subparagraph c): Fulfillment of the membership agreement and digital account usage conditions,
Legal obligation (subparagraph ç): Verification of the identity of the listing provider in accordance with Article 12/A of the Real Estate Trade Regulation and record-keeping obligations under Law No. 6563,
Legitimate interest (subparagraph f): Processing for the purposes of ensuring platform security and preventing fraud.
4. Data Transfer: Your personal data; limited to the purposes stated above; is transferred to licensed payment institutions (for Virtual POS transactions), authorized public institutions and organizations (BTK, Ministry of Trade), and—provided that you have explicit consent on a listing basis—to Solution Partner offices within the MLS system.
5. Your Rights: Pursuant to Article 11 of the KVKK; you have the right to learn whether your data is processed, to request correction, deletion or destruction, and to request compensation for damages. You may submit your applications to [support@ilanpa.com].
SECTION 2: EXPLICIT CONSENT DECLARATION
EXPLICIT CONSENT DECLARATION REGARDING THE PROCESSING OF PERSONAL DATA
I have read the Information Notice provided by ILANPA. Within this scope;
I give my consent of my own free will to the processing of my personal data for the purpose of providing me with marketing, campaigns, discounts and promotions customized according to my usage habits and preferences,
to sending commercial electronic communications to my contact information,
and to storing my credit/debit card information in a masked form within the payment institution infrastructure in order to facilitate Virtual POS/Digital Wallet transactions.
(Note: Not providing this consent will not prevent you from benefiting from ILANPA services.)
SECTION 3: ILANPA.COM PRELIMINARY INFORMATION TEXT FOR ALL PARTIES
1. Platform Status and Limitation of Liability: ILANPA is an “Intermediary Service Provider” pursuant to Law No. 6563. In accordance with the KVKK Decision No. 2023/1234, it is not a party to real estate sale/rental agreements. ILANPA only provides technical infrastructure and a digital approval mechanism; the member who posts the listing is personally responsible for the accuracy of the listing content.
2. Digital Account and Wallet System: The wallet on the platform is not a bank or payment account within the scope of Law No. 6493. This system can only be used for services within ILANPA (Boosting, Sponsored Office, etc.). Fund ownership and transfer operations are carried out by CBRT-licensed payment institutions (PSPs).
3. MLS and Solution Partnership Transparency: In accordance with the Sahibinden decision; the process of sharing listings with other corporate members (MLS) within the scope of authorization obtained from the individual member is subject to fully transparent and traceable logs. Data transfer is carried out within the scope of KVKK Article 5/2-c (performance of a contract), only to the extent required by the nature of the work (data minimization).
4. Virtual POS and Card Security: In accordance with the KVKK Decision No. 2023/567, card information entered at the time of payment is not stored by ILANPA. Card storage service is carried out within the infrastructure of a PCI-DSS compliant payment institution with the user’s separate and optional explicit consent.
5. Exception to the Right of Withdrawal: Pursuant to Article 15 of the Distance Contracts Regulation; services that are performed instantly in an electronic environment, such as listing publication, boosting and sponsored services, cannot be subject to the right of withdrawal once the performance of the service has started due to their nature.
6. Digital Approval and Evidence Agreement: All approvals given via OTP or checkbox on the platform constitute conclusive evidence pursuant to Article 193 of the Code of Civil Procedure. IP and timestamped log records kept in the system constitute exclusive evidence in disputes between the parties.
4. SYSTEM INTEGRATION AND CHECKBOX INSTRUCTIONS
Stage – Action / Text – Approval Mechanism – Legal Requirement
Membership Registration – KVKK Information Notice – “I have read” statement (must not be pre-checked) – Mandatory (KVKK Art. 10)
Membership Registration – Membership Agreement & Preliminary Information – “I have read and approve” checkbox – Mandatory (Law No. 6563 Art. 3)
Membership Registration – Marketing/Commercial Communication Consent – Separate checkbox (must be empty) – Optional (Law No. 6563 Art. 6)
Listing Submission – Real Estate Verification Approval – “I declare that the property belongs to me/my relative or that I am authorized” – Mandatory (Real Estate Trade Regulation 12/A)
Payment (Virtual POS) – Digital Account / Payment Terms – “I accept the payment and wallet usage terms” – Mandatory (Law No. 6493)
Warning:
The Information Notice is not a contract; therefore, the expression “I have read/been informed” should be used instead of “I approve.”
The explicit consent checkbox cannot be combined with the membership agreement approval checkbox (Board Decision 2018/90).
The preliminary information form must be shown to the user again immediately before entering into a payment obligation (before the payment button) (Distance Contracts Regulation Art. 6).
mesaj içeriği
