1. Identity of the Data Controller
In its capacity as the data controller, Viridis İnşaat Gayrimenkul Sanayi Tic.Ltd.Şti. (“Company”), domiciled at Fatih Sultan Mehmet Mah. Poligon Cad. No:8 C İç Kapı No:98 Ümraniye-İstanbul and duly registered in the Istanbul Trade Registry Directorate under registration number 138906-5, hereby provides notice in accordance with our statutory obligations under Data Protection Law No. 6698 (“Law”), concerning the collection and processing of your personal data.


2. Why We Process Your Personal Data
The Company is authorised to process a comprehensive set of your personal data in accordance with the principles set out in the Act. This data set, which includes elements such as identity, contact, financial and professional details, visa/passport details, audio/visual content, insights into your familiarity with our projects, your tailored preferences and requests relevant to our initiatives, vehicle information and signature records, is collected in light of your distinguished status as a customer of the Company. The overarching objectives of this data assimilation encompass a number of critical operational aspects. These include, but are not limited to, the meticulous orchestration of customer satisfaction paradigms, the execution of fiscal obligations relating to proposals and remittances, the stewardship of both antecedent and subsequent financial and accounting transactions – this specifically encapsulates the creation and meticulous control of promissory notes and invoices. In addition, it assists in the proficient management of current account processes, the dissemination of insights regarding the Company’s bespoke campaigns and ventures, the enhancement of brand awareness, the strategising and deployment of marketing efforts, the smooth management of pertinent contractual and protocol processes, the skilful coordination and monitoring of freight shipments, the assurance of post-sale utility provisions encompassing electricity, water and natural gas, and the drafting of indispensable legal instruments – a category that specifically includes consents, delegations of authority, and certification of authorisation to speed up legal mandates tied to our Company’s operation, guaranteeing the integrity and safety of the Company’s physical premises while carefully monitoring and carrying out relevant legal proceedings. This entire spectrum of activities strictly adheres to the processing conditions and objectives stipulated in the Law and relevant legislative arrangements.

Furthermore, the above personal data may be archived in the Company’s physical repositories and information systems and preserved in both electronic and physical formats.


3. Who we share your personal data with and for what purposes
For the purposes of Article 2 of this Disclosure Text, your personal data may be directly or indirectly shared with our domestic and international affiliates or subsidiaries. This includes relevant financial institutions, independent audit firms, and financial advisors for managing our financial and accounting needs. Furthermore, for the communication aspects related to Company campaigns and operations, data may be passed on to the respective operator company. Our branding and marketing activities, which are designed to improve brand recognition, may necessitate data sharing with both domestic and international partners. In logistics, the freight company overseeing the initiation and monitoring of shipments may be privy to necessary data. Following the sale of property, the relevant electricity, water and gas distribution companies may receive relevant data to ensure the provision of utilities. During the execution of processes inherent to the Company’s projects, necessary data may be shared with relevant land registry departments, municipalities and Emlak Konut GYO to meet the requirements. To strengthen the security of our physical assets, relevant data may be transferred to the relevant legal entities, including security units and courts, on request. Finally, to manage and speed up legal matters, our consulting law firms may access relevant data.


4. How we collect your personal data and legal bases
For the purposes of Articles 2 and 3 of this Disclosure Text, your personal data can be processed and passed on by the Company, through both automated and non-automated mechanisms. Such processing and transfer are based on the legal grounds set out in Article 5 of the Law, which include the need to process data for the establishment, exercise or defence of rights, the conclusion or performance of a contract, the legal obligations of the data controller and the legitimate interests of the data controller.

The Company collects your data through various channels. This includes information you convey directly, whether orally, in writing, electronically or physically. Data is also obtained from affiliated agency companies relevant to projects carried out in collaboration with such agencies. Completing customer information forms on the Company’s website, in its offices and during events also serves as a source of data collection. Moreover, the Company uses specific applications and software tools as part of its regular operations. These tools, together with CCTV cameras situated in the Company’s facilities, help with compiling relevant data.

Rights of the data subject

Pursuant to Article 11 of Data Protection Law No. 6698,
Each individual is entitled to do the following:

1. Ascertain whether their personal data is subject to processing
2. Request information about the processing of their personal data
3. Determine the intended purpose of the processing of their personal data and confirm that it is in line with said purpose
4. Determine the identity of any third parties to which their personal information may be passed on, either domestically or internationally
5. Request the rectification of personal data in instances where the processing is incomplete or inaccurate
6. Request the erasure of personal data pursuant to Article 7 of Data Protection Law No. 6698
7. Request notification of actions taken in accordance with Articles (5) and (6) from third-party entities to which their personal data has been communicated
8. The right to object to a decision that has been made solely through automated processing of data, which results in an adverse consequence for the individual
9. The right to request compensation for damages in the event of personal data being processed unlawfully.

To exercise the above rights, individuals may submit their requests to the Company in written form. This can be done by completing the Data Subject Application Form available on www.viridis.com.tr. The completed form can be sent through the following communication channels provided by the Company: