Personal Data Protection

General Information

We have designed our website so that users who wish to visit us on the internet can browse comfortably without having to identify themselves or provide personal information.

When you choose to provide us with your personal information, we will protect it and use it only in the ways set out below.

Purpose of this Privacy Policy

We are committed to always respecting and protecting your privacy. Evorand will not sell, rent, transfer or otherwise make available to anyone else any information about any person visiting our website, other than as expressly stated in this Privacy Policy.

The purpose of this Privacy Policy is to:

• Personal data we collect from you: to determine the type and use of personal data that Evorand will collect from you (see Section A. below, 'Personal data we collect from you').
• How we use your information and legal basis for processing: to determine the basis on which any personal data is processed by Evorand (see Section B. below, 'How we use your information' and Section C., 'Legal basis for processing').
• To inform you: to inform you about how Evorand will use your personal data.
• Data protection regulations: to clarify Evorand's obligations under data protection regulations regarding the lawful and responsible processing of your personal data.
• Your rights as a data subject: to inform you of your data protection rights (see Section J. below, 'Your rights as a data subject').

We process your personal data in accordance with applicable data protection regulations and the EU 2016/679 General Data Protection Regulation ('GDPR'), in force since 25 May 2018, and the law.

We will comply with the local data protection laws of the jurisdictions in which we operate, and to do so the personal information we hold about you will be:

• Used by us in a lawful, fair and transparent manner.
• Collected only for legitimate purposes that are clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to and limited to the purposes mentioned to you.
• Accurate and kept up to date.
• Kept only for as long as necessary for the purposes mentioned to you.
• Kept securely.

This Privacy Policy should be read together with our Cookie Policy and other Privacy Notices that we may provide in certain circumstances when collecting or processing your personal data, so that you are fully aware of how and why we use your data. This Privacy Policy was last updated in February 2024.

A. Personal Data We Collect From You

When using our website, you may contact our representatives or obtain information about the services offered by Evorand and begin the process of acquiring any service you may be interested in.

We will collect and process personal data about you:

Information you provide to us:

Personal information includes your name, surname, nationality, country of residence, email address and telephone number. These details may include information about the services you are interested in or details regarding your enquiry. Information you provide to us may also include data relating to marketing preferences.

You may provide this information in the following situations:

• Completing an information form on our website
• Corresponding by mail, telephone, email or other means when applying for our services
• Providing feedback to us
• Beginning negotiations to supply goods and/or services or entering into a contract.

In cases where we collect or process further information, we will provide separate privacy notices that explain in greater detail how and why we use your personal data.

2. Information We Collect About You From Our Website

Each time you visit our website, we automatically collect the following information:

Technical Information:

The IP address used to connect your computer to the internet, your login details, browser type and version, uniform resource locators (URLs) and interactions made through our website (including date and time), including clickstream to, through and from our website.

Other information about your experience on our website, such as page response times, download errors, length of visits to particular pages, page interaction information (such as scrolling, clicks and mouse-overs) and the methods used to leave a page.

Location Information:

We may obtain information about your location and determine your location via your IP address, and when you access our website from a mobile device, using the data collected from that device. This includes information about wireless networks or base stations near your mobile device during access.

Our website uses cookies to distinguish you from other users of our website. This helps us provide you with a good experience while browsing our website and allows us to improve it. For detailed information about the cookies we use and the purposes for which we use them, you may refer to our Cookie Policy.

B. How We Use Your Information

1. Information You Provide to Us:

The purposes for which this information is used:

• To facilitate the provision of the services you have requested and where we need to perform a contract we have entered into or are about to enter into with you.
• Where necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• To resolve issues you have reported and to provide support-related services.
• To manage our supplier relationship with you.

2. Information We Collect About You From Our Website:

The purposes for which this information is used:

• For internal operations, including managing and troubleshooting our website, and to keep our website safe and secure.
• To improve our website to ensure that content is delivered to you in the most effective way.
• To ensure that content displayed on the website is presented in a user-friendly manner.

C. Legal Basis for Processing

We will process your personal data for as long as necessary to provide the services we offer to you and/or for the purposes set out in this Privacy Policy (see Section B., 'How we use your information').

We may also process your personal data based on any legitimate interest or to comply with any legal obligation. These interests and obligations may include the pursuit or defence of legal claims or compliance with the order of any court, judge or authority, or disclosure to a government or regulatory body.

In general, we do not regard your consent as a legal basis for processing your personal data. However, where your consent is required, we will provide you with a form requesting explicit consent for that purpose.

D. Sharing of Your Information

We may share your personal data with any of our international offices or with companies that form part of Evorand and may act as joint data controllers or data processors. These offices or companies will be data controllers for your data when you benefit from our services and/or may provide management, control and reporting services. We respect and protect the security of your personal data in accordance with applicable laws (including the GDPR) and apply the security measures and protections described below (see Section G. below, 'Data Security'). We will only provide information necessary to perform the services under our contract with you.

We may need to share your data with local representatives or other service providers (considered as data processors) as necessary for us to provide the services you have requested. These local representatives and providers store and process your data on a strictly confidential basis and subject to the appropriate security measures and safeguards as described in Section H below.

We may also share your data with other third parties in their capacity as data controllers, such as legal, tax, real estate, immigration or other advisers and consultants, (international) banks for payment details, or third parties such as real estate agents, property owners or developers who provide you with other or additional services or goods, and those wishing to work with you and such third parties under separate terms and conditions. These third parties will process your data in their own right as data controllers and their data protection policies and processes will apply.

We may also disclose or share your data where we are required to comply with any legal obligation, jurisdiction, or pursuant to an order of a court, judge or authority. We may also disclose your data to enforce our terms of use or to protect the rights, property or safety of our partners or other users of our website. This includes the exchange of information with other companies and organisations for anti-money laundering or KYC checks, anti-bribery or anti-corruption law compliance and/or fraud prevention purposes.

E. Transfer of Data to Third Countries

Where we share your personal data with internal or external third parties, this may involve the transfer of your data outside the EEA. To ensure that your personal data is protected and transferred securely in accordance with applicable laws including the GDPR, we will transfer your personal data in accordance with standard contractual clauses (i.e., the European Commission's model clauses for the transfer of personal data to third countries, also known as 'SCCs').

Evorand acts as the EU data representative for all of our offices located outside the EEA. You may address any question, query or concern to Evorand by sending an email to the address below with 'Data protection' in the subject line: info@evorand.com

F. Third-Party Access to Your Personal Data

We work closely with third parties to provide you with the services you request on our website. These third parties include cloud storage providers, analytics providers and search engine information providers. We will only work with third-party providers that comply with the applicable laws in the jurisdictions in which we operate, comply with the GDPR, and undertake to be bound by SCCs (as mentioned in section E., 'Transfer of data to third countries') where necessary to adequately protect and safeguard your personal data.

G. Data Security

We will ensure that appropriate security measures are taken against the unlawful or unauthorised processing of personal data and against the accidental loss or damage of personal data.

The transfer of information between our website and your device is protected by Transport Layer Security (TLS) certificates. When the website is accessed using compatible browsers, this technology protects personal information by using both server authentication and data encryption to ensure that personal information is secure and safe during transmission. The main browser versions compatible with this technology are Internet Explorer (from version 11), Mozilla Firefox (from version 27), Google Chrome (from version 32) and Apple Safari (from version 7).

No method of data transmission is 100% secure and absolute security cannot be guaranteed.

H. Data Retention

We will retain your data only for as long as strictly necessary for the purposes for which it was collected (i.e., to provide you with our services or to meet any legal, accounting or reporting requirements). In any event, the retention of data shall not exceed 10 years from the date on which the services ended or were completed. This retention period allows us to use the data to defend potential legal claims, taking into account the applicable limitation periods under the relevant laws and, where applicable, to comply with anti-money laundering or KYC laws and regulations, anti-bribery or anti-corruption laws and regulations, and the accounting and tax laws applicable in the specific jurisdictions in which we operate.

I. Data Minimisation

When it is no longer necessary for us to identify you from this data, we anonymise the data we hold about you as much as possible.

J. Your Rights as a Data Subject

Under the GDPR, you have the following rights:

Right of Access: You have the right to request information about whether your personal data is processed by Evorand and how and why it is processed, by sending an email to info@evorand.com. If your request is manifestly unfounded, repetitive or excessive, we may charge a reasonable fee; in such cases we may also refuse to fulfil your request.

Right to Object: You may contact us at any time by sending an email to info@evorand.com and request that we stop processing your personal data. Upon written objection, your data will no longer be processed for those purposes.

Right to Rectification: You have the right to ensure that any incorrect personal data we process about you is corrected, to update any data that is out of date, and to complete any incomplete personal data.

Right to Erasure: You have the right to have your personal data deleted in certain circumstances when it is no longer necessary.

Right to Restrict Processing: You have the right to restrict our processing activities in certain circumstances.

Right to Data Portability: You have the right to receive your personal data in a structured and machine-readable format and to transmit that data to another data controller.

K. Right to Withdraw Consent

Where you may have permitted the collection, processing and transfer of your personal information for a specific purpose (for example, for marketing), you have the right to withdraw your consent for that specific processing at any time, or you may withdraw your consent in relation to this Privacy Policy. To withdraw your consent, please contact info@evorand.com. This request will not affect the lawfulness of any processing carried out on the basis of such consent before its withdrawal. When we receive notice that you have withdrawn your consent, we will no longer process your information for that purpose unless we have another legitimate basis to do so by law. Withdrawal of consent in relation to this Privacy Policy will not oblige us to immediately terminate our services to you.

You may withdraw any consent you have given for any of the purposes listed above at any time. This does not affect the lawfulness of your personal data for the purposes applicable prior to your withdrawal. You may send us an email at info@evorand.com stating that you have withdrawn your permission and indicating which processing activities the withdrawal relates to.

L. Complaints

We welcome any comments, complaints and queries regarding data protection. As stated above, you may contact our data protection officer at info@evorand.com or use the contact details in section N, 'How to contact us', below; we will do our best to address any issue or concern you may encounter.

M. Changes That May Be Made to This Privacy Policy

Any changes we make to this Privacy Policy in the future will be published on this page and, where appropriate, notified to you by email.

N. How to Contact Us

If you have any questions about this Privacy Policy or wish to send us your comments, please contact us today. Alternatively, you may write to us using the details below:

Evorand

Müeyyetzade Mah.

Lüleci Hendek Cad.

No:54 NOA Binası

Beyoğlu İstanbul

Tel: +90 534 279 45 13

Please check back frequently to see any updates or changes to this Privacy Policy.