Privacy Policy and KVKK Notice

Data Controller

Your personal data is processed by ALS Gayrimenkul, acting as data controller, within the purposes and limits described below.

Address: Alaçatı, Atatürk Blv. No:32, 35930 Çeşme/İzmir

Phone: +90 544 260 06 85

Email: info@alsemlak.com

Website: https://www.alsemlak.com

Instagram: instagram.com/alsgayrimenkul

Personal Data We Process

We process only the data you submit and the data that arises automatically due to the technical operation of the site. The categories of data are as follows:

• Identity and contact data: The name, phone number and (if you enter it) email address you submit through the contact, buy-sell or offer form.
• Transaction/request data: The content of your form message and optional fields such as offer amount and budget (only when you enter them).
• Security and usage data: IP address, browser and device information, pages visited and interaction data generated automatically while you use the site (via analytics and security cookies).
• Preference data: Your on-site preferences such as theme (light/dark), language, currency and measurement unit.

How We Collect Personal Data

Your personal data is collected electronically, by automated or partly automated means, through:

• Completing and submitting the contact, buy-sell and offer forms on the website,
• Contacting us by phone or email,
• Cookies and similar technologies (including localStorage) generating data automatically during your visit,
• The operation of bot/spam protection (Cloudflare Turnstile) and our security and content-delivery infrastructure.

Purposes of Processing

Your personal data is processed for the following specific, explicit and legitimate purposes:

• To receive your contact, buy-sell and offer requests, deliver them to our office by email and respond to you,
• To provide our real-estate advisory services and assess your requests,
• To ensure the security of the website and forms and to prevent bot and spam submissions,
• To measure, understand and improve site performance and user experience (only via analytics cookies you have consented to),
• To remember your preferences such as theme, language, currency and measurement unit,
• To fulfil our legal obligations and to establish, exercise or protect a right in possible disputes.

Legal Grounds for Processing

Your personal data is processed on the basis of the conditions set out in Article 5 of the KVKK, with the following legal grounds applied per processing activity:

• Necessity directly related to the conclusion or performance of a contract (KVKK Art. 5/2-c) - receiving and assessing the request you submit through the contact, buy-sell and offer forms, and conducting the pre-contractual process, rely on this ground.
• Legitimate interests of the data controller (KVKK Art. 5/2-f) - responding to general contact requests and securing the site and forms, preventing spam/bots.
• Explicit consent (KVKK Art. 5) - statistics (analytics) and any marketing cookies operate only with the explicit consent you give in the cookie banner; if you do not consent, these cookies are not used. The contact data needed to handle your request relies on the legal grounds above and is not subject to separate consent.
• Necessity for the establishment, exercise or protection of a right (KVKK Art. 5/2-e) - defence in possible disputes.
• Express provision in law and compliance with a legal obligation (KVKK Art. 5/2-a, Art. 5/2-ç) - as required by applicable legislation.

Special Categories of Personal Data

Our website is not intended to collect the special categories of personal data defined in Article 6 of the KVKK (such as health, religion, ethnic origin or biometric data), and our forms do not request such data. Please do not enter special-category data into free-text fields.

Transfer of Personal Data

Your personal data is processed through the service providers below, used to deliver our services and operate our website, strictly limited to the relevant purpose. We maintain the necessary technical and administrative measures and data-processing/confidentiality commitments with these providers.

• Hetzner Online GmbH (Germany/EU): Hosting of the web application and PostgreSQL database (servers are located in Germany).
• Cloudflare, Inc. (USA): Content delivery network (CDN), DNS, security/proxy, media storage (R2) and form security (Turnstile). IP address and request data are processed in this scope.
• Resend / Plus Five Five, Inc. (USA): Delivery of contact, buy-sell and offer form submissions to our office inbox (info@alsemlak.com). Your email is set as the reply-to address.
• Google LLC (USA): Tag management via Google Tag Manager and site-usage analytics via Google Analytics 4 (only with your explicit consent).
• Microsoft Corporation (USA): Session analytics, heatmaps and session recordings via Microsoft Clarity (only with your explicit consent).
• OpenStreetMap Foundation and CARTO (map tile providers): When the map on listing pages loads, your IP address is sent to these providers.
• Authorised public authorities: Where a legal obligation arises and only to the extent requested.

International Transfer

As some of the providers above are established abroad, your personal data is transferred internationally for the provision of these services. The main countries of transfer are: Germany (EU) for Hetzner; the United States for Cloudflare, Google, Microsoft and Resend.

These transfers are carried out under Article 9 of the KVKK as amended by Law No. 7499 and the Regulation on Procedures and Principles for the Transfer of Personal Data Abroad. For transfers to countries without an adequacy decision, appropriate safeguards under KVKK Art. 9 (in particular the standard contract published by the Board) are relied upon, and the notification procedures required by law are followed.

As these transfers are regular and continuous, they are based on appropriate safeguards under Art. 9 rather than on the explicit-consent exception alone. Hosting via Hetzner takes place within the EU, so data is not transferred to a third country; however, since it is outside Türkiye, it is still treated as an international transfer and is disclosed here for transparency.

Data Security Measures

To prevent unlawful processing of, access to and loss of your personal data, we take appropriate technical and administrative measures under Article 12 of the KVKK:

• HTTPS/TLS encryption for all site traffic,
• Security, proxy and bot/spam protection (Turnstile) via Cloudflare,
• Authorised and restricted access to the admin panel and database,
• Server-side validation of form submissions,
• Processing data only for the stated purposes and for the necessary period,
• Data-processing/confidentiality commitments with service providers.

Retention Period

Your personal data is retained for as long as necessary for the purposes for which it is processed and for the limitation/retention periods stipulated by applicable legislation. Data relating to contact and offer requests is kept for a reasonable period for resolving your request and for possible disputes. Cookies remain on your device for the durations stated in the relevant cookie table. At the end of these periods, your data is deleted, destroyed or anonymised.

Automated Decision-Making and Profiling

Our website does not carry out solely automated decision-making or profiling that produces legal effects concerning you or significantly affects you. Analytics tools are used only for aggregated, statistical measurement, within the scope of the consent you provide.

Children's Data

Our website is not directed at children, and we do not knowingly collect personal data from persons under 18. If we become aware that a child's data has been submitted without consent, we delete it as soon as possible.

Third-Party Links

Our site may contain a link to our social media account (Instagram) and uses OpenStreetMap and CARTO map tiles to display maps on listing pages. When a map loads, your IP address is exposed to the relevant tile providers. These third-party services and sites are governed by their own privacy policies; ALS Gayrimenkul is not responsible for those policies.

Your Rights as a Data Subject

Under Article 11 of the KVKK, by applying to the data controller you have the following rights regarding yourself:

• To learn whether your personal data is being processed,
• To request information if your personal data has been processed,
• To learn the purpose of processing and whether it is used in accordance with that purpose,
• To know the third parties to whom your personal data is transferred at home or abroad,
• To request correction if it is incomplete or inaccurately processed,
• To request its deletion or destruction within the conditions of Article 7 of the KVKK,
• To request that correction, deletion or destruction be notified to third parties to whom the data was transferred,
• To object to a result against you arising from the analysis of your data solely by automated systems,
• To claim compensation if you suffer damage due to unlawful processing.

Applications and Complaints to the Board

To exercise your rights, you may submit your request in writing to the address above, to info@alsemlak.com, or by the other methods set out in the Communiqué on the Procedures and Principles of Application to the Data Controller (e.g. an email address registered in our system, secure electronic signature/mobile signature). Your application should include your name, the subject of the request and information that makes you reachable.

To prevent disclosure of personal data to unauthorised persons, we may request additional information to verify your identity before concluding your application.

Your applications are concluded free of charge as soon as possible and within 30 days at the latest, depending on the nature of the request; if the process requires additional cost, the fee in the tariff set by the Board may be charged.

If your application is rejected, answered insufficiently or not answered within 30 days, you may file a complaint with the Personal Data Protection Board within 30 days of learning the response and in any case within 60 days of the application date.

Updates to This Policy

This text may be updated from time to time due to changes in legislation or developments in our services. The current version is always published on this page, with the effective date shown at the top. Last updated: 10 June 2026.