KVKK Notice

Privacy and Personal Data Protection Policy

At EmlakBase, we process, store and protect your personal data in accordance with the Turkish Personal Data Protection Law No. 6698 ("KVKK" or "the Law") and related legislation. This text provides general information about the data processing activities we carry out on our platform.

This English translation is provided for convenience. The Turkish version is legally binding.

Definitions and Scope

This policy covers the procedures and principles for obtaining, recording, storing, updating and transferring personal data within the scope of the Law, whether by automated or non-automated means, and for other processing activities.

The policy concerns the authorized representatives and employees of agencies subscribing to the platform, visitors who view our listings and become members, persons who contact us through our website, and all natural persons who use the platform.

Data Controller and Data Processor Roles

EmlakBase is the data controller for the data you share directly with us in membership, communication and support processes.

For the personal data that subscribing agencies enter into the platform about their own customers, portfolios and contracts, the relevant agency is the data controller; EmlakBase acts as a data processor providing hosting and technical processing services for this data. The obligations to inform data subjects and to obtain consent for this data rest with the relevant agency.

Categories of Personal Data Processed

Within the scope of our activities, we may process your data in the following categories: identity (first and last name), contact (e-mail, phone), customer transactions (subscription and usage records), transaction security (login records, IP address, log records), finance (invoice and payment information) and, where you have given explicit consent, marketing.

The categories of data processed vary according to the purpose of the activity and are determined in line with the principle of data minimization.

Purposes of Processing Personal Data

Your personal data is processed for the purposes of creating and managing your platform membership, establishing and performing the subscription contract, providing and improving the service, responding to support requests, carrying out invoicing and collection processes, ensuring information security, fulfilling our legal obligations, responding to requests from authorized institutions and organizations, and carrying out marketing and information activities for which you have given explicit consent.

Methods of Processing and Legal Grounds

Your data is collected through channels such as registration and contact forms, records generated while you use the platform, and e-mail correspondence, on the legal grounds set out in Article 5 of the Law: the establishment and performance of a contract, compliance with a legal obligation, legitimate interest and explicit consent.

Where processing is based on explicit consent, you have the right to withdraw your consent at any time.

Cookies (Cookie Policy)

Our website and platform use cookies and similar browser storage technologies for three purposes: (1) Strictly necessary cookies — to maintain your session, ensure security, and remember your language, theme and cookie preferences; they are required for the service to work, so they do not depend on your consent and are always on. (2) Analytics cookies — to measure how the site is used with Google Analytics, with your IP address truncated. (3) Marketing cookies — to measure ad performance and show relevant ads with Google Ads.

Analytics and marketing cookies are activated only with your explicit consent and are not used until you make a choice. On the banner shown at your first visit, rejecting is as easy as accepting, and in the "Cookie Settings" window you can switch each category on or off separately. You can withdraw your consent at any time via the "Cookie Settings" link at the bottom of the page. The preference you give or withdraw is recorded with the date, text version, IP address and browser information as evidence.

Data obtained through analytics and marketing cookies may be processed abroad (USA/EU) by our service provider Google; this transfer is carried out in accordance with Article 9 of the Law. Retention periods for cookie data and consent records are listed in the "Personal Data Processing Inventory" section at the end of this page.

You can delete or block cookies in your browser settings; however, if strictly necessary cookies are blocked, you may not be able to sign in to the platform.

Transfer of Data

Within the limits set by the legislation, your personal data may be transferred to the hosting, database and e-mail infrastructure providers we work with to provide the service, to the relevant financial institutions in payment and invoicing processes, and to authorized public institutions and organizations and courts.

The platform infrastructure runs on servers hosted in the European Union (Frankfurt) region. Where a transfer abroad is required, the safeguards and contractual measures set out in the Law are applied.

Data Security and Retention Periods

Your data is protected by technical and administrative measures, including access authorization, encrypted communication (TLS), agency-level data isolation and regular backups.

Your personal data is retained for the period required by the relevant legislation or by the purpose of processing; at the end of these periods, it is deleted, destroyed or anonymized.

The full list of processing activities, retention periods by category and data processors are published in the "Personal Data Processing Inventory" section at the end of this page; expired records are destroyed automatically every night. Members can download all data linked to their account from the My Account page, and agency owners can download agency data under Settings > Agency, in machine-readable (JSON) format.

Account Deletion and Destruction of Data

Members (of the EmlakBase listings app and www.emlakbase.com/hesap) can permanently delete their own accounts through the "Delete Account" step on the My Account page by confirming their password. Upon deletion, the account and login information, first and last name, phone number, favorites, saved searches, comparison list and notification preferences are destroyed immediately. Questions, messages and appointment requests sent to agencies remain in the relevant agency's records in a form separated from identity (anonymized) and cannot be linked back to the person.

Agency employees (EmlakBase Pro and the web panel) close their accounts through the "Delete My Account" step under Settings > My Account by confirming their full name; the property, customer, contract and task records they created are agency data and are therefore not deleted but transferred to the agency owner. The agency owner closes the business through the "Delete Business" step under Settings > Subscription; agency data is kept in a recoverable state for 7 days and is then permanently destroyed. Invoice and subscription records subject to statutory retention obligations are kept for the period required by the legislation.

Users who cannot access their accounts can open a request in the "Account Deletion Request" category at www.emlakbase.com/support or write to iletisim@emlakbase.com from their registered e-mail address; after identity verification, the account is deleted within 7 business days at the latest. A step-by-step explanation is available at www.emlakbase.com/hesap-silme.

Rights of the Data Subject

Under Article 11 of the Law, you have the right to learn whether your personal data is processed, to request information about the processing activities, to learn whether it is used in accordance with its purpose, to know the third parties to whom it is transferred in Turkey or abroad, and to request its correction if it has been processed incompletely or inaccurately.

You also have the right to request the deletion or destruction of your data under the conditions set out in the Law, to request that these operations be notified to the third parties to whom the data has been transferred, to object to any outcome against you resulting from analysis exclusively by automated systems, and to claim compensation if you suffer damage.

How to Apply

You can submit requests regarding your rights in writing to iletisim@emlakbase.com from your registered e-mail address, or by other methods that verify your identity.

In accordance with the Law, your applications are concluded free of charge within thirty days at the latest.

Policy Updates

This policy may be updated when necessary; the current version takes effect as soon as it is published on our website.

You can always access the most current version of the policy on this page.

Annex

Personal Data Processing Inventory

What data we process, for what purpose and on what legal basis, how long we keep it and with whom we share it.

Processing Activities

ActivityData subjectsData categoriesPurposeLegal basisRetentionRecipients / processors
Member account (listings app and web membership)Visitor membersFull name, e-mail, phone, password hash, login records, device notification tokenEstablishing the membership contract, sign-in and account security, sending notificationsPerformance of a contract (Art. 5(2)(c)); explicit consent for notificationsFor the duration of membership; destroyed immediately when the account is deletedSupabase (database and authentication), Expo (push notifications), Vercel (hosting)
Favorites, saved searches, comparisonVisitor membersListing preferences, search filters, price-drop notification preferencePersonalized tracking and notificationsPerformance of a contract (Art. 5(2)(c))For the duration of membership; destroyed immediately when the account is deletedSupabase
Listing questions, messages and appointment requestsVisitor members, agency employeesFull name, contact information, message content, requested dateEstablishing communication between the visitor and the agency that published the listingPre-contractual request (Art. 5(2)(c)); legitimate interest for the agency (Art. 5(2)(f))Remains in the agency's records; separated from identity (anonymized) when the member account is deletedThe relevant real estate agency, Supabase, e-mail provider (SMTP)
Agency employee account (Pro panel)Agency owners and agentsFull name, e-mail, phone, role, avatar, two-factor authentication setting, login recordsPanel access, authorization, account securityPerformance of a contract (Art. 5(2)(c)), legal obligation (Art. 5(2)(ç))Until the employee account is deleted; work records are transferred to the agency ownerSupabase, Vercel, e-mail provider
Customer (CRM) recordsAgencies' customers and leadsFull name, phone, e-mail, Turkish ID number/tax number (optional), budget and preferences, meeting notesManagement of the agency's own customer relationships (EmlakBase is the data processor)The ground determined by the agency as data controller; EmlakBase processes the data under contract as a data processorDestroyed when deleted by the agency or 7 days after the agency is closedThe relevant agency only; Supabase (hosting)
Contract, income/expense and document recordsAgency customers, property ownersIdentity and contact information, property information, amounts, uploaded documentsThe agency's contract and finance management; document generationThe ground determined by the agency as data controller (EmlakBase acts as data processor)Destroyed when deleted by the agency or 7 days after the agency is closedThe relevant agency only; Supabase Storage
Listing view and share statisticsVisitorsView time, listing, member ID (if any), share channelMeasuring listing performance, agency reportsLegitimate interest (Art. 5(2)(f))Views 180 days, shares 365 days (retention policy)The agency that published the listing (aggregate counts), Supabase
Cookies and analyticsAll visitorsStrictly necessary cookies (session, theme), analytics cookies (Google Analytics, anonymized IP), marketing cookiesSession continuity, usage statistics, ad conversion measurementLegitimate interest for strictly necessary cookies; explicit consent for analytics and marketingConsent record 2 years; Google Analytics data 14 monthsGoogle (only if consent is given)
Support requests and contact formVisitors, members, agency employeesFull name, e-mail, message content, category; optional attachments (screenshots, documents such as invoices); an irreversible hash of the IP address for the abuse quotaResponding to support and KVKK requests; preventing abuse of file uploadsLegal obligation (Art. 5(2)(ç)), legitimate interest2 years after the request is closed; attachments are deleted 180 days after the request is closed; IP hash 30 daysSupabase, e-mail provider
AI content generationAgency employeesProperty information and photos submitted for listing descriptions (expected not to contain personal data)Generating listing and marketing copyPerformance of a contract (Art. 5(2)(c))Generated content stays in the agency's records; not retained by the provider for training purposesGoogle Gemini API
Pre-publication listing reviewAgency employees; third parties who may appear in listing photosTitle, description and photos of a listing submitted for publicationDetecting inappropriate content and images containing personal data before publicationLegitimate interest (Art. 5(2)(f)), legal obligation (Art. 5(2)(ç))The review result (decision and a short reason) is kept until the listing is deleted; not retained by the provider for training purposesAnthropic (Claude)
AI assistant and voice inputVisitors, members, agency employeesMessages typed or spoken to the assistant and its replies; in the agency assistant, agency records read to answer. With voice input, speech is converted to text by the phone's speech recognition service; audio is not sent to or stored by EmlakBaseAnswering questions and helping with property search and agency workPerformance of a contract (Art. 5(2)(c)), legitimate interestConversations are deleted 90 days after the last message; answers to common questions without personal data are cached for a limited time; not retained by providers for training purposesAnthropic (Claude), Google Gemini API; for voice input, the device's speech recognition service (Apple/Google)
Subscription and billing informationAgency ownersAgency legal name, tax number, tax office, plan and payment recordsSubscription management and statutory invoicingLegal obligation (Art. 5(2)(ç))10 years (Tax Procedure Law)Certified public accountant, payment institution (planned)

Retention Periods

The records below are deleted automatically when the period expires (by a retention job that runs every night).

Listing view recordsVisitor view rows (statistics). Deleted at the end of the period; the listing view counter decreases.180 days
Listing share recordsShare button events (statistics).365 days
In-app notificationsNotification bell records in the panel and mobile apps.365 days
Sent e-mailsRecords with "sent" status in the e-mail queue (including content).90 days
Admin audit recordsLog of platform administrator interventions.730 days
Workflow logsTechnical logs of approval workflows (the decision history is kept separately and is not deleted).365 days
Moderation attemptsRecords of blocked-word / spam attempts.90 days
Anonymous cookie preferencesCookie consent records of non-member visitors.730 days
Data export logWho downloaded their data and when.365 days
Support request attachmentsScreenshots and documents (such as invoices) attached to the support form. Location data in images is removed before upload.180 days after closing
Support attachment quota recordsAn irreversible hash of the IP address, the number of files and their size, kept to prevent abuse.30 days
Agency business data (properties, customers, contracts, income/expenses, tasks)The agency's own data; destroyed 7 days after the agency is deleted.For the duration of the purpose
Member account, favorites, saved searchesFor as long as the membership continues; destroyed immediately when the account is deleted.For the duration of the purpose
Document approvals (Terms of Use, KVKK)Kept throughout the membership as proof of consent; deleted together with the record when the account is deleted.For the duration of the purpose
Subscription and billing information10 years, as required by tax legislation.For the duration of the purpose

Data Processors

SupabaseDatabase, authentication and file storageEU (Frankfurt)
VercelApplication hosting and CDNEU and US edge locations
Google (Analytics, Gemini)Consent-based analytics; AI content generation and assistantUS/EU
Anthropic (Claude)AI assistant in the agency panel; pre-publication listing reviewUS
ExpoMobile push notification deliveryUS
E-mail provider (SMTP)Transactional e-mail deliveryEU
Apple and Google (app stores)App distributionUS

Your Rights and How to Apply

Under Article 11 of KVKK, you have the right to access, correct, delete and port your data and to object to its processing.

  • • Members can download their data as JSON and delete their account on the My Account page.
  • • Agency owners can export agency data under Settings > Agency.
  • • For other requests, open a KVKK request; it is answered within 30 days at the latest after identity verification.