GUIDE PROPERTY GAYRİMENKUL TİCARET LİMİTED COMPANY

INFORMATION TEXT CONCERNİNG THE PROTECTION AND PROCESSING OF PERSONAL DATA İN SCOPE OF THE LAW NO 6698

The purpose of this information text consists of fulfilling the obligation of enlightenment brought by the 10th article of the Protection of Personal Data Law (No 6698) regarding the use of personal data obtained by sharing with the consent of third parties and/or during the use of the website with the address of “http:// www.globerry.com” which managed by Guide Property Gayrimenkul Ticaret Limited Company (Globerry).

With the services offered for real estate adverts in the categories on the website, potential buyers can reach an agreement by communicating through the secure environment offered by Globerry. Within this activity, personal data is processed in the ways specified in the information text available as a requirement for the use of Globerry's functions.

Globerry follows the agenda with its investments in technology in accordance with today's world and constantly renews itself to provide better service to its users with innovative service applications and works to provide the best service. Globerry takes the highest level of security measures possible in order to ensure that personal data is collected, stored and shared in accordance with the law and to protect its confidentiality. In order to achieve this purpose, the personal data of the Users are processed in the scope and conditions detailed below.

Globerry may update and amend these Disclosure provisions at any time by means of a new information text to be published on this site with address of https:// www.globerry.com. Updates and changes made by Globerry will be effective from the date they are published in this Site.

1. Data Controller

As GUIDE PROPERTY GAYRİMENKUL LIMITED COMPANY (hereinafter referred to as the "Company"), we inform you that we are processing your personal data as data controller within the scope of the Personal Data Protection Law No. 6698 (Turkish Legislation) (hereinafter referred to as "KVKK") and other relevant legislation.

2. Processed Personal Data

In accordance with the KVKK and other relevant legislation, your personal data consisting of your identity and contact information will be processed within the scope of the purposes and legal reasons specified in this Clarification Text. (The processed informations are ; Name-Surname, T.C. Citizenship number, T.C. Foreign number, Passport number and other passport information, nationality, place of birth, place of residence, date of birth as day, month and year, Telephone number, address, IP address, port address, all kinds of photos uploaded to the site, credit card information, bank account information, all kinds of address information, land registry information, information on real estates offered for sale, and e-mail address)

3. How is Personal Data Stored and Processed?

Your personal data we obtain may be stored in another country where Globerry or its affiliates, subsidiaries or service providers are in cooperation, at home or abroad, and may be processed in line with the purposes in this Information and in proportion to these purposes.

Your personal data collected within the scope of this Information will be processed in accordance with the provisions herein and within the scope of the legislation in force in the country where the data is stored and processed and within the scope of the foreseen security measures.

4. For What Purpose Personal Data Will Be Processed

Your personal data, will be processed within the legal reasons specified in Article 5 (2) “a) It is expressly permitted by any law”, “c) It is necessary to process the personal data of parties of a contract, provided that the processing is directly related to the execution or performance of the contract”, “ç) It is necessary for compliance with a legal obligation which the controller is subject to”, “e) It is necessary for the institution, usage, or protection of a right” of the KVKK for the purposes of informing our customers who;

Carrying out the necessary work by our business units to benefit you from the products and services offered by our company,

Recommending the products and services offered by our company to you; Planning and/or execution of market research activities for the sales and marketing of products and services,

Informing our customers who benefit from our products and services about sector developments and management of these processes.

Your personal data obtained through cookies placed on your device may be shared with third parties for the scope and purposes specified in this Information.

Globerry may transfer personal data to third parties in the country, as well as abroad, within the above-mentioned categories and purposes, limited and proportionally for these purposes.

It is accepted and declared that all kinds of contact information given by the consented person, commercial messages and calls to be sent by our company are approved.

5. To Whom and For What Purpose the Processed Personal Data Can Be Transferred

Your personal data processed by our company are not transferred to any institution, natural persons or private law legal entities. Your personal data may be shared with relevant public institutions and organizations, if necessary or in case of demand, in order to fulfill legal obligations in accordance with the relevant legislation, to respond to their requests, without seeking the explicit consent of the person concerned, pursuant to Article 8 (2) (a) of the KVKK. Your data, which can be processed in these cases, will be processed in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law No. 6698.

6. Personal Data Retention Period

Globerry will retain the personal data it obtains for the period necessary for the purpose for which the data is processed, within the framework of the conditions specified in this Information text, in order for the Users to make the best use of the Service and in order for the site to fulfill the obligations expected from it.

In addition, Globerry will keep personal data in case of any dispute that may arise, limited to the execution of administrative or judicial processes within the scope of the dispute, and during the statute of limitations determined in accordance with the relevant legislation.

7. Transfer to Abroad

Your personal data processed based on the legal reasons specified in Article 5 (2) of the KVKK are transferred abroad, as the sales and marketing activities of Globerry's products and services are carried out through online software systems whose databases are abroad. may be transferred to the following countries without obtaining the express consent of the person concerned, in accordance with the terms and conditions of:

Foreign countries declared to have adequate protection by the Personal Data Protection Board (hereinafter referred to as the "Board") ("Foreign Country with Sufficient Protection")

Foreign country and/or countries where data controllers in Turkey and in the relevant foreign country undertake adequate protection in writing and where the Board has permission for the relevant transfer (“Foreign Country where the Data Controller Undertaking Adequate Protection exists”)

The transfer of your personal data processed within the scope of the above-mentioned purposes to abroad will be carried out in accordance with the decisions taken by the Board and relevant regulations, in particular the KVKK and other relevant legislation. In this process, our Company will take the necessary care and all necessary security measures will be taken.

8. Method and Legal Reason for Personal Data Collection

Your personal data will be obtained, in order to fulfill the purposes specified in paragraph (d) of this text, by the methods which based on the legal reasons specified in Article 5 (2) of the KVKK, filling out a contact form on the website, sending an e-mail message and visiting the website in electronic environment with automatic or non-automatic way.

Globerry may share the personal data of the User and the new data obtained by using this personal data, or the personal information that the Users enter on the site with their own positive actions, in order to perform any of the purposes specified in the above processing purposes section, especially to perform the Services that the site aims to be a tool for, to improve the user experience (including improvement and personalization), to ensure the security of users, to detect and prevent fraud, to improve the Services, to carry out inquiries that may be important for the Services, to conduct operational evaluation research, to fix errors, to verify user identities, to improve performance of the system are some of the aims that may require obtained datas transfer. The shares to be made for these purposes can be made with the following;

Outsourcing service providers, business partners, suppliers, expertise and real estate consultancy firms, corporate account holders, cargo companies, law offices, research companies, call centers, software companies for complaint management and security, agencies to the extent required by the transfer while performing the Services , consulting companies, companies in the printing industry, banks for real estate sales, contracting companies for real estate projects, social media channels, third real and/or legal persons including certification bodies and authorized institutions, organizations, authorities, administrative bodies within the scope of legal obligations, judicial bodies and independent audit companies.

For the purpose of online behavioral advertising and marketing, Globerry collects usage data such as associating the behavior of the user on the site with a cookie in the browser and the number of pages viewed, duration of visit and number of target completions, even if they do not have an account. How to manage cookies is also outlined in our Cookie Policy.

9. Your Rights Under Article 11 of KVKK

You have rights as a data owner under Article 11 of the KVKK. Your requests regarding these rights in accordance with Article 11 and paragraph 1 of Article 13 of the KVKK and the Communiqué on Application Procedures and Principles to the Data Controller may be directed to us;

by personally coming to our Company at “Kışla Mah. Şehit Binbaşı Cengiz Toytunç Cad. Antelsan İşmerkezi Sitesi Antelsan İş Merkezi Blok No: 118 İç Kapı No: 401 Muratpaşa/ANTALYA″,

In order to be able to identify your identity and not to give information to the wrong people, by writing, through a notary public or by registered letter with return receipt,

(if any) by sending an e-mail to the e-mail address by using the e-mail address previously notified to our Company and registered in our systems,

or by other methods to be determined by the Board in the future.

10. Changes and Updates

This clarification text has been prepared within the scope of the Law on the Protection of Personal Data No. 6698 and other relevant legislation. Necessary changes can be made in the aforementioned disclosure text in line with the relevant legal legislation and/or changes in the Company's personal data processing purposes and policies.

The most up-to-date version of the Clarification Text can be accessed at www.globerry.com.