KVKK (data protection clause)
The purpose of this information on the protection and processing of personal data ("Information") is the financial advice of CEMIL HALUK Kızılırmak ("2clicks.io") managed by https://www.2clicks.io 10 of Law No. 6698 on Protection personal data ("law") on the processing of personal data obtained during the activity of 2clicks and / or received from third parties, including the use of the website ("portal"). it is the fulfillment of the lighting obligation according to the article.
This information includes the following topics:
Identity of the person responsible,
Which personal data was collected,
Type of collection of personal data,
For what purpose is the personal data processed?
Legal basis for the processing of personal data,
Duration of storage of personal data,
To whom and for what purpose personal data can be transmitted,
Storage and security of personal data,
Other rights of the natural person whose personal data are processed ("data subject") in accordance with Article 11 of the Act,
Application process for the data controller.
1) data controller
In accordance with the law on the protection of personal data, your personal data will be collected and processed by 2Clicks, as the data controller, in the manner described in this notice.
2) Personal data collected
2Clicks collects a variety of static and dynamic data related to the methods mentioned below. The data recorded by 2clicks differ depending on the services that the data subject receives from 2clicks and the specifics of the service.
2Clicks does not collect any particularly qualified personal data about the person concerned. Personal data is data about race, ethnic origin, political thinking, philosophical belief, religious, sect or other beliefs, clothing and clothing, membership in a club, foundation or union, health, sex life, conviction and safety measures.
Which personal data is collected by 2Clicks is specified below in groups.
ID and contact information: first name, last name, mobile phone, house phone, home and business address, email address, TC identification number, login information in the identification document and other similar information.
Authentication information: member information of the contact person, passwords for authentication and access to the account, username, contact information, ad numbers.
Demographic data: date of birth, age, gender.
Usage data and favorites: including, but not limited to, data collected from the devices of the data subject through various software and technological tools., Data of the data subject indicated in the relevant questionnaire or banner to provide information about projects of the contractor about Get the portal for real estate projects, data of the data subject, priority options, preferred return method and date for the sale of real estate, answered channels, last entry in 2clicks, type of ad used, shipping method, websites visited, number of pages viewed, time of visit and number the results, search terms entered, categories of products and advertisements visited, errors in using the service and similar problems.
Location data: Location information that is obtained when the contact wants to search for ads around his own location and is allowed while using the mobile application.
Payment data: Billing data and payment information for the contact (first name, last name, billing address, TC identification number, tax identification number), invoices sent to the contact and receipt templates for payments from the contact, payment number, invoice number, invoice amount, invoice date.
Survey data: responses from those affected to periodic surveys to evaluate 2clicks products and services as well as responses from those affected to surveys of natural and legal persons with whom 2clicks cooperates.
3) Method of Collecting Your Personal Information
Your personal data are collected using the following methods :;
Data that you make available to 2clicks directly: They refer to personal data that the person concerned made available to 2clicks on their own initiative before or during the use of the services provided by 2clicks, including the portal. These personal data relate to all personal data that the data subject has transmitted directly to 2clicks. For example, first and last name, contact information, survey responses, demographic data, and content information are entered into this data. These personal data are data that are not automatically recorded by our data collection system.
Data that we receive when using the portal: it includes personal data about the usage habits of the data subject, which are received by 2clicks via certain software or technological means during the service. For example, location data, add to favorites and favorites as well as interest and usage data are entered into this data. In addition, 2Clicks assigns the behavior of the data subject who uses the portal for online behavioral advertising and marketing to a cookie in the browser and collects data based on metrics such as the number of pages displayed, visit time and number of target completions. These personal data are data that are fully or partially collected automatically.
Data from open sources: if necessary, personal data of the data subject can be collected from publicly accessible sources such as the commercial register, social media. This personal data is data that is collected in whole or in part by automated methods or not automatically as part of our data registration system.
4) Purpose of processing your personal data
The purposes of the group-based processing of the personal data collected by 2Clicks are listed below:
Purpose of processing ID and contact information:
User registration,
Recognizing the customer,
Claims tracking, collection and billing,
Customer portfolio management,
Information about promotions and events,
Risk analysis,
Complaint management,
Managing customer satisfaction processes,
Sending marketing and promotional messages
Contact person,
Implementation of operational activities,
Control and control,
Customer validation,
Implementation of sales and after-sales services,
Fraud detection and prevention.
Purpose of processing authentication information:
User registration,
Problem / error notification,
Control,
Implementation of operational activities,
Elevation,
Customer portfolio management,
Test,
Risk management,
Customer validation,
Fraud detection and prevention.
Purpose of processing demographic data:
Improvement of sales processes,
Advertising message,
Risk analysis,
Contact person,
Corporate development,
Usage data and interest recognition,
Marketing, sales, advertising ..
Usage data and purpose of the processing of favorites:
Control of user records,
Development of after-sales services,
Measuring and developing the quality of customer portfolio management,
Online behavioral advertising and marketing,
User registration,
Problem / error notification,
Control of operational activities,
Claims tracking, collection and billing,
Analysis of user interests,
Control,
Implementation and development of operational activities,
Development of after-sales services and after-sales processes,
Corporate development,
Run marketing, sales, advertising, communication, complaint management processes.
Purpose of processing location data:
Using 2clicks functions linked to or linked to the position,
Control and control,
Risk management.
Purpose of processing payment data:
Administration of the billing process,
Bookkeeping,
Claims tracking, collection and billing,
Measurement and profiling,
Customer portfolio management,
After-sales service provision,
Control and control,
Monitoring of processes with payment service providers.
Purpose of processing the survey data:
Development and evaluation of products and services,
Improvement of marketing, statistical analysis and processes in accordance with the goals of using the portal with natural and / or legal persons with whom 2clicks cooperates
5) Legal basis for the processing of personal data
The reasons for processing your personal data vary depending on the purpose of the processing. The reasons for the processing of personal data by 2Clicks are listed below. Express consent from the data subject is not sought in cases other than for reasons of express consent.
Processing based on the express consent of the data subject: customer portfolio management, information about promotions and events, sending marketing and advertising messages, communication for these purposes, identification of usage data and interests, sales, online behavioral advertising and marketing, user interest Analysis, location information, measurement and profiling, the processing of personal data with which 2clicks works with natural and / or legal persons and for the purposes of using the portal, e.g. B. for marketing, is based on the express consent of the person concerned.
2clicks processes IP information from portal visitors as a location provider in accordance with Law 5651, processes data such as immovable information and contact information in accordance with the provisions of the Ordinance on Real Estate Trading and the processing of personal data in accordance with similar legal provisions.
Processing based on the reason why it is directly related to the creation or execution of a contract: registration of users, execution of services from membership contracts and terms of use, claims tracking, collection and billing, carrying out operational activities related to the contractual performance, customer review, performance of After-sales services, tracking of processes with payment service providers as part of the contractual performance, the processing of personal data for purposes such as reporting problems / errors in connection with the contract is based on the creation and execution of the contract.
Processing of personal data for purposes such as the implementation of complaint management processes, communication for this purpose, answering inquiries from the competent authorities and authorities, the fulfillment of taxes, SGK and other legal obligations takes place on the basis of the fulfillment of the legal obligation.
The processing of personal data from open sources, such as commercial registers, social media, takes place on the basis of public law.
The processing of data for the exercise, exercise or protection of a right is mandatory: the personal data we collect are based on the reasons for establishing, using or protecting our rights in cases such as filing a lawsuit, enforcement proceedings, exercising the right to complain processed.
The processing of the data must take place in the legitimate interest of the person responsible in order not to violate the fundamental rights and freedoms of the data subject: risk analysis, improvement of sales processes, development of after-sales services, measurement and improvement of the quality of customer portfolio management, development of products and Services, statistical analysis and process improvement, fraud prevention and fraud prevention. the processing of personal data for purposes such as control and monitoring is carried out for reasons of legitimate interest.
6) Duration of storage of personal data
2Clicks will store the personal data received from it within the scope of this information and the conditions set out in the membership agreement and for the time necessary for the purposes for which they are processed.
These limits are complied with if personal data must be kept by the competent authorities and other competent authorities in compliance with statutory deadlines and for reporting and information purposes.
2Clicks can store personal data during the deadlines set in accordance with the relevant legal provisions for the implementation of administrative or legal proceedings in the context of the dispute in the event of disputes that may arise from the membership contract and / or other legal relationships with the data subject.
7) Transfer of Your Personal Data
2Clicks, the personal data of the Relevant Person and the new data obtained by using this personal data, especially to fulfill the requirements of the membership agreement and the services it provides, to improve the system performance, to improve the user experience (including improvement and personalization), to ensure the security of the users, to detect and prevent fraud, Outsourcing service providers, cargo companies, law offices, research companies, call centers, complaint management, with which we have a contractual relationship, in order to improve the services offered, to conduct operational evaluation research, to correct errors, to verify user identities, and to achieve any of the purposes specified in the above processing purposes section. software companies, agencies, consultancy companies, companies in the printing sector, banks for real estate sales of banks, contracting companies for real estate projects, social media me third real and/or legal persons, including the persons and institutions that we receive services for storing data in the cloud environment, the institutions with which we have an agreement to send the messages we send to our customers, domestic and foreign banks (including correspondent banks) with which we cooperate or receive services, financial institutions, payment institutions. and to authorized institutions, organizations, authorities, administrative and judicial bodies within the scope of legal obligations.
2Clicks will be able to 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.
8) Storage and Security of Personal Data
Necessary security measures will be taken by us in order to prevent the stored and recorded data from being lost, not falling into the hands of unauthorized persons and preventing illegal use.
2Clicks is committed to protecting personal data securely. In order to prevent the illegal processing and access of personal data and to ensure the protection of personal data, technical and administrative measures are carried out by using various methods and security technologies.
2Clicks will not disclose the personal data it obtains to anyone else in violation of this Information and the provisions of the Law on the Protection of Personal Data No. 6698, and will not use it for purposes other than processing.
In the event that personal data of the Relevant Person is shared with outsourcing service providers pursuant to this Disclosure, 2Clicks will make necessary warnings for the said outsourcing suppliers to comply with the commitments under this article.
In case of linking to other applications via 2Clicks, 2Clicks does not bear any responsibility for the protection of personal data, privacy policies and content of the linked applications.
The Relevant Person undertakes that the personal data he/she gives to 2Clicks is complete, accurate and up-to-date, and that he/she will immediately update them at [email protected] in case of any changes in this information.
9) Your Rights Under the Law
Pursuant to Article 11 of the Law; your personal data by applying to our company; To learn whether it has been processed, to request information about it if it has been processed, to learn the purpose of the processing and whether it is used in accordance with its purpose, to know the third parties to which it has been transferred in the country or abroad, to request correction if it has been processed incompletely or incorrectly, requesting the deletion or destruction of data, requesting the notification of the above-mentioned correction, deletion or destruction of the data to the third parties, objecting to the emergence of a result against you by analyzing it exclusively through automatic systems, You have the right to request removal.
10) Application Procedure to the Data Controller
Your request regarding the exercise of your above-mentioned rights, in Turkish; As the data controller, 2Clicks' Türkmen Mahallesi, Saçıkara Sokak, B-Block NO. You can send it to 21 B, 09400 Kuşadası-Aydin, Turkey by hand with documents identifying your identity, via a notary public, as an e-mail registered to [email protected] or by other methods determined by the Personal Data Protection Authority.
2Clicks reserves the right to verify your identity before replying.
In your application;
Your name, surname and, if the application is written, your signature,
For citizens of the Republic of Turkey: T.C. identification number, nationality if you are a foreigner, passport number or identification number, if any,
Your place of residence or workplace address for notification,
Your e-mail address, telephone and fax number, if any,
Your request subject,
It is obligatory to include information and documents related to the subject, if any, and must be attached to the application.
Contact details
2Clicks - CEMİL HALUK KIZILIRMAK FİNANSAL DANIŞMANLIK FAALİYETLERİ
Türkmen Mahallesi, Saçıkara Sokak, B-Block NO. 21 B, 09400 Kuşadası-Aydın, Türkiye
E-Mail: [email protected]