Privacy Policy

This Privacy Policy explains how Model Property Lab collects, uses, shares and protects personal data when you visit modelpropertylab.com (the "Website") or use our property exchange, brokerage and advisory services (the "Services"). We are committed to handling your personal data in accordance with the Turkish Law on the Protection of Personal Data No. 6698 ("KVKK") and, where it applies to you, the EU General Data Protection Regulation 2016/679 ("GDPR").

1. Who we are (Data Controller)
The controller responsible for your personal data is:
Model Gayrimenkul Yatırım İnşaat Ticaret ve Pazarlama Hizmetleri Limited Şirketi
Gürsu Mah. Atatürk Bulvarı 187C Daire:2, Konyaaltı, Antalya, Türkiye
Trade Registry / MERSIS No: 0751004884300011
Email: diloram.ocakli [at] modelpropertylab.com
Website: modelpropertylab.com
We also operate through an affiliated company in Germany. Where your data is processed in connection with our European operations, that entity may act as a joint or independent controller.

2. What personal data we collect
We collect the following categories of personal data:

• Data you provide through our contact / intake form: your name, email address, telephone number, and any information you choose to share about your property, your investment criteria or your service request.
• Communications data: the content of messages you send us by email, WhatsApp, Telegram, telephone or other channels, and our correspondence with you.
• Transaction and due-diligence data: where you proceed with our Services, information about the relevant properties, ownership, financial terms and, where legally required, identification documents for compliance checks.
• Technical and usage data: IP address, device and browser type, pages viewed, referring URLs and similar information collected automatically through cookies and analytics tools when you use the Website.

You are not legally obliged to provide your personal data, but if you do not, we may be unable to respond to your enquiry or provide the Services.

3. How and why we use your data (purposes and legal bases)

4. Cookies and analytics
The Website is built on the Tilda platform and uses cookies and similar technologies. Strictly necessary cookies keep the site working; analytics and performance cookies help us understand how the Website is used. Non-essential cookies are only set with your consent, which you can give or withdraw through the cookie banner or your browser settings.

5. Who we share your data with
We do not sell your personal data. We may share it with:

• Service providers who process data on our behalf, such as our website host (Tilda), email and communication providers, and IT and analytics providers, under appropriate data-processing agreements.
• Professional advisors — lawyers, notaries, tax advisors and other parties involved in a transaction — where necessary to deliver the Services.
• Counterparties to a potential exchange, only to the extent needed to evaluate or complete a transaction and on a need-to-know basis.
• Authorities where we are required to do so by law.

6. International transfers
Because we operate between Turkey and Europe, your data may be transferred between Turkey, the European Economic Area and the countries where our service providers are located. Where data is transferred out of the EEA or out of Turkey, we rely on an adequacy decision or appropriate safeguards (such as the European Commission's Standard Contractual Clauses, or explicit consent / the conditions set out in KVKK Article 9) to protect it.

7. How long we keep your data
We keep personal data only for as long as necessary for the purposes set out above, and then for any additional period required by law (for example, Turkish tax and commercial record-keeping obligations, generally up to 10 years for transaction records). Enquiries that do not result in an engagement are kept for a shorter period and then deleted or anonymised.

8. Your rights
Subject to applicable law, you have the right to:

• be informed about, and request access to, the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request erasure of your data ("right to be forgotten");
• request restriction of, or object to, processing;
• request data portability;
• withdraw consent at any time, without affecting prior processing;
• under KVKK Article 11, learn whether your data is processed, request information about the processing, and request that any third parties to whom data has been transferred are notified of corrections or deletions.

To exercise any of these rights, contact us at diloram.ocakli [at] modelpropertylab.com. We will respond within the timeframes set by KVKK (30 days) and the GDPR (one month).

9. Complaints
If you are in Turkey, you may lodge a complaint with the Turkish Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu — KVKK). If you are in the EU/EEA, you may lodge a complaint with your local data protection supervisory authority. We would, however, appreciate the chance to address your concerns first.

10. Data security
We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration. No method of transmission over the internet is completely secure, so we cannot guarantee absolute security.

11. Changes to this Policy
We may update this Privacy Policy from time to time. The current version is always available on the Website, and the "Last updated" date above indicates when it was last revised.

12. Contact
For any question about this Policy or your personal data, contact us at diloram.ocakli [at] modelpropertylab.com or by post at the address in Section 1.