KVKK notice (Turkey)

1. Data controller

The data controller with regard to our website (gayrimenkul-ai.com, immovision.ai), platform user accounts, contract, billing and support is: Der KI Flüsterer, owner Halil Aksit, Pickertstr. 45, 24143 Kiel, Germany — kontakt@derkifluesterer.de.

Real estate agencies (our customers) use the platform for their own business. With regard to the data you submit via an agency's listing, exposé or microsite, the data controller is the respective AGENCY; we process this data on the agency's behalf as data processor. Please address your requests concerning this data primarily to the respective agency; the agency's contact details are given in the legal notice of the page.

2. Personal data processed

• Identity and contact: first and last name, e-mail, telephone,
• Customer transactions: enquiry, appointment, search criteria, property of interest, messages,
• User account: role, login and device information, two-factor authentication, preferences and settings,
• Transaction security: IP address, session and transaction logs,
• Finance: subscription, credit balance, invoice and payment information (card details are held by the payment service provider),
• Visual and audio recordings: uploaded photos and videos; only with consent: chat/voice with the AI assistant, telephone call recording,
• Marketing: only with consent, subscription to push notifications.

3. Purposes of processing

• provision of the website and platform, management of user accounts,
• handling of enquiry, appointment and communication processes,
• provision of artificial intelligence functions (text, translation, image, video, voice, assistant),
• handling of contract, subscription and billing processes,
• information security, prevention of misuse and fulfilment of legal obligations,
• management of requests and complaints.

4. Legal grounds (KVKK Articles 5 and 6)

• processing being directly related to the establishment or performance of a contract (Art. 5(2)(c)),
• fulfilment of a legal obligation of the data controller (Art. 5(2)(ç)),
• establishment, exercise or protection of a right (Art. 5(2)(e)),
• legitimate interest, provided that your fundamental rights and freedoms are not harmed (Art. 5(2)(f)) — e.g. system security,
• explicit consent (Art. 5(1)) — for functions subject to consent such as the AI assistant, call recording, push notifications and map display. You can withdraw your explicit consent at any time.

5. Method of collection

Personal data is collected electronically, partly by automated means, via website forms, the platform, exposés and microsites, the AI assistant, WhatsApp/Instagram/Messenger channels, telephone and e-mail.

6. Transfer and transfer abroad (KVKK Articles 8 and 9)

Our servers are located in Germany (Hetzner Online GmbH); artificial intelligence processing takes place in European Union regions (Google Cloud Vertex AI; where necessary, Microsoft Azure OpenAI). The processing of data relating to persons in Turkey therefore constitutes a transfer abroad.

Transfers abroad are carried out in accordance with KVKK Article 9 by means of the standard contracts announced by the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu) and notification to the Board, or under the other conditions set out in Article 9.

To the extent necessary, your data may also be transferred to the following recipients: the video creation service (Shotstack, Australia), telephony and messaging services set up by the agency (Twilio, Voximplant, Meta: WhatsApp/Instagram/Messenger), the payment service provider (Stripe), services connected by the agency (e-mail/calendar, CRM, portals, İYS, e-invoice integrator) and public authorities authorised by law. List and details: Sub-processors page.

7. Retention period

Data is stored for the period required by the purpose of processing and for the statutory retention periods, and is then deleted, destroyed or anonymised. Examples: AI assistant chat history 90 days, microsite statistics 90 days, search requests 180 days after the last activity, call recordings for the period chosen by the agency (default 30 days). Details are set out in the privacy policy.

8. Your rights under KVKK Article 11

• to learn whether your personal data is processed and to request information about it,
• to learn the purpose of processing and whether the data is used in accordance with its purpose,
• to know the third parties in Turkey or abroad to whom the data is transferred,
• to request rectification if the data is incomplete or incorrectly processed,
• to request deletion or destruction within the framework of KVKK Article 7,
• to request that rectification, deletion and destruction be notified to the third parties to whom the data has been transferred,
• to object to a result to your detriment arising from analysis exclusively by automated systems,
• to claim compensation for damage if you suffer damage as a result of unlawful processing.

You can submit your applications in writing, together with information identifying you, to the address above or to kontakt@derkifluesterer.de. Applications are concluded free of charge within thirty days at the latest (Communiqué on the Procedures and Principles for Applications to the Data Controller). Please address requests concerning data processed by an agency to the respective agency; we will support you in this. If your application is rejected or you find the response insufficient, you may lodge a complaint with the Personal Data Protection Board.

9. Artificial intelligence

Artificial intelligence functions generate suggestions; artificial intelligence does not on its own make decisions about individuals that have consequences for them. Your data is not used to train artificial intelligence models. Details: AI transparency page.