Colife Privacy PolicyLast updated: March 14, 2023

1. PREAMBLE AND REMINDER

Welcome to Colife’s Privacy Policy!

This Privacy Policy (“Privacy Policy”) sets out how we collect, use, and manage the personal information we receive from you in connection with our provision of services to you or which we collect from your use of our website https://colife.group/ (“Site”) and our other associated services. All references to “Company”, “we”, “us”, “our”, or “Colife” refer to COLIFE GAYRIMENKUL TICARET LIMITED SIRKETI, a Turkish company.

By accessing the Site or our services and/or using the Site or our services, you agree to the terms and conditions set forth in this Privacy Policy, including the collection and processing of your personal information (as defined below). If you disagree with any term provided herein, you may not use the Site.

Please note that you are not legally obligated to provide us with any personal information. You hereby acknowledge and agree that you provide us with personal information at your own free will. You hereby agree that we may collect and use such personal Information pursuant to this Privacy Policy and applicable laws and regulations.

We fully understand and respect the importance of your personal information to you, and we will adopt corresponding appropriate safety protection measures to protect your personal information in accordance with the requirements of the applicable laws and regulations.

Before using our Service, please read carefully and thoroughly understand Privacy Policy. Make sure you fully understand and agree to it before using our services.

2. ACCEPTANCE OF THIS PRIVACY POLICY

By accessing or using the Site or other Colife services, you signify acceptance of the terms of this Privacy Policy.

3. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our services, and the requirements of applicable law. This includes information you provide to us, and information that is collected about you automatically.

Information you provide to us

To use our services, we'll ask you to provide us with some important information about yourself. This information is either required by law (e.g., to verify your identity), necessary to provide the requested services, or is relevant for certain specified purposes, described in greater detail below. As we add new features and services, you may be asked to provide additional information.

We may collect the following information that you provide to us:
  • Your name, email address, telephone number, and your social network alias when you use our services;
  • Information you provide by sending us an email, contacting us with a messenger, forms, or otherwise voluntarily providing us with your personal information. Such information may include your name, date of birth, address, email address, telephone number, identifying documents, bank details, and other information obtained from your communications.

Information we collect from you automatically

To the extent permitted under the applicable law, we may collect certain information automatically, such as whenever you interact with the Site or use the services. This information helps us address customer support issues, improve the performance of our Site and services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

  • Automatic Data Collection. We may collect certain information automatically when you use our services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising, and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our services, such as pages that you visit before, during, and after using our services, information about the links you click, the types of content you interact with, and the communities that you join, the frequency and duration of your activities, and other information about how you use our services.
  • Cookies, Pixel Tags/Web Beacons, and other technologies. We may use cookies, pixel tags, local storage, and other technologies to collect information automatically through your use of our services.

4. THE REASONS FOR USING YOUR PERSONAL INFORMATION

We are going to use your personal information for the following purposes:

Provision of our services to you

  • to fulfill the obligations under contracts signed with you, as well as to provide you with the information, and services that you requested;
  • to ensure the security of our services;
  • for the administration of our Site and for internal operations, including troubleshooting, data analysis, testing, statistical data collection, and conducting surveys;
  • to support, respond and resolve your complaints and issues related to the use of our services and the capabilities of our Site;
  • to provide relevant marketing, as well as to communicate with you by providing you with information about our events, or services, that may be interesting to you.

Data analysis

Our website pages and emails may contain web beacons or pixel tags, or any other similar types of data analysis tools that allow us to track the receipt of correspondence and count the number of users that have visited our webpage or opened our correspondence. We may aggregate your personal information with the personal information of our other clients on an anonymous basis (that is, with your personal identifiers removed) so that more rigorous statistical analysis of general patterns may lead us to provide better products and services.

5. LEGAL GROUNDS FOR THE PROCESSING OF YOUR PERSONAL INFORMATION

We may process your personal information on several legal grounds, depending on the specific purpose for which we use your information:

Execution of the contract

In the event that the processing of your personal information is necessary to fulfill the obligations under contracts signed with you, as well as to provide you with the information, products, and services that you requested.

Legal obligation or public interest

In the event that we need to process your personal information in accordance with legal obligations.
The purposes of processing include the control of identity verification, the prevention of money laundering and fraud, risk control measures, and the provision of information to a competent authority, public authority, or law enforcement agency.

Services optimization

In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our services. We may also use your information to respond to your comments and questions regarding the services, and to provide you and other users with general customer service.

Your consent

In certain circumstances, we may, based on your contact details, ask you for specific permission to process personal information for specific purposes.
Your information will be processed in this way if you consent to it. If the legal basis is the consent you have given, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of the data processed prior to the withdrawal.

6. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose personal information in the following circumstances and to the following parties:

  • Other companies belonging to or directly affiliated to Colife and always in accordance with this policy.
  • Certain service providers perform a number of services on our behalf, such as web hosting, email service providers, payment processing, analytics, etc. To do so, we sometimes need to share your personal information with them for the purposes described above.
  • Certain third-parties when required by law, and when necessary to provide, and protect our services.
  • Certain third-party partners, after we receive your explicit consent. We will request your consent to share personal information about you with third parties so that they may provide you with special offers, promotional materials, and other materials that may be of interest to you.

Colife may share your personal information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so.

7. SECURITY OF YOUR PERSONAL INFORMATION

We have implemented security measures to ensure the confidentiality of your personal information and to protect it from loss, misuse, alteration, or destruction. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our services. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on our services, by mail, or by sending an email to you.

8. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

Under certain conditions, by contacting us, you can use the following rights:
  • the right to delete your personal information (all or part thereof);
  • the right to change or correct your personal information, in particular when it is incorrectly stated;
  • the right to object to us using your personal information for a particular purpose or purposes or restrict processing of your personal information;
  • the right to access your personal information;
  • the right to withdraw consent to our processing or (and) controlling your personal information.

If you would like to exercise any of these rights, please contact us as set forth in Section 16 of this Privacy Policy. We will process such requests in accordance with applicable laws.

Your exercise of these rights is subject to certain exceptions to protect the public interest (such as preventing or detecting crime) and our interests (such as maintaining legal privileges).

Our Site may contain active links from/to the websites of our partners and advertisers. If you are following an active link, please note that other websites have their own privacy policies, and we are not responsible for the provisions of these policies. Please review the privacy policies of these websites before sharing your personal information with them.

9. RIGHTS OF USERS FROM THE EU AND THE UK IN RELATION TO YOUR PERSONAL INFORMATION


“GDPR” means the European Union General Data Protection Regulation (EU) 2016/679, and the UK version. Information that you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. If you are located in the EU or the UK, you freely consent to the transfer of personal information outside of the EU and the UK. Your consent to this Privacy Policy constitutes your agreement to these transfers.

Data Controller

For the purposes of this Privacy Policy, COLIFE GAYRIMENKUL TICARET LIMITED SIRKETI is the Data Controller of your personal information.

Rights of the EU and the UK Residents

If you are accessing or using the services from within the EU or the UK, you may have the following rights under the GDPR (as well as other rights). If you wish to exercise any of these rights, you may do so by contacting us as provided in this Privacy Policy.

  • Right of Access: You have the right to obtain confirmation from us as to whether or not we process personal information from you, and you also have the right to at any time obtain access to your personal information stored by us.
  • Right to Correction of your personal information: If we process your personal information, we use reasonable measures to ensure that your personal information is accurate and up-to-date for the purposes for which your personal information was collected. If your personal information is inaccurate or incomplete, you have the right to require us to correct it.
  • Right to Deletion of your personal information or Right to Restriction of Processing: You may have the right to require us to delete your personal information or to restrict the processing of your personal information.
  • Right to Withdraw your Consent: If you have given your consent to the processing of your personal information, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on the consent before the withdrawal.
  • Right to Data Portability: You may have the right to receive the personal information concerning you and which you have provided to us in a structured, commonly used, and machine-readable format or to transmit this data to another controller.
  • Right to Object: You may have the right to object to the processing of your personal information as further specified in this Privacy Policy.
  • Right to Lodge a Complaint with the Supervisory Authority: You have the right to lodge a complaint with a data protection supervisory authority located in the European Union or the UK. Further information about how to contact your local data protection authority is available on the website of the European Commission.

If you would like to exercise any of these rights, please contact us as set forth in Section 16 of this Privacy Policy. We will process such requests in accordance with applicable laws.

10. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”).

For more details about the personal information we collect from you, please see Section 3 “PERSONAL INFORMATION WE COLLECT” above. We collect this information for the business and commercial purposes described in Section 4 “THE REASONS FOR USING YOUR PERSONAL INFORMATION” above. We share this information with the categories of third parties described in Section 6 “DISCLOSURE OF YOUR PERSONAL INFORMATION” above.

For purposes of the CCPA, we do not “sell” personal information.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us as set forth in Section 16 of this Privacy Policy.

11. RETENTION OF YOUR PERSONAL INFORMATION

Making sure your personal information is safe and secured is of the highest priority to us. We use secure storage facilities, ensuring the safeguarding of the personal information you share with us at all stages of interaction with our Site using our products and services. All appropriate measures to secure your personal information from potential hacking attacks, loss, or misuse are implemented by our team.

We will hold your personal information only for the duration you use our products and services via your account, having regard to the purposes described in this Privacy Policy as well as legal and regulatory obligations that we comply with.

Unless otherwise provided by law, you agree that we have the right, but are not required to, retain all personal information collected for the duration of your use of our services and for the period required by law, but no longer than 5 (five) years. The storage period may be extended for a period not exceeding 1 (one) year if there is a reasoned request from the competent authority.

The Company will retain your personal information for the duration of your contractual relationship with the Company and, to the extent possible, after the termination of that relationship, for as long as necessary to fulfill the purposes set out in this Privacy Policy.

We may access your personal information or retain it for a longer period if it will be subject to an official request or legal obligation, an investigation by governmental bodies or an investigation into possible violations of our Terms of Use and its essential parts, or in other cases to prevent potential harm based on our reasonable considerations.

12. CHILDREN’S INFORMATION

To register a Site account, use our Site and/or services, and accept the terms of this Privacy Policy, you must be over the age of eighteen (18) (or other age as required by local law). Without relieving you of your responsibility to comply with the terms hereof, we reserve the right (without obligation) to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using our Site without their parent or legal guardian consent.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in Section 16 of this Privacy Policy. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected unless we have a legal obligation to keep it and terminate the child’s account.

13. THIRD-PARTY WEBSITES

While using the Site, you may encounter links to third-party websites and/or services. Please be advised that such third-party websites and/or services are independent of us and may use cookies and other web-tracking technologies, not specified or otherwise handled in our Privacy Policy, to collect non-personal and/or personal information about you. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third-party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third-party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties. We have no control over using any information you provide to these third-party services.

14. UPDATES TO THIS PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page. By continuing to use our services, you agree to the changes made, so we encourage you to check this page frequently to be aware of any updates or changes to the Privacy Policy.

15. MISCELLANEOUS PROVISIONS

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of England and Wales.

This Privacy Policy was written in English and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.


16. CONTACT US

If you choose to use our services, your use and any dispute over privacy are subject to this Privacy Policy. If you have any concerns about privacy at Colife, please contact us by email at info@colife.group.