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Data Processing Agreement

Obligations of the parties as data controller and data processor for personal data that Listonya customers process through their panels and websites.

This translation is provided for information. In case of any conflict, the Turkish version prevails.

This agreement forms an integral part of the Listonya Subscription Agreement. For personal data processed through the Listonya management panel, mobile app and the customer's website, the Customer is the data controller and Listonya ("Listonya") is the data processor processing such data only on the Customer's behalf and instructions (KVKK Art. 3 and 12).

1. Scope

  • Data subjects: the Customer's employees and users, property and vehicle owners, prospective buyers and tenants, website visitors and contact form senders.
  • Data categories: identity, contact, listing and portfolio information, request content, user activity records.
  • Processing: hosting, storage, backup, display, publication on the website, sending notifications (e-mail/SMS/WhatsApp) and other technical operations required by the service.

2. Listonya's obligations

  1. Process personal data only to provide the service and on the Customer's documented instructions; never use it for its own purposes, sell it or share it with third parties.
  2. Keep the data in a database dedicated to the Customer, logically separated from other customers.
  3. Take appropriate technical and organisational measures under KVKK Art. 12: encrypted communication, permission checks, access logs, backups and staff confidentiality.
  4. Use sub-processors (hosting, e-mail, SMS, WhatsApp business platform, etc.) only under obligations at least as protective as this agreement.
  5. Inform the Customer without delay of any data breach and support the Customer's notification obligations.
  6. Provide reasonable technical support for data subject requests and forward requests received directly.
  7. On termination, upon the Customer's request deliver the data in a reasonable format, and delete or anonymise it subject to statutory retention obligations.

3. Customer's obligations

  1. Fulfil its own data controller obligations (privacy notices, consent where required, VERBİS registration, data subject requests) and publish its own privacy notice on its website.
  2. Enter only lawfully obtained data and obtain the permissions needed to publish owners' and persons' images and information.
  3. Manage user accounts and permissions and revoke access of departing employees.
  4. Avoid including personal data (such as the owner's name and phone) in listings shared in the listing pool.

4. Information

Listonya provides information demonstrating compliance with this agreement upon the Customer's reasonable request.

5. Term

This agreement remains in force for the term of the Subscription Agreement; confidentiality obligations survive termination.