EMAAR SQUARE MALL
MOBILE APPLICATION PRIVACY NOTICE FOR THE PROCESSING AND PROTECTION OF PERSONAL DATA
As Emaar, we give utmost importance to the confidentiality and security of personal data. In that regard, with this Privacy Notice for the Processing and Protection of Personal Data (“Privacy Notice”), we would like to inform you as Emaar Libadiye Gayrimenkul Geliştirme A.Ş. (“Emaar” and/or “Company”) in our capacity as data controller about processing of your personal data in accordance with the applicable legislation (“Legislation”) including specifically Personal Data Protection Law No. 6698 (“PDPL”) and Law on the Regulation of Electronic Commerce No. 6563 (“ETK”).
Your Personal Data We Process
Pursuant to PDPL, all kinds of information relating to a real person who is identified or identifiable is defined as “personal data” and all sorts of procedures carried out on the data such as extraction, recording, storage, safe-keeping, alteration, rearrangement, disclosure, transfer, acquisition, rendering obtainable, classification and prevention of utilization of personal data by automated means or nonautomatic methods in part or in whole provided that they are part of any data recording system are called “processing of personal data”. When you use the Emaar Square Mall Mobile Application (“Mobile Application”), we may process your personal data, including your personally identifiable information, that you voluntarily choose to provide when accessing our Mobile Application. In this context, your personal data processed by Emaar is as follows::
- Identity Data (name, surname, birth date, sex)
- Contact Information (e-mail address, GSM number, address)
- Location and Transaction Security Information (your consent records, IP address, pixel tags, click flow, traffic data),
- Membership Data: Your identity and contact data, location and transaction security information,
- Financial Data: As part of Emaar Loyalty Program (“Loyalty Program”), if you upload voucher/invoice/e-archive invoice to Emaar Mobile Application in connection with your shopping at different stores of Emaar, your shopping details indicated on the voucher/invoice/earchive invoice that you uploaded and amount spent by you will be processed. Your bank details for the credit card used in your payment, last 4 digits of your credit card and credit card score details will be processed. Name/surname appearing on the credit card used for payment will be also processed to ensure accuracy of the spending.
- Vehicle Information: If you want to benefit from our valet services, your license plate number will be processed.
- Reservation Information: If you create a Reservation Form (“Form”) within the scope of a restaurant reservation request, in addition to your identity information, contact information, your reservation information and other personal data you specify in the Form will also be processed.
Purposes of Processing of your Personal Data and Legal Reason
In line with the fundamental principles set forth in PDPL, your personal data mentioned above will be processed by Emaar for the following purposes and based on your explicit consent required under article 5/1 of KVKK:
- Offering you various awards, enabling you to earn points and granting you drawing right under the campaign you will participate,
- Providing you with better services, offering various advantages, providing information about sales, marketing, and promotions, providing information about campaigns and their conditions, performing surveys and carrying out customer satisfaction researches,
- Traffic measurement, statistical and analytical analyses, profiling/segmentation procedures that will be executed for the sales and marketing activities and for providing you with the offers relating to the customized products and services through targeting and re-targeting,
- Execution of profiling and analysis activities; suggesting and introducing to you those products and services after customizing them according to your preferences, usage habits and requirements,
- If you are included in the Loyalty Program, carrying out profiling/segmentation, targeting and retargeting procedures based on the information you shared with Emaar;
- Communicating with you by using your contact data in connection with all services and products offered by Emaar (for example AVM, Aquarium, residence etc.) and providing your information and data for the purpose of making introductions and marketing through phone, SMS, e-mail and digital channels provided that you granted your consent for this,
- Planning and executing corporate communication activities,
- Receiving your reservation request and carrying out the reservation processes
- Sharing digital content online or offline.
Your personal data will be processed without your explicit consent in accordance with the basic principles stipulated in the Legislation and within the scope of Article 5/2-ç of PDPL within the scope of the legal reason “it is mandatory for the data controller to fulfill its legal obligations”, for the purpose of carrying out activities that have legal, technical and administrative consequences and to provide information to authorized institutions arising from the legislation, to carry out activities related to legal requests and legal affairs, Article 5/2-c “It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract” and Article 5/2-f, “Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person.” for the purposes of providing valet services within the scope of legal reasons, making the mobile application easier to use, carrying out development activities such as improvement and return, and execution and follow-up of financial transactions.
The Parties and Purposes of Transfer of Your Personal Data
Your personal data processed by Emaar within the scope of Article 5/2 of the PDPL, which we have explained above, may be transferred to our business partners, service providers, especially the company that provides valet service with which we have a contract, to legally authorized public institutions and authorized private persons in accordance with Article 8/2 of the PDPL.
In addition, your personal data may be processed by Emaar within the scope of the above-mentioned purposes, in accordance with Article 8/1 of the PDPL, in case of your explicit consent, may be shared with Emaar’s domestically resident individuals and institutions, suppliers, service providers, business partners and Emaar’s domestically resident group members, from whom Emaar receives service and/or consultancy for the purpose of providing the service and product or the performance of the contract and Emaar’s group companies resident in the country, Emaar employees who are representatives of the data controller, and restaurants.
Within the framework of the loyalty programs carried out by Emaar, in order to offer you various special campaigns and opportunities, your personal data will be shared with Emaar Human Resources Department, if you are an Emaar employee. If you are an Emaar office employee, it will be shared with Emaar Office Management and if you are an Emaar Residence resident, it will be shared with Emaar Residence Management in accordance with PDPL Artickle 8/1 in order to confirm your identity for the group of people you have selected on the Mobile Application registration page and to obtain approval from the institution you are affiliated with.
In addition, in line with the realization of the above-mentioned objectives and due to the global structure of Emaar, in accordance with PDPL Article 9/1, if you have your explicit consent, it may be shared with group companies resident abroad, especially Emaar Hospitality Group LLC and Emaar Properties PJSC, and with our business partners and suppliers from whom we receive services through a contract and who are obliged to confidentiality.
As our Company changes and grows, it may be restructured, we may acquire new companies, our Companies may be transferred, all or some of our Company’s assets, including its own assets, may be transferred, it may merge with new companies, or there may be divisions within our Company. As a result of such changes in the Company structure, our Company’s assets containing personal data, including the personal data of our customers, may be transferred. In case of such changes, you will be informed via e-mail, letter or public announcements in order to control your personal data in accordance with Article 10 of the PDPL, and your explicit consent will be obtained when necessary.
How We Collect Your Personal Data
Your personal data will be collected through the cookies we use if you visit our Mobile Application or if you fill out and send the form on our “Start Exploration” page via e-mails, online communication systems, customer relations management systems (CRM, SAP etc.) or with other automatic methods or by obtaining the same from the suppliers with whom Emaar has contractual relations provided that it is not contrary to the Legislation.
Notification
Where Emaar collects your personal data directly from you, we inform you about the purposes of processing and use of your collected personal data. We also provide you with options to restrict our uses and disclosures of your personal information. Our notifications are made in clear and understandable language when we request information from you. Emaar does not use or disclose this information for any purpose other than the purpose notified when it was first collected.
Your Permission and Explicit Consent
Emaar believes that explicit consent from you is one of the most important privacy principles. You have the right not to provide us with your personal data.
Emaar also obtains explicit consent to send commercial electronic messages to Emaar through all kinds of electronic communication tools, directly or indirectly, regarding general and special campaigns, advantages, product and service promotions, advertising, market research surveys and other customer satisfaction practices.
If you do not want to be included in our announcement and information list, you have the authority to access and control the commercial electronic messages sent by Emaar for notification and communication purposes. If you do not want us to communicate with you, you can use your “Cancellation” right in digital media. If you exercise your right to cancel, you will not be contacted, and marketing and promotional activities will not be carried out via electronic messages. Two different “opt-in” mechanisms are offered for you to receive electronic messages from Emaar via e-mail or SMS within the scope of promotional and marketing activities. Unless you tick the “opt-in” boxes separately to give explicit consent, your personal data will not be processed by Emaar and you will not receive any electronic messages from Emaar. For certain communications and services, we verify the express consent you have given us before we begin to provide you with the requested service. If you would like to stop receiving electronic messages from us at a later time, you can cancel your preference by clicking the “opt-out” link in each e-mail if we send you an e-mail. You can cancel via SMS by texting EMR to 4607 free of charge.
Your Rights As the Data Owner Under The PDPL
By applying to our Company in terms of your personal data processed by our Company, you are entitled to (i) find out whether your personal data is being processed, (ii) request further information about the processing, (iii) learn the purposes of processing your personal data whether your personal data is being used for the intended purpose, (iv) know the third parties to whom your personal data is transferred at home/abroad, (v) request the rectification of incomplete or inaccurate data processed, and request to inform third parties to whom your personal data is transferred, if you exercise this right, (vi) request their deletion or destruction and request that your personal data be notified to third parties to whom your personal data is transferred, if you exercise this right, (vii) object to the result about you by analyzing the information we obtain through automatic systems (viii) request indemnification of damage because to unlawful processing of your personal data.
You can forward your applications for mentioned above via sending electronic mail to kvkk@emaar.com.tr or filling in the “Emaar Turkey PDPL Application Form” where you may access on www.emaarsquaremall.com and printing out the form and sending it to our Company at Ünalan Mah. Libadiye Cad. No:82F, K:1, Üsküdar/İstanbul address, by writing “Information Request within the Scope of the Personal Data Protection Law” on the envelope. Your applications will be concluded costless, as soon as possible and in thirty days at the latest according to the qualification of your request; however, if the transaction will be required an additional cost, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Board.
Security
We are committed to the security of personally identifiable information and take all reasonable precautions to protect it. To prevent the transmission of personally identifiable information, Emaar uses SSL technology in its Mobile Application. With this technology, your personal data is encrypted before being transmitted between your computer and our servers. Although Emaar implements SSL technology, for some reasons we cannot guarantee the confidentiality of any messages sent to or from our websites or mobile applications (including email communications). We protect your personal data from unauthorized access by storing it on website servers and using reasonable technical and procedural controls.
Third Party Services
Emaar is not responsible for the disclosure of personal data by third parties with whom it cooperates for services such as security, development, maintenance, etc. of the Mobile Application and/or has a connection within the Mobile Application. Emaar does not make any warranty, undertaking or representation of any kind as to the accuracy, timeliness, quality, completeness or fitness for purpose of any information contained on such websites and cannot be held liable for any loss, damage or expense arising from such information. The presence of any third-party links does not imply endorsement or recommendation by Emaar.
Your Privacy Controls
By uninstalling the Mobile Application from your device, you can stop all information you enter into the Mobile Application from being processed, collected and stored by the Mobile Application.
If you wish to access, review, correct, change, update, store or delete personal data you have provided to Emaar through the Mobile Application (for example, the data you entered when you registered), you can access or change your Account, or use various tools in the Mobile Application.
Please note that we may need to retain some information for record keeping purposes and/or to complete transfers you initiated prior to your request for an amendment or deletion. Your request will be fulfilled after the transfers are completed.
Web Line Outage Messages
Our Mobile Application may use “pixel tags” (also called GIFs), web outage messages, and web bugs in conjunction with cookies to measure activity and/or traffic on our Mobile Application. A pixel tag is a type of web page graphic that is usually invisible because it is 1×1 pixel in size. These tags track the number of users who visit our Mobile Application and track their navigation within our Mobile Application. For example, we can use this tag when we want to statistically count the people who use our Mobile Application or which pages of our Mobile Application these users visit.
We do not use pixel tags technology to collect any personal data.
We sometimes include pixel tags in the HTML e-mail messages we send (or are sent on our behalf) to determine which e-mail messages have been opened and whether any action has been taken based on the e-mail messages. You can make certain pixel tags or web outage messages unusable by disabling the relevant cookie.
IP Addresses
An Internet Protocol (IP) address is usually a number that your Internet Service Provider automatically assigns to your computer when you connect to the Internet. Like other websites and mobile applications, Emaar may collect IP addresses to analyze aggregate visitor and Mobile Application usage information. Your IP address has no connection with the personal information you have provided. However, in accordance with regulatory requirements, Emaar reserves the right to use IP addresses to identify individuals who threaten our sites, mobile applications, services or customers.
Clickstream
“Clickstream” or “clickstream data” reflects the web pages a user visits and, more importantly, indicates the state or traffic pattern that makes a user move from one web page to another. We only track such information within our own Mobile Application; In particular, we do not track clickstream actions outside of the Emaar Mobile App.
Clickstream data does not contain or disclose any personally identifiable information about the user, nor do we compare this data with personal information you have provided.
Changes in the Privacy Notice
The Privacy Notice may be reviewed and corrected periodically. By using this Mobile Application, you understand and agree that we have the right to change this Privacy Notice and Cookie Policy without prior notice, and that we will take care to publish the changes on this page so that you can be informed about the types of information we collect, how we use it, and under what circumstances, if any, we disclose it. In our Mobile Application, we will show the last updated date of the Privacy Notice. Our advice to you is to visit our PDPL page every time you visit our Mobile Application and be informed of the changes in this way.
EXPLICIT CONSENT
I have read the Emaar Square Mall Terms & Conditions and accept its contents.
Emaar Square Mall Mobil Uygulama Kullanıcılarının Kişisel Verilerin İşlenmesi ve Korunmasına İlişkin Aydınlatma Metni’ni I have read and understood Emaar Square Mall Mobile Application Privacy Notice For The Processing And Protection Of Personal Data and in this context, I consent to the processing of my personal data for the purposes specified in the Privacy Notice, and to their sharing with the groups of people specified in the Privacy Notice, especially Emaar Group Companies resident at home and abroad, and to be transferred abroad..
In addition, I consent to be contacted and to be sent commercial electronic messages through the communication channels specified below, to provide and offer various advantages, to make announcements and information, and for promotions, promotions, advertising, sales, marketing, surveys and similar purposes.
Text (sms)
Telephone
