Turkey, Istanbul, Akasya AVM, A1 block, 21 floor, office 91
Address
Istanbul
Bodrum
Antalya coast
Contact number
Privacy Policy
1. General Provisions
1.1 This Privacy Policy is developed by NIKA ESTATE LLC 51 677 464 660 998 (hereinafter, respectively, the Policy and the Operator) to fulfill the requirements of paragraph 2, part 1, article 18.1 of the Federal Law of 27.07.2006 № 152-FZ "On Personal Data" (hereinafter, the Personal Data Law) and regulates the issues of the Operator’s processing of personal data of the Website Users.
1.2 The Policy uses terms in the sense as defined in clause 1.6 of the Policy. The Policy applies to the relations in the field of personal data processing, which have arisen for the Operator both before and after the approval of this Policy.
1.3 The Operator independently or jointly with other persons organizes processing of personal data, as well as determines the purposes of personal data processing, determines actions (operations) performed with personal data.
1.4 The Policy applies to all personal data that the Operator receives from the Website Users.
1.5 Pursuant to the requirements of Part 2, Article 18.1 of the Law on Personal Data, this Policy is published in free access in the information and telecommunication network Internet on the Website.
1.6. Basic concepts used in the Policy:
1.6.1. Personal Data — any information relating to a directly or indirectly determined or defined User of the Site;
1.6.2. Website — a set of logically connected web pages (web documents) located in the Internet at the address: nikaestate.ru;
1.6.3. User — any person who has provided information to the Operator using the Site;
1.6.4. Personal Data Information System — a set of personal data contained in databases and information technologies and technical means ensuring their processing;
1.6.5 Processing of personal data — any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation means. Processing of personal data includes, but is not limited to:
1.6.7 Dissemination of personal data — actions aimed at disclosure of personal data to an indefinite number of persons. 1.6.8. Provision of personal data — actions aimed at disclosure of personal data to an indefinite number of persons;
1.6.8. Provision of personal data — actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
1.6.9. Depersonalization of personal data — actions that make it impossible to determine, without using additional information, whether personal data belong to a particular subject of personal data. 1.6.10. Blocking of personal data — actions that make it impossible to determine whether personal data belong to a particular subject of personal data;
1.6.10. Blocking of personal data — temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data);
1.6.11. Destruction of personal data — actions, as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed;
1.6.12. Trans-border transfer of personal data — transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual or a foreign legal entity.
2. Purposes of personal data processing
2.1 Processing of personal data by the Operator is carried out for the following purposes:
2.1.1 Processing of Users' applications in order for the Operator to conclude contracts with Users;
2.1.2. Conclusion and execution of contracts with Users by the Operator;
2.1.3 Providing Users with access to information and materials contained on the Website;
2.1.4 Informing Users about goods, services, advertising and other activities of the Operator;
2.1.5 Other purposes necessary for the Operator’s compliance with the legislation on personal data.
3. Categories of processed personal data
3.1 The Operator processes the following personal data of Users:
Data you collect.
3.2 The Operator collects and processes anonymized data about visitors (including cookies) using Internet statistics and advertising services (Yandex Metric, Google Analytics and others).
3.3 The Operator does not process special categories of personal data stipulated by the Personal Data Law.
3.4 The Operator does not process biometric categories of personal data stipulated by the Personal Data Law.
4. Procedure and conditions of personal data processing
4.1 Processing of personal data is carried out by the Operator with the consent of Users to the processing of their personal data, as well as without it in cases provided by law. The User’s consent to the processing of personal data is considered to be received by the Operator from the moment the User makes a special mark in the corresponding field of the personal data collection form posted on the Website.
4.2 The Operator performs automated processing of personal data.
4.3 The Operator processes personal data in a form that allows to identify the subject of personal data for no longer than required by the purposes of personal data processing.
4.4 When the purposes of personal data processing are achieved, as well as in case the User revokes consent to their processing, the personal data shall be destroyed, except for cases provided for by law.
4.5 The Operator implements the following requirements for personal data protection:
4.5.1. requirements to observe confidentiality of personal data;
4.5.2. requirements to ensure realization by the subject of personal data of his/her rights, including the right of access to information;
4.5.3. requirements to ensure the accuracy of personal data and, where necessary, relevance to the purposes of personal data processing (with taking (ensuring the taking of) measures to delete or clarify incomplete or inaccurate data);
4.5.4. requirements for protection of personal data against unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as against other unlawful actions with regard to personal data;
4.5.5. other requirements stipulated by the legislation.
4.6 The Operator shall take the following measures necessary and sufficient to ensure fulfillment of the obligations stipulated by the legislation concerning the procedure of processing and protection of personal data:
4.6.1. appointment of the Responsible person for ensuring personal data security;
4.6.2. determination of the list of employees authorized to work with personal data;
4.6.3. approval of the present Privacy Policy concerning the issues of personal data processing, ensuring their security;
4.6.4. application of legal, organizational and technical measures to ensure personal data security, in particular:
4.6.6. familiarization of employees directly involved in personal data processing with the provisions of the Russian Federation legislation on personal data, including the requirements to personal data protection, as well as with this Policy.
4.7 The Operator has the right to transfer the User’s personal data to third parties in the following cases:
4.7.1. The User has expressed consent to such actions;
4.7.2. The transfer is necessary for the purpose of the Operator’s fulfillment of the contract concluded with the User;
4.7.3. Transmission is necessary in order to provide the User with access to certain services of the Website at his/her request;
4.7.4. Transmission is stipulated by the current legislation;
4.7.5 Transfer of personal data is carried out for statistical or other research purposes, except for the purposes specified in Article 15 of the Law on Personal Data, subject to mandatory depersonalization of personal data.
4.8 When collecting personal data of Users, the Operator shall ensure recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for the cases specified in the Law on Personal Data.
5. Procedure of interaction between Users and the Operator
5.1 Users have the right to request information from the Operator regarding the processing of their personal data. To do this, a request should be sent to the e-mail address: info@nikaestate.ru. The User’s request must contain the information stipulated in Article 14, paragraph 3 of the Personal Data Law.
5.2 Users have the right to send requests for clarification, updating of personal data, applications for withdrawal of consent to the processing of personal data to the e-mail address specified in clause 5.1 of the Policy.
1.1 This Privacy Policy is developed by NIKA ESTATE LLC 51 677 464 660 998 (hereinafter, respectively, the Policy and the Operator) to fulfill the requirements of paragraph 2, part 1, article 18.1 of the Federal Law of 27.07.2006 № 152-FZ "On Personal Data" (hereinafter, the Personal Data Law) and regulates the issues of the Operator’s processing of personal data of the Website Users.
1.2 The Policy uses terms in the sense as defined in clause 1.6 of the Policy. The Policy applies to the relations in the field of personal data processing, which have arisen for the Operator both before and after the approval of this Policy.
1.3 The Operator independently or jointly with other persons organizes processing of personal data, as well as determines the purposes of personal data processing, determines actions (operations) performed with personal data.
1.4 The Policy applies to all personal data that the Operator receives from the Website Users.
1.5 Pursuant to the requirements of Part 2, Article 18.1 of the Law on Personal Data, this Policy is published in free access in the information and telecommunication network Internet on the Website.
1.6. Basic concepts used in the Policy:
1.6.1. Personal Data — any information relating to a directly or indirectly determined or defined User of the Site;
1.6.2. Website — a set of logically connected web pages (web documents) located in the Internet at the address: nikaestate.ru;
1.6.3. User — any person who has provided information to the Operator using the Site;
1.6.4. Personal Data Information System — a set of personal data contained in databases and information technologies and technical means ensuring their processing;
1.6.5 Processing of personal data — any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation means. Processing of personal data includes, but is not limited to:
- collection;
- recording;
- systematization;
- accumulation;
- storage;
- clarification (update, change);
- extraction;
- utilization;
- transfer (distribution, provision, access);
- depersonalization;
- blocking;
- deletion;
- destruction.
1.6.7 Dissemination of personal data — actions aimed at disclosure of personal data to an indefinite number of persons. 1.6.8. Provision of personal data — actions aimed at disclosure of personal data to an indefinite number of persons;
1.6.8. Provision of personal data — actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
1.6.9. Depersonalization of personal data — actions that make it impossible to determine, without using additional information, whether personal data belong to a particular subject of personal data. 1.6.10. Blocking of personal data — actions that make it impossible to determine whether personal data belong to a particular subject of personal data;
1.6.10. Blocking of personal data — temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data);
1.6.11. Destruction of personal data — actions, as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed;
1.6.12. Trans-border transfer of personal data — transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual or a foreign legal entity.
2. Purposes of personal data processing
2.1 Processing of personal data by the Operator is carried out for the following purposes:
2.1.1 Processing of Users' applications in order for the Operator to conclude contracts with Users;
2.1.2. Conclusion and execution of contracts with Users by the Operator;
2.1.3 Providing Users with access to information and materials contained on the Website;
2.1.4 Informing Users about goods, services, advertising and other activities of the Operator;
2.1.5 Other purposes necessary for the Operator’s compliance with the legislation on personal data.
3. Categories of processed personal data
3.1 The Operator processes the following personal data of Users:
Data you collect.
3.2 The Operator collects and processes anonymized data about visitors (including cookies) using Internet statistics and advertising services (Yandex Metric, Google Analytics and others).
3.3 The Operator does not process special categories of personal data stipulated by the Personal Data Law.
3.4 The Operator does not process biometric categories of personal data stipulated by the Personal Data Law.
4. Procedure and conditions of personal data processing
4.1 Processing of personal data is carried out by the Operator with the consent of Users to the processing of their personal data, as well as without it in cases provided by law. The User’s consent to the processing of personal data is considered to be received by the Operator from the moment the User makes a special mark in the corresponding field of the personal data collection form posted on the Website.
4.2 The Operator performs automated processing of personal data.
4.3 The Operator processes personal data in a form that allows to identify the subject of personal data for no longer than required by the purposes of personal data processing.
4.4 When the purposes of personal data processing are achieved, as well as in case the User revokes consent to their processing, the personal data shall be destroyed, except for cases provided for by law.
4.5 The Operator implements the following requirements for personal data protection:
4.5.1. requirements to observe confidentiality of personal data;
4.5.2. requirements to ensure realization by the subject of personal data of his/her rights, including the right of access to information;
4.5.3. requirements to ensure the accuracy of personal data and, where necessary, relevance to the purposes of personal data processing (with taking (ensuring the taking of) measures to delete or clarify incomplete or inaccurate data);
4.5.4. requirements for protection of personal data against unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as against other unlawful actions with regard to personal data;
4.5.5. other requirements stipulated by the legislation.
4.6 The Operator shall take the following measures necessary and sufficient to ensure fulfillment of the obligations stipulated by the legislation concerning the procedure of processing and protection of personal data:
4.6.1. appointment of the Responsible person for ensuring personal data security;
4.6.2. determination of the list of employees authorized to work with personal data;
4.6.3. approval of the present Privacy Policy concerning the issues of personal data processing, ensuring their security;
4.6.4. application of legal, organizational and technical measures to ensure personal data security, in particular:
- determination of threats to the security of personal data during their processing in the Personal Data Information System;
- application of organizational and technical measures to ensure the security of personal data during their processing in the Personal Data Information System, necessary to meet the requirements to personal data protection, the execution of which ensures the levels of personal data protection established by the Government of the Russian Federation;
- application of duly approved procedures for conformity assessment of information protection means;
- establishment of rules for access to personal data processed in the Personal Data Information System;
- control over the measures taken to ensure the security of personal data and the level of protection of the Personal Data Information System;
4.6.6. familiarization of employees directly involved in personal data processing with the provisions of the Russian Federation legislation on personal data, including the requirements to personal data protection, as well as with this Policy.
4.7 The Operator has the right to transfer the User’s personal data to third parties in the following cases:
4.7.1. The User has expressed consent to such actions;
4.7.2. The transfer is necessary for the purpose of the Operator’s fulfillment of the contract concluded with the User;
4.7.3. Transmission is necessary in order to provide the User with access to certain services of the Website at his/her request;
4.7.4. Transmission is stipulated by the current legislation;
4.7.5 Transfer of personal data is carried out for statistical or other research purposes, except for the purposes specified in Article 15 of the Law on Personal Data, subject to mandatory depersonalization of personal data.
4.8 When collecting personal data of Users, the Operator shall ensure recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for the cases specified in the Law on Personal Data.
5. Procedure of interaction between Users and the Operator
5.1 Users have the right to request information from the Operator regarding the processing of their personal data. To do this, a request should be sent to the e-mail address: info@nikaestate.ru. The User’s request must contain the information stipulated in Article 14, paragraph 3 of the Personal Data Law.
5.2 Users have the right to send requests for clarification, updating of personal data, applications for withdrawal of consent to the processing of personal data to the e-mail address specified in clause 5.1 of the Policy.