GDPR Privacy Notice - Emlivo Data Protection Policy

Last updated: October 10, 2026

Under Article 10 of the Turkish Personal Data Protection Law No. 6698 (KVKK) and the related Communiqué, this notice explains why, on what legal basis and how we process your personal data. Data controller: Muherrem Batuhan Durmaz · Address: Caferağa Mah. Şifa Sk. No: 19, Kadıköy / İstanbul, Türkiye · Email: [email protected]

1. Whose data we process

•Members: real estate agents, agencies and property owners who open an Emlivo account.
•Form submitters: people who fill in the property sale request, listing offer, viewing appointment, contact and service quote forms.
•Profile visitors: people who use the AI chat on agent profiles.
•Support assistant users: visitors and members who chat with Emlivo Assistant on the Emlivo website and app.
•People who send an enquiry by email: people who contact an agent through a listing site, where the agent forwards the enquiry notification to their own Emlivo address. The agent is the data controller for this data; Emlivo processes it only on the agent's behalf and instructions.
•Agents' clients: client, tenant, dues payer and owner details that members enter for their own business. The agent is the data controller for this data; Emlivo processes it only on the agent's behalf and instructions (see Data Processing Terms).

2. What data we process

•Identity and contact: name, email, phone, company and title, profile photo.
•Professional details: licence details, listing verification number, brand colour and profile content.
•Listings and content: listing details, address and location, uploaded photos and videos, generated images, videos, audio and copy.
•Tax reporting details: the name or company name and Turkish ID or tax number of the agent sharing a listing and, if different, the property owner; publication events of the listing.
•Listing verification (EİDS) details: the name verified through e-Devlet, the user code issued by the Ministry of Trade, the tax number when acting for a company, the verified mobile number; the property number of the listed property and the province, district, neighbourhood, block, parcel and authorisation period from the title deed record.
•Requests and messages: what you write in forms, offer and appointment details, chat messages, your conversations with Emlivo Assistant, the ratings you give to its answers and the name, email and phone you share for a support request.
•Listing reports: when you report a listing, your name, email, optional phone, the reason and your description. Your identity is not shared with the advertiser.
•Email enquiries: the sender address, subject and text of enquiry notifications an agent forwards to their own Emlivo address; the name, phone, email, listing number and message extracted from that text.
•Connected accounts: basic details, messages and comments of Instagram and YouTube accounts you choose to connect.
•Security: IP address, browser details, session and activity logs, records of the consents you give.
•Payments: records of subscription and credit transactions. Card details are never seen or stored by Emlivo.

3. How we collect data

•Directly from you through sign-up, profile, listing creation and site forms; from accounts you connect, with your authorisation; from enquiry notification emails agents forward to their own Emlivo address; automatically through cookies and server logs while you use the site.

4. Purposes and legal bases

•Opening your account, providing the service, generating content, subscriptions and payments: performance of a contract (KVKK Art. 5/2-c).
•Answering support requests and service notices: performance of a contract and legitimate interest (Art. 5/2-c, 5/2-f).
•Answering Emlivo Assistant chats, forwarding them to the support team when needed and reviewing them to improve answers: legitimate interest (Art. 5/2-f). Answers added to the knowledge base from chats contain no personal data.
•Reporting online listings to the Turkish Revenue Administration, invoicing and official requests: legal obligation (Art. 5/2-ç).
•Verifying the advertiser identity and the listing authorisation for the property through the Ministry of Trade Electronic Listing Verification System (EİDS), showing the title deed details on the listing and unpublishing listings whose authorisation has ended: legal obligation (Art. 5/2-ç; Regulation on Real Estate Trade).
•Service security, preventing abuse and fake accounts, keeping consent records: legitimate interest and establishing or defending legal claims (Art. 5/2-e, 5/2-f).
•Reviewing reports about listings, removing unlawful content and informing the reporter of the outcome: legal obligation and legitimate interest (Art. 5/2-ç, 5/2-f).
•Showing enquiry notifications an agent forwards in a review inbox and turning them into a client record if the agent approves: Emlivo does this as a data processor on the agent's instructions (see Data Processing Terms). No notification becomes a client record without the agent's approval.
•Sharing property sale, offer and appointment form details with the relevant agent: explicit consent (Art. 5/1), see Explicit Consent.
•Marketing messages: explicit consent and commercial electronic message consent under Law No. 6563, see Commercial Message Consent.
•Using content you create as examples in our marketing: explicit consent, see Media Use Consent.
•Measuring site use and advertising performance with cookies and similar technologies: your explicit consent (Art. 5/1), except for necessary cookies; details and your choices are in the Cookie Policy.

5. Who we share data with

•Infrastructure providers we use to run the service (hosting, database and file storage, email delivery and receipt, SMS delivery, payments, AI content generation, map data, social media connections), only as far as each task requires. The current list is in the Privacy Policy.
•The relevant real estate agent, with your explicit consent, for property sale, offer and appointment forms.
•Tax reporting details to the Turkish Revenue Administration as required by law, and to other authorities on lawful request.
•For listing verification, your verified phone number, your tax number where applicable and the property number of the listed property, to the Ministry of Trade as required by law.
•We never sell your data for marketing.

6. International transfers

•Our database and file storage run on servers in the European Union (Germany); some hosting, email, payment and AI services are provided by providers abroad.
•These transfers are made within the appropriate safeguards set out in Article 9 of KVKK and are limited to the data needed to provide the service.

7. Retention

•Account data is kept while you are a member and then for the applicable limitation periods.
•Tax, invoice and listing reporting records are kept for the period required by law (at least five years under the Tax Procedure Law).
•Form requests are kept until their purpose ends; consent and withdrawal records are kept as evidence for the applicable limitation periods.
•Emlivo Assistant chats are kept for 12 months after the last message; chats that became a support request are kept for 12 months after the request is closed.
•Listing report records are kept for two years after the report is closed.
•Email enquiry notifications are kept for 90 days after they are received; the text of a notification the agent marks as "not an enquiry" is deleted immediately. Details turned into a client record stay in the agent's client record.
•Expired data is deleted, destroyed or anonymised.

8. Your rights (KVKK Art. 11)

•Learn whether your personal data is processed.
•Request information about processing.
•Learn the purpose of processing and whether it is used accordingly.
•Know the third parties it is transferred to in Türkiye or abroad.
•Request correction of incomplete or inaccurate data.
•Request deletion or destruction under the conditions of KVKK Art. 7.
•Request that corrections and deletions are notified to the third parties the data was transferred to.
•Object to a result against you arising solely from automated analysis.
•Claim compensation for damage caused by unlawful processing.

9. How to apply

•Send your request with details that verify your identity to [email protected] from the email address registered with us, or in writing to Caferağa Mah. Şifa Sk. No: 19, Kadıköy / İstanbul, Türkiye.
•We answer free of charge within thirty days at the latest; if the request requires additional cost, the fee set by the Personal Data Protection Board may apply.
•Requests about data held by an agent about their clients should first go to that agent; we forward such requests to the agent concerned.

Contact: [email protected]