Privacy Notice
As ASPAKTUR Turizm Taşımacılık Sanayi ve Ticaret Limited Şirketi (Villa Direkt), the security and privacy of our valued customers' personal data is among our highest priorities. Accordingly, we provide this notice to fulfil our duty to inform under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK").
"Personal data" means any information relating to an identified or identifiable natural person. Below we explain the personal data processed by Villa Direkt, the purposes of processing, the recipient groups to whom it may be transferred, the method and legal basis of collection.
1. WHICH PERSONAL DATA DO WE PROCESS?
Persons who rent the villas (holiday homes) listed on villadirekt.damga.co are referred to as "Customer". If you make a booking through our website, the following personal data may be processed.
- Identity data: your name, surname, Turkish ID number and age information (processed only where required by law, e.g. for children or where age entails risk/illness).
- Contact data: your mobile phone number, e-mail address and postal address.
- Customer transaction data: booking and invoice details, check-in/check-out information, requests and complaints, content of reviews or questions you post, correspondence via our support channels, your IBAN, bank account numbers and payment information.
- Transaction security data: your IP address (stored in masked and encrypted/anonymised form for unique-visitor counting; raw IP is not stored), cookie information, device type, operating system and browser information.
- Marketing and analytics data: statistical data about how you use our website; pages you visit, time spent on a page, the traffic source and campaign you arrived from (UTM source/medium/campaign), the referring site, the landing page, and approximate location (country/city). Subject to your explicit consent, this data is collected via cookies and third-party measurement/advertising tools (Google Analytics, PostHog, Google Ads, Meta).
- Legal transaction data: information in correspondence with authorities, and in litigation/enforcement files.
- Audio records: your voice recording if you contact our call/support line.
- Visual records: records of your visits to Villa Direkt offices and, where present, property camera records.
2. WHAT IS THE LEGAL BASIS FOR PROCESSING?
Villa Direkt processes your personal data for the purposes below, relying on the lawful bases set out in Articles 5, 8 and 9 of the KVKK: where processing is expressly provided for by law; where it is necessary for the establishment or performance of a contract (e.g. the distance rental agreement); where it is necessary to fulfil our legal obligations; where it is necessary for the establishment, exercise or protection of a right; where it is necessary for our legitimate interests without harming your fundamental rights; and, where applicable, based on your explicit consent (for cross-border transfers and marketing/advertising communications).
3. FOR WHAT REASONS AND TO WHOM IS YOUR DATA TRANSFERRED?
To duly perform our contractual and legal obligations, your personal data may be shared, limited to what is necessary, with: property owners (to carry out rental and accommodation processes); business partners, banks, financial advisers and service providers (for invoicing, finance and accounting); call-centre/support providers; tax authorities (for tax obligations); and providers operating our IT infrastructure (including web hosting, e-mail and payment-infrastructure providers).
Analytics and advertising-measurement service providers (only subject to your explicit consent): to measure site traffic and advertising performance, improve our services and show you relevant advertising, with providers established abroad (primarily in the USA), namely Google LLC (Google Analytics and Google Ads), PostHog Inc., and Meta Platforms, Inc. (Meta/Facebook advertising and measurement). This sharing occurs only if you select "Accept all" on the cookie consent banner; it does not occur if you select "Only necessary".
Your data may also be shared with auditors, cyber-security and tax advisers, lawyers, and with regulatory/supervisory authorities, courts and enforcement offices, as required to meet our legal obligations.
Cross-border transfer: Because Villa Direkt also serves international guests in 8 languages (Turkish, English, German, Russian, French, Dutch, Polish, Arabic), where you have given explicit consent your personal data may be transferred to cloud, e-mail, analytics, advertising and payment-infrastructure providers established abroad.
4. BY WHICH PURPOSES AND METHODS IS YOUR DATA COLLECTED?
Your data is collected directly from you and automatically through the website, by electronic means, for purposes including: conducting and auditing Villa Direkt's business; performing online rental transactions and verifying the renter's identity; establishing and performing contracts; finance, accounting and invoicing; communications; statistical/strategic analysis; subject to your explicit consent, marketing and advertising and offering you suitable properties; handling requests, complaints and suggestions; after-sales support; information-security processes; ensuring legal compliance; and providing information to authorised persons and public bodies.
5. HOW DO WE PROTECT YOUR DATA?
As data controller, Villa Direkt undertakes to establish the necessary organisation and take appropriate technical measures to protect the confidentiality and integrity of your personal data, including: protecting data using current technology; restricting access to authorised staff; performing regular risk analyses and penetration tests; and applying access and authorisation controls.
6. YOUR RIGHTS
By applying to Villa Direkt using the methods in Section 8, you have the right to: learn whether your data is processed and request information; learn the purpose of processing and whether it is used accordingly; know the third parties to whom it is transferred at home or abroad; request correction of incomplete or inaccurate data; request erasure or destruction within the conditions of the KVKK; request that such actions be notified to third parties; object to results arising solely from automated analysis; and claim compensation for damages arising from unlawful processing.
7. COOKIES, ANALYTICS AND ADVERTISING-MEASUREMENT TOOLS
Our website uses cookies and similar technologies to operate the site, for anonymous visitor statistics and (subject to your explicit consent) for advertising measurement. You can set your preference via the cookie consent banner shown on first visit: "Accept all" or "Only necessary". Your preference is stored in your browser and can be reset at any time by clearing cookies. Thanks to our Google Consent Mode v2-compliant setup, analytics and advertising tools do not collect personal data or set cookies unless you consent.
Main cookies and tools used:
- Strictly necessary / functional cookies (no consent required): your cookie preference and its date (villam365_consent, villam365_consent_meta), the session key, and any affiliate/discount-code cookies. Purpose: core site functionality and remembering your preferences.
- Analytics cookies/tools (with explicit consent): Google Analytics 4 (Google LLC) and PostHog (PostHog Inc.). Purpose: anonymous visitor statistics, page-view and performance measurement. This data may be processed abroad (USA).
- Advertising / measurement cookies (with explicit consent): Google Ads (Google LLC) and Meta Pixel (Meta Platforms, Inc.). Purpose: measuring ad conversions, remarketing and showing interest-based advertising. This data may be processed abroad (USA).
Retention: visitor session records used for analytics are kept for a maximum of 90 days and then deleted automatically. Your IP addresses are stored in masked and encrypted (anonymised) form; raw IP addresses are not stored.
You can also manage your cookie preferences from your browser settings and delete existing cookies. If you reject cookies, the core functions of the site continue to work; only analytics and advertising measurement are disabled.
Server-side advertising measurement (Meta Conversions API): If you give explicit consent to advertising measurement, then in addition to the Meta Pixel in your browser, conversion events such as reservation requests, form submissions and reservation confirmations may be sent from our server directly to the Conversions API (CAPI) of Meta Platforms, Inc. (Meta/Facebook). In this method, information such as your e-mail address, phone number and first/last name is irreversibly encrypted (pseudonymised by hashing with SHA-256) before being sent to Meta; your IP address and browser information are also transmitted. The purpose is to measure advertising conversions more accurately and to improve advertising performance. This data may be processed abroad (in the USA). This sharing only takes place while your advertising-measurement consent is active; if you do not consent or you withdraw your consent, no data is sent on either the browser (Pixel) or the server (CAPI) side.
8. CONTACT FOR YOUR REQUESTS
You may submit your questions and requests regarding your personal data in writing, in accordance with the Communiqué on Application Procedures to the Data Controller, via the methods below.
- In-person written application: Bezirgan Mah. Kördere Sk. No: 673, Kaş / Antalya
- Notary: Bezirgan Mah. Kördere Sk. No: 673, Kaş / Antalya
- Registered office (post): İstiklal Mah. Cengiz Topel Cad. No: 15, Biga / Çanakkale
- E-mail (signed with secure electronic or mobile signature): [email protected]
Applicants using the "in-person written application" method must present identity documents. Please write "Personal Data Protection Law – Data Subject Request" on the envelope or in the e-mail subject.
Villa Direkt reserves the right to update this Privacy Notice at any time in line with changes in applicable legislation.