1. Introduction & Data Controller
RGY Global ("we," "our," or "us"), based in Istanbul, Türkiye, respects your privacy and is committed to protecting your personal data. This Privacy Policy explains what personal data we collect when you use our website, contact forms, WhatsApp line (including our automated WhatsApp assistant) and other communication channels; how we use, share and protect it; and the rights you have under the Turkish Personal Data Protection Law No. 6698 ("KVKK") and, where applicable, the EU General Data Protection Regulation ("GDPR").
For the purposes of KVKK and GDPR, RGY Global acts as the data controller. You can reach us at info@rgyglobal.com for any privacy-related matter.
2. Data We Collect
- Identity Data: first name, last name.
- Contact Data: email address, telephone number (including your WhatsApp number when you contact us via WhatsApp).
- Investment Preference Data: information you voluntarily share about the projects, countries, budget range and investment goals you are interested in — for example your answers to the questions asked in our contact forms or by our WhatsApp assistant.
- Communication Data: the content of messages you exchange with us via contact forms, email, telephone and WhatsApp, together with related metadata (date, time, delivery status).
- Technical Data: IP address, browser type and version, device and operating system information, pages visited and interaction data collected through cookies and similar technologies (see Section 7).
- Marketing Preference Data: your consent and opt-out choices regarding marketing communications.
We do not knowingly collect data from persons under 18 and we do not collect special categories of personal data.
3. How We Collect Your Data
- Website forms: when you fill in an information request, contact or newsletter form on our website, your data is stored in our secure database.
- WhatsApp line: when you message our WhatsApp number — whether you reach us through an advertisement, a campaign link or the WhatsApp button on this website — your number, name and message content are processed. Parts of this conversation may be handled by an automated assistant (see Section 5).
- Email and telephone: when you contact us directly.
- Cookies and analytics tools: when you browse our website, subject to your cookie preferences.
4. Purposes & Legal Bases
We process your personal data for the following purposes and on the following legal bases:
- Responding to your information requests and presenting real estate projects suited to your preferences (performance of a contract / steps prior to a contract; legitimate interest).
- Managing our customer relationships, including recording your requests in our customer relationship management (CRM) system (legitimate interest).
- Sending you campaign, project and investment updates via WhatsApp, email, SMS or telephone, where you have consented (explicit consent — you may withdraw at any time).
- Improving our website, services and campaigns through analytics (consent for non-essential cookies; legitimate interest for aggregated statistics).
- Complying with our legal obligations and establishing, exercising or defending legal claims (legal obligation; legitimate interest).
5. WhatsApp & Automated Messaging
We use WhatsApp Business services, delivered through the communication infrastructure provider Twilio Inc., to communicate with you. When you write to our WhatsApp line, your first messages may be answered by an automated assistant (chatbot) that asks a small number of questions — such as the region you are interested in, your budget range and your email address — in order to route your request to the right consultant and prepare relevant materials for you.
- By initiating a WhatsApp conversation with us, you accept that we may respond to you on the same channel regarding your request.
- Promotional (marketing) messages are only sent where you have opted in; you can opt out at any time by replying to any message (e.g. "STOP" / "İPTAL") or contacting us at info@rgyglobal.com.
- Your WhatsApp messages are also subject to WhatsApp's (Meta Platforms) and Twilio's own privacy terms, which operate independently of ours.
- Conversation summaries and the answers you provide may be recorded in our lead tracking sheets and CRM system so that a consultant can follow up with you.
8. Data Retention
We keep your personal data only for as long as necessary for the purposes described in this policy: lead and communication records are retained for the duration of our relationship and for the limitation periods required to establish or defend legal claims; data processed on the basis of consent is deleted or anonymized without undue delay after consent is withdrawn, unless another legal basis requires retention.
9. Data Security
We apply appropriate technical and organizational measures — including encrypted connections (TLS), access controls, and contractual confidentiality obligations for our processors — to protect your personal data against accidental loss, unauthorized access, alteration or disclosure. Access to your data is limited to personnel and processors who need it to perform the services described above.
10. Your Legal Rights
Under Article 11 of the KVKK (and, where applicable, the GDPR) you have the right to:
- learn whether your personal data is processed, and request information about such processing;
- learn the purpose of processing and whether the data is used in line with that purpose;
- know the third parties to whom your data is transferred, in Türkiye or abroad;
- request correction of incomplete or inaccurate data, and deletion or destruction of your data;
- request notification of such correction/deletion to third parties to whom the data was transferred;
- object to results produced exclusively by automated analysis of your data;
- claim compensation for damages arising from unlawful processing;
- withdraw your consent at any time, with effect for the future.
To exercise these rights, email us at info@rgyglobal.com. We will respond as soon as possible and in any case within the period required by law (30 days under KVKK).
11. Changes to This Policy
We may update this Privacy Policy from time to time. The current version is always available on this page together with its "last updated" date. Material changes will be highlighted on the website.
12. Contact Us
For any questions about this policy or our privacy practices: RGY Global, Istanbul, Türkiye — info@rgyglobal.com — +90 549 513 13 28.