1. Purpose and Scope

At Avrupakent Gayrimenkul Yatırım Ortaklığı A.Ş. ("Avrupakent GYO"), we attach great importance to the protection and privacy of the personal data of visitors to our website, www.avrupakentgyo.com.

This Cookie Policy has been prepared to inform visitors about the cookies and similar technologies used on our website and to explain their purposes, the principles governing the processing of personal data, and how visitors can manage their cookie preferences.

Personal data processing activities carried out through cookies are conducted in accordance with the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the applicable legislation.

2. What Are Cookies?

Cookies are small text files that may be stored on users' computers, tablets, or mobile devices through their browsers by the websites they visit.

Cookies may be used for purposes such as ensuring the secure and proper functioning of a website, remembering user preferences, and analyzing visitor statistics.

Data such as IP addresses, browser and device information, pages visited, session information, and interactions with the website may be processed through cookies.

3. Types of Cookies Used

Cookies used on our website are classified into two categories according to their purposes.

3.1. Strictly Necessary Cookies

Strictly necessary cookies are essential for the operation of our website's core functions, maintaining its security, and storing users' cookie preferences.

These cookies are used to ensure the proper functioning of the website and may be used without obtaining explicit consent where an appropriate legal basis is available under the applicable legislation.

Strictly necessary cookies are not used for advertising or marketing purposes.

3.2. Performance and Analytics Cookies

Performance and analytics cookies are used to analyze how frequently our website is visited, how visitors interact with its pages, and the website's overall performance.

Google Analytics 4 is used for this purpose.

The statistical information obtained is used to evaluate website usage, improve the user experience, and enhance the performance of our digital services.

Performance and analytics cookies are enabled only when visitors provide their explicit consent to this category.

4. Cookies Used on Our Website

The main cookies identified within the current technical infrastructure of our website are described below.

Some of the cookies listed above may only be used when the relevant services are enabled and the necessary technical conditions are met. Actual cookie usage and retention periods may vary depending on the service providers' settings and the technical configuration of our website.

5. Personal Data Processed Through Cookies

Depending on the type and purpose of the cookies, the following categories of data may be processed:

• IP addresses and connection information,
• Browser, operating system, and device information,
• Pages visited and visit times,
• Session and user interaction information,
• Cookie identifiers,
• Cookie preferences.

Such data is processed only for the purposes of the relevant cookie category and in accordance with the general principles set out under the KVKK.

6. Legal Bases for Processing Personal Data

Personal data processing activities carried out through strictly necessary cookies are based on the applicable legal grounds set out in Article 5(2) of the KVKK, depending on the specific processing activity.

Personal data processing activities involving performance and analytics cookies that require explicit consent are based on visitors' explicit consent pursuant to Article 5(1) of the KVKK.

Visitors are not required to accept non-essential cookies. Refusing to provide explicit consent does not prevent visitors from using the core functions of our website.

7. Transfer of Personal Data to Third Parties

Google Analytics 4 is used on our website to analyze visitor statistics.

Where visitors consent to performance and analytics cookies, certain technical data and interaction information obtained through this service may be processed by the relevant service provider.

In this context, personal data may be transferred to service providers located abroad. Any such transfer is carried out in accordance with the conditions and appropriate transfer mechanisms set out in Article 9 of the KVKK.

Further information about the service provider's data processing activities can be found in its privacy policy.

Google: https://policies.google.com/privacy

8. Managing Cookie Preferences

When you visit our website for the first time, a cookie information banner is displayed, allowing you to set your preferences regarding the use of non-essential cookies.

You can use the options provided in this banner to:

• Accept All: Allow the use of performance and analytics cookies.
• Reject All: Reject the use of non-essential cookies.
• Manage Preferences: Enable or disable performance and analytics cookies.

Strictly necessary cookies cannot be disabled through the cookie preference management tool, as they are required for the core functions of our website.

You can change your cookie preferences or withdraw your previously given explicit consent at any time by using the Cookie Settings link available on our website.

Withdrawal of explicit consent does not affect the lawfulness of processing activities carried out before such withdrawal.

You can also view, delete, or restrict cookies stored on your device through your browser settings. However, blocking strictly necessary cookies may prevent certain features of our website from functioning properly.

9. Your Rights Regarding the Protection of Personal Data

Under Article 11 of the KVKK, you have the following rights concerning your personal data:

• To learn whether your personal data is being processed,
• To request information if your personal data has been processed,
• To learn the purpose of processing and whether your personal data is used in accordance with that purpose,
• To know the third parties to whom your personal data has been transferred, whether domestically or abroad,
• To request the correction of incomplete or inaccurate personal data,
• To request the deletion or destruction of your personal data under the conditions prescribed by law,
• To request that corrections, deletions, or destruction of personal data be communicated to third parties to whom the data has been transferred,
• To object to any outcome that is detrimental to you and results exclusively from the analysis of your personal data through automated systems,
• To request compensation for damages arising from the unlawful processing of your personal data.

You may exercise these rights by submitting your requests to the data controller, Avrupakent Gayrimenkul Yatırım Ortaklığı A.Ş., in accordance with the procedures specified in the Personal Data Protection Notice and the relevant application procedures available on our website.

10. Amendments to the Cookie Policy

Avrupakent Gayrimenkul Yatırım Ortaklığı A.Ş. may update this Cookie Policy in response to changes in legislation, updates to the technologies used, or improvements to the services provided through its website.

The current version of the Cookie Policy is published on www.avrupakentgyo.com. Where material changes are made to the purposes of non-essential cookies or the scope of explicit consent, the necessary information and consent procedures will be carried out again.

Last Updated: 20 October 2026