Homes Gravity Privacy Policy

Effective Date: 23 August 2026
Last Updated: 23 August 2026

This Homes Gravity Privacy Policy explains how Homes Gravity collects, uses, stores, shares and protects personal data when you:

  • visit our website;
  • contact us;
  • submit a property enquiry;
  • request project or developer information;
  • communicate with our team;
  • attend a property viewing;
  • use our real estate services;
  • subscribe to marketing communications;
  • enter or consider an international property transaction.

We believe property buyers should understand what happens to their personal information just as clearly as they should understand what happens to their money.

1. Who Is Responsible for Your Personal Data?

The data controller responsible for personal data processed through Homes Gravity is:

GRAVİTY İNŞAAT EMLAK GEMİ TURİZM SANAYİ VE TİCARET LİMİTED ŞİRKETİ

Trade Registry Number: 480371, Ankara Chamber of Commerce
Tax Identification Number: 4111056150, Doğanbey Tax Office
Registered Office: Beytepe Mah. Kanuni Sultan Süleyman Blv. No: 93 B İç Kapı No: 27 Çankaya, Ankara, Türkiye
Website: https://homesgravity.com/

Contact emails include:

In this Privacy Policy, “Homes Gravity,” “we,” “us” and “our” refer to the company identified above.

2. Which Data Protection Laws Apply?

Homes Gravity is established in Türkiye and processes personal data primarily under Law No. 6698 on the Protection of Personal Data, commonly known as the KVKK.

Official information about Turkish personal-data protection law is available through the Personal Data Protection Authority.

Because Homes Gravity provides international property information and may communicate with people living in different countries, additional privacy laws may apply to particular processing activities depending on:

  • where you live;
  • where our services are offered;
  • how your information is collected;
  • the nature of the processing.

Where legislation such as the EU General Data Protection Regulation (GDPR) or another mandatory data-protection law applies to a particular individual or processing activity, we will respect the applicable rights and obligations.

This Policy should therefore be read together with any additional privacy notice provided for a specific service where necessary.

3. What Personal Data May We Collect?

The information we collect depends on how you interact with Homes Gravity.

Identity Information

This may include:

  • name;
  • surname;
  • nationality;
  • date of birth where necessary;
  • passport or identification information where required for a transaction;
  • tax identification information where legally necessary.

We do not normally need detailed identification documents merely because someone reads our website or asks a general property question.

More extensive identification information may become necessary if you proceed toward an actual transaction.

Contact Information

This may include:

  • email address;
  • telephone number;
  • WhatsApp or messaging contact;
  • country of residence;
  • postal address where required.

Property Enquiry Information

When you contact Homes Gravity about property, we may collect information such as:

  • preferred country;
  • preferred city or location;
  • property type;
  • approximate budget;
  • preferred number of bedrooms;
  • intended purchase timeline;
  • whether you are buying for living, holiday use, retirement, investment or another purpose;
  • preferred payment structure;
  • properties or developments you have requested information about.

This helps us avoid the rather pointless exercise of recommending everything to everyone.

Communication Records

We may retain records of communications including:

  • emails;
  • contact forms;
  • WhatsApp or other messaging conversations;
  • meeting notes;
  • viewing records;
  • telephone call notes;
  • video-meeting information;
  • customer-service correspondence.

These records may help us:

  • respond to enquiries;
  • understand preferences;
  • maintain transaction history;
  • provide follow-up support;
  • establish which properties or projects were introduced by Homes Gravity;
  • resolve disputes.

Transaction Information

If you proceed toward a property purchase, we may process information concerning:

  • selected property;
  • developer or seller;
  • reservation;
  • purchase price;
  • payment plan;
  • payment status information;
  • transaction stage;
  • lawyers or professional advisers involved;
  • relevant contractual communications.

Homes Gravity does not necessarily receive or store all documentation used by lawyers, banks or developers.

Financial and Source-of-Funds Information

Property transactions may require information concerning:

  • financing;
  • mortgage requirements;
  • source of funds;
  • payment ability;
  • bank-related documentation;
  • proof of funds.

We collect or receive this information only where reasonably necessary for the service, compliance or transaction.

Unless expressly agreed otherwise, Homes Gravity does not act as your bank or escrow provider and does not normally hold your property purchase funds.

Residency or Immigration Information

Where you ask about property connected with residence or citizenship programmes, information may include:

  • nationality;
  • current country of residence;
  • family members included in an application;
  • intended residence route;
  • relevant investment information.

Detailed immigration applications should generally be handled by the appropriate licensed or authorised professional.

Technical and Website Information

When you use our website, technical information may include:

  • IP address;
  • browser type;
  • device type;
  • operating system;
  • pages visited;
  • referring website;
  • approximate geographic information derived from IP address;
  • interaction information;
  • cookie identifiers;
  • website security logs.

Some of this information may be collected automatically.

4. How Do We Collect Personal Data?

We may collect information:

Directly From You

For example, when you:

  • submit an enquiry;
  • email us;
  • call us;
  • message us;
  • request a brochure;
  • request a property recommendation;
  • arrange a viewing;
  • attend a meeting;
  • start a transaction.

Through Our Website

Information may be collected through:

  • enquiry forms;
  • contact forms;
  • subscription forms;
  • cookies;
  • security technologies;
  • analytics technologies where used.

Through Property Portals and Advertising Platforms

If you submit an enquiry through a third-party property portal, social-media platform or advertising service concerning a Homes Gravity property or campaign, that platform may transmit the information you provided to us.

The third-party platform remains responsible for its own independent processing under its privacy terms.

Through Developers, Sellers or Partners

In some cases, we may receive information from:

  • developers;
  • sellers;
  • partner agencies;
  • referral partners;
  • professional advisers;

where this is necessary for a property enquiry or transaction and the sharing is lawful.

From Public Sources

Where reasonably necessary for business or due-diligence purposes, information may come from legitimate public sources such as:

  • corporate registries;
  • professional registries;
  • government databases;
  • public business websites.

5. Why Do We Process Personal Data?

Homes Gravity processes personal information for specific business and legal purposes.

These may include:

Responding to Enquiries

To:

  • respond to your questions;
  • understand what you are looking for;
  • provide relevant property information.

Providing Property Recommendations

To compare your requirements with available:

  • countries;
  • locations;
  • properties;
  • projects;
  • payment plans.

Providing Real Estate Services

To:

  • introduce properties;
  • arrange viewings;
  • introduce developers or sellers;
  • communicate offers;
  • coordinate negotiations;
  • support reservations;
  • coordinate parts of a transaction.

Managing Our Client Relationship

To maintain reasonable records concerning:

  • enquiries;
  • projects introduced;
  • communications;
  • preferences;
  • transaction status.

Protecting Legitimate Business Interests

Records may be used where reasonably necessary to establish:

  • when a project was introduced;
  • what information was provided;
  • transaction history;
  • commission entitlement;
  • contractual rights;
  • defence or establishment of legal claims.

This relates particularly to the introduction and non-circumvention provisions described in our Terms and Conditions.

Legal and Regulatory Compliance

We may process information where necessary for:

  • legal obligations;
  • tax requirements;
  • accounting;
  • anti-money-laundering controls;
  • sanctions compliance;
  • fraud prevention;
  • lawful requests from authorities;
  • establishment or defence of legal rights.

Website Security

Technical information may be processed to:

  • protect the website;
  • identify suspicious activity;
  • prevent abuse;
  • diagnose technical problems.

Website Improvement and Analytics

Where legally permitted, we may use data to understand:

  • website traffic;
  • popular content;
  • visitor behaviour;
  • website performance.

Where applicable law requires consent for analytics technologies, they should be activated only after the required consent has been obtained.

Marketing

Where permitted by law, we may communicate relevant:

  • property opportunities;
  • market updates;
  • new projects;
  • educational content;
  • Homes Gravity news.

Where consent is legally required, marketing will be based on that consent.

You can withdraw marketing consent or unsubscribe from ordinary marketing communications.

6. What Is Our Legal Basis for Processing?

We do not rely on one legal basis for every activity.

Depending on the circumstances and applicable law, processing may be based on:

Steps Requested Before a Contract

For example, when you ask us to:

  • find a property;
  • arrange a viewing;
  • provide project information;
  • help prepare a transaction.

Performance of a Contract

Where processing is necessary to provide an agreed Homes Gravity service.

Legal Obligation

Where information must be processed because of:

  • tax;
  • accounting;
  • regulatory;
  • court;
  • government;
  • anti-money-laundering;

requirements.

Legitimate Interests

Where legally permitted, processing may be necessary for legitimate business interests such as:

  • responding to clients;
  • maintaining business records;
  • preventing fraud;
  • protecting network security;
  • establishing introductions;
  • managing disputes;
  • protecting legal rights.

We consider whether these interests are overridden by the rights and freedoms of the person concerned.

Consent

Consent may be used where required, including for certain:

  • marketing communications;
  • non-essential cookies;
  • particular data transfers;
  • other processing where consent is the appropriate legal basis.

Where processing depends on consent, you may withdraw it.

Withdrawal does not generally make processing that occurred lawfully before withdrawal unlawful.

7. Sensitive Personal Data

Homes Gravity does not seek sensitive or special-category personal information unless it is genuinely necessary.

Depending on the transaction or service, certain sensitive information might occasionally become relevant.

Where this occurs, we process it only where an appropriate legal condition exists and with suitable safeguards.

Please do not send unnecessary:

  • medical information;
  • biometric information;
  • religious information;
  • political information;
  • other highly sensitive information;

through ordinary property enquiry forms.

If such information becomes relevant to an immigration or legal process, it may be more appropriate to provide it directly to the qualified professional handling that process.

8. Who May Receive Your Personal Data?

Personal information is not automatically shared with every company we work with.

Depending on your request, relevant information may be shared with:

Developers and Sellers

Where necessary to:

  • confirm availability;
  • negotiate;
  • arrange a viewing;
  • reserve a property;
  • proceed with a transaction.

Partner Real Estate Agencies

Where a property or country is handled with a legitimate local brokerage partner.

Lawyers and Other Professional Advisers

Where you ask us to coordinate or introduce professionals such as:

  • lawyers;
  • tax advisers;
  • accountants;
  • surveyors;
  • engineers;
  • immigration advisers.

Banks and Finance Providers

Where you specifically request financing or banking assistance.

Property Managers

Where rental or after-sales management is requested.

Technology and Service Providers

We may use service providers supporting:

  • website hosting;
  • email;
  • customer relationship management;
  • communications;
  • analytics;
  • cybersecurity;
  • data storage;
  • document management;
  • advertising.

These providers should receive only information reasonably necessary for their role and are subject to applicable contractual and legal obligations.

Government or Regulatory Authorities

Information may be disclosed where lawfully required by:

  • courts;
  • tax authorities;
  • regulators;
  • law-enforcement authorities;
  • other authorised public bodies.

9. International Transfers of Personal Data

Homes Gravity works internationally.

Some of the organisations or technology services involved in our operations may therefore process data outside Türkiye.

Examples can include:

  • international email services;
  • cloud hosting;
  • CRM platforms;
  • messaging providers;
  • analytics systems;
  • advertising platforms;
  • foreign developers;
  • overseas professional advisers.

International transfer does not mean personal data can simply be sent anywhere because it is convenient.

Article 9 of Türkiye’s Personal Data Protection Law regulates transfers of personal data abroad.

The current framework allows international transfers where the required legal conditions are satisfied, including mechanisms such as:

  • an applicable adequacy decision;
  • appropriate safeguards;
  • standard contractual clauses;
  • binding corporate rules;
  • other legally recognised transfer mechanisms;
  • limited statutory exceptions where applicable.

Current official information is available through the KVKK guidance on international data transfers.

Where another privacy law such as the GDPR also applies, we will use a legally recognised transfer mechanism where required under that law.

10. Communication Through WhatsApp and Similar Services

Clients often choose to communicate with Homes Gravity through messaging services because property buyers, astonishingly, tend to prefer receiving photographs on their phones rather than by registered post.

Where you choose to communicate using:

  • WhatsApp;
  • another messaging application;
  • social-media messaging;

the platform provider may independently process information under its own privacy policy and may process data internationally.

Homes Gravity controls how we use the information we receive, but we do not control the independent operation of third-party communication platforms.

For particularly sensitive documents, we may recommend a more appropriate communication method.

11. Email Communications

When you communicate with Homes Gravity by email, we may retain:

  • sender and recipient information;
  • message content;
  • attachments;
  • timestamps;
  • related transaction history.

Email correspondence may be retained where reasonably necessary for:

  • client service;
  • transaction management;
  • legal compliance;
  • protection of contractual rights.

12. Cookies

Cookies are small files or identifiers used by websites for purposes such as:

  • basic website operation;
  • security;
  • remembering preferences;
  • analytics;
  • advertising.

Strictly Necessary Cookies

Some cookies may be necessary for the website to:

  • function;
  • remain secure;
  • remember essential settings.

Where a cookie is genuinely necessary for the service requested by the user and another valid legal basis exists, consent may not always be required.

Analytics and Performance Cookies

These technologies may help us understand:

  • visitor numbers;
  • page performance;
  • navigation behaviour;
  • website usage.

Advertising and Marketing Cookies

Where used, these may help:

  • measure campaigns;
  • understand advertising performance;
  • show more relevant advertising.

Where applicable law requires consent for non-essential cookies, Homes Gravity will seek the appropriate consent before activating them.

The Turkish Personal Data Protection Board has specifically addressed the distinction between strictly necessary cookies and non-essential analytics, performance and advertising cookies.

Users should be able to exercise the cookie choices required by applicable law.

13. Google, Meta and Other Third-Party Technologies

Homes Gravity may use third-party technologies in connection with:

  • website analytics;
  • advertising;
  • enquiry attribution;
  • social-media campaigns;
  • website performance.

Depending on our current website configuration, providers may include companies such as Google or Meta.

These providers may process certain information independently according to their own privacy documentation.

Where consent is legally required for the relevant technology, we will seek to operate it on that basis.

This Privacy Policy does not replace the privacy notices of independent third-party platforms.

14. Marketing Communications

If you have requested information or agreed to receive marketing, we may contact you about relevant:

  • properties;
  • projects;
  • market information;
  • country guides;
  • investment opportunities;
  • Homes Gravity services.

You may request that ordinary marketing communications stop.

You can:

  • use an unsubscribe mechanism where available;
  • reply asking us to stop;
  • contact us directly.

Opting out of marketing does not necessarily prevent communication that is required for:

  • an active property transaction;
  • a service you requested;
  • contractual administration;
  • legal obligations.

15. How Long Do We Keep Personal Data?

We do not intend to keep every piece of personal information forever simply because storage space has become cheap.

Retention depends on why the information was collected.

Factors can include:

  • duration of the client relationship;
  • whether a transaction occurred;
  • contractual requirements;
  • tax and accounting rules;
  • legal limitation periods;
  • regulatory requirements;
  • potential disputes;
  • consent status;
  • whether the information remains necessary.

For example, a simple enquiry that never progresses may not need to be retained for the same period as documentation concerning a completed property transaction.

Information required to:

  • comply with law;
  • establish contractual rights;
  • defend legal claims;
  • meet accounting requirements;

may need to remain stored after the active client relationship ends.

When personal information is no longer required and no legal basis requires continued retention, it should be deleted, destroyed or anonymised as appropriate.

16. Property Introduction Records

Homes Gravity may retain reasonable records showing:

  • which projects were introduced;
  • when the introduction occurred;
  • correspondence concerning that project;
  • viewings;
  • negotiations.

These records may be relevant to Homes Gravity’s legitimate commercial and legal interests, including the non-circumvention provisions in our Terms and Conditions.

This does not mean we may keep every communication indefinitely.

Retention remains subject to applicable data-protection law and necessity.

17. How Do We Protect Personal Data?

Homes Gravity takes reasonable technical and organisational measures intended to protect information from:

  • unauthorised access;
  • unlawful processing;
  • accidental loss;
  • alteration;
  • disclosure;
  • destruction.

Measures may include, where appropriate:

  • access controls;
  • password protection;
  • account security;
  • restricted staff access;
  • secure hosting;
  • backups;
  • software updates;
  • employee procedures;
  • cybersecurity controls.

No online system can be guaranteed to be completely secure.

Users should also protect:

  • passwords;
  • devices;
  • email accounts;
  • messaging accounts.

In particular, verify payment instructions independently before transferring money in a property transaction.

18. Personal Data Breaches

If Homes Gravity becomes aware of a personal-data breach, we will assess:

  • what information was affected;
  • the likely consequences;
  • people affected;
  • legal notification requirements;
  • measures required to contain the incident.

Where applicable law requires notification to the relevant authority or affected individuals, we will take the required steps.

19. Your Rights Under Turkish Data Protection Law

Under Article 11 of Türkiye’s Personal Data Protection Law, eligible individuals have rights concerning their personal data.

These include the right to request information about:

  • whether personal data is being processed;
  • information concerning processing;
  • the purpose for which data is processed;
  • whether it is used consistently with that purpose;
  • third parties to whom it has been transferred domestically or internationally.

Eligible individuals may also have rights to request:

  • correction of incomplete or inaccurate information;
  • deletion or destruction where the legal conditions are satisfied;
  • notification of correction or deletion to relevant third parties;
  • objection to certain results produced exclusively through automated processing;
  • compensation where damage results from unlawful processing.

The complete statutory rights are available through the Personal Data Protection Authority.

20. Additional Rights Where GDPR Applies

Where the GDPR legally applies to a particular processing activity, you may have additional rights including, depending on the circumstances:

  • access;
  • correction;
  • erasure;
  • restriction;
  • objection;
  • data portability;
  • withdrawal of consent;
  • certain rights concerning automated decision-making;
  • complaint to the appropriate supervisory authority.

These rights are not absolute.

For example, a request to delete information may not require us to delete records that must legally be retained for:

  • tax purposes;
  • legal claims;
  • contractual evidence;
  • regulatory compliance.

21. How to Exercise Your Privacy Rights

To make a personal-data request, you may initially contact us at:

[email protected]

Please use a subject such as:

Personal Data Request

You may also contact us through:

https://homesgravity.com/contact-us/

We may need to verify your identity before providing, changing or deleting personal information.

This protects your information from being handed to someone who merely knows your name and has developed an enthusiastic interest in your property transactions.

For formal requests under Turkish KVKK, the legally recognised application methods include written applications and certain authorised electronic methods described by the Personal Data Protection Authority.

Official procedures are available through the KVKK application guidance.

Under the Turkish procedure, qualifying requests should generally be answered as soon as reasonably possible and no later than 30 days, subject to the applicable statutory conditions.

22. When We Cannot Fulfil a Deletion Request

There may be circumstances in which we cannot immediately delete all information.

Examples can include information required for:

  • ongoing contract performance;
  • tax records;
  • accounting;
  • anti-money-laundering obligations;
  • regulatory compliance;
  • litigation;
  • establishment or defence of legal claims.

Where appropriate, information no longer needed for active business use may instead be restricted or archived.

23. Automated Decision-Making

Homes Gravity may use software to:

  • organise enquiries;
  • categorise interests;
  • recommend relevant properties;
  • prioritise follow-up;
  • analyse website activity.

We do not intend to make legally significant property-purchase decisions about clients solely through automated processing without appropriate human involvement where applicable law requires otherwise.

The decision whether to purchase property remains yours.

24. Children

Homes Gravity services are directed toward adults considering property transactions.

We do not intentionally use our website to collect personal information directly from children for property marketing.

Information concerning children may occasionally become relevant where a parent or guardian is considering matters such as:

  • family relocation;
  • property ownership arrangements;
  • residency applications.

Such information should only be provided where genuinely necessary.

25. Third-Party Websites

Homes Gravity links to external websites including:

  • government authorities;
  • research organisations;
  • developers;
  • professional services;
  • other informational sources.

We do not control the privacy practices of independent third-party websites.

When you leave Homes Gravity, the third party’s own privacy policy applies.

26. Business Transfers

If Homes Gravity undergoes a legitimate:

  • merger;
  • corporate restructuring;
  • acquisition;
  • transfer of business;

relevant personal information may be transferred as part of that business transaction, subject to applicable legal safeguards.

A corporate transfer does not create permission to use personal information for completely unrelated purposes.

27. Changes to This Privacy Policy

Property markets change.

Privacy law, inevitably unwilling to be left out, changes as well.

Homes Gravity may update this Privacy Policy where necessary because of:

  • legal changes;
  • regulatory guidance;
  • website changes;
  • new technology;
  • new services;
  • changes in how personal data is processed.

The latest version will be published at:

https://homesgravity.com/privacy/

The Last Updated date at the top of the page shows when the Policy was most recently materially revised.

Where a change materially affects processing based on consent or otherwise requires additional notice or consent, we will take the steps required by applicable law.

28. Relationship With Our Terms and Conditions

This Privacy Policy explains how personal information is handled.

Our Terms and Conditions govern the broader use of the website and our real estate service relationship.

The documents serve different purposes and should be read together where relevant.

You can also learn more about who we are and how Homes Gravity operates through About Homes Gravity.

29. Contact Homes Gravity About Privacy

Questions or requests concerning this Homes Gravity Privacy Policy or your personal information can be sent to:

GRAVİTY İNŞAAT EMLAK GEMİ TURİZM SANAYİ VE TİCARET LİMİTED ŞİRKETİ

Beytepe Mah. Kanuni Sultan Süleyman Blv.
No: 93 B İç Kapı No: 27
Çankaya, Ankara
Türkiye

Primary privacy contact:
[email protected]

Website:
https://homesgravity.com/

Contact page:
https://homesgravity.com/contact-us/

For information about your statutory rights under Turkish law, you can also consult the official Personal Data Protection Authority.

Our principle is straightforward: collect information because we need it for a legitimate purpose, protect it while we have it, and do not keep or use it simply because technology makes doing so easy.