Besa Software, LLC acts as the data controller for personal data processed within the BinaYön platform. Building managers may also act as a data controller or data processor with respect to data relating to their own residents.
2. Personal Data We Process
BinaYön processes the following categories of personal data:
Category
Scope
Purpose
Identity
First name, last name, national ID/passport no., nationality
User identification, legal obligation
Contact
Email, phone, address
Notifications, support, contract performance
Financial
Payment history, dues information, balance status
Building management, accounting
Technical
IP address, session data, browser type
Security, debugging
Property
Unit/building information, lease/ownership status
Building management service
3. Legal Basis for Processing
Your personal data is processed on the following legal bases:
EU
GDPR
Performance of a contract (Art. 6(1)(b))
Legitimate interest (Art. 6(1)(f))
Legal obligation (Art. 6(1)(c))
Explicit consent (Art. 6(1)(a))
TR
KVKK
Performance of a contract (Art. 5/2-c)
Legitimate interest (Art. 5/2-f)
Explicit consent (Art. 5/1)
CA
CCPA
Commercial use
No sale of data
Right to opt out granted
4. Purposes of Data Use
Providing the building and site management service
Tracking dues, expenses, and outstanding balances
Sending announcements and notifications to residents
Fulfilling support requests
Complying with legal obligations
Protecting platform security and integrity
Improving service quality (anonymous analytics only)
5. International Data Transfers
Because Besa Software, LLC is incorporated in the US, your personal data may be transferred outside the European Economic Area (EEA) or Turkey. Such transfers are protected by the following safeguards:
For EU users: Standard Contractual Clauses (SCC / GDPR Art. 46)
For Turkey users: Explicit consent or adequate protection under KVKK Art. 9
Infrastructure providers have signed Data Processing Agreements (DPA)
6. Data Sharing
Your personal data is never sold or shared with third parties for commercial purposes without your consent.
Infrastructure providers: Hosting, database services (as processor, under signed DPA)
Payment processor: For processing subscription payments (card numbers are not stored by BinaYön)
Building manager: Managers can only see resident data belonging to their own sites
Legal requirement: At the request of competent authorities in the US, EU, or other jurisdictions
7. Data Security
Encrypted transmission via HTTPS/TLS
Encrypted password storage (bcrypt)
Role-based access control (RBAC)
Regular backups and audit logging
Organization isolation — data from different sites is kept completely separate
8. Data Retention Periods
Active account data: For as long as the account remains active
Financial records: 7 years as legally required (US federal requirements)
Log files: 12 months
After account deletion: Permanently deleted or anonymized within 30 days
9. Your Privacy Rights
Depending on your location, you may exercise the following rights:
Access
Request information about and a copy of the data we process about you
Rectification
Request correction of inaccurate or incomplete information
Erasure
Request deletion of your data ("right to be forgotten")
Restriction
Request restriction of certain processing activities (GDPR/KVKK)
Portability
Receive your data in a machine-readable format
Opt-out
Object to or opt out of certain data processing activities
You can send your requests to privacy@binayon.com. Requests are answered within 30 days (1 month for GDPR, 45 days for CCPA). EU users have the right to lodge a complaint with the competent Data Protection Authority (DPA).
10. Cookies
BinaYön only uses strictly necessary session cookies:
Session cookie: Required for secure session management; deleted when the browser is closed
Preference cookie: For language and interface preferences (12 months)
No third-party tracking, advertising, or analytics cookies are used.
11. Changes to This Policy
If a material change is made to this policy, a notification will be sent to your registered email address and the updated version will be published on this page. Continuing to use the platform after such a change means you accept the updated policy.