Privacy Policy

INFORMATION NOTE ON THE PROCESSING OF PERSONAL DATA

….. (“Company”), is the Data Controller. Your personal data are processed by the Company within the framework explained below and always in compliance with the Law numbered 6698 on the Protection of Personal Data (“the Law numbered 6698”).

1. Purposes of the Processing of Your Personal Data:

Your personal data processed by The Company is categorized according to (i) the Law for Protection of Personal Data (“Law”); and (ii) General Data Protection Regulation (“GDPR”) as provided for in the following. Unless expressly stated otherwise, the terms “personal data” under the terms and conditions of this Privacy Policy shall cover the following information.

Identity and Contact Information:

Name, surname, phone, birthdate, gender, address, workplace information, e-mail address.

Information About the User, User Transaction Data and Financial Information:

Membership data, membership ID number, data on the date and time of using The Company services, reasons for communication with The Company, terms you use when searching at the Site and filtering preferences, scores and remarks, preferences, pages you have visited, errors during use.

Location Information:

Specific or approximate location information about your location, such as GPS data, that we have received while using the services of The Company.

Transaction Security Information:

Marketing Information:

Reports and evaluations showing your habits and likes, notifications, targeting information, and information on cookie records, etc.

Complaint Management Information:

Communications you make through the Site.

Risk Management Information:

IP Adress.

Data anonymized under Articles 3 and 7 of the Law will not be considered as personal data in accordance with the provisions of the said law and the processing of such data will be conducted without being bound with the provisions of this Privacy Policy.

Please apply to the Company whether your data is being processed.

Personal data you share with The Company may be processed for making your membership registration on the Site, updating the membership registration, conducting commercial activities including improvement of the services offered by The Company and providing new services through the Site, and providing you with information on these activities, determining and implementing commercial and business strategies, ensuring legal and commercial security of the persons who are in business relationship with The Company and providing necessary information to you and fulfilling responsibilities arising from the nature of these activities to allow you to utilize the services provided through the Site or via the Mobile Application.

Such personal information may be used to communicate with you or to improve your experience on the Site or on the mobile application (such as managing the communication management process, conducting research on customer satisfaction, etc.), and also to perform internal reporting and business development, and to make various statistical evaluations without disclosing your identity, to create database and perform market research. This information can be processed, stored and transmitted to third parties by The Company for the purposes of direct marketing, digital marketing, remarketing, targeting, profiling and analysis, and you may be contacted for promotion, maintenance and support activities on various applications, products via the aforementioned information.

The Company will also be able to process and share your personal data with third parties, pursuant to Articles 5 and 8 of the Law, and/or in the presence of exceptions under the applicable law, without obtaining your consent as Data Owner. Such conditions mainly include:

If clearly prescribed in the law,
If necessary to protect the life or physical integrity of a person or third parties, where the person is unable to explain his consent or the consent of such person is not legally accepted,
If the processing of personal data is required for performance or execution of an agreement between the Data Owner and The Company,
If it is compulsory for The Company to fulfill its legal obligations,
If it has been revealed to the public by the Data Owner,
If its compulsory for the establishment, use or protection of a right,
Data must be processed for the legitimate interests of The Company, provided that it does not jeopardize fundamental rights and freedoms of the Data Owner.

As mentioned above, The Company will be able to use cookies and transmit data to third parties for processing purposes only to the extent required by such third party to generate analysis services based on the data in question. The technical communication files mentioned above are the small text files that the Site sends to the browser of the Data Owner for storage in the main memory. The technical communication file makes the use of the Site more convenient by storing status and preference settings for the website. The technical communication file is designed and used for helping to generate statistical information on the number of people who use internet sites in what proportion of the time, the number of times a person visits a website, the number of times they have visited a particular website, the amount of time they have stayed at the site; and to dynamically generate advertisements and content from user pages specially designed for users. The technical communication file is not designed to receive any other personal data from the main memory. Most browsers are configured to accept the technical communication file by default; however, users can always change the browser settings so that the technical communication file is blocked or a notification is made upon receiving a technical communication file.

Adsbot use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.”

2.The Method and Legal Reason of Collecting Your Personal Data

Your personal data are obtained and processed by Company through Company website and its affiliated websites, with entirely or partly automatic methods, or non-automatic/physical methods provided that it is part of a data recording system, depending on your type of communication with the Company.

Your personal data are processed with your explicit consent as per Article 5/1. Additionally, should conditions provide, your personal data may be processed in order to conclude, execute and terminate a relevant contract with you, if any, as per Article 5/2/c; in order for the Company to be able to perform its legal obligations such as storing commercial electronic communications as per Article 5/2/ç; in case data processing is mandatory for the establishment, exercise, or protection of any right as per Article 5/2/e; and in case data processing is mandatory for the legitimate interests of the data controller provided that this processing shall not violate the fundamental rights and freedoms of the data subjects as per Article 5/2/f.

3. To Which Parties and For What Purposes Your Personal Data May Be Transferred

Your personal data may be shared with and transferred to ongoing business partners, intermediary service providers, real or legal entities that provides various services, suppliers and consultants, for purposes such as fulfilling the abovementioned data processing Purposes, sending electronic mails, processing, storing and protecting data, in line with legal limitations and to the extent of the necessity and purpose of such transfer, in line with the abovementioned Purposes and in accordance with the Articles 8 and 9 of the Law numbered 6698.

Personal data may be transferred to real or legal entities residing in Turkey as well as abroad on the condition that they shall be processed in Turkey or processed and stored outside Turkey (to countries that have sufficient measures regarding the protection of personal data and/or to countries falling short of such measures provided that the conditions specified by the Personal Data Protection Law shall be satisfied).

Furthermore, personal data may be shared with public bodies or institutions authorized to demand and obtain such data out of legal necessity.

4.Rights of Data Subject under the Law numbered 6698 Article 11

As personal data owners, you are entitled

to learn whether or not your personal data have been processed;

to request information as to processing if your data have been processed;

to learn the purpose of processing of the personal data and whether data are used in accordance with their purpose;

to know the third parties in the country or abroad to whom personal data have been transferred;

to request rectification in case personal data are processed incompletely or inaccurately;

to request deletion or destruction of personal data within the framework of the conditions set forth under article 7;

to request notification of the operations made as per indents (d) and (e) to third parties to whom personal data have been transferred;

to object to occurrence of any result that is to your detriment by means of analysis of personal data exclusively through automated systems;

to request compensation for the damages in case the person incurs damages due to unlawful processing of personal data

by applying to the Company.

As personal data owners, in case you deliver your claims related to your rights to the Company, your claim will be concluded as soon as possible or, at the latest, within 30 (thirty) days depending on the nature of the claim.

In case this transaction brings an extra cost, a compensation will be requested from you as per the rates determined by the Personal Data Protection Board.

5.For How Long Do We Store Your Data?

Your personal data you share with The Company will be kept for the period required for the fulfillment of the purposes set out in this Privacy Policy and for the time limits set forth in the applicable legislation. In addition, your personal data may be retained for a limited purpose of defending against any dispute that may arise between you and The Company.

6.How Do We Ensure the Security of Your Data?

The Company takes necessary technical and administrative precautions and has necessary audits performed to ensure prevention of

illegal processing of personal data,

illegal access to personal data, and

protection of personal data

for the purpose of providing the minimum level of security by considering appropriate conditions and costs set out under the applicable legislation or expressed in this Privacy Policy.

In addition, The Company does not disclose any personal data obtained from you to third parties in contravention of the provisions of this Privacy Policy, the Protection of Personal Data Law and GDPR and does not use it for purposes other than processing.

For links located in the Site to other applications, The Company does not bear any responsibility for the privacy policies and content of such applications and advises that you review them.

7.Amendments

This Privacy Policy may be updated from time to time in order to comply with any changes in requirements and the legislation.

OVERSEAS DATA TRANSFER

Personal data mentioned above may be transferred to real or legal entities residing in Turkey as well as abroad on the condition that they shall be processed in Turkey or processed and stored outside Turkey to countries that have sufficient measures regarding the protection of personal data and/or to countries falling short of such measures provided that the conditions specified by the Personal Data Protection Law shall be satisfied.