ACCORDING TO THE LAW ON THE PROTECTION OF PERSONAL DATA

OUR PRIVACY POLICY AND USER DISCLOSURE TEXT

(“ViaRuuma”)

1. OUR POLICY AND BASIC EXPLANATIONS REGARDING THE PROCESSING OF YOUR PERSONAL DATA

As BYC BİLİŞİM HİZMETLERİ TİCARET LİMİTED ŞİRKETİ (“Company”), which is the data controller pursuant by the Personal Data Protection Law No. 6698 (“Law”), within the scope of all websites and applications we operate under the ViaRuuma brand (“our services”), the data categories specified in the second title of this text We process your personal data within the scope of the relevant legislation with due care and sensitivity. As you can see with this clarification text, we are very transparent about which data we process. We never hesitate to provide you with all kinds of information about your personal data processed at any time. Due to the importance we attach to the security of your personal data and our legal responsibilities, we protect our website with state-of-the-art security certificates and firewalls.

We have prepared this policy and clarification text to enlighten the people who use and purchase our services or contact for any support and suggestion requests, about the protection and processing of personal data. Before the details of the processing of your personal data specified in the other headings, we would like to make a statement on some issues in particular:

First of all, let us state that to inform you about our campaigns; In order to provide you with special products or services, to provide information and in all other cases where we require your explicit consent, we definitely obtain your explicit consent with the explicit consent information and approval text we share with you before processing your personal data. For example, we will never process this data if you do not consent to the use of marketing cookies that personalize your preferences. In some cases, you may share your personal data by making it public while using our services. For example, it is entirely up to you to mention something about yourself in the bio section of your user account.

In order to use our services, we do not offer you to share your personal data such as location information with us as a prerequisite when creating a user registration, but we may request you to share your location information with us through third party applications in order to benefit from our services after the registration stage. After you allowing your location information to be shared with us via your personal devices, we process your location information instantly with your explicit consent, but we never store it.

If you want to make purchases while using our services, we are obliged to request some information that we did not request during user registration due to our legal obligations. Our most primary legal obligation is our liability to issue an invoice for the product or service you have purchased. For this, we need your surname and your city-district information. If you would like to include a TR Identity Number on your invoice, you can share this information with us on your own initiative.

As can be seen in the "Data Category and Processed Personal Data" section of this clarification text, we do not process the credit or debit card information you make a payment. This information is processed and stored by organizations that ensure the successful execution of your payment and provide a secure payment system integrated with our website or mobile applications.

No one, including us, can access the passwords you create to log in to your account. The passwords you create are stored as encrypted with certain algorithms.

While using our services, we offer messaging with third parties for a limited time and then the entire message history is not possible for anyone to view, including the communicating parties. When your messaging with the third party ends, we encrypt all message records instantly and store them on our servers, where we take adequate security measures, for a certain period of time. The reason why we keep your message records for a certain period of time is to take precautions for your safety and to share them with law enforcement/legal authorities when necessary. We only store your messages encrypted for 15 days and then permanently delete them from all our servers, irretrievably.

When an application is made to us with the claim that you have used third-party photos or information on our website or mobile application, we may request you to share a certain part of your Republic of Turkey Identity Card in order to ensure transaction security and security confirmation. The personal data we process for this purpose is based on the reason for fulfilling our legal obligations.

Apart from all these explanations, which of your personal data is processed; We would like to inform you about the purposes for which your processed personal data is processed, with whom it can be shared, the method of collection of your data, and the right to apply, which is the data controller (“our company”) for legal reasons, with this clarification text prepared in accordance with Article 10 of the Law No. 6698. :

2. DATA CATEGORY AND PROCESSED PERSONAL DATA

We may not request some of your personal data categorized in the table below. However, we wanted to briefly inform you about the purposes for which you process this data when we request it. As explained in the relevant part of this text, you can use your rights listed in Article 11 of the relevant Law to obtain more detailed information about the processing of your personal data.

DATA CATEGORY

DATA

SPECIAL DISCLOSURE AND DATA PROCESSING PURPOSE

ID Information

  • Name surname
  • Gender
  • TR Identification number
  • Date of birth
  • Some Information on the Turkish Identity Card

We process the surname information in accordance with our legal financial obligations when you make it public in your profile on account information or when you make any purchase.

Your TR Identity Number is not required during the purchasing process, but if you want it to be included in your invoice, we will process your personal data by making it public by your own will. For security and all other legal measures, we may be required to confirm your identity. In this case, we process certain information on your identity card in a measured and limited way.

According to the terms of use, the use of our services depends on the minimum age requirement. In order to determine compliance with our terms of use and for the purpose of using our services, we need birth year and gender information.

Contact information

  • E-Mail Address
  • Province-District

You can create a user record; In accordance with the policy decision of the Personal Data Protection Board, we process your e-mail address information so that we can verify your e-mail and provide you with legal information. When you make a purchase, we process the province-district information in order to issue an invoice to you.

Health Information

 

  • Height
  • Weight

Your height and weight are your personal health data. We do not process this data without your explicit consent, and we do not require the processing of this data in order for you to use our services. Even if you want to share this data on your profile with your explicit consent, we will definitely indicate for what purposes we will process it.

User Transaction Information

  • Product and Service Purchase History Information,
  • Billing Information
  • Request and Complaint Information
  • Third Party Interaction Information

We process this data in order to create sales and interaction statistics, fulfill legal obligations, ensure customer service satisfaction, protect personal rights and protect our legal rights/interests.

Transaction Security Information

  • IP Address
  • Log Records
  • Transaction History

We process this data in order to detect violations of terms of use, to fulfill legal obligations and to share information with judicial authorities when necessary.

Location Information

  • Your Current Location

You set a common meeting point when using the features of our service to interact with other users. We may request you to turn on your location information so that you can select this meeting point and users close to you can be filtered. If you do not share your location information with us with your explicit consent through third-party applications, we cannot process this data, but you may not be able to use some features.

Marketing Information

  • Cookies
  • Survey

We may use performance and marketing cookies, other than mandatory cookies, in order to provide you with a better user experience while browsing our mobile applications or websites. We definitely get your explicit consent for the use of cookies and make the necessary explanations. Participation in surveys we conduct in order to improve the user experience and to generate statistics for our legitimate interests is subject only to your express consent.

Audio and Audio Recording Information

  • Photograph
  • Voice Recording
  • Video
  • Call Center Voice Recordings

In order to meet the benefit our users expect from our services, we require everyone who registers to upload a reasonable number of photos to their profile. Some of our features may allow interactors to communicate with each other through audio recording and video footage. We only process audio and video footage while using these features, and then permanently delete them.

Legal Transaction Information

  • Contract Number
  • Notice and Warning Information
  • Case File Information
  • Information Shared with Judicial, Administrative, Regulatory and Supervisory Bodies

We process this data for our legal interests, management of customer relations and fulfillment of all other legal obligations.

Financial Information

  • IBAN Number
  • Account Number

In some cases, we may have financial obligations to you. In any case where it is not possible for us to issue a refund with payment intermediary institutions, we need and process your data for this reason.

3. PURPOSE OF PROCESSING PERSONAL DATA

We process your personal data that you share with us electronically or physically, in accordance with the law and in accordance with the rules of good faith, in connection with the purposes of processing, in a limited and measured way, accurately and up-to-date, for certain clear and legitimate purposes. These purposes are as follows:

4. TRANSFER OF PERSONAL DATA

Your collected personal data is limited only to the purposes described in the first article of this information text and the reasons that require it to be transferred within the scope of the relevant legal regulations, and in accordance with Articles 8 and 9 of the Law on the Protection of Personal Data No. 6698; supervisory and regulatory public institutions and organizations, judicial units and real or legal persons and business partners from whom the data controller receives services for their legitimate interests, provided that it does not harm the fundamental rights and freedoms of the data subject. Since express consent is required for your personal data to be shared with third parties, except for the reasons listed in the law, no data transfer is carried out at home or abroad without obtaining your explicit consent confirmation text. We share the table below with you as an example to the third parties to whom your data is transferred.

THIRD PARTY TO WHOM PERSONAL DATA IS TRANSFERRED

REASON FOR TRANSFER

E-Invoice Integration and Accounting Companies

Fulfillment of Legitimate Interests and Legal Obligations (Invoice issuance etc.)

Intermediary Payment Institutions

Legitimate Interest (Obtaining Payments)

Financial Advisor or Certified Public Accountant

Fulfillment of Legal Obligations

(Fulfillment of tax declarations etc.)

5. METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA

Your personal data, for the above-mentioned purposes, in accordance with the basic personal data processing principles stipulated in the Law; Based on legitimate interests and legal grounds, provided that it does not harm the fundamental rights and freedoms of the person concerned, if it is clearly stipulated in the law, for the data controller to fulfill its legal obligation, to be made public by you, for the establishment, use or protection of a right; In cases where data processing is not possible without express consent, it is collected by automatic or non-automatic methods by obtaining explicit consent:

6. YOUR RIGHTS UNDER THE LAW

Provided that it remains within the framework of KVKK and other applicable legislation,

you have rights.

7. HOW TO APPLY TO US

Your requests within the scope of Article 11 of the Law "regulating the rights of the person concerned", in accordance with the Communiqué on Application Procedures and Principles to the Data Controller, with the text of the "Relevant Person Application Form" that you can obtain on our website, provided that you have your wet signature, to Bulgurlu Mah. Technical Sk. Küçük Camlica Uzunlar Apt. C Block No:1C/36 address; or to kvkk@viaruuma.com or bycbilisim@hs01.kep.tr in writing and by providing your identity confirmation. (If you apply through your approved e-mail address, identity confirmation will be deemed to have been realized. The current version of the e-mail address should be notified to our company.) Our company will finalize the application requests in accordance with the 13th article of the Law, according to the nature of the request and within 30 (thirty) days at the latest.

If the transaction requires cost, the tariff determined by the Personal Data Protection Authority will be applied. If the request is rejected, the reason(s) for the refusal will be justified in writing or electronically.

In the application containing your explanations regarding the right you have as the personal data owner and you will make and request to use the above-mentioned rights; The subject you request must be clear and understandable, the subject you request is related to yourself or if you are acting on behalf of someone else, you must be specifically authorized in this regard and document your authority, the application must include identity and address information, and documents confirming your identity must be attached to the application.