PRIVACY POLICY

Collection, Purpose of Collection and Use of Personal Information

As Ibility, we process personal data of visitors and members in accordance with the Personal Data Protection Law No. 6698, legal legislation and decisions of the Personal Data Protection Authority. The personal data collected are your name, surname, phone number, address, e-mail address, name-surname and phone number of the person to be contacted in case of emergency, IP and Device IP information, credit card and bank information, health status information, gender and age information. In addition to identifying information about members, Ibility also collects aggregated statistics about visitors. For example; If the Ibility platform is visited, general information about the location of the computer of the users, the website from which the website is visited is automatically collected, and this information is not used to determine the identity information of the users.

Apart from the automatically collected data, it is also necessary to collect identifying personal data. These data include identity, contact and occupational information, as well as data such as photographs and video recordings in the shared content. Apart from this, comments on the content and records of conversations with Ibility employees (messages, comments, opinions) are also among the data to be collected. If deemed necessary, it is also possible to collect personal data of special nature, provided that it is collected in accordance with the law and with your explicit consent.

According to the regulation titled "Conditions for Processing Special Categories of Personal Data" in Article 6 of the LPPD, the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data are special categories of personal data. It is prohibited to process these special categories of personal data without the explicit consent of the data subject. However, in cases stipulated by law, personal data other than health and sexual life may be processed without the explicit consent of the data subject.

Purposes of Processing Personal Data

Your collected personal data may be processed by Ibility within the personal data processing conditions specified in Articles 5 and 6 of the KVK Law, limited to the service received for the fulfillment of obligations and proportionate to this purpose for the following purposes:

• To carry out the activities carried out by Ibility in accordance with the relevant legislation and Ibility policies,
• Provide better service to visitors and members through Ibility and improve our services,
• Realization of product/service offers, all kinds of information, advertising-promotion, promotion, sales and marketing activities,
• Development work can be carried out by us or our group companies in line with the interests and preferences of our customers,
• Ensuring the legal and commercial security of Ibility, its Affiliate Companies and persons who have established or are in a business relationship with Ibility,
• Carrying out the necessary work by our business units to benefit you depending on the product, service or commercial activity offered by Ibility;
• Determining and implementing Ibility's commercial and business strategies,
• Fulfillment of legal obligations arising from the relevant legislation,
• Contacting members for the specified purposes through the Ibility system, providing the requested information and documents,
• Your personal data has been made public by you,
• We process the contact information of our visitors who are members within the scope of Article 5/2-f of the KVKK in order to send commercial electronic messages in order to inform them about current developments and/or to provide them with more information upon their request, provided that their consent is obtained within the scope of the Electronic Commercial Messages Law and related legislation.

Legal Grounds for Processing Personal Data and Relevant Legislation

Data processing, for the purpose of purchasing services through digital applications and benefiting from customer services and support, Article 5/2 of the KVKK For reasons expressly provided for by law pursuant to subparagraph (a), it is necessary in direct relation to the conclusion or performance of the contract pursuant to subparagraph (c), It is mandatory for Ibility to fulfill its legal obligations as the data controller pursuant to subparagraph (ç), and It is based on the necessity to establish, protect and exercise a right of Ibility pursuant to subparagraph (e). The processing of this data is not subject to your consent. In this respect, we state that you do not have the right to request the deletion or destruction of your personal data until the end of the service utilized and the retention periods required by law.

Transfer of Personal Data

Our customers' personal information is not shared or sold to third parties without their consent. However, information may be shared with authorized business partners to fulfill legal requirements or to provide services. Data transfer within Turkey may be transferred without seeking explicit consent in accordance with subparagraph 8/2(a) of the KVKK, limited to the cases where it is required by law in accordance with 5/2 (a) of the KVKK, (c) is mandatory for the establishment and/or performance of the contract, (ç) is mandatory for the fulfillment of a legal obligation and (e) is mandatory for the establishment, exercise or protection of a right.

The data controller for the personal data you transmit in communication with the service providers is the relevant service providers, and in the same way, since the transactions you make through channels other than Ibility during the provision of the service (for example, payment transactions), the records regarding the provision of the service are part of the legal relationship between the service provider and the service recipient, Ibility does not act as the data controller for the data processed and stored within this scope.

Protection, Storage Period and Destruction of Personal Data

Ibility is obliged to take all kinds of physical, technical and administrative measures to ensure an adequate level of security in order to prevent unlawful processing of your personal data, unlawful access to your personal data and to ensure the protection of your personal data and takes these measures to the maximum extent. Ibility takes appropriate technical and organizational measures to ensure the security of customer information.

Unless otherwise stated in the Clarification Text [link], your personal data are stored until the end of the 10 (ten) year retention period from the date of termination of the service relationship. For detailed information, please review the Clarification Text.

Processing of your personal data for marketing purposes is limited to the service period. Ibility will not use your personal data to contact you for marketing purposes at the end of the service period.

At the end of these periods, your personal data will be deleted, destroyed or anonymized in the first destruction period.

Ibility has prepared separate special information texts ("Clarification Text") for users, employees, employee candidates, suppliers and managers. These clarification texts have been delivered to each relevant person group or access authorization has been given.

Rights of the Data Subject

As a data subject, in accordance with the legislation in force, your Personal Data

• (a) to request information on whether and how it is being processed (Art. 11/(a), (b)),
• (b) to learn the purpose of the processing and whether they are used for their intended purpose (Art. 11/c),
• (c) to know the third parties to whom it is transferred (Art. 11/ç)
• (d) request rectification (Art. 11/d),
• (e) To request the deletion of your personal data in case the reasons requiring its processing disappear (Art. 7, Art. 11/e),
• (f) in case of correction and deletion, to request notification of the relevant transactions to third parties to whom your personal data have been transferred (Art.11/f),
• (g) challenge the results of the analysis (Art. 11/g),
• (h) Request restriction of processing (Art. 7),
• (ı) you have the right to demand compensation for any damage caused by unlawful processing (Art. 11/ğ).

Your aforementioned rights are restricted by law and can probably only be provided by us under certain conditions.

You may submit the above-mentioned requests to the e-mail address [email protected]. Ibility will finalize your request as soon as possible upon receipt of the relevant documents. Depending on the nature of your request, this period is at the latest thirty days.

Contact Us

If you have any questions or concerns regarding our privacy policy, please feel free to contact us. Please visit our website for our contact details.

Identity of the Data Controller:

Company Title: Ibility Technology Joint-Stock Company

Mersis No: 1008207

Contact Address: KOZYATAĞI MAH. DEĞİRMEN SK. NIDA KULE A BLOK NO: 18 İÇ KAPI NO: 19 / KADIKÖY

Telephone No: +90 212 355 89 50

E-Mail Address: [email protected]

KEP Address: