Published on 5/10/2022
Below, you will find an explanation of general principles for the processing of personal data by Ounternet, the purposes for which your personal data is processed, and the rights that you have concerning your personal data.
- General Information
While Ounternet is an entity located in the Republic of Turkey and complies with the provisions of the Law No. 6698 on the Protection of Personal Data (“Law No. 6698”), it also complies with the European General Data Protection Regulation (“GDPR”) when it is applicable for the related personal data processing.
- Data Controller:
OUNTERNET MARKETING YAZILIM VE PAZARLAMA LİMİTED ŞİRKETİ
Harbiye Mah. Bostan Sok. No:15/5, Şişli, İstanbul, Turkey
İstanbul Chamber of Commerce Registry No: 1359245
- Data Protection Officer of Ounternet:
You may approach the Data Protection Officer at [email protected]
- What is Personal Data?
“Personal Data” means any information relating to an identified or identifiable individual (a data subject) in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
- How do we collect Personal Data?
If you fill out contact forms available on our website, Ounternet will collect Personal Data directly through these forms and process such Personal Data required for following up on your request, its management, and the provision of our services. Furthermore, Ounternet may collect and process Personal Data when you submit your Personal Data to Ounternet for any reason.
- Which Personal Data do we collect?
We collect and process the following information relating to the use of the Ounternet Website such as your name, contact details, your requests and complaints, incident management, and other related information relevant to your request.
We do not process sensitive Personal Data of special categories, as well as any biometric personal data.
- For Which Purposes Is Your Personal Data Processed?
The purpose of processing Personal Data is to follow up on your request. This purpose implies the following cases of Personal Data use:
- Within the scope of your request: processing and analyzing personal data entered into the contact form, understanding the request, communicating with you regarding your request;
- Within the scope of quality assurance and product & service development activities: processing and analyzing processes for product and service quality assurance, product research, and product & service development purposes. In this case, your Personal Data will be de-personalized and/or anonymized in order to prevent any connection to be linked with you;
- Within the scope of the processes relating to direct or indirect marketing: the customization, development, and reconstruction of the Ounternet Services, in accordance with the related individual’s likes, preferences, and usage habits, the realization of targeted advertising, promotion, and campaign communications with real-time location determination, carrying out data analytics and market analysis studies in order to determine the strategies and target audience regarding marketing activities (if you give consent to process your personal data for direct or indirect marketing purposes);
- Within the scope of compliance with the legal obligations arising from the relevant legislation: fulfillment of any and all obligations arising from the relevant legislation and regulations, carrying out any and all legal proceedings initiated before legal institutions, component courts, enforcement offices, and any other authorized authorities;
- Within the scope of legal, safety and security purposes: carrying out activities in order to protect or defend our or another’s rights or property, or to detect, prevent, or otherwise address fraud, criminal activities, security, safety, or privacy issues, providing safe and secure database.
- The following types of processing of Personal Data are applied:
Collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission or transfer, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Legal Basis for Processing Personal Data
Depending on the purposes of processing and its circumstances, in processing your Personal Data we may rely on the following legal bases in the priority of their order below:
- The processing is necessary in order to be able to follow up on your request,
- The processing is necessary for connection with any contractual relationship that you may enter into with us,
- The processing is required by applicable law;
- The processing is necessary to protect the vital interests of any individual;
- We have obtained your explicit prior consent to the processing.
- Where May We Receive Your Personal Data From?
Ounternet collects Personal Data directly from you through contact forms. Ounternet may also receive Personal Data from other communication channels preferred by you.
- Who May Access Your Personal Data?
- Ounternet processes the Personal Data alone or may give assignments to third parties to process your data. If we are involving data processors in the performance of our services and contractual obligations, we have entered into data processing agreements with them.
- Ounternet may also transfer your Personal Data within the scope of this Policy to business partners, shareholders, affiliates, legally authorized public institutions and individuals in order to realize the above-mentioned data processing purposes within the framework of this Policy.
- Ounternet and some of its third parties are located outside the EU, which have not been the subject of an adequate decision of the EU Commission pursuant to Article 45 GDPR. Ounternet will ensure that the level of data protection is guaranteed by taking necessary legal precautions.
- International transfer of your Personal Data is required in order to ensure that you benefit from services.
- How do we protect and store Personal Data
- We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
- pseudonymisation and encryption of Personal Data;
- the ability to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
- the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
- a process for regular testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
- In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from an accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed.
- Consequences in case we may not collect your Personal Data
We need your Personal Data to enable follow-up on your request and to provide the Services in order to perform our contractual obligations with you. Without providing such Personal Data, we may not be able to communicate with you in order to answer your request.
- Consent and withdrawal
- Any consent is provided freely. If you give your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. After your withdrawal, we will stop processing your Personal Data, including storage, unless further data processing is legally permitted.
To withdraw your consent, please send us an e-mail to [email protected] or a letter to the company address provided above.
We only keep your personal information in identifiable form for as long as one of the following applies:
- Your information is reasonably required in order to satisfy the purpose for which you submitted, or we collected the information;
- Your information is reasonably required in order to protect and defend our rights or property (this will generally be the length of the relevant limitation period in your jurisdiction); or
- We are otherwise required to keep your information by applicable laws or regulations.
- Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please send us an e-mail to [email protected] or a letter to the company address provided above.
- Your rights related to data privacy
- You have the right to request access to and rectification or erasure of your Personal Data, or restriction of their processing.
- You have the right to request data portability.
- If you are situated in the EU, you have the right to file a complaint to the relevant data protection authority.
- If you have questions or concerns regarding our use of your information, or would like to exercise any of your rights, please send us an e-mail to [email protected] or a letter to the company address provided above.
We may modify or update this information from time to time. Please check https://ounternet.agency/