Clarification Text on the Protection and Processing of Personal Data

Clarification Text on the Protection and Processing of Personal Data

Infleap Teknoloji A.Ş. (Infleap) has given the basic information about the protection of transferred personal data belowThe purpose of this Information on Protection and Processing of Personal Data is the fulfillment of the disclosure obligation brought by Article 10 of the Law on the Protection of Personal Data No. 6698 (Personal Data Protection Law) in relation to the use of personal data obtained and / or received from third parties during the use of the website (Portal) at the INFLEAP web and mobile address managed by Infleap Technology Services.(Infleap). In addition, the purpose of this text is to inform the Users in a transparent manner about the ways in which personal data collected by Infleap regarding the use of the Portal or the positive actions of the Users and the personal data they enter into the Portal, the purposes of processing, legal reasons and rights.

Those who offer products and services in various categories and phenomena get the opportunity to make agreements such as product placement agreements, performance agreements, gift agreements by communicating and connecting through the secure environment offered by Infleap. Within this activity, personal data is processed as a requirement for the use of Infleap functions, as specified in this Information text.

Infleap constantly renews itself in order to provide better service to its users in the internet field with innovative product and service applications by investing in technology and works to provide the best service, takes the highest possible level of security measures in order to ensure that personal data is collected, stored and shared in accordance with the law and to protect its confidentiality. In order to achieve this purpose, the personal data of the Users are processed in the scope and conditions detailed below.

Infleap may update and change the provisions of this Disclosure at any time by posting them on the Portal. Updates and changes made by Infleap will be effective from the date they are published on the Portal.

Legal Basis for Collection of Personal Data

With the Law No. 6698 on the Protection of Personal Data, the principles of protection of personal data have been determined. In addition, the Law No. 6563 on the Regulation of Electronic Commerce also includes a provision on the protection of personal data. Penal sanctions are envisaged in some cases for the protection of personal data through the provisions of the Turkish Penal Code No. 5237. On the other hand, it is necessary to collect and use data in order to fulfill our obligations arising from the Law No. 6502 on the Protection of the Consumer and the Regulation on Distance Contracts.

Data Controller

In accordance with the Law on the Protection of Personal Data, your personal data will be collected and processed by Infleap as the data controller within the scope described below.

Personal Data Collected

Infleap collects various static (fixed) and dynamic (variable) data from Users with the following methods. The data Infleap collects depends on the services and features that Users use.

Under this heading, the data processed within the scope of the Services offered by Infleap and considered as personal data in accordance with the Personal Data Protection Law are listed below in groups. Unless otherwise clearly stated, the terms “personal data” and “personal data of special nature” include the following information within the scope of the terms and conditions presented in this Information:

PHENOMENA /USERS/INFLUENCER

1- ID information

Processed Personal Data:

Name – Surname, Date of Birth

Personal Data Processing Purposes:

– Execution of Finance and Accounting Affairs

– Execution of Communication Activities

– Execution of Company Service Engagement Processes

– Execution of Activities in Compliance with the Legislation

– Follow-up and Execution of Legal Affairs

– Execution of Business Continuity Ensuring Activities

– Execution and Supervision of Business Activities

– Execution of Service Processes

– Execution of After-Service Support Services

– Customer relations management

– Execution of Processes

– Execution of Activities for Customer Satisfaction

– Execution of Advertising, Campaign and Promotion Processes

– Execution of Storage and Archive Activities

– Execution of Contract and Membership Processes

– Follow-up of Requests / Complaints

– Planning and Execution of Commercial and/or Business Strategies

– Carrying out the Necessary Work by the Business Units to Benefit from the Services Provided and Execution of the Related Business Processes

– Providing Information to Authorized Persons, Institutions and Organizations

Legal Reasons for Personal Data Processing

Your personal data within this scope, for the realization of the above-mentioned purposes by Infleap, as specified in the relevant legislation and Article 5 of the KVKK are processed on the following bases:

– It is clearly stipulated in the law,

– Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,

– It is mandatory for the data controller to fulfill its legal obligation, and

– Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller, based on legal reasons. For cases not covered by the above purposes, your personal data is processed based on your explicit consent, the details of which are specified in the Consent Text.

Collection Methods of Personal Data:

The above-mentioned personal data are collected through the membership forms on our website, the fields in the content of my account page that can be filled depending on your preference, your requests and applications, contracts, campaigns and third-party authentication systems (Ex: Google Login, Facebook Login, etc.).

2- Contact information

Processed Personal Data:

E-Mail Address, Billing & Delivery Addresses, Mobile Number

Personal Data Processing Purposes:

– Execution of Finance and Accounting Affairs

– Execution of Communication Activities

– Execution of Business Activities

– Execution of Company Service Engagement Processes

– Follow-up and Execution of Legal Affairs

– Execution of Service Sales Processes

– Execution of After-Sales Support Services

– Execution of Customer Relationship Management Processes

– Execution of Activities for Customer Satisfaction

– Execution of Marketing Analysis Studies

– Execution of Advertising, Campaign and Promotion Processes

– Follow-up of Requests / Complaints; Execution of Marketing Processes of Services

– Execution of Storage and Archive Processes

– Providing Information to Authorized Persons, Institutions and Organizations

Legal Reasons for Personal Data Processing

Your personal data within this scope are used by Infleap in order to achieve the above-mentioned purposes, on the following legal bases as specified in the relevant legislation and Article 5 of the KVKK;

– Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,

– It is mandatory for the data controller to fulfill its legal obligation, and

– Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

For cases not covered by the above purposes, your personal data is processed based on your explicit consent, the details of which are specified in the Consent Text.

Collection Methods of Personal Data:

The above-mentioned personal data is collected through the membership pages on our website, the agreements, the fields in the content of our website, especially the my account page, which can be filled depending on your preference, your requests and applications, contracts, campaigns and third-party authentication systems (Ex: Google Login, Facebook Login etc.).

3- Legal Transaction Information

Processed Personal Data:

In Case of Dispute, Information in the Case File, Warnings, Correspondence with Judicial and Administrative Authorities

Personal Data Processing Purposes:

– Follow-up and Execution of Legal Affairs

– Execution and Supervision of Business Activities

– Providing Information to Authorized Persons, Institutions and Organizations

– Execution of Activities in Compliance with the Legislation

– Execution of Storage and Archive Activities

– Execution of Risk Management Processes

– Execution of Contract Processes

– Follow-up of Requests / Complaints

– Ensuring the Security of Data Controller Operations

Legal Reasons for Personal Data Processing

Your personal data within this scope, for the realization of the above-mentioned purposes by Infleap, on the following legal bases as specified in the relevant legislation and Article 5 of the KVKK;

– It is obligatory for the data controller to fulfill its legal obligation,

– Data processing is mandatory for the establishment, exercise or protection of a right ve

– Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Collection Methods of Personal Data:

The above-mentioned personal data are collected through official letters and other printed / electronic documents from judicial and administrative authorities.

4- Phenomenon/Users/Influencer Process Information

Processed Personal Data:
Billing Information, Request Information, Order Details, Phenomena/Users/Influencer Comments

Personal Data Processing Purposes:

Execution and Supervision of Business Activities; Providing Information to Authorized Persons, Institutions and Organizations; Execution of Activities in Compliance with the Legislation; Execution of Finance and Accounting Affairs; Execution of Storage and Archive Activities; Execution of Contract Processes; Execution of Service Sales Processes; Execution of After-Sales Support Services; Execution of Customer Relationship Management Processes; Execution of Activities for Customer Satisfaction; Conducting Marketing Analysis Studies; Execution of Advertising, Campaign and Promotion Processes; Follow-up of Requests / Complaints, Execution of Marketing Processes of Services

Legal Reasons for Personal Data Processing
Your personal data within this scope are used by Infleap in order to achieve the above-mentioned purposes, on the following legal bases as specified in the relevant legislation and Article 5 of the KVKK.;

It is clearly stipulated in the law,
Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
It is mandatory for the data controller to fulfill its legal obligation, and
Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller, based on legal reasons.

For cases not covered by the above purposes, your personal data is processed based on your explicit consent, the details of which are specified in the Consent Text.

Collection Methods of Personal Data:
The above-mentioned personal data are collected through printed/electronic forms, call center records, e-mails and SAP programs.

5- Transaction Security Information

Processed Personal Data:
IP Address Information, Website Login and Exit Information, Username Information, Password Information, Traffic Data (Connection Time / Duration etc.)

Personal Data Processing Purposes:
Execution of Information Security Processes; Conducting Audit / Ethical Activities; Execution and Supervision of Business Activities; Execution of Storage and Archive Activities; Ensuring the Security of Data Controller Operations; Providing Information to Authorized Persons, Institutions and Organizations; Execution of Activities in Compliance with the Legislation; Follow-up and Execution of Legal Affairs; Execution of Goods / Services Sales Processes; Follow-up of Requests / Complaints

It is clearly stipulated in the law,
It is mandatory for the data controller to fulfill its legal obligation, and
Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller, based on legal reasons.

For cases not covered by the above purposes, your personal data is processed based on your explicit consent, the details of which are specified in the Consent Text.

Collection Methods of Personal Data:

The personal data mentioned above are collected through information security systems and electronic devices.

6- Financial Information

Processed Personal Data:

Encrypted Credit Card Information, Bank Account / IBAN Number Information

Personal Data Processing Purposes:
Execution of Activities in Compliance with the Legislation; Follow-up and Execution of Legal Affairs; Execution of Finance and Accounting Affairs; Execution and Supervision of Business Activities; Execution of Service Sales Processes; Execution of Storage and Archive Activities; Execution of Risk Management Processes; Execution of Contract Processes; Providing Information to Authorized Persons, Institutions and Organizations

Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
It is mandatory for the data controller to fulfill its legal obligation, and

Collection Methods of Personal Data:
The above-mentioned personal data are collected through printed and electronic forms, e-mails and requests and messages on the website.

7- Visual and Audio Recording Information

Processed Personal Data:

Call Center Audio Recordings

Personal Data Processing Purposes:

Execution of Commitment Processes for Company Products and Services; Execution of Customer Relationship Management Processes; Execution of Activities for Customer Satisfaction; Execution of After-Sales Support Services; Execution of Storage and Archive Activities; Follow-up of Requests / Complaints; Execution of Marketing Processes of Services; Execution of Customer Relationship Management Processes; Conducting Marketing Analysis Studies; Providing Information to Authorized Persons, Institutions and Organizations

Legal Reasons for Personal Data Processing

It is clearly stipulated in the law,
It is mandatory for the data controller to fulfill its legal obligation, and
Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller, based on legal reasons.

Collection Methods of Personal Data:

The above-mentioned personal data is collected electronically during calls to our call center.

8- Location Information

Processed Personal Data:

Location Information

Personal Data Processing Purposes:

Execution of Customer Relationship Management Processes; Execution of Marketing Analysis Studies; Execution of Advertising / Campaign / Promotion Processes; Execution of Activities for Customer Satisfaction; Execution of Marketing Processes of Services; Execution of Service Sales Processes; Execution of Service Production and Operation Processes

Legal Reasons for Personal Data Processing

Your personal data within this scope is processed for the realization of the above-mentioned purposes by Infleap on the following legal basis, the details of which are specified in the relevant legislation and Article 5 of the KVKK to which you can access from the Consent Text;

Explict Consent

Collection Methods of Personal Data:

The above-mentioned personal data is collected according to your preference in the internet browser you use and our Company’s mobile application.

TRANSFERRING PERSONAL DATA

Personal data belonging to customers are only available to the extent necessary for the realization of the relevant purpose, by following the rules in Article 8 titled “Transfer of Personal Data” and/or Article 9 titled “Transferring Personal Data Abroad” and by taking the necessary technical and administrative measures;

To our affiliates and subsidiaries limited to the purposes listed above,
To the seller of the purchased product,
(for the delivery of the product) courier companies, (in order to receive payment for the service) banks and (to provide information on delivery, etc.) our business partners who work in sending bulk SMS / e-mail and
(for after-sales services when necessary), our suppliers and product authorized services in order for Fenomen/Users/Influencer to benefit from the service they have chosen through Infleap or to receive the product (for the delivery of the product) within the scope of the agreements between us for the above-mentioned purposes, in accordance with the legislation.In order to fulfill our legal obligations, it can be transferred to authorized persons and official institutions in accordance with legal regulations and legislation and
It can be recorded in our programs and/or systems provided / made available to us by our infrastructure suppliers in the field of technology.

ONLINE USERS

DATA CATEGORIES

Transaction Security Information

Processed Personal Data:

IP Address Information, Website Login Information, Password Information Computer Screen Records, Device IMEI Number, Device MAC Address

Personal Data Processing Purposes:

Execution of Information Security Processes; Execution of Activities in Compliance with the Legislation; Managing Customer Relationship Management Processes; Follow-up of Requests and Complaints; Providing Information to Authorized Persons, Institutions and Organizations

Legal Reasons for Personal Data Processing

It is clearly stipulated in the law,
It is mandatory for the data controller to fulfill its legal obligation, and
Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller, based on legal reasons.

Collection Methods of Personal Data:

Your personal data mentioned above are collected through internet applications, information systems and electronic devices (telecommunication infrastructure, computers and telephones, etc.) and other documents declared by you.

TRANSFERRING PERSONAL DATA

Personal data belonging to Online Users, are only available to the extent necessary for the realization of the relevant purpose, by complying with the rules in Article 8 titled “Transfer of Personal Data” and/or Article 9 titled “Transferring Personal Data Abroad” and by taking the necessary technical and administrative measures;

In order to fulfill our legal obligations, it can be transferred to authorized persons and official institutions in accordance with legal regulations and legislation and
It can be recorded in our programs and/or systems provided / made available to us by our infrastructure suppliers in the field of technology.

BUSINESS PARTNER OFFICIALS AND EMPLOYEES

DATA CATEGORIES

1- ID Details

Processed Personal Data:

Name – Surname

Personal Data Processing Purposes:

Execution of Communication Activities; Execution and Supervision of Business Activities; Planning and Execution of Commercial and/or Business Strategies; Follow-up of Requests / Complaints; Providing Information to Authorized Persons, Institutions and Organizations; Execution of Activities in Compliance with the Legislation; Execution of Contract Processes

Legal Reasons for Personal Data Processing

It is clearly stipulated in the law,
Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
It is mandatory for the data controller to fulfill its legal obligation, and
Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller, based on legal reasons.

Collection Methods of Personal Data:
The personal data mentioned above are collected through business cards, contracts, face-to-face meetings, electronic forms and calls to our call center.

2- Contact information

Processed Personal Data:
E-Mail Address, Mobile Number, Address

Personal Data Processing Purposes:
Execution of Communication Activities; Execution and Supervision of Business Activities; Planning and Execution of Commercial and/or Business Strategies; Follow-up of Requests / Complaints; Providing Information to Authorized Persons, Institutions and Organizations; Execution of Activities in Compliance with the Legislation, Execution of Contract Processes

It is clearly stipulated in the law,
Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
It is mandatory for the data controller to fulfill its legal obligation, and

Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller, based on legal reasons.

Collection Methods of Personal Data:
The personal data mentioned above are collected through business cards, contracts and face-to-face interviews.

3- Transaction Information

Processed Personal Data:

Request Information

Personal Data Processing Purposes:

Legal Reasons for Personal Data Processing

It is clearly stipulated in the law,
Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
It is mandatory for the data controller to fulfill its legal obligation, and

Collection Methods of Personal Data:

The above-mentioned personal data are collected through printed / electronic forms, call center records, e-mails, SAP programs.

4- Financial Information

Processed Personal Data:

Bank Account / IBAN Number Information, Billing Information Request Information

Personal Data Processing Purposes:

Execution of Finance and Accounting Affairs; Execution and Supervision of Business Activities; Execution of Activities in Compliance with the Legislation; Providing Information to Authorized Persons, Institutions and Organizations

Legal Reasons for Personal Data Processing

It is clearly stipulated in the law,
Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,
It is mandatory for the data controller to fulfill its legal obligation.

Collection Methods of Personal Data: The above-mentioned personal data is collected through electronic and printed forms.

5- Legal Transaction Information

Processed Personal Data:

In Case of Dispute, Information in the Case File, Warnings, Correspondence with Judicial and Administrative Authorities

Personal Data Processing Purposes:

Follow-up and Execution of Legal Affairs; Execution and Supervision of Business Activities; Providing Information to Authorized Persons, Institutions and Organizations; Execution of Activities in Compliance with the Legislation; Execution of Storage and Archive Activities; Execution of Risk Management Processes; Execution of Contract Processes; Follow-up of Requests / Complaints

It is clearly stipulated in the law,
It is mandatory for the data controller to fulfill its legal obligation.
Data processing is mandatory for the establishment, exercise or protection of a right.

Collection Methods of Personal Data:
The above-mentioned personal data are collected through official letters and other printed / electronic documents from judicial and administrative authorities.

6- Risk Management Information

Processed Personal Data:
Information Processed for Managing Commercial Risks

Personal Data Processing Purposes:
Execution and Supervision of Business Activities; Execution of Storage and Archive Activities; Execution of Risk Management Processes; Execution of Contract Processes; Follow-up of Requests / Complaints; Carrying out Internal Audit Activities; Conducting Intelligence Activities

It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract, and
Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller, based on legal reasons.

Collection Methods of Personal Data:
The above-mentioned personal data are collected during participation in a meeting or event, during the sales process, through contracts and documents declared by the person concerned.

7- Visual and Audio Recording Information

Processed Personal Data:
Call Center Audio Recordings

Personal Data Processing Purposes:
Execution of Information Security Processes; Providing Information to Authorized Persons, Institutions and Organizations; Execution of Activities in Compliance with the Legislation; Conducting Audit / Ethical Activities; Execution of Service Sales Processes; Execution of Advertising / Campaign / Promotion Processes; Execution of Storage and Archive Activities; Follow-up of Requests / Complaints; Execution of Marketing Processes of Services

It is clearly stipulated in the law,
It is mandatory for the data controller to fulfill its legal obligation.
Data processing is mandatory for the establishment, exercise or protection of a right.
It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract, and
Provided that it does not harm the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller, based on legal reasons.

Collection Methods of Personal Data:
The above-mentioned personal data is collected electronically during calls to our call center..

TRANSFERRING PERSONAL DATA

Personal data belonging to business partners and workers, are only available to the extent necessary for the realization of the relevant purpose, by complying with the rules in Article 8 titled “Transfer of Personal Data” and/or Article 9 titled “Transferring Personal Data Abroad” and by taking the necessary technical and administrative measures;

In order to fulfill our legal obligations, it can be transferred to authorized persons and official institutions in accordance with legal regulations and legislation and
It can be recorded in our programs and/or systems provided / made available to us by our infrastructure suppliers in the field of technology.

GENERAL PERSONAL DATA PROCESSED FOR INFLEAP USERS

Polls and Answers

Answers to periodic surveys organized by Infleap within the Portal and responses to surveys made by natural and legal persons with whom Infleap cooperates

On-Site Messages With Filters or Content Contrary to Terms of Use

Among in-site messages sent by users to each other for secure communication and trade between users, they are only in-site messages that are caught in the filters or that are found to be contrary to the terms of use upon the complaint/notification received.

FOR WHAT PURPOSES THE GENERAL PERSONAL DATA PROCESSED FOR INFLEAP USERS WILL BE PROCESSED

Polls and Test Answers

Information requested from users who respond to periodic surveys or tests organized by Infleap within the Portal will be used for marketing directly to these users, performing statistical analysis, improving their processes, and creating a database by third natural and legal persons with whom the Portal cooperates within the scope of all processing activities mentioned above in accordance with the intended use of the Portal and for the fulfillment of these functions by Infleap by real and/or legal persons with whom Infleap cooperates for the use of Portal functions;

They will be processed in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698 for performing the obligations arising from the contracts made by Infleap with the business partner/customer/phenomenon, establishing rights, protecting the rights, conducting the commercial and legal evaluation processes, making legal and commercial risk analyzes, conducting the legal compliance process, obtaining the documents specified in the relevant legal regulations by the user, concluding the tests that are carried out for the purpose of fulfilling the financial affairs, fulfilling the legal requirements, fulfilling the decisions of the authorized institutions, organizations and authorities, and answering their demands for the realization of legal and commercial obligations within the framework of contracts made or activities carried out with third real or legal persons who have a business relationship with Infleap and obligations arising from legal regulations.

On-Site Messages with Filters or Content Contrary to Terms of Use

Our messaging service is offered with the aim of facilitating our users to communicate with the other party during the agreement process between them. Based on the legitimate interest in Article 5 of the Law, messages within this scope that contain insults, violate general morality, raise suspicion that advertisements are made for fraudulent purposes, may cause unfair competition, violate personal rights, intellectual and industrial property rights, and otherwise unlawful are filtered and moderated, and in-site messages that are contrary to the terms of use can be blocked by examining them.

WHERE IS PERSONAL DATA STORED AND PROCESSED?

Your personal data we obtain may be stored in another country where Infleap or its affiliates, subsidiaries or cooperating service service providers have facilities at home or abroad, and may be processed in line with the purposes in this Information and in proportion to these purposes.

Your personal data collected within the scope of this Information will be processed in accordance with the provisions herein and within the scope of the legislation in force in the country where the data is stored and processed, and within the scope of the foreseen security measures.

PERSONAL DATA STORAGE PERIOD

Infleap will keep the personal data it obtains for the period necessary for the purpose for which it is processed, in order for the Users to benefit from the Service in the best way possible, within the framework of the conditions specified in the Membership Agreement with this Information, and in order to fulfill the obligations arising from the nature of the Membership Agreement.

In addition, Infleap will keep personal data in case of any dispute that may arise from the Membership Agreement, limited to the execution of administrative or judicial processes within the scope of the dispute, and during the statute of limitations determined in accordance with the relevant legislation.

THE DATA WE OBTAIN WHEN USING OUR PLATFORM

It covers the personal data regarding the usage habits of the Users obtained through certain software or technological tools during the service offered by Infleap. For example, this type of data includes location data and favorites, as well as interests and usage data.

Cookies are small bits of data placed on computers and mobile devices to enable the proper functioning and development of the website visited, personalizing and improving the user experience, to visit the sites without logging in and/or to send commercial-social notifications to the party (which he can see even if the internet browser and/or the relevant mobile application is off, depending on the situation), and communication of general or customized information, advertisements and promotions to the site users-visitors in general, both on the relevant site and on other sites (including social media-networks and online advertising networks).

For the purpose of online behavioral advertising and marketing, Infleap collects usage data such as associating the behavior of the user on the site with a cookie in the browser, even if they are not a member, and the number of pages viewed, duration of visit and number of target completions. Your personal data collected through these methods, is processed on the following legal bases as specified in Articles 5 and 6 of the Law No. 6698;

It is clearly stipulated in the laws,
Being obligatory in order to fulfill its legal obligations (Legal regulations regulating electronic trade activities, financial and tax matters, consumer protection and other issues),
It is directly related to the establishment or performance of the contract and the processing is necessary (Membership Agreement, Terms of Use and performance of the contract based on them, establishment and protection of the right),
The processing is mandatory for its legitimate interest (Infleap’s collection of data necessary for its activities on the Portal to carry out services, especially to prevent fraud),
It has been made public by you,
Processing is compulsory for the establishment, use or protection of a right,
Having your express consent

Your personal data collected through these methods can be processed and transferred for the purposes specified in this Information within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law No. 6698.

Legal basis for collecting personal data;

Membership Agreement, Terms of Use and performance of the contract based on them, establishment and protection of the right
Legal regulations regulating electronic commerce activities, financial and tax matters, consumer protection and other issues
Infleap’s legitimate interest in collecting the data necessary to perform its services, in particular fraud prevention, in its activities related to the Portal.

OUR MEASURES AND COMMITMENTS REGARDING DATA SECURITY

Infleap is committed to protecting personal data securely. In order to prevent the illegal processing and access of personal data and to ensure the preservation of personal data, technical and administrative measures are carried out by using various methods and security technologies to ensure the appropriate level of security.

Infleap will not disclose the personal data it has obtained to anyone else in violation of the provisions of this Disclosure and the Law on the Protection of Personal Data No. 6698, and will not use it for purposes other than processing. Infleap declares that in case of sharing personal data of Users with outsourcing service providers in accordance with this Disclosure, it will carry out the necessary warning and audit activities for the said outsourcing suppliers to comply with the commitments under this article.

In case of linking to other applications through the portal, Infleap does not take any responsibility for the privacy policies and contents of the linked applications.

The User undertakes that the information subject to this Disclosure is complete, correct and up-to-date, and that in case of any changes in this information, he will immediately update them at https:// infleap.com.tr/. Infleap will not have any responsibility if the User does not provide up-to-date information.

RIGHTS OF THE PERSONAL DATA OWNER STATED IN ARTICLE 11 OF THE LAW NUMBERED 6698

As personal data owners, if you submit your requests regarding your rights to Infleap through the methods set out below, Infleap will finalize the request as soon as possible and within thirty days at the latest, depending on the nature of the request. Up to ten pages will not be charged for a reply. A transaction fee of 1 Turkish Lira will be charged for each page over ten pages. If the response to the application is given in a recording medium such as a CD or flash memory, the fee that may be charged by Infleap will not exceed the cost of the recording medium.

In this context, personal data ownershave the right:

To learn whether personal data is processed or not,
To request information about it if personal data has been processed,
To learn the purpose of processing personal data and whether they are used in accordance with the purpose,
To know the third parties to whom personal data is transferred in the country or abroad,
To request correction of personal data in case of incomplete or incorrect processing and request notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
to request the deletion or destruction of personal data in the event that the reasons for its processing disappear, and request the notification of the transaction made in this context to the third parties to whom personal data has been transferred although it has been processed in accordance with the provisions of the Law No. 6698 and other relevant laws,
To object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
To demand the compensation of the damage in case of loss due to unlawful processing of personal data.

You can communicate your your request regarding the exercise of your above-mentioned rights in Turkish to the address of as data controller in Turkish or can transmit it by other methods determined by the Personal Data Protection Authority in writing with documents identifying your identity,

Infleap reserves the right to verify your identity before replying.

Your application is required to include the following details;

Your name, surname and, if the application is written, your signature,
For citizens of the Republic of Turkey, T.R. identity number, your nationality if you are a foreigner, your passport number or your identity number, if any,
Your place of residence or workplace address for notification,
Your e-mail address, telephone and fax number, if any,
Your request subject

If any, information and documents related to the subject should be attached to the application.