This Personal Data Protection Policy and Disclosure Text, '' Article 10 of the Law No.6698 on the Protection of Personal Data '' and the '' Communiqué on the Procedures and Principles for Fulfilling the Disclosure Obligation '' is the data controller of GETLUG within the framework of the disclosure obligation. regarding the personal data collected in their capacity or entered by the user on the platform at their own request;
· What data is collected and for what purpose it is processed
· To whom and why the data are transferred
· Data collection methods and legal reasons
· What are your legal rights as a user?
· It has been prepared to inform you about how your collected personal data is protected, stored and secured.
From now on, in this disclosure text, Personal Data and Special Qualified Personal Data "Personal Data", Law No. 6698 on the Protection of Personal Data (KVKK) "Law" and Data Responsible GETLUG OÜ "GETLUG" 'will be referred to as.
While processing your personal data, we act in accordance with the following principles.
· Compliance with the law and good faith
· Being accurate and up-to-date when necessary:
· Processing for specific, explicit and legitimate purposes
· Connected to processing purposes, limited and restrained
GETLUG may update and change the information provisions in this disclosure text on the Platform at any time. Updates and changes made will be valid as of the date they are published on the Platform.
If you have any questions or problems regarding your Personal Data, you can contact [email protected].
1. COLLECTED PERSONAL DATA
Personal Data; Protection of Personal Data In Article 3- (d) of the Law, '' is all kinds of information regarding an identified or identifiable natural person. ''
Data Processing; In Article 3- (e) of the Law on the Protection of Personal Data, '' the acquisition, recording, storage, storage, modification, rearrangement of personal data fully or partially automatic or non-automatic, provided that they are part of any data recording system, all kinds of transactions performed on data such as disclosure, transfer, taking over, making available, classifying or preventing their use. ''
· Identity, Membership and Contact Information: Name, surname, mobile phone, home phone, business phone, address, e-mail address, identity or passport information (from identity or passport picture), password and password, profile picture and other similar data.
v When you log into the platform for the first time, the account is opened after you enter your name and surname, telephone, e-mail address, user password and password, and approve the usage and confidentiality agreement. After login to the application, in order to verify your account and information, membership activation is performed by making a phone (SMS) and e-mail verification process via third parties or institutions. In addition, if the user wishes to receive a verified profile icon, 3. Identity information can be verified through individuals and institutions. Confirmation is received from you when shooting for your profile picture or taking pictures from the gallery.
· Demographic Data: Date of birth, age, gender, occupation information, country of residence, interests, spoken and preferred language data.
v It is the information received by you through the forms filled out on the platform during your User Membership application.
· Usage Data: Content read or used on the platform, tags, categories, websites visited or accessed before the platform, pages viewed, date and time of entry and exit to the platform, the number and duration of visits, the most visited country, the most transported type of goods, search terms entered, categories of news visited and similar platform usage data.
v Information generated by semi or automated methods during your use of the platform.
· Location Data: It is the location data obtained through GPS data on the user device, if the users want to call the nearest airport and other users while using GETLUG mobile applications and allow the location to be reported from their own device.
v If permitted by you, it is the GPS information received from your device regarding your location.
· Announcement Creation Data: It is the data including the travel route, start and end points, travel date, time and duration by the passenger and the ticket visual.
v It is the information entered by you regarding the travel route and passed on the ticket image uploaded to the notice panel after your approval.
· Reservation Creation Data: It is the data containing information and pictures of the goods to be transported by the passenger, the place to be sent and the delivery information.
v It is the picture of the item to be transported loaded into the system by you and the delivery location and address information entered by you.
· Transaction Data: Usage, confidentiality and mutual contract information, user request and complaint information, service usage information, error notification during the use of the service, satisfaction notification and answers given to surveys, commenting and giving points, mutual messaging information, preferences and usage habits and with the judicial authorities correspondence, information on the case / enforcement files in case of dispute and etc. data.
v Information about all your activities performed by you during or after the use of the services on the platform . Approved users can send pictures and location information on the mutual message page without any encryption.
· Device Information and Log Records: IP Address, Device IMEI number, device MAC address, other traffic data (Connection Time and Duration etc.), Corporate E-Mail account archives, Electronic Access and Activity Records, Application Usage History.
· Notification Data: The user is informed in three different ways.
v In-app notification (socket system)
v System notification (3. Through individuals or institutions)
v Notification by e-mail
· Special Quality Personal Data; Pursuant to Article 6 of the Personal Data Protection Law; It is a person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, costume and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data. GETLUG does not collect or process private data in any way and does not ask you to share such data. In the context of the relationship established with GETLUG, do not share your personal data of special nature, regardless of communication.
2. PURPOSE OF PROCESSING PERSONAL DATA
Your personal data are processed for the purposes stated below, in accordance with the conditions regarding the processing of personal data specified in Articles 5 and 6 of the Law.
· Performing your membership registration to the GETLUG mobile application and determining member profiles,
· To ensure that the information contained in any document that may be obtained from you during the membership or during your use of the Platform or at any other time, when necessary, is processed by a third party service provider under the control of GETLUG, for the purpose of processing your identity, passport, driver's license,
Third service providers will be responsible at the same level as GETLUG for providing the security and care required under the provisions of this KVKK Policy. Your information received by GETLUG for verification is not used for marketing or any other purpose other than its purpose to any third party or institution.
· To carry out our commercial activities in accordance with the law, laws and our company policy, to carry out audit and surveillance activities according to risk factors in service processes and to prevent fraud and other illegal activities,
· To arrange all records and documents that will be the basis for processing in electronic (internet / mobile etc.) or paper environment,
· To be able to provide information to public officials on public security issues upon request and in accordance with the legislation,
· To fulfill the legal obligations arising from the contract and to use our contractual rights and to provide and follow up the support service to you within the scope of the contractual services,
· To be able to recognize users in order to increase customer satisfaction and to carry out various marketing and advertising activities around the user, and to organize surveys in electronic and / or physical environment through contracted organizations and to use this data in market research and statistical studies,
· To inform you about innovations, updates and errors in our mobile application,
· To receive post-service user feedback, to measure and analyze satisfaction and complaints, and to customize and improve the service provided according to the preferences and interests of the users,
· Receiving passenger announcements and Sender reservations and ensuring that the most suitable passenger and the sender are matched, ensuring that Passengers and Senders confirm their location and meet at the designated location and provide the nearest airport location information,
· To promote the services offered by GETLUG; to carry out marketing and advertising activities and to carry out marketing analyzes in order to make the most of our services and to inform you about campaigns and special opportunities in accordance with your communication permission preferences, +
· To ensure and manage information flow processes and security and to ensure that the data are accurate and up-to-date,
3. COLLECTION METHOD OF PERSONAL DATA AND LEGAL REASONS
Your personal data is collected through GETLUG mobile applications or other channels to be established or to be created in the future, such as the website, call center, social media accounts, through automatic, partially automatic or non-automatic methods, verbally, in writing or electronically, with the consent of the user.
The collected data are in line with the purposes of Article 2 of this Clarification Text, in Article ( 5/2-c) of the Law on Protection of Personal Data, "It is necessary to process personal data belonging to the parties of the contract, provided that it is directly related to the establishment or execution of a contract", In Article ( 5/2-ç), "It is mandatory for the data controller to fulfill his legal obligation", " Data processing is mandatory for the establishment, use or protection of a right" in Article (5/2-e) of the Personal Data Protection Law and the Social Security Institution. and the fulfillment of the obligations against the Labor Law No. 4857 are processed on the basis of legal reasons.
4. PARTIES TO WHICH THE PERSONAL DATA CAN BE TRANSFERED AND THE PURPOSE OF TRANSFER
Your collected personal data are subject to the personal data processing conditions specified in Articles 8 and 9 of the Law and the purposes described in Article 2 of this Clarification Text and within the scope of the legislation and the reasons that require their transfer and limited to these reasons; With the program partner institutions and organizations that we cooperate with in order to carry out our activities, with domestic / foreign individuals and institutions that we receive services for storing data in the cloud, with domestic / foreign organizations that we have contracted to send commercial electronic messages to our customers, official institutions and organizations, independent audit firms, consultancy companies In order to provide better service to you and the companies that we benefit from and cooperate with, and to ensure customer satisfaction, within the scope of various marketing activities, various domestic and international agencies, advertising companies and survey companies and other domestic / foreign third parties and our relevant business partners.
Your personal data can be transferred in order to find the most suitable user between Passengers and Senders, to carry out the communication between Passengers and Senders, to confirm the location of Passengers and Senders, to meet at the designated location and to provide the most appropriate service.
GETLUG, as the data controller, may reasonably and appropriately transfer your personal data to third party service providers such as Google Firebase and Google Analytics in order to supplement the services offered or to increase their quality.
It may be transferred to company officials, business partners, suppliers, shareholders, legally authorized institutions and organizations for the purpose of ensuring the commercial reputation of the company and the legal and commercial security of the persons with whom there is a business relationship.
The Company may transfer the data of personal data owners without obtaining explicit consent in the following cases;
· It is clearly stipulated in the laws.
· It is compulsory for the protection of the life or body integrity of the person who is unable to disclose his consent due to the actual impossibility or whose consent is not legally valid.
· 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 his legal obligation.
· It is made public by the person concerned.
· Data processing is mandatory for the establishment, use or protection of a right.
· It is mandatory to process data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed.
5. TRANSFER OF PERSONAL DATA ONTO ABROAD
The data collected within the scope of this Personal Data Protection Policy and the Clarification Text are hosted by third party service providers and can be reproduced or transferred on more than one server in more than one country in accordance with Article 9 of the Law, regardless of the country where third party service providers are located. By using or accessing the platform, you consent to the transfer or reproduction of your data to third party service providers.
Your personal data cannot be transferred abroad without your explicit consent. However, it can be transferred without your express consent in the following situations. However, GETLUG, in line with the legitimate and legal personal data processing purposes, the existence of one of the following conditions for personal data and if there is sufficient protection in the foreign country where the data will be transferred or there is not enough protection, GETLUG and the data controller in the foreign country should undertake sufficient protection in writing and the Personal Data Protection Board ' can be transferred abroad with the permission of.
· It is clearly stipulated in the laws.
· It is compulsory for the protection of the life or body integrity of the person who is unable to disclose his consent due to the actual impossibility or whose consent is not legally valid.
· 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 his legal obligation.
· It is made public by the person concerned.
· Data processing is mandatory for the establishment, use or protection of a right.
· It is mandatory to process data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed.
· Personal data relating to health and sexual life, on the other hand, can only be collected by persons under the obligation of confidentiality or authorized institutions and organizations for the purpose of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, without seeking the explicit consent of the person concerned. can be processed.
Countries with sufficient protection are determined and announced by the Board. The Board shall determine whether there is sufficient protection in the foreign country and whether it will be permitted in accordance with subparagraph (b) of the second paragraph;
a. international conventions that Turkey is a party,
b. Personal data requesting countries with reciprocity condition for transferring data between Turkey,
c. Regarding each concrete personal data transfer, the nature of the personal data and the purpose and duration of the processing,
d. The relevant legislation and implementation of the country to which personal data will be transferred,
e. It makes a decision by evaluating the measures undertaken by the data controller in the country to which the personal data will be transferred and, if necessary, by taking the opinion of the relevant institutions and organizations.
Personal data, without prejudice to the provisions of international conventions, Turkey or in the interests of the person concerned will suffer a serious condition, but considering the views of relevant public institutions or organizations transferred abroad with the permission of the Board. The provisions of other laws regarding the transfer of personal data abroad are reserved.
Again, according to Article 9 of the Law, if third party service providers are located outside the European Economic Area (EEA), your consent will be obtained for the transfer of your personal data to countries outside the EEA or to other persons or companies. In this case, if there is a requirement for the use of EU Model clauses in any contract concluded with a third party, it will take all steps to provide the most appropriate protection mechanisms to ensure the protection of personal data.
6. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
Pursuant to Article 11 of the Law, you have the following rights as a data owner in Personal Data processing activities included in this Clarification Text.
· Learning whether their Personal Data is processed,
· Requesting information if Personal Data has been processed,
· Learning the purpose of processing Personal Data and whether they are used appropriately for their purpose,
· To know the third parties to whom Personal Data is transferred domestically or abroad,
· To request correction of Personal Data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom Personal Data is transferred,
· Although it has been processed in accordance with the provisions of the Law and other relevant laws, in case the reasons requiring its processing disappear, to request the deletion or destruction of Personal Data and to request the transaction made within this scope to be notified to third parties to whom Personal Data has been transferred,
· To object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,
· We would like to state that you have the right to demand the compensation of the damage in case of damage due to unlawful processing of Personal Data.
In addition, you have the right to request GETLUG to correct your inaccurate and incomplete Personal Data and to inform the recipients whose data may or may have been transferred.
You can request from GETLUG the destruction (deletion, destruction or anonymization) of your personal data within the framework of the conditions specified in Article 7 of the Law.
At the same time, you can request that third parties to whom the data is or may be transferred be informed about your destruction request. However, by evaluating your request for destruction, we will evaluate which method is appropriate according to the conditions of the concrete event. In this context, you can always request information from us about why we chose the destruction method we chose.
7. METHODS OF USING YOUR RIGHTS REGARDING YOUR PERSONAL DATA
Personal Data Owners can make their requests for the rights in Article 11 of the Law using one of the following methods.
· By sending an e-mail to '' [email protected] '' via your e-mail registered in the system approved by the platform,
· By filling the "Application Form for Personal Data" on the platform,
· It will be able to transmit the Personal Data to GETLUG through "other methods" determined by the Protection Board.
GETLUG will be evaluated and finalized within 30 (thirty) days at the latest. Although it is essential that no fee is charged for the requests, GETLUG reserves the right to charge a fee on the fee schedule determined by the Personal Data Protection Board.
The mandatory information that should be in the information request applications according to the 13th article of the Law is as follows;
a. Name and Surname and if the application is in writing, its signature
b. ID number for the citizens of the Republic of Turkey, the people of foreign nationality, passport number or identification number, if any
c. Place of residence or workplace address for notification
d. E-mail address, telephone and fax number for notification, if any,
e. Demand
8. PRIVACY, PROTECTION AND STORAGE OF YOUR PERSONAL DATA
We use firewall and various data protection applications as well as secure data networks to ensure the security and confidentiality of your Personal Data collected.
Data controller according to Article 12 of the Law,
a. To prevent unlawful processing of personal data,
b. To prevent unlawful access to personal data,
c. In order to ensure the protection of personal data, it must take all necessary technical and administrative measures to ensure the appropriate level of security.
The technical and administrative measures we always keep up to date to ensure security are:
- Acting on the principle of " data minimization" in the processing of personal data, we never share other personal information such as ticket number or image, PNR code, identity information, phone number, e-mail address other than the user's name. In this context, users have the authority to hide their surnames and can share them at any time or keep them confidential.
- We take cyber security measures, including up-to-date anti-virus systems and firewalls, to ensure personal data security.
- Restricts access to personal data only to our employees who are required to access relevant personal data; We ensure compliance with data access authorizations in the systems we use to run our operations.
- We implement our policies and practices on information security and protection of personal data.
· Your personal data can be stored for the periods required by the purposes of processing. Your personal data will be deleted, destroyed or anonymized if there is no legal reason to keep it after our processing purpose is eliminated. If you request the deletion of your data for a valid reason, your data will be deleted within 30 days at the latest.
COOKIE POLICY
We use two types of cookies across our sites: session cookies and persistent cookies. Session cookies are temporary cookies and are valid only until you close your browser. Permanent cookies remain on your hard drive until you delete them or expire (in this way, how long the cookies will remain on your device will depend on the "lifetime" of the cookies).
GETLUG cookies; It uses it to remember your preferences and to personalize your website / mobile application usage. This usage includes cookies that record your password and keep your website / mobile application session open continuously, thus saving you from the trouble of entering a password more than once each visit, and cookies that remember and recognize you on your next visit to the website / mobile application.
A cookie is data that is stored locally on your computer and contains information about your activities on the Internet. The information contained in a cookie does not include personally identifiable information you provide to our site.
Cookies, including determining how you use the website / mobile application / mobile site, such as where and from which devices you connect to the electronic commerce platforms operated by GETLUG, what content you view on the website / mobile application / mobile site, and the duration of your visit; uses it to determine how you use the website / mobile application / mobile site.
GETLUG is also owned by Google, Inc. ("Google") uses Google Analytics, a web analysis service. Google Analytics uses cookies to analyze how visitors use the website / mobile application / mobile site with statistical information / reports.
For more information on the use of Google Analytics (including opt-out options), you can visit: https://www.google.com/intl/tr/policies/privacy/#infocollect
We use cookies on the Site to track how users move on the Site; this enables us to make improvements based on usage data. In addition, we use cookies to keep you signed in to one of our online services whenever you log into that service. A cookie gives you the opportunity to make the most of the Site and give us a more customized service.
When you close your browser, your access to the cookie will end. You have the option to accept or decline cookies. Many Internet browsers automatically accept cookies, but you can change your browser to refuse cookies if you prefer. To change your browser settings, you must click on advanced preferences.
We need your consent to use cookies. [There is a clear cookie notice on the home page of the website.] On the site, you will be given the option to confirm the cookie notification and use.
Failure to accept cookies will not affect your access to many information on the Site. However, you may not be able to take full advantage of our online services.
You can refuse "Cookies" if your browser allows, however this is the case with the website.
It may affect your usage and access to some website features. To turn off cookies; You can select "Settings / Privacy / Content Settings / Turn off the use of cookies" option in your browser settings in Chrome, "Preferences / Privacy / Block All Cookies" in your browser settings in Safari, "Options / Internet Settings / Privacy / Settings" in your browser settings in Internet Explorer. You can use the option "Tools / Options / Privacy / Cookie acceptance method / Until Firefox is closed" option in Firefox.
EXPRESS CONSENT TEXT OF THE LAW ON PROTECTION OF PERSONAL DATA
In cases where you give your explicit consent while creating an account at Getlug, registering or using our services, you have read and understood the above "Privacy Policy and Clarification Text" and your personal data can be collected by GETLUG within the scope of KVKK with the above-mentioned methods, within the scope of the above-mentioned purposes. You accept and declare that you give your explicit consent to the processing and transfer of the above-mentioned third (real / legal) persons at home and abroad. You can give your explicit consent in other ways.
CONTACT AND WORKING HOUR INFORMATION
Working Hours
Monday-Friday 09:00-18:00
Data Supervisor: Getlug OÜ
Address: Harju maakond, Kesklinna linnaosa, Vana-Veerenni tn 4-15, 10135 Tallinn, Estonia
E-mail: [email protected]