PRIVACY POLICY

SR Teknoloji Yatırımları ve Danışmanlık A.Ş., Kassa Mobil Bilgi Teknolojileri A.Ş. and its affiliate companies attach importance to and protect your privacy and confidentiality. We would like to inform you about the types of data we collect, the reason for us to collect it, how we use the said data, and your rights under the relevant legislation. Please carefully read this Privacy Policy. By being a member of us and by providing your personal information, you are deemed to have accepted this Privacy Policy.

1. Services covered by our Privacy Policy

Currently, we operate Kassa mobile application ("Application"). This Privacy Policy covers the services you receive when you use the Application (“Services").

2. What kind of personal data do we collect?

2.1. We and our service providers may collect your personal data through our Services and by the way specified in this Privacy Policy. The said data may involve your name, e-mail address, mail address, mobile phone number, date of birth, gender and photos. In addition, we may supply your personal data from public databases, our business partners, social media platforms (including acquisitions through the persons you become friends or you have other contacts) and other third parties. We use your personal data in order to provide our Services which ensure your transactions with other users. We do not share your personal data with third parties unless it is required for your use of Services as detailed in this Privacy Policy or unless you give permission.

It is not possible for you to use our Application without providing your personal data. We would like to notify that we will not be able to provide you with our Services in case you refuse to provide your personal data. In case you transfer the personal data of third parties regarding the Services to us or our service providers, you are deemed to have declared that you are authorized for the realization of the said transfer and for our use of the transferred personal data in accordance with this Privacy Policy, and that you give permission to us.

2.2. Your physical location may be collected with the use of means such as satellite, mobile phone tower or Wi-Fi signals. You may allow or refuse such collection of your device information.

2.3. Within the framework of the purposes specified in this Privacy Policy, we may transfer your personal data, which we collect from you, to our affiliate companies and to our service providers who provide us with data analysis, payment systems, transaction order application, information technology services and infrastructure services, customer services, e-mail transmission, audit and other services, and to third parties which are/may be a party of these transactions in case of reorganization, merger or joint venture, provided that it complies with the purpose of collecting such data from you.

2.5 We may process your personal data, which we collect from you, and transfer such data to the administrative authorities due to reasons that we deem required or suitable such as providing safety of life and property of persons, securing our services, rights and assets, fulfilling our legal obligations, meeting the requests of security forces, and meeting the requests of other government agencies.

2.6 We may gather your personal data in such a way that its last version cannot be associated with you or other users. For example, we may gather the personal data of our users in order to calculate the percentage of users who use a certain postal code.

3. Membership and Registration

3.1. In order to use certain Services, you are required to be registered by providing your e-mail address or social media account. In addition, we may collect information for issues such as your telephone number, date of birth, gender and preferences (for example, mode of communication that you prefer). If you prefer being registered with a social media account, you entitle us to access and use certain information depending on your privacy settings on relevant social media network. We may give your basic account information (e.g. name, e-mail address, gender, date of birth, residence city, profile photo, user name, friend list, etc.) and other information and activities, which you give permission of use to third party social media network, as example for the information that we use after combining.

3.2. We may request your data such as your profile photo, name, surname, user name and e-mail address in order to make the said data be accessible through the Application. You may navigate certain parts of the Services as a guest, but it will not be possible for you to access all contents and features without being registered.

4. Public information

4.1. We would like to state that the information you publish regarding with our Services is public information and that it becomes accessible by other users and persons. We recommend you to be very careful while deciding which information you will disclose through the Services.

4.2.When you participate in certain Services, your user name and your public photo will become open to public; for this reasons, please exercise caution while using the said Services. Your personal data which has been announced by you or which has been disclosed to other users may be collected by other users of our Services and may cause messaging that you have not requested before. We decline any responsibility for the protection of the said data that you may disclose to third parties through our Services (for example, sending your mobile phone number to another user through our Services).

5. News bulletins sent by e-mail and push notifications

In order for you to better benefit from the Services, we may send you electronic commercial messages by means of electronic communication channels such as e-mail and we may inform you about our products, services, opportunities or other commercial content about our company. If you do not want to receive the said marketing e-mails from our company, you may leave our e-mailing list by using the method specified in the said e-mails. We would like to remind that even you leave our commercial electronic mailing list, you will continue receiving administrative notifications such as confirmations regarding the realization of your transactions, information notes related to your account activities (e.g. account verification, change of password, etc.) and other important notifications. In addition, we will be able to send you push notifications provided that you have accepted such notifications in advance. You may deactivate the push notification feature from the settings of your mobile device.

In accordance with the membership agreement, KASSA will be authorized to send information e-mails to its users' e-mail addresses recorded in it and to send information SMSs to mobile phone numbers of its users; and by approving this user agreement, the member will be deemed to have accepted the sending of information e-mails to his/her e-mail address and of information SMSs to his/her mobile phone number. The member may give up receiving e-mail and/or SMS by sending an e-mail to info@kassa.co.

6. Non-personal information that we collect from you

6.1. Regarding your use of our Services, we are required in many cases to automatically collect your non-personal information. We collect the said information in order to ensure the proper functioning of our Services. We may collect the information such as internet browser that you use, mobile device, application usage data, information collected through the cookies, pixel label, and other technologies and combined information. The said information may include the following:

Depending on your device number, the Application usage data such as date and time when the Application in your device has accessed our servers, and the information that has been downloaded to your Application. In addition, depending on the version of your Application, we may collect information also about the other applications in your device (this will never include the content of the other applications in question). We may also collect the information which has been automatically collected by your internet browser or your device, or the information which has been automatically collected by the Application that you have downloaded and used. We may also collect the information about the Media Access Control address that you use, type of computer (Windows or Macintosh), screen resolution, manufacturer and model of device, language, internet browser type and version, and name and version of our Services (for example, Application).
The operating system that you use, domain name of your internet service provider and your clicking route related to the Web Site or Application.
Your IP address to be used for calculation of the usage level, determination of server problems, and administration of the Services. In addition, we may determine your approximate location through your IP address.

6.2. For the information collection operations in this section, we may use the cookies and other technologies detailed in the next sections.

6.3. We may collect your non-personal information that you have provided to us with you own will, such as the mode of communication that you prefer.

6.4 We may gather the personal data in such a way that its combined version cannot be associated with you or other users. For example, we may gather the personal data of our users in order to calculate the percentage of users who use a certain postal code. As long as it is legal, we may use or disclose the said combined information for any purpose.

6.5. In some cases, we may combine the said information with personal information. We would like to notify that in case we perform the said activity, we will treat the combined information (as long as it is combined) like personal information.

7. Information on cookies and relevant technology

7.1. Our Services may include “cookies”.

We may use cookies in order to manage the sessions of our users, to monitor information, and to select language. Cookies may be used independently from your registration. "Cookies" are small text files which are sent to your hard disk by a network server and which are then kept in your computer. The information collected by the cookies includes date and time of your visits, your navigation history and preferences.

We may use the information that we collect through the cookies in order to feature some products under our Services used by you, to give certain form to them, or to make them significant in other ways. We may use your reactions to the said products which have been featured or made significant, or your search requests and results in order to make our Services special for you.

You may set your internet browser so as not to accept the cookies in general. In addition, you may also get information from www.allaboutcookies.org/manage-cookies/.

7.2. Google Analytics

We use Google Analytics, which uses the cookies and similar technologies, to give us information about your use of our Services and to report the activities and trends. The said service may also collect information about other web pages, applications and online sources.

You may get information about Google's activities from the following address: https://www.google.com/policies/privacy/partners/,

In order to leave Google Analytics, you may use the following internet browser: https://tools.google.com/dlpage/gaoptout.

 


8. Your rights on your personal data that you provide to us

8.1 Pursuant to the Law on Protection of Personal Data number 6698 ("LPPD"); by making application to us, you have right regarding the personal data you have shared to: 

a) learn whether such data has been processed or not,
b) request information if such data has been processed,
c) find out the reason for processing of such data and whether such data has been used properly for that purpose,
d) know the 3. persons to whom such data has been transferred at home or on abroad,
e) request its correction if such data has been processed missing or wrong,
f) request the deletion or removal of such data within the frame of the prescribed provisions of the Article 7 of LPPD,
g) request the notification of the transactions, performed in accordance with the above paragraphs (e) and (f), to the 3. persons to whom such data has been transferred,
h) object to a result against yourself due to the analysis of such data exclusively by automatic systems, and
i) demand indemnification of loss if you suffer loss due to processing of such data in breach of the law.
For the applications, you may use our address Esentepe Mah. Talat Paşa Cad. No: 5 Şişli İstanbul or our e-mail address info@kassa.co

8.2. In order for us to properly reply your requests, please state for which personal data you contact us. We would like to state that for your safety, we will be able to reply only the requests regarding the personal data that can be associated with the e-mail address through which you contact us, and that we may be required to make your identity be verified before putting your request into process. We will reply your requests as soon as possible. However, we may be required to keep certain information and some redundant information may rest in our databases and other records for archiving purposes and due to our legal obligations.

9. Measures that we take regarding your personal information collected by us, and explanations

In order to protect your personal information, we utilize any kind of measure, and accordingly, we take reasonable organizational, technical and administrative measures. However, we would like you to know that no website or transfer through the internet is safe. For this reason, Kassa cannot guarantee that unauthorized access, hacking, data loss and other violations will never take place. You use the Application and the Services at your own risk. Kassa recommends you to take required security measures by memorizing your password or by keeping it in a safe place. In case you have doubt that your communication with us is not safe (for example, in case you suspect that safety of your account has been violated), please immediately inform us from the section "Contact Us" below.

10. Third parties

This Privacy Policy does not cover the third parties' confidentiality, information security and other activities in this regard (including sites or services having connections in our Services), and Kassa is not responsible for it.

In case you make a payment through the Services, your personal information will be collected by the said third party (not by us) and will subject to the privacy policy of the said third party instead of this Privacy Policy. We may use the third party payment system service to put payments regarding the Services into process. We do not have any control or responsibility regarding your personal data collected, used and disclosed by the said third parties.

11. Term of storage

In case a longer term is not required or possible by law, your personal information will be stored for the term required to realize the purposes specified in this Privacy Policy.

12. Usage by minors

Our Services are not intended for persons under 18 years of age and we request from such persons not to share their personal information with us through the Services.

13. Transfer of your personal information

We, our affiliate companies and our service providers may process and store your personal information within or outside your residence country, or we may transfer your personal information to such places. The legislation regarding the protection of the personal data in the said countries may be different (in a way to be less or more protective) than that of your country. However, Kassa guarantees that it will take all possible measures regarding the protection of your personal data in relevant countries, even in case the legislation on protection of personal data is different in the said countries. By accepting this Privacy Policy, you accept the said transfer, storage and processing of your personal information.

14. Notification of amendments to the Privacy Policy

Kassa may at anytime amend this Privacy Policy by making notifications to these registered users via e-mail or the Application, and/or by publishing the Privacy Policy under the Services. All amendments regarding the Privacy Policy enter into force on their date of publication and your continued use of Kassa Services following relevant amendment means that you have accepted the said amended Privacy Policy.

15. Contact

In case you have any question or comment about this Privacy Policy, you may contact us from our address Esentepe Mah. Talat Paşa Cad. No: 5 Şişli İstanbul or from our e-mail address info@kassa.co Please do not send us sensitive information via e-mail because communication via e-mail may not always be safe.

SR Teknoloji Yatırımları ve Danışmanlık A.Ş.

Kassa Mobil Bilgi Teknolojileri A.Ş.