COWEALTHY USER CLARIFICATION TEXT
COWEALTHY TEKNOLOJİ A.Ş. (“COWEALTHY”) is committed to protecting the privacy of its visitors and clients (“you”).
This clarification text, in the capacity of data controller COWEALTHY TEKNOLOJİ A.Ş. (“COWEALTHY”) in line with the importance we attach to your personal data, we will inform you, our users, how and how your personal data is handled by us, within the scope of the Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Disclosure Obligation with Article 10 of the Law on the Protection of Personal Data No. 6698 (“Law”). It has been prepared to inform you on what basis it is collected, how it is processed, to which people for what purposes and your rights regarding these.
This policy applies to our websites, apps, services, and other software that may be downloaded to, or accessed by you or by any mobile or computing device you own or control in connection with our services (the “Services”).
When we say “Personal Information,” we mean identifiable information about you, like your name, email, support queries, community comments, information about yourself that you share via the Services, and so on. This notice doesn’t apply to information that cannot be used to identify you (e.g. where personal data has been aggregated and anonymised). Check out our terms and conditions for more information on how we treat your other data.
This policy is effective from the date set out above. We may need to update this notice from time to time. You should check this policy periodically. Your continued use of our Services after we post any modifications to this policy on this page will constitute your acknowledgement of the modifications and your consent to abide and be bound by the modified policy. Where a change is significant, we’ll make sure to let you know – by either sending you an email to the email address you provided us or by placing a prominent notice on our Services.
Who are “we”?
When we refer to “we” (or “our” or “us”) that means COWEALTHY TEKNOLOJİ A.Ş., a Turkey corporation, and all its wholly owned subsidiaries.
Our principles of data protection.
Our approach to data protection is built around four key principles. They are at the heart of everything we do relating to personal data:
We do not collect any more Personal Information than is necessary to provide our Services.
We do not keep your Personal Information if it is no longer needed.
How we collect your data.
When you visit or use our Services, we collect Personal Information. The ways we collect it can be broadly categorised into the following:
Information you provide to us directly: When you visit or use some parts of our Services we might ask you to provide Personal Information to us. For example, we ask for your contact information when you sign up to use our Services, request to be added onto our waitlist, participate in community forums, contact us with questions or request support. If you don’t want to provide us with Personal Information, you don’t have to, but it might mean you can’t use some parts of our Services.
Information we collect automatically: We collect some information about you automatically that your browser sends whenever you visit or use our Services. This information may include your computer’s/mobile phone/tablets Internet Protocol (“IP”) address, browser type, browser version, mobile carrier, geo-location information, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, what links you clicked on and other statistics. This information is useful for us as it helps us get a better understanding of how you’re using our Services so that we can continue to provide the best experience possible for our users.
Some of this information is collected using cookies, pixel tags, local storage and similar tracking technologies via third party services such as Google Analytics and Facebook Analytics that collect, monitor and analyze this information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners. For more information about Facebook Analytics, please visit analytics.facebook.com.
Information we get from third parties: The majority of information we collect, we collect directly from you. For business customers we might collect Personal Information about you from other sources, such as publicly available materials or trusted third parties like our marketing and research collaborators. We will use this information to supplement the Personal Information we already hold about you, in order to better inform, personalise and improve our Services, and to validate the Personal Information you provide.
Purposes of Processing Personal Data
All the above-mentioned data are processed for the following purposes:
Execution of Information Security Processes
Execution of Access Authorities,
Execution of Company / Product / Services Loyalty Processes
Execution of After-Sales Support Services
Execution of Service Sales Processes
Execution of Communication Activities
Creating and Tracking User / Visitor Records
Execution of Customer Relationship Management Processes
Execution of Activities for Customer Satisfaction
Conducting Marketing Analysis Studies
Execution of Advertising / Campaign / Promotion Processes
Follow-up of Requests / Complaints
Execution of Marketing Processes of Products / Services
Where we collect Personal Information, we’ll only process it:
To provide the Services or to perform any other contract or subscription service for or with you;
Where we have legitimate interests to process the Personal Information and they’re not overridden by your rights;
In accordance with a legal obligation; or
Where we have your consent.
If we don’t collect your Personal Information, we may be unable to provide you with all our Services, and some functions and features on our Services may not be available to you.
How we use your data.
First and foremost, we use your Personal Information to operate and provide you with our Services and to manage our relationship with you. We also use your Personal Information for other purposes, which may include:
Communications – This may include:
Providing you with the information you’ve requested from us or information we are required to send you;
Operational communications, like changes to our Services, security updates or assistance in using our Services;
For business customers – Marketing communications such as newsletters, marketing or promotional materials and other information that we think will improve your experience while using our product, in accordance with your marketing preferences; and
Asking for your feedback or to take part in any research we are conducting (which we may engage a third party to assist with).
Support – This may include assisting with the resolution of technical support issues or other issues relating to the Services, whether by email, live-chat, in-app support or otherwise.
Service Enhancement – By tracking and monitoring your use of our Services we can keep improving, or by carrying out technical analysis of our Services so that we can optimise your user experience and provide you with more efficient tools.
Protection – By tracking and monitoring the use of our Services, we aim to detect and prevent any fraudulent or malicious activity, and make sure that everyone is using our Services fairly and in accordance with our terms and conditions.
Marketing – In addition to sending you marketing communications, we may also use your personal data to display targeted advertising to you online – through our Services or through third party websites and their platforms.
Analysis and Reporting – We may use the Personal Information we collect about you and other users of our Services to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties. We may also use such aggregated and anonymised data in a number of ways, including research, internal analysis, analytics or other legally permissible purposes.
How we can share your data.
There will be times when we need to share your Personal Information with third parties. We will only disclose your Personal Information to:
Other companies in our group of companies;
Third party service providers and collaborators who assist and enable us to use the Personal Information to, for example, support the delivery of or provide functionality on the Services, or to market or promote our Services to you;
Regulators, law enforcement bodies, government agencies, courts or other third parties where we think it is necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;
An actual or potential buyer (and its agents and advisors) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and/or
Other people where we have your consent.
International Data Transfers.
When we share data, it may be transferred to and processed in countries other than the country you live in such as Turkey where our data hosting provider’s servers are located. These countries may have laws different to what you’re used to. Where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.
The security of your Personal Information is important to us. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens. We will do our best to protect your Personal Information but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
The length of time we keep your Personal Information depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements).
We’ll retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we’ll make sure it’s deleted or anonymised. We will endeavour to keep your Personal Information for the minimum period possible.
During the use of the Services and/or marketing activities within the Application, on the mobile phone from which the Application was downloaded, based on the legal reason that “it is necessary for the legitimate interests of the data controller COWEALTHY provided that it does not harm the fundamental rights and freedoms of our data subject users”, “the business processes and Instant push notifications are sent to carry out marketing activities.
If our users do not want to receive push notifications sent by COWEALTHY this feature can be turned off completely via the user preference settings on mobile phones with both Android and IOS operating systems.
As COWEALTHY, we do not process, store or see your information about your payments (credit card, bank account, etc.). In addition, we do not have access to your financial payment information. Payment transactions while using the Services are made through payment system providers licensed by the BRSA, who have taken all technical and administrative measures and data security measures to protect personal data.
Storage and disposal of personal data
COWEALTHY stores the personal data it processes for the periods determined by the legislation, and in the absence of a separate period specified in the legislation; personal data is stored for the period that requires processing in accordance with the practices of the Application and its commercial life, depending on the services COWEALTHY provides while processing that data, and after this period, only for the periods of time required in practice in order to constitute evidence in possible legal disputes. After the expiry of the specified periods, the personal data in question is deleted, destroyed or anonymized.
It’s your Personal Information and you have certain rights relating to it. When it comes to marketing communications, you can ask us to not send you these at any time by following the unsubscribe instructions in our marketing communications, you can also email us directly at firstname.lastname@example.org.
You also have rights to:
know what personal data we hold about you, and to make sure it’s correct and up to date;
request a copy of your personal data, or ask us to restrict processing your personal data or delete it; and
object to our continued processing of your personal data.
You can exercise these rights at any time by making a request by emailing us directly at email@example.com.
If you are not happy with how we are managing your Personal Information, please let us know by getting in touch with us via firstname.lastname@example.org. We will review and investigate your complaint and do our best to get back to you in a reasonable time. You can also complain to your local data protection authority. They will be able to advise you how to submit a complaint.
Our Services are not directed to children under the age of 13. You are not permitted to use the Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect Personal Information from children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected Personal Information of a child under the age of 13 (or under the age of 16 in certain jurisdictions), we will take steps to delete such information from our records as soon as possible and terminate the child’s account until we receive verifiable parental consent.
How to contact us.
Current time and effectiveness
COWEALTHY reserves the right to make changes regarding this text. This Clarification Text is dated 17.01.2022, and if it is partially or completely updated by COWEALTHY, it will be published via the Application as of the effective date and made available to the relevant person users.