DATA PRIVACY NOTICE PURSUANT TO THE PERSONAL DATA PROTECTION LAW
CONFIDENTIALITY OF PERSONAL DATA
In This Is a Company Teknoloji Gelişim ve Yatırım A.Ş. (“TIAC”), we are very pleased with the interest that
you have shown towards our mobile application. Your personal data that you have transferred to us due to
transactions executed over our mobile application (“Mobile Application”) are protected with utmost care and
diligence and are processed in line with the applicable legislation.
DATA PRIVACY NOTICE FOR PERSONAL DATA PROCESSING DATA PRIVACY
Pursuant to Article 10 of the Personal Data Protection Law no. 6698 (“PDPL”) which is titled “Data
Controller’s Privacy Notice Obligation”, we, acting as the data controller, are under the obligation to
inform data subjects about the identity of TIAC, the purposes for processing their personal data, those
parties to whom personal data are transferred and the purpose of such transfer, legal grounds and methods
for collecting personal data as well as the rights of such data subjects as listed in Article 11 of the PDPL
that they may wish to exercise towards the data controller. This Data Privacy Notice pursuant to the
Personal Data Protection Law (“Privacy Notice”) is hereby drawn up to inform data subjects and to allow
TIAC, acting as the data controller, to account for the processing of personal data of FRINK users in line
with the PDPL.
You can find more detailed information about the processing of your personal data that you have disclosed to
TIAC by reading TIAC’s Policy for the Protection and Processing of Personal Data by visiting our web site at
www.thisisacompany.com.
a. Identity of the Data Controller:
Article 3/1 (ı) of the PDPL defines a data controller as “an individual or entity that determines the
purpose and means to process personal data and is responsible for the establishment and management of a data
recording system”. Article 10/1(a) of the PDPL which is titled “Data Controller’s Privacy Notice Obligation”
prescribes that the identity of the data controller should be informed to a data subject.
TIAC may be a “data controller” under the PDPL due to your disclosure of your personal data to us in both
the Mobile Application and at our web site. In this respect, “the identity of the data controller” is THIS
IS A COMPANY TEKNOLOJİ GELİŞİM VE YATIRIM ANONİM ŞİRKETİ, a joint-stock company organized pursuant to
Turkish Republic law and registered with Istanbul Trade Registry under the registration no. 225814-5, with
its headquarters located at Ömer Avni Mah., Meclis-i Mebusan Cad., İnebolu Sok., No:1, Ekemen Han, Kat:4,
Kabataş, Beyoğlu, Istanbul (MERSIS no: 0843068587600001).
b. Purpose of processing Personal Data:
Your Personal Data shall be processed in line with the principles of personal data processing as listed in
Article 4 of the PDPL and on the basis of one or several of conditions applicable to personal data
processing as set forth in Article 5 of the PDPL. All personal data processing activities carried out by
TIAC are in conformity with the obligations prescribed in the entire legislation, including the PDPL.
Among the purposes of processing your personal data are, subject to such conditions and purposes applicable
to personal data processing as listed in Articles 5 and 6 of the PDPL, to ensure that our business units
shall carry out such works that may be necessary to allow you to make use of products and services offered
by us, to perform any contract in relation to such products and services offered by us, to perform the
membership (user) agreement made between you and us, to plan and carry out such activities necessary to
offer and promote such products and services offered by us by customizing them based on your likes, habits
of use and needs and to enhance your user experience, to allow our business units do necessary works and
handle related business processes in order to allow data subjects to make use of products and services
offered by our Company and to enhance their experience, to ensure the legal, technical and commercial
security of our Company and persons engaged with a business deal with our Company and to map out and apply
commercial and business strategies of our Company. Detailed information about the purposes. Detailed
information about purposes by which our Company processes your personal data are given in TIAC Policy for
Personal Data Processing and Policy by visiting our web site at www.thisisacompany.com.
c. To whom processed Personal Data may be transferred and for what purpose:
Your personal data collected by us may be transferred to our business partners, suppliers, shareholders,
group companies, affiliates, statutorily authorized public agencies and private persons based on the legal
grounds set out in Paragraph (d) hereof and for purposes listed in Paragraph (b) hereof and in line with the
purposes and conditions to process personal data listed in Articles 8 and 9 of the PDPL and in a manner
limited to the purposes defined in TIAC Policy for the Protection and Processing of Personal Data, which you
can read by visiting www.thisisacompany.com.
d. Our Methods and Legal Grounds to Collect your Personal Data:
Your personal data are collected by us (TIAC) by means of your registration for the use of Mobile
Application and the web site and from different channels, including contracts made between our Company and
you and in line with the applicable laws. Your personal data may be processed and transferred for the
purposes set out herein commensurate with the purposes and pursuant to personal data processing conditions
as described in Articles 5 and 6 of the PDPL.
e. Rights of Data Subject:
As a data subject, you may send your demands about your rights by means of such methods described in the
TIAC Policy for the Protection and Processing of Personal Data, which has been published for public at the
web site www.thisisacompany.com. TIAC shall finalize your request free of charge as soon as possible
depending on the nature of the request, and at the latest, within (30) days.
In the event that inquires that you send to our Company in connection with your Personal Data require the
payment of a further cost, then this information will be provided to you on the condition that the fee set
out in the tariff determined by the Personal Data Protection Committee is paid. Below are the rights of
individuals whose personal data are processed as described in Article 11 of the PDPL:
- To inquire into whether his personal data are processed;
- To ask for information in case his personal data are processed;
- To inquire into the purpose underlying the process of his personal data, and whether or not such data
are used in line with that purpose;
- To know about third parties to in Turkey or abroad to whom his personal data are transferred;
- Where his personal data are processed incompletely or wrongly, then to ask for its correction and to
ask further that such corrective action shall be notified to third parties to whom his personal data are
transferred;
- Even if his personal data are processed in accordance with the PDPL and other applicable laws, in the
case that reasons for processing it are no longer applicable, to ask for the deletion or destruction of
his personal data, and to ask further that such action shall be notified to third parties to whom his
personal data are transferred;
- To object to any consequence that is detrimental to it and that arises from the analysis of processed
data by means of solely automated systems;
- To claim a damages in case you sustain a loss due to the unlawful process of your personal data.
As a data subject, you can send your inquiries about your rights to the following address pursuant to TIAC
Policy for the Protection and Processing of Personal Data:
frink@thisisacompany.com An application shall not be processed
unless it meets such conditions set by the Personal Data Protection Authority under the applicable
legislation and any additional information that may be requested from you is completed.
OPTIONAL RIGHTS
Provided that data that we store pursuant to legal requirements and our contractual relations are reserved,
we are willing to make use of your personal data in order to inform you about our products and services. It
is at your option to allow us to use your Personal Data for this purpose and in the event that you do not
give your approval or you are willing to withdraws your approvals previously given by you, your data shall
be blocked to access and their use for such purpose shall be terminated.
COOKIES
We use cookies at our web site in order to track user preferences. Cookies are tiny files embedded in the
hard disc of your computer. This facilitates your navigation, allowing for a more user-friendly use of the
web site. Cookies also help us identify the most popular areas of our web site. This way, we can create such
contents at our web site to meet your needs better and therefore we can improve the services offered to you.
Cookies may also be used to determine if there has been an access from your computer to our web site in the
past.
You can use our web site without cookies as well. You can discontinue the saving of cookies in your
computer’s hard disc by selecting the “deactivate cookies” in your browser settings. However, we would like
to draw your attention to the fact that many browsers automatically accept cookies and that unless you
accept that, your use of our web site will be limited.
SECURITY
We protect your personal data that you permit us to collect against losses, damages and access by
unauthorized persons and we therefore employ certain security measures. Our security measures are constantly
developed in parallel with technological advances.
RIGHT TO INFORMATION
We are obliged to inform you about whether or not there are personal data of yours that have been stored by
us under the PDPL, and if there are, then to allow you to view such data or to edit or change them if
necessary. In the event that you wish to get information about your Personal Data, we kindly request you to
complete and send the attached application form to our Company. Your request will be replied within 30 days.
TIAC reserves its right to unilaterally update this Privacy Notice in case business needs or statutory
requirements dictate so. We recommend you to visit our web site regularly to have access the most current
version of this notice.