Souldy Privacy Policy

Souldy Tech Technology, Education and Consulting LTD. STI. (“Souldy”), we have prepared this Privacy Policy in order to inform you about the methods and purposes of processing your personal data and your rights.

We would like to remind you that by downloading the Souldy mobile application ("Application") or using the www.souldy.com website ("Website"), you will be deemed to have accepted the terms and conditions of the Souldy User Agreement and Privacy Policy.

Within the scope of the law, personal data is defined as “any information relating to an identified or identifiable natural person”; The processing is “the acquisition, recording, storage, preservation, modification, rearrangement, disclosure, transfer, taking over, making available, classification of personal data fully or partially automatic or non-automatic, provided that it is part of any data recording system. or any kind of operation performed on the data, such as preventing its use.

As Souldy, we would like to bring the following explanations to the attention of all our users, including the third parties who use the Website and/or Application, in order to fulfill the disclosure obligation regulated in Article 10 of the Personal Data Protection Law (“KVKK”) with regard to personal data regarding our users.

We may update this Privacy Policy from time to time in order to inform our users in the most up-to-date and comprehensive way, and that you can always access the most up-to-date version of the Privacy Policy on the "www.souldy.com" website, you can send your questions, opinions, suggestions and requests to [email protected]. We want you to know that you can always send it to us via the souldy.com e-mail address or other communication channels below.

Which Personal Data Do We Process For What Purpose?

In accordance with the basic principles stipulated in the law and the relevant legislation, registration of the SOULDY application website and application, making the necessary studies to benefit from the services provided by SOULDY, adapting our services according to your taste and needs, determining the strategies of SOULDY and It can be processed for the purpose of application, solution of technical problems and anonymous marketing and advertising.

Your user information may be shared with Google and / or Apple by using Google Customer Match (Google Customer Match) and Apple services for ad targeting purposes. The Google Customer Matching service allows Google to use your user information to reach you by targeting through its advertising network (e.g. Search, Gmail, Youtube) and to view marketing messages tailored to you. Google users can control the ads they see on Google services, including Customer Match ads, in their Google ad settings.

Your personal data;

Name and Contact Information: We do not collect your name and contact information from within the application; We keep records in case of returns or questions/suggestions. Internal evaluation, communication, obtaining potential customer information, development of after-sales processes, business development, collection, customer portfolio management, promotion, analysis, complaint management, managing customer satisfaction processes, marketing, advertising, research, invoicing, event notification, operational execution of activities, measurement and improvement of service quality, audit, control, optimization, customer verification, marketing, sales, advertising, after-sales services, fraud detection and prevention;

Usage Data and Favorites: Problem/error reporting, control, execution and development of operational activities, after-sales services and development of post-sales processes, business development, collection, internal evaluation, online behavioral advertising and marketing, customer portfolio management, measurement of service quality and development, communication, optimization, audit, risk management and control, promotion, analysis, determination of interests, scoring, profiling, marketing, sales, advertising, communication, complaint management processes, registration, problem / error reporting;

Location data: We do an approximate location analysis using App Store and Google Play Analytics, not through the app. Direct location data is not stored. Use of location-related or location-related functions of our services and products, audit and control, risk management, marketing, sales, after-sales services;

Payment Data: Managing the invoicing process, accounting, development of post-sales processes, business development, collection, internal evaluation, scoring, profiling, customer portfolio management, after-sales services, communication, marketing, audit, control, processes carried out with payment service providers;

Content: Business development, optimization, customer portfolio management, audit, control, development of operational activities, business development, promotion, internal evaluation, customer management, analysis, scoring, profiling, development of after-sales processes, collection, after-sales services, communication, measuring and improving service quality, conducting complaint management processes;

Survey Answers: The information requested from the users who responded to the surveys organized by Souldy, the real and/or legal entities that Souldy cooperates with for the use of the functions related to the products and services and the fulfillment of these functions by Souldy, and all the above-mentioned in accordance with the intended use of the products and services. marketing directly to these users, performing statistical analysis, improving processes and creating a database by third natural and legal persons with whom it cooperates within the scope of processing activities;

To fulfill the obligations arising from the contracts made by Souldy with the business partner/customer/service providers, to establish rights, in order to fulfill the legal and commercial obligations within the framework of the contracts made or the activities carried out and the obligations arising from the legal regulations with the third real or legal persons who are in a business relationship with Souldy, protecting rights, conducting commercial and legal evaluation processes, conducting legal and commercial risk analysis, conducting legal compliance process, carrying out financial affairs, fulfilling legal requirements, fulfilling the decisions of authorized institutions, organizations and authorities, answering their demands;

within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law No.6698 and under all circumstances.

• In accordance with the law, justice and honesty rules,
• In the most up-to-date form notified to us,
• For specific, open, transparent and lawful purposes,
• Limited and measured for processing purposes

We can process them by storing them for the time required for the purpose for which they are processed or stipulated in the relevant legislation.

Your Personal Data will be stored for 6 (six) months following the deletion of the Application or termination of your membership in order to speed up the transactions and for user satisfaction, in case you wish to become a member again later.

In addition to these, Souldy can also analyze your personal data by anonymizing them, conduct research and use this data both to provide you with a better service and in some scientific and statistical studies.

HOW DO WE OBTAIN YOUR PERSONAL DATA?

• Forms on our websites or third-party websites that you fill in to contact us or share your experiences, opinions and suggestions about us,
• Cookies used to recognize you, our mobile applications,
• All kinds of e-mails, requests, work orders, faxes and letters you have sent to our company with the various contracts you have signed with our company,
• Third party company(s) that processes data on behalf of our company or supports our company at any stage of the membership program process,
• Our customer service channels, including our employees, digital marketing and call center,
• Social media channels, Google etc. use of search engines,
• Membership agreements and other agreements, campaigns, applications, forms, offers,

From your personal data obtained in accordance with the above-mentioned methods, your data required for the establishment of the contract and the execution of the contract in the event of a contract with you, provided that it is directly related to the establishment or execution of a contract, provided that it is directly related to the establishment or performance of a contract. It will only be processed based on the User Agreement and Privacy Policy without your express consent, based on the exception of "the processing of personal data is necessary".

“Explicit consent” based on the first paragraph of Article 5 of the Law, “explicitly stipulated in the laws” in subparagraph (a) of the second paragraph of Article 5 of the Law, and “directly related to the establishment or performance of a contract” in subparagraph (c). It is necessary to process the personal data of the parties to the contract, provided that it is necessary to process the personal data of the parties of the contract”, “it is necessary for the data controller to fulfill its legal obligation” in subparagraph (ç), “data processing is mandatory for the establishment, exercise or protection of a right” It can be processed based on the legal reasons stated in subparagraph (f) that "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".

We would like to remind you that by downloading the Application to your mobile device and/or visiting the Website, you will become a party to the Souldy User Agreement and Privacy Policy, and your personal data may be processed without express consent, based on the legal reasons in Article 5/2 of the KVKK.

All your personal data, other than your personal data required for the establishment or performance of the contract between you and Souldy, will be processed based on your express consent, if you give your express consent after reading this Privacy Policy. You have the right not to give explicit consent to the processing of your personal data other than your personal data required for the execution of the contract during or in the continuation of the contract, this express consent is not a prerequisite for establishing a contract with you or purchasing products, and using the following communication means, arising from Article 11 of the KVKK. We would like to point out that you can use all your rights and thus request the destruction of your personal data.

Cookie (Cookie etc.) Application

Various types of cookies are used on the Website. These are cookies such as session cookies, persistent cookies, essential cookies, functionality cookies, analytics cookies, commercial cookies and third party cookies.

Cookies help the website to work properly and improve, to personalize and improve the user experience, to visit the websites without logging in and/or to send commercial-social notifications to the site (even if the internet browser is closed, depending on the situation), and to site users-visitors in general. These are small pieces of data placed on computers in order to provide and transmit general or customized information, advertisements and promotions both on the relevant site and on other sites (including social media-networks and online advertising networks).

Cookies are kept on computers-devices for a suitable period of time, provided that the legal maximum period, if any, is not exceeded.

Persons using the Website are deemed to have accepted the above-mentioned application, as well as the processing of the relevant cookies in the personal data legislation and other parts of this information text for the purposes and scope-conditions stipulated for your various information (including transfer-sharing and use to third parties in this framework).

Visitors can remove cookies and/or stop the aforementioned notifications at any time by editing the program and/or operating system and/or internet browser settings on their devices; however, it should be known that the Website may not work as desired and/or not be aware of the notification contents.

Purpose of Use of Cookies

Our website uses first and third party cookies. First-party cookies are mostly necessary for the website to function correctly, they do not keep your personal data. Third-party cookies are used to improve our website's performance, interaction, security, advertisements and ultimately a better service. It helps speed up user experience and future interactions with our website. In this context, cookies;

Statistics: These cookies include the number of visitors to the website, the number of unique visitors, which pages of the website are visited, the source of the visit, etc. stores information. This data helps us analyze and analyze how well the website is performing.

Marketing: Our website advertises. These cookies are used to personalize the ads we show you in a way that is meaningful to you. These cookies also help us track the efficiency of these advertising campaigns. The information stored in these cookies may also be used by third-party ad providers to show you ads on other websites in the browser.

Functional: These are cookies that help some non-essential functions on our website. These functions include embedding content such as videos or sharing website content on social media platforms.

Preferences: These cookies help us save your settings and determine your browsing preferences, such as language preferences, so that you have a better and more efficient experience on future visits to the website.

Technically, the types of cookies used on our website are shown in the table below.

(Session Cookies) : Session cookies are temporary cookies that are used during our visitors' visit to our website and are deleted after the browser is closed. Its purpose is to ensure that the Website functions properly during your visit.

(Persistent Cookies) : Persistent cookies are types of cookies used to increase the functionality of the website and to provide a faster and better service to our visitors. Such cookies are used to remember your preferences and are stored on your device via browsers.

(Technical Cookies) : With technical cookies, the operation of the website is ensured, and the pages and areas of the website that are not working are detected.

(Authentication Cookies) : If visitors log in to the website using their passwords, it is determined that they are a site user on each page they visit, and they are prevented from re-entering their password on each page.

(Flash Cookies) : These are the types of cookies used to enable image or audio content on the website.

(Customization Cookies) : These are the cookies used to remember the preferences of the users, such as language, when visiting different pages of different websites.

(Analytical Cookies) : These are cookies that monitor analytical results such as the number of visitors to the website, the detection of pages viewed, visiting hours, page scrolling movements.

The main purposes of using cookies on our website are listed below:

• To improve the services offered to you by increasing the functionality and performance of the website,
• To improve the Website, to offer new features on the Website and to customize the features offered according to your preferences,

To ensure the legal and commercial security of the Website, You and SouldyTech.

Controlling Cookie Preferences

Different browsers offer different methods to block and delete cookies used by websites. Browser settings must be changed to block/delete cookies. To learn more about how to manage and delete cookies, visit www.allaboutcookies.org. The visitor has the opportunity to customize his preferences for cookies by changing his browser settings.

Enforcement of the Policy

This Policy is effective on the date of publication. In case all or certain articles of the Policy are renewed, the effective date of the Policy is revised.

WHAT DO WE DO FOR THE SECURITY OF YOUR PERSONAL DATA?

We would like you to know that as Souldy, we provide all possible administrative and technical measures for the security of your personal data, and that we are developing and increasing all our administrative and technical measures day by day with a dynamic perspective by following the latest developments in technology and management procedures.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Your collected personal data in line with the above-mentioned purposes and based on the processing reason specified in Article 5/2(c) of the KVKK and limited for this reason; all kinds of service providers; We are able to transfer it to real or legal persons, legally authorized public institutions and private persons, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, in the event of participation and / or in any way with whom we cooperate.

Your personal data may be shared with our suppliers, business partners, shareholders and authorities for the purposes of conducting commercial and financial operations, carrying out activities with technical and administrative results, executing and monitoring legal processes, conducting internal operations and business processes, strategy planning & business partners/supplier management.

WHAT ARE YOUR RIGHTS?

According to Article 11 of the KVKK, we would like you to know that you have the following rights:

• Learning whether your personal data is processed,
• If your personal data has been processed, requesting information about it,
• Learning the purpose of processing your personal data and whether your personal data are used in accordance with the purpose of processing,
• To know the third parties in the country or abroad to whom your personal data has been transferred,
• Requesting correction of your personal data if it is incomplete or incorrectly processed,
• Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
• Requesting that the correction, deletion and destruction processes made in accordance with the relevant legislation be notified to the third parties to whom your personal data has been shared,
• Objecting to the emergence of a result against you by analyzing your processed personal data exclusively through automated systems,
• If you suffer damage due to unlawful processing of your personal data, requesting the compensation of the damage.

You can send us any of your requests or questions regarding these rights by choosing the most appropriate communication channels below.

Email : [email protected]
Souldy Tech Teknoloji, Eğitim ve Danışmanlık Ltd. Şti. (Tax Office: Zincirlikuyu, Tax Number: 7750824962)
Address : Levent, Talatpaşa Cd Şair Çelebi Sokak No1 Floor 2, Ortabayır Mah, 34413 Kagithane/Istanbul, Turkey

Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and within thirty days at the latest; however, if the transaction requires an additional cost, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Board.