PRIVACY POLICY STATEMENT 

1) Purpose:

This Privacy Policy Statement explains the methods used and the legal reasons for collecting personal data under Personal Data Protection Law No 6698 (Law), which personal data are processed when you as the User use the App or website, what said personal data is used for, to whom your personal data may be transferred and for what purposes, your rights as the Data Subject to have your personal data deleted, destroyed, and anonymized, and how you can exercise said rights.   

2 ) Identity of the Data Controller:

For the purposes of your personal data collected from you using the following methods, the Data Controller is Porty Smart Tech Technoloji Anonim Şirketi, Mersis number 0732165123300001, located at Esentepe Mahallesi, Büyükdere Caddesi, Metrocity, Blok No:171a, İç Kapı No:191 Şişli/Istanbul. 

Processed Personal Data and the Purpose of Processing:

Some of the personal data processed is provided directly by the User during or after signing up or creating a user profile. Some of the personal data is obtained automatically. The Use shares the following information with PORTY:

The company as Data Controller processes your personal data for the following purposes:

We need to process the personal data of the parties to the agreement such as name and surname, phone number, e-mail address, location information, IP address, device operating system and version, device type, hardware model, and user transaction records so we can provide you with services via our app, to create a membership record, for the performance of the agreement between us and to ensure Company compliance with regulations, and for the legal reasons stipulated in the laws;

We shall process your information relating to your name-surname, e-mail address, phone number, App usage data, location information, device ID, complaint and suggestion records, bank IBAN number, Porty wallet balance, payment and payment methods so we can provide you with services via our App, inform you about Campaigns and opportunities, and carry out pricing, payment, and customer relations processes for the legal reason that data must be processed for our Company’s legitimate interests provided that this does not harm your fundamental rights and freedoms and to the extent that it complies with the principles of proportionality and data minimization;

We shall process information relating to name-surname, phone number, IBAN number, amount owed, invoice number, payment, and payment methods to carry out invoicing and to follow up finance and/or accounting transactions for the legal reason that this is compulsory for our Company to fulfill its legal obligations;

We shall process correspondence with the judicial authorities, information included in the case file, membership date, customer ID, complaint and suggestion records, Porty usage details, call-center records, and App usage information so the Company can manage, audit, and improve its services and operations, conduct Market research and strategic planning, carry out personalized marketing activities, provide service, operation, and App security, detect fraudulent or illegal activities, detect and prevent scams and campaign abuse, and carry out internal audit, internal control, legal, financial, reporting, and internal operations for the legal reason that data must be processed for our Company’s legitimate interest provided that this does not harm your fundamental rights and freedoms and to the extent that it complies with the principles of proportionality and data minimization;  

4 ) Transfer of Personal Data:

We can share your personal data with the Public Institutions and organizations, affiliates, subsidiaries, business partners, lawyers, banks, and financial institutions we work with as part of the practices to be made to increase the quality of the service we provide to the extent allowed by the legislation and required by our business processes for the aforementioned purposes and with persons acting inside and on behalf of the Company within the scope of the conditions and purposes for processing personal data specified in Articles 8 and 9 of the Law. 

5 ) Deletion, Destruction, and Anonymization of Personal Data:

Within the scope of our policy and procedures determined per the Regulation on the Deletion, Destruction or Anonymization of Personal Data, we shall process your personal data for as long as required by our relevant activities and the data deleted either ex-officio or at the request of the data subject when you no longer have a relationship with our Company, there is no longer any reasonable or legal reason for processing them, or the reasons for processing them no longer exist.

6) Method of Collecting Your Personal Data and Legal Reason:

Our Company shall collect your personal data for the purposes specified in this Privacy Policy Text, by physical documents and e-mails, by non-automatic methods, via the mobile app and automatically on the website.  We shall process said personal data in accordance with Article 5, paragraph 2, subparagraph (c) of Law No. 6698 which states that the processing of the personal data of the parties to a contract is necessary provided it is directly related to the establishment or performance of a contract, and subparagraph (e) of the same, which states, “data processing is mandatory for the establishment, exercise, or protection of a right.”

7) Your Rights as the Data Subject:

You can send your requests under Article 11 of the Law in writing to the Company's address at “Esentepe Mah., Büyükdere Cad. Metrocity Blok No:171/A/191 Şişli / Istanbul” from your registered electronic mail (REM) address to our porty@hs03.kep.trREM address, or to our destek@porty.tech e-mail address by using your secure e-signature, mobile signature, or your e-mail address previously notified to XX and registered in our system. 

The Company can revise this Privacy Policy Text at its sole discretion. We shall inform you if and when such a revision is made. You can access the most up-to-date version of the Privacy Policy Text on the https://www.porty.tech/ and via the PORTY mobile app.