Member-Subscriber Information
POTENTIAL CUSTOMER/CUSTOMER PRIVACY NOTICE
We, as Infoset Teknoloji Anonim Şirketi (“Company”) registered with Istanbul Trade Registry Office with the trade registry number 291692-5, would like to inform you as a Data Controller under Personal Data Protection Law numbered 6698 (“Law”) regarding your personal data that we process in terms of the processes in which you use https://infoset.app website and/or mobile application (“App”).
Personal Data Processed, Purposes of Processing of Personal Data, Transferred Parties and Purposes of Transferring
We process your personal data, which are included in the following processes, within the scope of the specified processing purposes, in the light of the general principles in Article 4 of the Law, by fully or partially automated or non-automated means, provided that they are part of any data recording system, and transfer them to the specified recipient groups. Our Company takes necessary administrative and technical measures to ensure the security of your personal data.
The following personal data are processed when you visit the App but have not created a trial membership:
| Process | Personal Data | Purpose of Processing | Legal Grounds | Transferred Party | Purpose of Transfer |
|---|---|---|---|---|---|
| If you send an e-mail to [email protected] e-mail on the homepage of our application. | Identification (Name, Surname) Contact (E-mail Address, Telephone Number) Professional Experience (Workplace) Other (Your Request/Query) | Conducting Sales Processes; Contacting Potential Members Finding out which Real Person/Legal Entity the Potential Customer is | Establishment of the agreement Compulsory for the legitimate interest of the data controller | Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. |
| If you want to get information by calling the call center phone number on the homepage. | Identification (Name, Surname) Contact (E-mail Address, Telephone Number) Audio Recordings (Voice Recording); Professional Experience (Workplace) Other (Your Request/Query) | Conducting Sales Processes Contacting Potential Customer Finding out which Real Person/Legal Entity the Potential Customer is | Establishment of the agreement Compulsory for the legitimate interest of the data controller Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Conducting communication processes Receiving server infrastructure service |
| If you request information by sending a message via the chatbot and live chat on the application homepage. | Identification (Name, Surname); Contact (E-mail Address, Telephone Number) Transaction Security (IP Address) Location (Location Details) Other (Your Request/Query) | Conducting Sales Processes Contacting Potential Member, Finding out which Real Person/Legal Entity the Potential Customer is; Ensuring Transaction Security | Establishment of the agreement Compulsory for the legitimate interest of the data controller Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Conducting communication processes Receiving server infrastructure service Ensuring transaction security |
| If we contact you through social media platforms and obtain your personal data thereupon. | Identification (Name, Surname) Contact (E-mail Address, Telephone Number) Professional Experience (Workplace) Other (Your Request/Query) | Conducting Sales Processes Contacting Potential Member - Finding out which Real Person/Legal Entity the Potential Member is; | Establishment of the agreement Compulsory for the legitimate interest of the data controller Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Conducting communication processes Receiving server infrastructure service |
The following personal data is processed if you visit the App as directed by the Customer or the Company's business partners:
| Process | Personal Data | Purpose of Processing | Legal Grounds | Transferred Party | Purpose of Transfer |
|---|---|---|---|---|---|
| If you log in to the App as directed by Infoset business partners. | Identification (Name, Surname) Contact (E-mail Address, Telephone Number) Professional Experience (Workplace) Transaction Security (Cookie related to logging in to the Application from the business partner URL) Other (Information on which product you need) | Conducting Sales Processes; Contacting Potential Members; Finding out which Real Person/Legal Entity the Potential Customer is; Determining Which Business Partner Referred the Potential Customer | Establishment of the agreement Compulsory for the legitimate interest of the data controller Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service Conducting communication processes |
| If existing Infoset subscribers share your contact information with us upon your request. | Identification (Name, Surname) Contact (E-mail Address, Telephone number) Professional Experience (Workplace) Other (Information on which product you need) | Conducting Sales Processes Contacting Potential Member, Finding out which Real Person/Legal Entity the Potential Member is | Establishment of the agreement Compulsory for the legitimate interest of the data controller Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service Conducting communication processes |
The following personal data are processed during the processes in which we contact you for the purpose of promoting the application:
| Process | Personal Data | Purpose of Processing | Legal Grounds | Transferred Party | Purpose of Transfer |
|---|---|---|---|---|---|
| If we contact you through various applications and you share your contact information with the Company. | Identification (Name, Surname) Contact (E-mail Address, Telephone number) Professional Experience (Workplace) Other (Information on which product you need, if any) | Conducting Sales Processes Contacting Potential Member | Establishment of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service Conducting communication processes |
The following personal data are processed if you create a trial membership on the App
| Process | Personal Data | Purpose of Processing | Legal Grounds | Transferred Party | Purpose of Transfer |
|---|---|---|---|---|---|
| If you create a trial membership on the App. | Identification (Name, Surname); Contact (E-mail Address, Telephone Number) Professional Experience (Workplace), Transaction Security (IP Address) | Conducting Sales Processes Contacting Potential Member Finding out which Real Person/Legal Entity the Potential Customer is | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service Ensuring transaction security |
The following personal data are processed if you subscribe to the App:
| Process | Personal Data | Purpose of Processing | Legal Grounds | Transferred Party | Purpose of Transfer |
|---|---|---|---|---|---|
| Agreement processes according to the type of use of the App (Onprem or SaaS) | Identification (Name, Surname, Identification Number, Signature, List of Authorized Signatories) Contact (Address, Telephone number, E-mail Address) Professional Experience (Workplace, Title) Legal action (Product Agreement) | Conducting agreement processes | Establishment of the agreement | Our foreign based service providers from which we receive technical services | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
| Payment or refund processes of subscription fees by credit/debit card. | Identification (Name, Surname, Foreign Identification Number, Tax Identification Number) Contact (Address, Telephone number) Transaction Security (IP Address, Payment ID); Finance (Bank Account/Card Details) | Conducting Subscription Fee Collections Conducting invoicing and forwarding transactions Conducting Refunds Issuing and Forwarding the Refund Invoice | Performance of the agreement Fulfilling legal obligations Explicit consent (for transferring abroad) | Our domestic and foreign based service providers from which we receive technical services. | Conducting Retention and Archiving Activities Conducting Subscription Fee Collections Conducting Card Retention and Periodic Payment Transactions |
| Payment or refund processes of subscription fees by write transfer/EFT. | Identification (Name, Surname) Contact (E-mail Address); Finance (Bank Account Details) | Conducting Subscription Fee Collections | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services, bank for refund | Conducting Retention and Archiving Activities Conducting Subscription Fee Collections Sending Reminder E-mails to Non-Payers |
| Reminding those who failed to pay their subscription fees | Contact (E-mail address) | Processes for sending reminder emails | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Sending Reminder E-mails to Non-Payers |
| Invoicing and forwarding process. | Identification (Name, Surname; Foreign Identification Number; Tax Identification No) Contact (Address) Finance (Payables/Receivables Details, Invoice Details) | Conducting invoicing and forwarding transactions | Performance of the agreement Explicit consent (for transferring abroad) | Our domestic and foreign based service providers from which we receive technical services | Conducting Retention and Archiving Activities Conducting Invoice Issuing Transaction Forwarding the Issued Invoice to the Paying Party |
| Payment request form processes | Identification (Name, Surname) Finance (Payables/Receivables Details); Contact (E-mail Address) | Reminding Payment of Balance Payables | Performance of the agreement Explicit consent (for transferring abroad) | Our domestic and foreign based service providers from which we receive technical services. | Sending reminder e-mails |
| Processes where mass e-mails are sent to subscribers. | Contact (E-mail Address) | Sending E-mails for Marketing and Advertising Purposes | Explicit Consent | Our foreign based service providers from which we receive technical services. | Ensuring E-Mail Delivery |
*Our Company does not process personal data such as the 16-digit card number, CCV number and expiration date of the credit/debit card you make transactions with.
The following personal data are processed if you use the services within the Application during trial membership or after subscribing*:
| Process | Personal Data | Purpose of Processing | Legal Grounds | Transferred Party | Purpose of Transfer |
|---|---|---|---|---|---|
| If you log in to the App with a Google or Microsoft account. | Contact (E-mail address) | User's Easy Access to the Platform | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
| If you send e-mails through the App by connecting your own e-mail account to the Application. | Contact (E-mail address) | Enabling the Subscriber to Enjoy Subscription Services | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
| If Banner and Announcement screens are used. | Contact (E-mail Address, Telephone number) | Making Announcements to Subscribers or Members | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Conducting communication processes Receiving server infrastructure service |
| If Chat Trigger and Chatbot modules are used. | Any Personal Data in the Chat Content | Enabling the Subscriber to Enjoy Subscription Services | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
| If the Audit Logs module is used within the Enterprise Hub package. | Transaction Security (IP Address, Login time) | Enabling the Subscriber to Enjoy Subscription Services | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
| Conducting Syslog processes if Enterprise Hub package is used. | Transaction Security (Audit Logs) | Enabling the Subscriber to Enjoy Subscription Services Ensuring transaction security | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities |
| Conducting log processes | Transaction Security (Used ID, Operating system details, Browser Details, Logs apart from audit logs) | Enabling the Subscriber to Enjoy Subscription Services Ensuring transaction security | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
* We would like to point out that if you save and process personal data belonging to your potential customers, customers, employees and other persons to the App while using the App, our Company will be in the role of data processor, therefore, the obligations arising from being a data controller within the scope of the Law and secondary legislation regarding the relevant personal data must be fulfilled by you. Accordingly, you are responsible for informing the data subjects about the personal data you process within the Appor transfer to us in any way other than the App and obtaining their explicit consent.
The following personal data are processed if you receive technical support from our Company during the use of the application:
| Process | Personal Data | Purpose of Processing | Legal Grounds | Transferred Party | Purpose of Transfer |
|---|---|---|---|---|---|
| If you request technical support via remote connection. | Identification (Name, Surname) Contact (Province of Residence, Address, E-mail Address, Telephone number) Transaction Security (IP Address); Professional Experience (Position Details, Workplace) Visual and Audio Recordings (Photograph; Voice Recording); Other (Problem/Request/Complaint Details) | Providing Support Services | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
| If you request technical support via e-mail. | Identification (Name, Surname) Contact (E-mail Address) Professional Experience (Position Details, Workplace) Other (Problem/Request/Complaint Details) | Providing Support Services | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
| If you request technical support via live support or Chatbot. | Identification (Name, Surname) Contact (E-mail Address, Telephone number) Transaction Security (IP Address) Location (Location Details) Professional Experience (Position Details, Workplace) Other (Problem/Request/Complaint Details) | Providing Support Services | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
| If you request technical support via the call center. | Identification (Name, Surname) Contact (Telephone Number) Professional Experience (Position Details, Workplace) Visual and Audio Recordings (Voice Recording) Other (Problem/Request/Complaint Details, calling number, date and time of the call) | Providing Support Services | Performance of the agreement Explicit consent (for transferring abroad) | Our foreign based service providers from which we receive technical services. | Carrying Out Retention and Archiving Activities Receiving server infrastructure service |
- Personal Data Collection Method and Legal Grounds
Your personal data is collected electronically and physically through information and documents transmitted through the Application, customers, business partners or other methods.
- Personal Data Retention Period
You can always submit your requests regarding your personal data processed by us within the scope of Article 11 of the Law in writing in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller or by using your registered electronic mail (KEP) address, secure electronic signature, mobile signature or your e-mail address that you have previously notified us and registered in our system to the following addresses
Data Controller: İnfoset Teknoloji Anonim Şirketi Anonim Şirketi
E-mail:[email protected]
Kep (Registered E-mail) Address:[email protected]
EXPLICIT CONSENT FORM FOR PROCESSING OF PERSONAL DATA
I hereby agree and declare that I give my explicit consent under my free will to the transfer of my personal data processed by the Company for the purposes specified in the Potential Customer/Customer Privacy Notice ("Privacy Notice") prepared by Infoset Teknoloji Anonim Şirketi ("Company") within the framework of the Personal Data Protection Law numbered 6698 ("Law") to the technical infrastructure providers and suppliers abroad and that I have been informed about my rights arising from the Law.
Furthermore, I hereby agree, declare and undertake that while using the application of your Company, I have informed the data subjects as the data controller regarding the personal data belonging to my potential customers, customers, employees and other persons that I have processed/saved in the application for my own purposes, and that I have obtained the necessary explicit consents from them, and that I will hold the Company free from any damages in the event of any damage arising in relation to this matter.
Last updated: 10.10.2023