Data Privacy, Protection Policy

BUDDY, primarily in accordance with the Personal Data Protection Law No. 6698 ("PDPL") and other Relevant Legislation, adopts the principle of protecting the confidentiality of your personal data and agrees to act in compliance with all legal obligations regarding the processing of your personal data.

BUDDY's Data Protection Policy has been prepared to provide you with information on how and for what purpose your personal data is processed and protected by BUDDY, with the aim of ensuring the highest level of transparency possible.

Scope of the Privacy Policy

This Data Protection Policy covers only personal data within the Buddy Application, and does not cover information collected by applications outside BUDDY's control, communication channels belonging to Member Merchants, websites, and platforms, information collected by Member Merchant Sites through the application, or campaigns and other advertisements or promotions. BUDDY is not responsible for the processing of personal data collected, stored, and used by Member Merchants through their own websites or other channels.

Definitions

Personal data: Any kind of information related to an identified or identifiable real person, Anonymization: Making personal data impossible to associate with any identified or identifiable real person, Processing of personal data: Any kind of transaction performed on data, such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making obtainable, classifying, or preventing the use of data, either entirely or partially, through automatic or non-automatic means, as part of any data recording system.

How is Your Data Obtained?

Our main purpose in collecting your data is to provide you with a secure, uninterrupted, efficient, and personalized service. Except for the provisions stipulated in the Relevant Legislation, BUDDY and service providers acting on behalf of BUDDY collect and use your personal data within the scope of the necessary permissions and in accordance with the following processes.

We collect your data using the following methods:

Data Directly Provided by Member Companies and Users: These data refer to the personal data that Users and/or Member Companies directly provide to BUDDY before or during their use of the Application. These personal data include all personal data provided directly by Users to BUDDY.

Data Obtained When Using the Application: These include personal data related to Users' usage habits obtained through the Application during the provision of BUDDY's services.

Detailed information on the collection of data and the purposes for which they are collected can be found below.

Which Data is Collected?

The data collected by BUDDY depend on the services and features it uses, and below, we have listed the data that are considered personal data according to PDPL and Relevant Legislation, and that are processed by BUDDY within the scope of the services provided.

Identity Verification Information: Username, last name, email address, membership information provided directly to BUDDY by Users for identity verification and account access purposes.

Data Usage: These include, but are not limited to, satisfaction surveys or similar survey results that can be conducted through the Application, data collected from your devices through various software and technological tools, information about the type of messages (text, video, etc.) sent without keeping content information, active time intervals, the services followed, usage habits related to the Application interface, the last login date to the Application, and errors that occur during Application use, as well as analytical data related to reward programs, if any, collected from Users by other services.

Point and Badge Acquisition Data: Data on the monetary and non-monetary gain data of Users during their use of the application.

Device Data: Brand of the device, operating system of the device, language used by the user, information about the user's mobile operator, country information.

How Does Buddy Use Collected Data?

In accordance with the purposes specified in this Data Protection Policy and the User Agreement, your personal data will be processed within the scope of PDPL and Relevant Legislation, and the detailed information on the purposes for which the data categories mentioned above will be processed is provided below.

User registration, problem/error reporting, control, improvement of operational activities, execution, business development, collection, internal evaluation, customer portfolio management, measurement of service quality, communication, internal evaluation, promotion, and opportunity notification, service analysis, complaint management, management of customer satisfaction processes, processing for the purpose of transferring the application membership to other devices.

Processing for purposes such as promotion, internal evaluation, analysis, communication, business development through statistical evaluation via Anonymous Data, without identifying a single user.

Processing for the purpose of improving business processes, availability of existing services, marketing, advertising, profiling, audit and control, risk management, improvement of after-sales processes, internal evaluation, portfolio management, measurement, improvement of service quality, communication, and complaint management processes, and for the purpose of conducting operational activities and improving them based on usage habits.

Processing for providing location-based services, presenting location-based opportunities and campaigns, and ensuring control and supervision based on user preferences and device settings.

Processing for the purpose of managing billing processes, accounting, improvement of after-sales processes, business development, collection, internal evaluation, customer portfolio management, after-sales services, communication, marketing, audit, and control for users who purchase services through the application.

Processing for ensuring the optimum user experience with the device on which the application will work and compatibility with the language used.

Processing for the purpose of detecting usage habits and unauthorized and fraudulent use for business development and improving service quality. There is no purpose of monitoring such data for communication.

Processing for the purpose of backing up user communications upon user request. Within the scope of backup data, messages received by the user and sent by the user will only be archived upon the user's request. Users will be able to access backup data when they want to use the backup feature.

Processing to determine which contacts registered on the device where the application is installed are using the application, depending on the user's control of device settings.

Where is Personal Data Stored and Processed?

The Personal Data mentioned above, as required by this Policy and in compliance with the regulations to be issued by the Personal Data Protection Authority within the framework of PDPL, may be stored and processed in a facility located in another country where BUDDY or its affiliated companies, subsidiaries, or service providers have established a facility. Your personal data collected within the scope of this Data Protection Policy will be processed in accordance with the provisions hereof and within the framework of the legislation in effect in the country where the data is stored and processed, including the prescribed security measures.

Who are the Data Shared With?

BUDDY may share Users' personal data and the new data obtained using this personal data with third parties, including software service providers, hosting service providers, law firms, research companies, software companies providing complaint management and security, agencies, consulting companies, and social media platforms, among others, in order to fulfill any of the purposes set forth in this Data Protection Policy, subject to the provisions of the Relevant Legislation (conditions for lawful processing of personal data). In addition, Users' personal data may be shared with public institutions and organizations authorized under the current legislation, as required by their duties and powers. Sharing with third parties of any communications content shared with third parties as part of communication content shared by Users for the purpose of establishing communication is not covered by this article. BUDDY may transfer Users' personal data to third parties both domestically and abroad, in accordance with this Data Protection Policy and the provisions of the legislation in effect.

User’s Rights

By applying to our Company through the application channel specified below, you have the following rights:

To learn whether your personal data is being processed,

To request information if your personal data has been processed,

To learn the purpose of processing your personal data and whether they are used in accordance with that purpose,

To know the third parties to whom your personal data is transferred at home or abroad,

To request correction if your personal data is incomplete or incorrectly processed,

Within the scope of the relevant legislation, to request the deletion or destruction of your personal data if the reasons for its processing disappear,

To request notification to third parties to whom your personal data has been transferred, in case your personal data is corrected, deleted, or destroyed,

To object to the occurrence of a result against you by analyzing your processed data exclusively through automated systems,

To request compensation for the damage you have suffered in case your personal data is processed unlawfully.

Storage Period for Personal Data

BUDDY will retain the personal data it obtains for the time necessary to fulfill the purposes stated in this Data Protection Policy and the Membership Agreement, in accordance with the terms and conditions specified therein, and to fulfill the obligations arising from the nature of the Membership Agreement. The user will deactivate the application from the device and the information will be stored in the background, but it will not be used. In addition, BUDDY may keep personal data for a limited period, which is determined by the legislation in effect and required for the realization of defenses in case of any dispute arising from the Membership Agreement.

Data Security Measures

BUDDY will take the necessary security measures to protect your personal data in a secure manner, to prevent its unlawful processing and access, and to ensure the protection of personal data by providing the appropriate level of security. It will carry out technical and administrative measures using various methods and security technologies to ensure the security of your personal data. In addition, personal data is processed by the Institution with sufficient precautions determined by the Institution for special quality personal data. BUDDY will not disclose or use the personal data it has obtained about Users to third parties or use them for purposes other than processing, in violation of this Data Protection Policy, PDPL No. 6698, and Relevant Legislation. BUDDY takes the necessary precautions for external service providers to comply with the provisions of this article when sharing personal data of Users with external service providers. However, if links are provided to other applications through the Application and during the third-party processes offered in the Application, BUDDY shall not assume any responsibility regarding the information provided by the User on issues such as the information provided by the User regarding the communication content.

Changes to the Data Protection Policy

BUDDY may update and change the provisions of this Data Protection Policy at any time by publishing them through the Application. The updates and changes made by BUDDY to the Data Protection Policy will be effective as of the date they are published on the Application.

Contact

For all questions and requests related to your personal data within the scope of the Personal Data Protection Law No. 6698, you can contact Buddy@buddyperformance.com in writing (through a notary public, etc.).