Privacy Policy
Policy of PAYMASTER TECHNOLOGIES ELEKTRONIK PAZARLAMA DIS TICARET LIMITED SIRKETI on the Processing and Protection of Personal Data (Privacy Policy)
1. General Provisions
1.1 This policy is implemented by PAYMASTER TECHNOLOGIES ELEKTRONIK PAZARLAMA DIS TICARET LIMITED SIRKETI, the rightholder of the WHOTAM software and the website https://whotam.com (the "Company"), with respect to the processing and protection of personal data (the "Policy") of personal data subjects in order to comply with applicable law.
1.2 The Policy applies to all personal data (subjects) that may be obtained by the Company in the course of its activities, including from Company clients, and to all applications, services, features, software and the website of the Company (collectively, the "services"), unless otherwise stated.
1.3 The purpose of the Policy is to provide persons who submit their personal data with the information they need to understand what personal data the Company processes, for what purposes, and what security measures are applied.
1.4 The Policy has been developed to protect the rights and freedoms of personal data subjects when their personal data is processed, and to establish the responsibility of Company officials with access to personal data for failure to comply with the requirements and rules governing personal data processing.
1.5 By using the Company's services and providing their personal data to the Company, including through third parties, clients consent to the processing of their personal data in accordance with this Policy.
1.6 Consent to the processing of personal data may be withdrawn by the personal data subject. If consent is withdrawn, the Company may continue processing personal data without the subject's consent where there are grounds provided for by applicable law. The personal data subject may withdraw consent at any time by sending a letter to Merkez Mah. Kagithane cad. A, office No 11/61 Kagithane/Istanbul/TURKEY, or an email to support@whotam.com. If the personal data subject withdraws consent, the Company must stop processing the data and, if retention of the personal data is no longer required for the purposes of processing, destroy the personal data within 30 (thirty) days from receipt of the withdrawal, unless otherwise provided by an agreement to which the personal data subject is a party, beneficiary or guarantor, by another agreement between the Company and the personal data subject, or unless the Company is entitled to process the personal data without the subject's consent on grounds provided for by applicable law.
2. Definition and Scope of Personal Data
2.1 For the purposes of this Policy, personal data means any information relating to a directly or indirectly identified or identifiable natural person (personal data subject).
2.2 To carry out its activities and fulfil its obligations, the Company may process the Client's personal data, including information necessary for the Company to fulfil its obligations under its contractual relationship with the Client and to comply with applicable law.
2.3 The Company processes the following personal data when the Client uses the Company's services:
2.3.1 last name, first name, patronymic;
2.3.2 phone numbers;
2.3.3 email addresses;
2.3.4 data on services provided and being provided to the personal data subject / use of the services;
2.3.5 history of the personal data subject's requests, including data sent by the subject when contacting the Company;
2.3.6 payment information: payment date and amount, payment method, the last four digits of the bank card number or another payment identifier.
2.4 When the services are used, the Company also processes other anonymized data that is automatically transmitted through software installed on the Client's device: information about the browser used (or other program used to access the service/website); IP address; mobile device identifiers, MAC address, IMEI; device and operating system name; cookie data; geographic location based on IP address; precise geolocation data (GPS, with consent); etc.
2.5 The Company guarantees that organizations external to the Company do not have access to such data that may be used by the Company, except as expressly provided by applicable law and this Policy, or as expressly provided in an agreement with the Client.
2.6 Consent to the processing of personal data is deemed given when the personal data subject performs any action or set of actions to use the Company's services.
2.7 Consent is deemed obtained in the established manner and remains valid until the personal data subject submits a request to stop processing.
2.8 The personal data subject is solely responsible for the accuracy, completeness and lawfulness of the data provided to the Company.
2.9 The Company is not responsible for disclosure of confidential information (including personal data) of personal data subjects by third parties.
2.10 The Company does not store users' full bank card details. Bank card data entered on the payment page is processed by the payment service engaged by the Company, and, for payments through app stores, by the relevant app store.
3. Grounds and Purposes of Personal Data Processing
3.1 The Company processes personal data to carry out its activities and to pursue its legitimate interests and requirements.
3.2 The purpose of processing personal data is to perform the functions assigned to the Company by applicable law, the Company's internal regulations and the agreement with the personal data subject.
3.3 The Company processes personal data of personal data subjects by maintaining databases by automated, mechanical and manual means for the purposes of:
3.3.1 providing services to the personal data subject, processing requests or other actions of the personal data subject related to the performance of agreements between the Company and the personal data subject, including accepting payments, considering refund requests and resolving payment disputes, etc.;
3.3.2 with the express consent of the personal data subject, promoting the Company's goods, works and services, notifying about promotions, events and discounts, and conducting marketing campaigns of the Company and its partners;
3.3.3 other purposes, provided that the Company's actions do not contradict applicable law and the personal data subject has consented to such processing.
3.4 The data specified in clause 2.4 of this Policy is processed, among other things, for analytics of the services/website, improving the functioning of the services/website, solving technical problems of the services/website, developing new products, expanding services, ensuring security and preventing fraud, and providing effective customer support.
3.5 The Company processes personal data by performing any action, including collection, recording, systematization, accumulation, storage, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction.
4. Personal Data Processing Periods
4.1 Personal data processing periods are determined based on the purposes of processing in the Company's information systems, in accordance with the term of the contract or agreement with the personal data subject, the limitation period, and other requirements of applicable law and the Company's internal regulations.
5. Persons Authorized to Process Personal Data
5.1 Only those Company employees whose job duties include personal data processing are authorized to process personal data. Other employees may be granted access only in cases provided for by law. The Company requires its employees to maintain the confidentiality and security of personal data during processing and establishes liability for breaches of personal data processing requirements.
5.2 The Company may transfer personal data to third parties in the following cases:
- in performance of the agreement between the Company and the personal data subject, including to the payment service engaged by the Company to accept payments, to the extent necessary to accept payments and process refunds, and to app stores (Apple App Store, Google Play) for payments made through them;
- to banks, payment systems and other authorized organizations when a disputed payment is under review in the manner set out in section 10 of the User Agreement;
- the personal data subject has expressly consented to such actions;
- the transfer is provided for by applicable law within the procedure established by law.
5.3 Because the Company is located in the Republic of Turkey, processing of personal data may involve its cross-border transfer to the Republic of Turkey. Cross-border transfer is carried out for the purposes set out in section 3 of this Policy and in accordance with applicable law.
6. Personal Data Processing Methods
6.1 In providing services and carrying out its activities, the Company uses both automated processing of personal data, using computer equipment, and non-automated processing, using paper document flow.
6.2 The confidentiality of the user's personal information is maintained, except where the user voluntarily makes information about themselves publicly available to an unlimited number of persons. In that case, the user agrees that a certain part of their personal information becomes publicly available.
6.3 The Company guarantees organizational and technical measures to protect the user's personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions of third parties.
7. Personal Data Protection
7.1 The Company's processing of personal data in information systems is inseparably linked to the Company's protection of the confidentiality of the information received. All Company employees are obliged to ensure the confidentiality of personal data and other information designated by the Company, unless this contradicts applicable law.
7.2 The security of personal data processed in the Company's information systems is ensured by an information security system that includes organizational measures restricting physical access, and software and hardware protection measures (including encryption (cryptographic) tools, tools to prevent unauthorized access, and software and hardware impact on personal data processing equipment).
7.3 To ensure the security of personal data during processing, the Company takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions, including:
7.3.1 identifying threats to the security of personal data processed in personal data information systems;
7.3.2 applying organizational and technical measures to ensure the security of personal data processed in personal data information systems that are necessary to meet personal data protection requirements, the fulfilment of which ensures the established levels of personal data protection;
7.3.3 using information security tools that have passed conformity assessment in the established manner;
7.3.4 detecting unauthorized access to personal data and taking action;
7.3.5 restoring personal data modified or destroyed as a result of unauthorized access;
7.3.6 timely detection of unauthorized access to personal data and taking the necessary measures;
7.3.7 monitoring the measures taken to ensure the security of personal data and the level of protection of personal data information systems.
7.4 To ensure that the level of personal data protection complies with applicable law, the Company does not disclose information about the specific tools and measures used to ensure the information security of personal data.
8. Final Provisions
8.1 This Policy has been approved by the management of PAYMASTER TECHNOLOGIES ELEKTRONIK PAZARLAMA DIS TICARET LIMITED SIRKETI.
8.2 Amendments and additions may be made to this Policy and are approved by the management of PAYMASTER TECHNOLOGIES ELEKTRONIK PAZARLAMA DIS TICARET LIMITED SIRKETI.
8.3 The current version of the Policy is publicly available on the Internet at: https://whotam.com/foruposts/privacy-policy.
9. Company Details
Full name: PAYMASTER TECHNOLOGIES ELEKTRONIK PAZARLAMA DIS TICARET LIMITED SIRKETI
Address: Merkez Mah. Kagithane cad. A, office No 11/61 Kagithane/Istanbul/TURKEY
Registration Number: 451893-5
Email: support@whotam.com