PRIVACY NOTICE

We, as Mikigi Mobil Teknoloji Anonim Şirketi (“Mikigi”), are dedicated to complying with the Law No. 6698 on the Protection of Personal Data (to the extent it is applicable, the European Union General Data Protection Regulation, and the other applicable laws and regulations regarding data privacy).

The purpose of this privacy notice is to provide information to Yoorbit users on the processing of their personal data. Please carefully read this privacy notice before using Yoorbit.

1.              The collection of your personal data and the purposes of processing

Personal data that we collect when you create a Yoorbit account (user data). When you create a Yoorbit account, your name, surname, e-mail address and selected profile picture will be requested. You may also sign in Yoorbit over your Facebook account, without creating a separate Yoorbit account. When you access Yoorbit through your Facebook profile, we receive your Facebook ID, Facebook profile picture and age-range (e.g. minimum 21). The data that we receive from Facebook depends on Facebook’s privacy policies as well as your privacy settings and your friends’ privacy setting.

User data is processed for the purposes of creating your account, verifying user account and responding to your complaints, requests and queries.

Personal data that we collect when you use Yoorbit (usage data). We collect and process any content that you provide when using Yoorbit, including when you create or post any comment, photo, tag, ranking or other content, or send a message to, or otherwise contact, others. Considering the interaction between Yoorbit users, we process data related to the user’s follows, posts, favorites, rankings, usage information and their interactions with each other to provide a user specific and consistent experience.

We process usage data for the purposes of provision of Yoorbit platform available to users, verification of user accounts and actions, personalization of the content made available on Yoorbit in accordance with the preferences, interests, platform activities and interactions of you and those you interact with, displaying contents and advertisements that we believe would be of interest to you, and thereby improving your user experience, analyzing Yoorbit users and their user behaviors, creating aggregated statistical data on users’ preferences and interests, analyzing user contents and behaviors to detect suspicious and/or manipulative activities, and ensuring the integrity and security of Yoorbit services. We create aggregated demographic personas by analyzing user data for creating aggregated statistical data on users’ preferences and interests. Such aggregated data and demographic personas are anonymous, do not contain any data specific to any user, and make it possible to make Yoorbit platform available to users free of charge.

Data regarding devices (device data). We collect and process the following data that we receive from the mobile device that you use to connect Yoorbit over the Internet:

·     Device information: Your device’s brand, model, language, operation system and version

·     Identifiers: Your device’s advertising ID (IDFA for iOS devices and GAID for Android devices). These are unique identifiers for mobile devices that advertisers use for personalized advertising.and consistent across all mobile applications and thus allow cross-app tracking. You may disable this option by activating “limit advertisement tracking” from the privacy settings of Apple devices. As for the Google Android devices, you may change your advertisement setting by activating the “disable advertisement personalizing” option. Advertising IDs, are non-permanent identifiers, which are uniquely associated with your device.

·     Data collected from device settings: Your location data if you grant access to your GPS location in your device settings.

·     Network and connection data: The Internet protocol number (IP) used for accessing the application.

Your device data is processed for improving and updating Yoorbit services, responding to your complaints and requests, solving any technical problem that you may experience when using Yoorbit, and improving user experience. Your location data (if authorized by you) is processed for improving user experience and personalizing the services based on your interactions while using Yoorbit. Device identifiers are used for sending push notifications and displaying contents and ads that may be of your interest, according to your preferences and activities. Your data processed by Yoorbit is also processed for creating aggregated demographic personas to be used for improving user experience in our platform and allowing us to offer this platform to you free of charge. Such demographic data is anonymized and aggregated and does not contain any person specific data.

Your personal data is stored as long as required for the provision of Yoorbit services, and deleted when it is no longer necessary for the purposes set forth in this privacy notice. The user contents that you share on Yoorbit will become open to everyone’s access in accordance with the operation system of the platform, and kept on the platform unless the relevant user modifies or deletes such contents. You may, at any time, delete and/or modify any content that you have previously posted. Please note that other users may search for, display, use or share your contents before you delete or modify them. All of your usage data other than the user content, your user data and your device data will be retained for resolving any potential dispute, as evidence that may be used in any potential litigation, responding to queries of authorized authorities and institutions, and detecting and preventing illegal activities on the platform for a period of two years commencing at the end of the year in which you delete or deactivate your account.

2.              Legal Grounds of Processing of Personal Data

Your personal data is processed within the scope of the following legal grounds: the establishment and execution of the user agreement, fulfilling Mikigi’s legal obligations as a data controller, the establishment, exercise and protection of any right, being necessary for Mikigi’s legitimate interests.

Mikigi’s legitimate interests in processing your device and usage data are to analyze, measure and report the use of its services, and improve and develop your user experience. By virtue of such analyses and measurements activities, we are able to provide Yoorbit services more efficiently and effectively, to optimize the user experience and to provide our services to our users free of charge.

3.              Transfer of Personal Data

We transfer your personal data to our domestic or foreign service providers and business partners for the purposes of improving Yoorbit services, meeting technical requirements and displaying personalized and activity based ads that may be of your interest, in accordance with the applicable laws and regulations. Within this context, your personal data is transferred to our below mentioned business partners and service provides:

Cloud services. Your personal data is stored in the cloud on the servers -located abroad- of our cloud service providers providing hosting services for the purposes of procurement of our technical requirements.

Our business partners using our analysis services. We share aggregated demographic statistics that we create by analyzing usage data to our business partners engaged in market research in order to allow them to understand user interactions and activities. We transfer such data to our business partners in aggregated and anonymized way without including any person specific data.

Advertisers. We share aggregated demographic statistics with advertisers so that they may display ads suitable for users’ interests, activities and interactions. We transfer such data to advertisers in aggregated and anonymized way without including any person specific data.

Legal queries. In case a public institution is authorized to request personal data by the law, your personal data can be transferred to such authorized public institution in accordance with the applicable personal data protection legislations. Requests from judicial authorities will also be fulfilled in accordance with the applicable legislation.

4.              Your Right to Protect your Personal Data

According to the applicable laws and regulations, you are entitled to (i) learn whether your personal data has been processed; (ii) request information on the processing, if your personal data has been processed; (iii) learn the purpose of the processing, and whether or not your personal data has been used for this purpose; (iv) learn the identity of third parties to whom your personal data has been transferred; (v) request the correction of your personal data, if your personal data processed is incomplete or inaccurate; (vi) request the deletion or destruction of your personal data; (vii) request the notification of any third party to whom your personal data has been transferred of your request to have such data corrected, deleted or destroyed; (viii) challenge any unfavorable result of any analysis made exclusively by automated systems; (ix) request the indemnification of your damages arising from the illegal processing of your personal data; (x) demand the restriction of data processing activities; (xi) request the relocation of your personal data; (xii) challenge the processing of your personal data; and (xiii) file a complaint with the authorized data protection authority.

As per the relevant legislation, you have the right to; (i) learn whether or not your personal data is processed, (ii) request information as to processing if your data is processed, (iii) learn the purpose of personal data processing and whether the personal data is used in accordance with such purposes, (iv) know the third parties to which your personal data is transferred domestically or abroad, (v) to request correction if your personal data is incompletely or incorrectly processed,(vi) to request deletion or destruction of your personal data, (vii) request the transmission of your correction, deletion and destruction requests to third parties to whom your personal data has been transferred, (viii) object to any consequence occurred against you by analyzing your processed data through automated systems (ix) request compensation in case you incur any damage due to the unlawful processing of personal data, (x) request restriction of data processing activities, (xi) request data portability, (xii) object against personal data processing, and (xiii) to lodge a complaint with the relevant data protection authority.

You may send your queries, requests for deletion or destruction of your personal data, objections, and other requests related to your personal data to privacy@yoorbit.com . We will revert to you as soon as possible and within no more than 30 days.

Mikigi Mobil Teknoloji Anonim Şirketi