Update Date: [●]
This Policy has been prepared in order to enlighten and inform the Users about the terms and conditions regarding the use of the data obtained and/or to be obtained from the Users in any way within the scope of the Services offered through the Platform operated by Searover Robotik ve Yazılım Anonim Şirketi (Werover or the Company) and the way the data is processed.
Werover is obliged to enlighten/inform the Data Subjects whose data will be processed during the acquisition of personal data in accordance with Article 10 of the Law. The scope of this disclosure obligation is as follows:
- Identity of the data controller and its representative, if any,
- The purpose for which personal data will be processed,
- To whom and for what purpose the processed personal data may be transferred,
- The management and legal reason for collecting personal data and
- Rights of the person concerned.
In this context, Werover aims to provide the necessary clarifications with this Policy.
Werover may only be the data controller in accordance with the relevant legislation for personal data whose purposes and legal reasons are clearly stated in this Policy. For personal data other than these, Werover processes this personal data on behalf of the Customer with whom it has a contractual relationship and is therefore a data processor in accordance with the relevant legislation. Because Werover processes Personal Data not specified in this Policy but processed within the scope of using the Platform only on the basis of the authorization given by its Customer and on its behalf, within the scope of the services it provides. For this reason, the data controller for personal data not specified in this Policy is Werover's Customer and Customers are obliged to fulfill their responsibilities in accordance with the relevant legislation against the relevant persons regarding this personal data.
Werover attaches importance to the confidentiality of personal data and takes care to be transparent about the storage of information. This Policy is a privacy policy that includes what kind of data is collected, how this data is used, with whom this information is shared if necessary, what are the rights regarding personal data and how these rights can be used, and the principles adopted by Werover regarding privacy.
1. Definitions
In this Policy:
Explicit Consent: Consent given on a specific subject, based on information and free will, in a clear manner that leaves no room for hesitation, limited only to that transaction,
Terms of Use: The Terms of Use contained on the Platform and accepted by the Users by marking by accessing the Platform
Relevant Person: The natural person whose personal data is processed,
Personal Data: Any information relating to an identified or identifiable natural person,
Processing of personal data: All kinds of operations performed on personal data such as obtaining, recording, storing, storing, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that they are part of any data recording system,
Law and/or Personal Data Protection Law: Law No. 6698 on the Protection of Personal Data,
User(s): Users who access the Platform
Customer means the person with whom Werover has entered into the Service Agreement; (mostly) the User's employer,
Platform means the online Saas platform, linked website and linked web applications that the Client and Users will use to benefit from the Products and Services,
2. Personal Data Collection Methods and Legal Reasons
Werover may obtain Users' Personal Data for the use of the Platform; such as the realization of relevant records, performance of Services, provision of technical support, renewal of contracts and termination of contracts. Werover may collect Personal Data from Users through communication channels such as e-mail, mail and telephone in accordance with the service agreements concluded with the Customer and/or Customer Representative, online through the Platform, the information specified in the table below:
- Registration, Service and Account information: In order to benefit from Werover's Services, Users are required to enter into the Terms of Use and register on the Platform as set forth in the Terms of Use. In this context, the Customer shall provide Werover with the name, surname, e-mail address and telephone number of the persons to be registered as Users on the Platform, and this information is collected by Werover to create an account on the Platform.
- Device data: Data is collected from the devices and applications you use to access the Services, such as your IP address, operating system version, device type, system and performance information, and browser type.
- Usage data: Usage data is collected about you each time you use the Services or access the Platform, with or without using the Services. This may include data such as when you visit the Platform, what you click on, when you perform these actions, etc. It also includes data about the nature of each access, such as source IP addresses, internet service providers, files displayed on the Website (e.g. HTML pages, graphics, etc.), operating system versions and timestamps.
a) Data Categories and Data Types
Credentials: Name, Surname
Contact Information: e-mail address, phone number
Customer Transaction: Transactions carried out within the Platform, reports issued and/or accessed.
Transaction Security: PC/system and Application user transaction information (username and password), Internet traffic data (network movements, IP address, visit data, time and date information), device information, log records and other user transaction information.
Job Experience: Company/Company Name, Position
b) Legal Reasons
The above-mentioned personal data may be processed for the purposes listed below, which are subject to the disclosure of this data by the Data Subject to Werover; in accordance with the conditions and principles set out in Article 4 of the Law; within the personal data processing conditions specified in Articles 5 and 6 of the Law. The legal grounds for each category of data are clearly stated below:
Identity and Contact Information, Professional Experience, Customer Transaction
- Provided that it is directly related to the conclusion or performance of a contract, it is necessary to process personal data of the parties to the contract,
- Data processing is mandatory for the establishment, exercise or protection of a right.
Transaction Security
- Explicitly stipulated in the law,
- It is necessary for Werover to fulfill its legal obligation.
3. Purpose for which Personal Data will be Processed
Within the scope of this Policy, the personal data of the Data Subjects are processed for the following purposes in accordance with the general conditions specified in this Policy:
Identity and Contact Information, Customer Transaction
- Execution of activities in accordance with the legislation
- Execution of company/product/service commitment processes
- Follow-up and execution of legal affairs
- Conducting communication activities
- Execution / supervision of business activities
- Carrying out activities to ensure business continuity
- Execution of after-sales support services
- Execution of service sales processes
- Execution of service production and operation processes
- Execution of customer relationship management processes
- Conducting activities for customer satisfaction
- Execution of advertising/campaign/promotion processes
- Execution of contract processes
- Follow-up of requests/complaints
Process Security, Professional Experience
- Execution of information security processes
- Conducting audit/ethics activities
- Execution of access authorizations
- Execution/supervision of business activities
- Carrying out activities to ensure business continuity
- Informing authorized persons, institutions and organizations
- Execution of access authorizations
- Execution of company/product/service commitment processes
- Execution / supervision of business activities
- Execution of after-sales support services
- Execution of service sales processes
- Execution of service production and operation processes
- Execution of customer relationship management processes
- Execution of contract processes
Werover is obliged to take all necessary technical and administrative measures to ensure the appropriate level of security in order to prevent unlawful processing and access to personal data and to ensure the protection of personal data by taking the utmost care in storing your information.
Werover will make maximum efforts to ensure that your personal data is not processed and stored unlawfully and that your personal data is not unlawfully accessed. Each time you visit the Platform, your IP address, operating system, connection time and duration information and similar information are automatically recorded; It is possible to use this information obtained without your consent anonymously.
The information collected by Werover may be used in aggregate in various ways in order for Werover to provide services, to optimize and improve the services, and to enrich the database and improve the service provided to the people who access the Platform through this database. Werover may use this information for website management, security, research and analysis.
4. To whom and for what purpose personal data may be transferred
Your collected personal data may be transferred, processed and stored on servers abroad for the storage of such data or for lawful purposes set out in this text. Werover may transfer the User's information, including Personal Data, to another country and jurisdiction that does not have the same/similar data protection laws in the jurisdiction in which they are located. Accordingly, Werover complies with the obligations stipulated in the relevant legislation when performing this transaction.
Your personal information may therefore be subject to different privacy rules than in your country of residence. However, the data will still be processed to the extent limited to the scope set out in this text.
Werover may share your personal data with companies that provide services (such as data processing centers, third party business partners or customer service centers to which Werover provides services under contracts concluded between you and Werover), taking into account its legal obligations. These service providers are obligated to protect this information
Your personal data may be shared with public institutions and organizations authorized to request personal data in order for Werover to fulfill its obligations under the law (in cases where there is an obligation to provide information such as crime prevention, prevention of laundering proceeds of crime and terrorist financing, combating crime and threats to state and public security).
In detail, with whom and for what purposes your personal data may be shared is stated below:
Transfer Purpose and Transferred Group
- Sharing transaction security information with authorized institutions and organizations upon request;
- Sharing personal data with judicial authorities in case of legal proceedings;
- Sharing with business and solution partner organizations, public/private institutions from which service/support/consultancy is received or with which cooperation is made, provided that it is mandatory for our legitimate interest and is directly linked to the execution of the contract between us, provided that it does not harm your fundamental rights and freedoms, and provided that you obtain your explicit consent to those abroad,
- Sharing all information for the purpose of carrying out storage and archive activities with service providers abroad, from which server services are obtained, in order to realize our legitimate interest, provided that we obtain your explicit consent and do not harm your fundamental rights and freedoms,
- Sharing directly with the legal entity Customer due to services rendered to the Customer.
6. Rights of the Relevant Person
The rights of the Data Subject pursuant to Article 11 of the Law are set out below:
- To learn whether personal data is being processed,
- Request information if their personal data has been processed,
- To learn the purpose of processing personal data and whether they are used for their intended purpose,
- To know the third parties to whom personal data is transferred domestically or abroad,
- To request correction of your personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom your personal data has been transferred,
- To request the deletion, destruction or anonymization of your personal data in the event that the reasons requiring the processing of your personal data disappear and to request notification of the transaction made within this scope to third parties to whom your personal data has been transferred,
- To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
- In case of damage due to unlawful processing of personal data, to demand compensation for the damage.
As Data Subjects, in order to state your requests regarding your rights and to exercise your rights on your personal data; by sending an e-mail to Werover's [●] address physically in writing, by signing with a secure electronic signature or mobile signature defined to you, by sending an e-mail to [●], the registered e-mail address of our Company via your KEP address, or by sending an e-mail to our [●] address by using your e-mail address previously notified to us and registered in our systems; By submitting it in a way that meets the minimum application requirements in the relevant legislation; You can carry out the necessary changes, updates and / or deletions and related requests.
If you send us your requests that meet the minimum application requirements in the Communiqué on the Procedures and Principles of Application to the Data Controller, Werover will finalize the request as soon as possible and within thirty days at the latest, depending on the nature of your request.