SUIT CONFERENCE PRIVACY NOTICE

Publication Date: 29.05.2023

Who We Are

The Suit Conference Application (“Application”) is provided by Lifecell Bulut Çözümleri A.Ş. (hereinafter to be referred to as “Lifecell”, “we”, “us”, “our”). 

Lifecell is committed to protect and respect your Personal Data in accordance with the applicable data protection legislation, including the provisions of the Law No. 6698 on the Protection of Personal Data, General Data Protection Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data and other applicable laws (hereinafter referred to as the “Data Protection Legislation”).

This Privacy Notice(“Notice”) sets out how we collect, use and share information that identifies or make specifiable your (“(you”, “your” or user”) identity (“Personal Data”). You may also contact your local data protection authority. For the interpretation of undefined terms stated in this Notice, we refer to the definitions as used in the internal Lifecell terms of use of Lifecell (“Terms of Use”). For more information about cookies please also read our cookie policy. 

In What Way are Your Personal Data Collected?

Lifecell collects your Personal Data from you when you voluntarily submit information directly to us or through the Application. This include information you provide when you register to use the Application, create an account, complete a form, correspond with us, purchase products through the Application or respond to surveys or promotions.

In addition to this, we also collect Personal Data indirectly from you such as the device you connect to the Application with, information about how you use the Application or information about you gained from third parties such as our service providers. 

In the following sections, you may find detailed information on which data are collected for which purposes.

Which Personal Data are Collected?

We describe the categories of Personal Data we have collected in more detail below:

• Identity and Contact Details: data such as your phone number, GSM operator, e-mail address and other similar data. 
• Account Details: passwords used for the Application if available for the identity verification and for access to the account, subscription information. 
• Usage Data and Favorites: data such as satisfaction survey results or similar survey results conducted through the Application, including but not limited to various technical data collected through technologic devices from your devices, active periods, types of services that are used, date of the last entry to the Application, errors occurred during the use of the Application.
• Device Data: data such as device model, operating system of the device, preferred phone language, information regarding which operator the users use, country information.
• Backup Data: in case the users request, the communication data can be backed up by Lifecell. 
• Complaint and Request Data: data that falling within the content of users requests and complaints which users communicated to Lifecell.
• Audio and Video Information: data refers to users audio and video data cannot be baked up or accessible by Lifecell. 

Purposes for Processing Personal Data

Your Personal Data is processed by  Lifecell for the purposes described below:

• Identity Information: These are processed for the purposes of user registration, error/failure notice, control, developing and realizing operational activities, business development, customer portfolio management, measurement of the service quality, communication, intra-company evaluation, service analysis, complaint management, management of the customer survey process and forwarding the Application subscription to other devices. 
• Usage Data and Favorites: These Personal Data are processed for the purposes of business development, direct or indirect marketing (customer campaigns, advertisement, services and functions within the application which are being advised to the customers, the offering of advertisements), profiling (the offering of advertisements according to your preferences, diversification of customers according to location, operator, tenure, the duration of using the application, and its functions), supervision and control, risk management, development of the after sale processes, intra-company evaluation, portfolio management, measurement and development of the service quality, communication, execution of the complaint management processes, execution and development of operational activities, error/failure notice and recovering service quality based on usage habits. These are processed for promotional purposes, intra-company evaluation, for analysis and communication through anonymous data (in a way that the users cannot be identified) and statistical evaluation.
• Payment Data: These Personal Data are processed for the purposes of managing the invoicing process and the payment information which belongs to the users who purchases in-app services (regardless whether such user is a Turkcell subscriber or not), the management of payment information, accounting, improving after sale processes, business development, intra-company evaluation, customer portfolio management, after sale services, communication, marketing, supervision and control.
• Device Data: These Personal Data are processed in order to optimize the Application and related services and to enable the device to work properly with the Application and its settings.
• Communication Data: These Personal Data are used to determine the usage habits with the purpose of the business development, marketing, enhancing the service quality and the unauthorized and fraudulent use. During the processing of these personal data, there is no processing of any data regarding the content of the communication.
• Backup Data: These Personal Data are used for backing up the communications of the users at their request. The messages that the user has received from or sent to another user shall be archived only upon the request of the user. 

Lifecell may anonymize and aggregate any of the data which has been collected (so that it does not directly or indirectly identifies or specifies the users).  Lifecell may use anonymized data for purposes that include testing its IT systems, research, data analysis, improving the Application, developing new products, direct or indirect marketing, advertisement, profiling and features.

What is The Legal Basis for Processing the Personal Data?

Lifecell is obligated to process the Personal Data in accordance with the above-mentioned purposes and in compliance with the applicable Data Protection Legislation. The Personal Data processed by  Lifecell may be required for registering the use of the Application, creating an account, , completing a form, corresponding with Lifecell, purchasing products through the Application or responding to surveys or promotions, for which the user has given its consent. 

Where the user has given consent as the legal basis for the processing of Personal Data, the user always has the right to withdraw consent at any time. 

Personal Data may be collected wholly or partially via automatic or non-automatic methods, processed and transferred for the purposes contained in this Notice based on legal grounds indicated in Articles 5 and 6 of Law on the Protection of Personal Data and listed hereunder and also Article 6 of GDPR (or other Applicable Data Protection Legislation) via vendors, call centers, web sites, application, messages and any kind of written, oral and electronic mediums. 

• As required in the legislation to which Lifecell is subjected,
• Provided that the processing is directly related to conclusion or performance of a contract, it is necessary to process Personal Data of the parties to the contract in order to be able to provide the requested products and services, or to fulfill the requirements of any contracts that users have concluded, 
• Data processing is mandatory in order for Lifecell to fulfill its legal liabilities,
• Respective Personal Data has already been made public by data subject,
• Data processing is obligatory for the establishment exercise or protection of a right,
• Data processing is necessary for the legitimate interests of Lifecell, provided that such processing does not violate the fundamental rights and freedoms of the data subjects.

Purpose Limitation

The Personal Data may only be processed to the extent necessary for the purposes described above. Personal Data may not be processed for other purposes other than that for which the Personal Data were collected. If there is a necessity or need to process Personal Data for other purposes, Lifecell shall investigate whether the purposes of the intended data processing are compatible with the original purposes. Lifecell shall provide the user prior to that further processing with information on that other purpose. Lifecell shall minimize data processing as is reasonable and appropriate to do so.

Where are Personal Data Being Stored and Processed?

Lifecell servers are located in Turkey, all data is stored for use in Turkey.

Within the scope of cooperation of operators abroad, in line with the use of Lifecell in their own countries, data related to users of these countries can be transferred to the relevant operator and stored on that operator’s servers. Lifecell takes all reasonable steps to ensure that the Personal Data is treated securely and in compliance with this Notice and the Data Protection Legislation. The transfer of Personal Data take place only in compliance with the applicable Data Protection Legislation, and where appropriate safeguards are in place that ensure the level of protection of parties as required by the applicable laws.

With Whom are Personal Data Shared?

Lifecell may share the Personal Data it has obtained with the following parties:

• Users: Lifecell and the user may share the Personal Data with other users (including Official Accounts) as part of the Application so users are able to interact with other users as permitted by the functionality of the service and their preferences and applicable law.  Where a User shares Personal Data of another individual, they take full responsibility for their actions in doing so.
• Law enforcement, regulators and other parties for legal reasons: third parties with whom Lifecell is under a legal obligation to disclose the Personal Data to or to whom Lifecell needs to disclose the Personal Data to protect its rights, property or safety or the rights, property or safety of others, detect and investigate illegal activities and breaches of any agreement we have with you.

Lifecell may provide third parties with aggregate statistical data and analyses about users of the Application. Lifecell declares that no one can be identified from the data shared like this as long as it has not been disclosed by Lifecell .

Please be noted that the content of communications between users are not monitored.

Your Rights Regarding Your Personal Data

Application users are entitled to exercise the following rights pursuant to Article 11 of Law on the Protection of Personal Data, may be entitled to exercise the following rights:

• To learn if their Personal Data is processed or not,
• If processed, to request information in this regard,
• To learn the purpose of processing for Personal Data and to know whether it is processed based on these purposes,
• To learn the third parties inside Turkey or abroad to whom the Personal Data is transferred,
• To request Personal Data to be corrected if it has been processed deficiently or incorrectly,
• To have their Personal Data deleted or destroyed within the framework of terms set forth in Article 7 of Law on the Protection of Personal Data,
• To request transactions made pursuant to correction, deletion and destruction rights indicated above to be informed to the third persons to whom Personal Data is transferred,
• To object to processing of their Personal Data exclusively by automatic means,
• To request to indemnify the damage they have suffered in case of illegal processing of their Personal Data.

In addition to the rights stated above, depending on their location, the Application users may also have the right to:

• learn whether their Personal Data are being processed; 
• request information and a copy if their Personal Data have been processed;
• learn the purpose of the processing of Personal Data and whether these are being processed in compliance with such purpose;  
• learn the third-party recipients to whom the Personal Data are disclosed within the country or abroad,  
• request rectification, correction or limitation of the processed Personal Data which is incomplete or inaccurate,
• erasure or destruction of data in accordance with the conditions set forth in the Data Protection Legislation,
• request processing is restricted where dependent on user consent,
• if applicable, request their personal data, which they provided to Lifecell, is transferred to another data controller or data subjects themselves in a structured, commonly used and machine-readable format,
• object to the processing of their personal data
• notify the third person to whom the Personal Data are disclosed, about the processes regarding rectification, erasure and destruction of data, 
• object to negative consequences about them that are concluded as a result of analysis of the processed Personal Data by solely automatic means, which produces legal effects or significantly affects them,

In order to exert any of your rights stated above in relation to your Personal Data or exert your right of data portability (if applicable), please contact us using the contact details set out in the “Contact Us” section below. In order to help you find the data you would like to use your abovementioned rights, please provide as much information as you can about the data you would like to use your rights. Information provided shall be free of charge, unless the request is clearly unfounded or disproportionate, in which case a reasonable fee may be requested, or the request may be refused. Users also have the right to lodge a complaint with a local supervisory authority. 

Alternatively, you can forward your questions and requests regarding your Personal Data via one of the following methods:

• Send an e-mail to kisiselverilerikoruma@istesuit.com with a request which is in accordance with Comminuque on the Principles and Producers for the Request to Data Controller, by using your e-mail address which is previously notified to the company applied and registered in the company's system. 
• Once you download and print out Personal Data Application Form ( conference.istesuit.com/form/personal-data-application.pdf ), completing the form in writing and sending it to “Lifecell Bulut Çözümleri A.Ş. Aydınevler Mahallesi İnönü Caddesi No:20 Küçükyalı Ofis Park B Blok - Maltepe/İstanbul” address via the notary public or postal services.

Retention Period of Personal Data

Lifecell shall retain Personal Data during the period necessary for the purpose(s) for which it has been collected and/or is being processed for up to 2 (two) years unless a longer retention period is established by applicable laws. This includes the retention of Personal Data during a limited period determined as per the relevant legislation in case any dispute might arise from the Terms of Use. Lifecell will securely delete Personal Data and ensure all recipients of Personal Data comply with the same obligation as soon as Personal Data is no longer necessary in relation to the purpose for which it was processed unless Lifecell is required to retain Personal Data for a longer period by law.

Measures for Data Security

Lifecell takes the security of your Personal Data seriously and it has appropriate technical and organizational measures in place in order to prevent unauthorized access and unlawful processing of Personal Data. Your Personal Data is protected by our strong security features, which we strictly enforce and periodically review.

Lifecell shall not disclose any Personal Data of users to any third party in defiance of this Notice and/or applicable Data Protection Legislation. Lifecell shall only use Personal Data for secondary processing insofar such processing is compatible and lawful. In case Personal Data of the users are shared with outsource service providers in accordance with the provisions of this Notice, Lifecell shall take necessary measures so that such third-party providers shall provide at least a similar level of security for the personal data.

However, Lifecell does not bear any responsibilities for third party applications to which a link is provided via the Application and for transactions conducted with other users, to the extent these applications are not under the control of Lifecell.

Automated Decision Making We do not use Personal Data to make automated decisions about users.

Use of the Services

If you want to delete your account, you can deliver your request over “Delete My Account” button under Settings/Account Information Tab inside the application.

Changes to this Notice

Lifecell shall update and change the provisions of this Notice, e.g. in case of any change/update in the Data Protection Legislation, in which case the updated Notice will be brought under your attention by publishing it via the Application. Updates and changes in the Notice made by Lifecell shall be effective as of the date of its publication on the Application. 

Contact us

Data Protection Officer

dpo@istesuit.com 

Address

Aydınevler Mahallesi İnnü Caddesi No:20/36 Küçükyalı Ofispark Maltepe/ İstanbul Turkey