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PRIVACY POLICY

The purpose of this Privacy Policy is, during the operation of the web site operated by (“Northernland Group), shared by the mobile application users/members (“Data Owner”) with Northernland Group or by the Companies, the Data Owner’s mobile application to determine the terms and conditions regarding the use of personal data generated during its use.

Which Data is Processed?

Under this heading, the data processed by Northernland Group and considered as personal data in accordance with the Personal Data Protection Law are listed. Unless expressly stated otherwise, the term “personal data” within the scope of the terms and conditions provided under this Privacy Policy will include the information contained in Article 2 of the Clarification Text on the Protection and Processing of Personal Data and the information below. Northernland Group processes data related to name, surname, address, phone number, identity and/or passport information, e-mail address, company title, documents required for membership, contact information, credit/debit card information, account information, device and application usage data, transaction history and shopping habits, GPS data to be obtained during the service, IP address, device operating system and version, device type, hardware model, user transaction records and traffic data, location information, device ID, complaint and suggestion records, bank IBAN number, membership date, customer ID, complaint and suggestion records, mobile application usage details, call center records, application usage information, wallet balance, information on payment and payment methods, user Transaction Information, Transaction Security Information, Marketing Information, Request/Complaint Management Information and Incident Management Information.

For What Purposes Are The Data Used?

Your personal data is used for the purposes stated below and included in Article 2 of the clarification text on the Protection and Processing of Personal Data.

Carrying out the necessary work for the relevant business units to benefit from the services offered by the Northernland Group and to carry out the activities carried out by the Northernland Group; Verifying the identities of users and providing security measures for the correct and effective operation of the application, performing and tracking payment transactions; Providing customer support, collecting analytical data for the development of services and application, presenting special offers and promotions to users, data processing process, establishment of the relevant contract for benefiting from the products and services offered by Northernland Group; Performing contractual acts such as receiving payment orders, realizing payment transactions, executing registration procedures to create an account and operating user accounts, providing payment tools, especially digital wallets, tracking accounts and transactions through the mobile application, providing expense summaries and similar functions; Carrying out information and promotion activities about the services offered by Northernland Group, monitoring and controlling unauthorized transactions and/or uses and suspicious transactions, and taking necessary measures and realizing transactions in unauthorized/suspicious transactions; operation of customer recognition and identity verification processes, control of information and documents required by the legislation, follow-up of financial transactions; Carrying out the necessary work by our business units and executing the relevant business processes in order to benefit the related persons from the products and services offered by the Northernland Group, including the sales and marketing activities of our services; To carry out the necessary work by the relevant business units for the realization of the commercial activities carried out by Northernland Group and to carry out the related business processes, to ensure the legal, technical and commercial-occupational security of the Northernland Group and the persons who have a business relationship with the Northernland Group, determining and implementing legal affairs, executing information security processes, performing audit and ethical activities, performing reservation and/or reservation activities in businesses within the Northernland Group, ensuring compliance with company policies and procedures, in case of explicit consent by the user Performing the marketing processes of the products and services offered by Northernland Group by communicating with the user with identity, communication, customer transaction and financial data, customizing the products and services offered by Northernland Group, including profiling and analysis activities, according to the tastes, usage habits and needs of the persons concerned, and recommending them to the relevant persons; to promote users, to create individual campaigns for users, to offer special opportunities by Northernland Group's business partners, to determine the target audience, to carry out activities to increase the user experience, to personalize the application, to carry out direct and personalized marketing activities, to provide services and services offered by Northernland Group. management, supervision and improvement of its operations; conducting market research, conducting strategic planning processes, performing non-personalized marketing activities, ensuring the security of our service, operation and application, detecting fraudulent or illegal activities; prevent and detect fraud and campaign abuse, conduct internal audit, internal control, legal, financial, reporting and internal operations; Again, if express consent is given, processing of preferred contact information for the purpose of sending commercial electronic messages, planning and execution of user satisfaction and corporate communication activities, realization of raffles, campaigns, competitions, promotions or advertising activities, and legal, technical in accordance with the principles to be applied in the processing of personal data specified in Articles 5, 6 and 7 of the "Personal Data Protection Law", including the provision of commercial job security and personal data that form or are planned to form a part of a filing system within a period appropriate for its purposes. regulates the principles and procedures regarding the processing and transfer, in whole or in part, by automatic or non-automatic methods and tools, and is stored securely. Northernland Group may use cookies, including cookies for segmentation and marketing purposes, used for analytical purposes, and in this context, data may be processed and transmitted to third parties for the purpose of processing within the scope of analysis services offered by third parties, only to the extent required by these analysis services. The technical communication files mentioned are small text files that it sends to the device to be stored in the main memory. The technical communication file facilitates the use of the Internet in this sense by storing the status and preference settings about a website or mobile application or device. The technical communication file is designed to help dynamically generate advertisements and content and is used for these purposes; to obtain statistical information for the determination of user behavior such as how many people use the websites or mobile applications in temporal proportions, how many times a person visits any website or mobile application for what purpose and how long they stay, and to obtain statistical information from user pages specially designed for users. The technical communication file is not designed to receive any other personal data from the main memory. Most of the browsers are initially designed to accept the technical communication file, but the User can always change the browser settings so that the technical communication file does not arrive or a warning is given when the technical communication file is sent.

Who Can Access the Data?

The personal data of the Northernland Group Data Owner and the new data obtained by using this personal data are sent to the third parties from whom Northernland Group makes use of its services in order to achieve the purposes set out in this Privacy Policy, to the Service providers to process the payment transactions between the Group companies and affiliates and to provide the benefits of the users. and its business partners, in order to perform and improve the functions of the application and in accordance with legal obligations, in accordance with a court decision or official requests. Northernland Group aims to improve the Data Owner experience (including improvement and personalization), to ensure the security of the Data Owner, to detect fraudulent or unauthorized use, to investigate operational evaluation, to fix errors related to mobile application services and to fulfill any of the purposes in this Privacy Policy, in order to be able to do so, will be able to share it with third parties such as outsourcing service providers, hosting service providers (hosting services), law firms, research companies, call centers, including those who send SMS.

About Right of Access to Data and Correction Requests Pursuant to Articles 13, 14 and 15 of the Law on the Protection of Personal Data, the subject of information is to learn whether personal data has been processed, to request information about it if personal data has been processed, to learn the purpose of processing personal data and whether they are used in accordance with its purpose, at home or abroad; knowing the third parties to whom the personal data is transferred, requesting correction of personal data in case of incomplete or incorrect processing and requesting the notification of the transaction to the third parties to whom the personal data has been transferred, even though it has been processed in accordance with the provisions of the Personal Data Protection Law and other relevant laws, the reasons requiring processing are eliminated, to request the deletion or destruction of personal data in case of withdrawal, to request the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred, to object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems, to incur losses due to the illegal processing of personal data has the right to demand the compensation of the damage. If Northernland Group does not respond within thirty days from the submission of the application made in accordance with the above-mentioned issues or if the response is not satisfactory, the person subject to the information has the right to apply to the Board. The Board makes the decision on this matter. The subject of the information can use the right of access with the help of an expert. The person subject to the information has the right to object at any time to the processing of his/her data that has been processed, is being processed or is planned to be processed, for legitimate reasons related to the particular situation he/she is in. The objection is made in writing to the controller and must include a request to take or not take a particular action, such as correction, temporary refusal from use, blocking, refusal from transmission or deletion, non-processing and deletion. The Controller must respond in writing to these objections within fifteen business days of the request being submitted. In his response, he should include the reasons for the action taken or, where necessary, not fulfilling the request. If the objections are rejected, the response must be forwarded to the Board. If the companies do not respond within the given time frame, or if the response is not found satisfactory, the person subject to the information has the right to apply to the Board and request that his objection be examined. The Data Owner is obliged to immediately update the information subject to this Privacy Policy, if there is any change in this information. Northernland Group will not be liable if the person or data subject does not provide up-to-date information. If the person or data subject to the information makes a request that will result in the inability to use any of their personal data by Northernland Group, they will not be able to fully benefit from the operation of the mobile application and any responsibility arising in this context lies with the Data Owner/User. Retention Period of Personal Data Northernland Group will keep the personal data provided by the person or data subject for the period required by the above-mentioned processing purposes. In addition, Northernland Group may store personal data for the limitation period determined in accordance with the relevant legislation, in case of any dispute that may arise between the Data Owner or the person subject to the information, for the purpose of making the necessary defenses within the scope of the dispute.

Data Security Measures and Commitments Northernland Group, under the conditions specified in the relevant legislation or expressed in this Privacy Policy, to ensure the confidentiality and protection of data against unintentional or unlawful damage, unintentional loss, alteration, transmission to unauthorized persons or providing access and any other illegal processing takes appropriate institutional and technical measures to Northernland Group cannot disclose the personal data obtained about the Data Owner or the person subject to the information to others in violation of the provisions of this Privacy Policy and the Personal Data Protection Law and cannot use it for purposes other than processing. In the case of linking to other applications via the mobile application, Northerland Group does not bear any responsibility for the privacy policies and contents of the applications. Changes to the Privacy Policy Northernland Group may change the terms of this Privacy Policy at any time. The current Privacy Policy becomes effective on the date it is submitted to the person or data owner by any means.