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Privacy Notice

Publication date: 23.09.2022

Who Are We?

EPOZTA Application (“Application”) is provided by MUNUBU (hereinafter referred to as “MUNUBU”, “we”,“us”or “our”).

MUNUBU is committed to protect and respect your personal data in accordance with the applicable data protection legislation, including the provisions of 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“) informs you about the information that makes your (“you”, “your” or “user”) identity specific or identifiable (“Personal Data“) which is collected, used and shared. For the interpretation of undefined terms stated in this Notice, we refer to the definitions as used in the MUNUBU’s EPOZTA End User Agreement (“Terms of Use”).

Which Personal Data are Collected?

Although the information in this transcript may differ from user to user due to circumstances such as differences of products and services that people benefit from or their requests and consents, the categories of your Personal Data that are processed by MUNUBU are as follows.

Credentials:refers to name, surname, user name, date of birth.
Subscription Information:refers to user number data.
Contact Information:refers to the data types used for the line number, contact number, e-mail, authentication, recovery e-mail and access to the account and the answer to the password and security question.
Usage and Behavioral information:refers to the various technical data collected from your devices, the language you prefer, active periods, types of services used, habits related to the Application interface, the last date of login to the Application, and errors that occur during Application use.
Device Information:refers to data types such as IP address, device brand and model, device operating system, phone usage language, information about which operator the user is using, country information, internet connection type.
Location Information:refers to the location data of the place where the device is located.
Complaint and Request Data: refers to the data included the content of your requests and complaints that you convey to MUNUBU as a user.
Purposes and Legal Basis for Processing Your Personal Data

Your Personal Data may be processed through the website, mobile Applications, short message, e-mail and voice response system, with fully automatic or partially automatic methods, in line with the legal reasons and purposes listed below.

Where processing your Personal Data is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract;
MUNUBU processes your Personal Data to present the Application to you in accordance with the Terms of Use and service standards.

We process; Identity, Subscription and Contact Information, Usage and Behavioral Information, Device Information, Location Information, Complaint and Request Data,

For the purposes ofcarrying out and monitoring the transactions you request regarding products and services, developing, diversifying, measuring, auditing and analyzing products and services and networks, as well as training of employees, and conducting financial reporting. Evaluating your interest in products and services, researching customer satisfaction are included in this scope. Answering questions, complaints and notifications from you are included in this scope. Transactions made within the scope of the Application, preferences and usage habits data, location data determined through the GPRS feature of the device, IP address information, device brand and operating system information, device usage language, operator and country information provided through the Application or in connection with the Application, the operation of the Application, its function are included in this scope.

Where processing is necessary for the compliance with a legal obligation to which MUNUBU is subject;
The data listed in this Notice may be processed if it is necessary to fulfill the obligations within the framework of the legal regulations to which MUNUBU is subject.

We process; Identity, Subscription and Contact Information, Usage and Behavioral Information, Device Information, Complaint and Request Data,

For the purposes of meeting the requests from authorized institutions and organizations, managing the processes of meeting user requests and complaints are included in this scope. This includes the protection of your information, which must be kept in accordance with the legislation regarding data processing activities, which arise from the secondary legislation to which MUNUBU is subject for the resolution of possible disputes and which is mandatory to protect the rights or security of the parties. This includes copying, backing up, checking the consistency of your information to prevent information loss, and taking the necessary technical and administrative measures for the security of our networks and information.

Where processing is necessary for the purposes of the legitimate interests pursued by MUNUBU or by a third party:
MUNUBU processes your Personal Data when processing is necessary for our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of users. When we process Personal Data for our legitimate interests, we identify these interests and establish the balance between those and data subjects’ rights. Users’ right to privacy and other personal rights are our top priority.

We process; Identity, Subscription and Contact Information, Usage and Behavioral Information, Device Information, Location Information,

For the purposes of measurement and improvement of service quality, service analysis, audit and control, risk management, detection of unauthorized and fraudulent use, product and strategy development. This includes providing the services within the scope of the Application and responding to your needs within the framework of the transactions and preferences you make, developing the services in question, detecting unauthorized and fraudulent uses, auditing and controlling them.

Upon Your Request

If you activate some settings of your device (access to contacts, camera or photos) to use some of the features of the Application, your Personal Data is processed based on your explicit consent.

Where are Personal Data Being Stored and Processed?

MUNUBU servers are located in Turkey and all data is stored for use in Turkey.

With Whom and For What Purposes are the Personal Data Shared?

MUNUBUmay share the Personal Data it has obtained with the following parties in accordance with the purposes and regulations set out in this Notice. The information under this section may differ from person to person due to circumstances such as the products and services that people benefit from or their requests and consents.

Law enforcement, regulators and other parties for legal reasons:MUNUBU is obliged to provide Personal Data within a legal obligation and in order to protect both its own rights, property or security and the rights, property or security of third parties with authorities. MUNUBU reviews whether the requesting parties are authorized for such request before sharing your Personal Data.

Your user name and password information, you may share to login other e-mail services you may access within the Application other than EPOZTA, are processed by third-party service providers. We would like to remind you that if you use these e-mail services other than EPOZTA, you will be subject to those service provider’s own terms and privacy policies. EPOZTA use and transfer to any other app of information received from Google APIs will adhere toGoogle API Services User Data Policy, including the Limited Use requirements.

Your Rights Regarding Your Personal Data

The Application users have the right to:

Right of access – the right to be informed of, and request access to, the Personal Data MUNUBU processes about you;
Right to rectification – the right to request that MUNUBU amends or updates your Personal Data where it is inaccurate or incomplete;
Right to erasure – the right to request that MUNUBU deletes your Personal Data;
Right to restrict – the right to request that MUNUBU temporarily or permanently stops processing all or some of your Personal Data;
Right to object –
the right, at any time, to object to MUNUBU processing your Personal Data on grounds relating to your particular situation;
the right to object to your Personal Data being processed for direct marketing purposes;
Right to data portability – the right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service; and
Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
In order to exert any of your rights stated above in relation to your Personal Data, 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:

(i)Prepared in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, sending a notarized letter to the following address: “Fulya Mahallesi Büyükdere Caddesi No:74/D İç Kapı No: 10, 34394 Şişli/İstanbul”

(ii)By submitting your request via the “Contact Us” tab in the Application, with your contact information including detailed explanations regarding your request.

Age Restriction

Users must be 16 years of age or older to subscribe, register or share any Personal Data to the Application and we do not intend to solicit, collect or process Personal Data of Users under the age of 16. In certain jurisdictions, the age may be older than 16, in which case, you must satisfy that age in order to become a subscriber. If you believe we have inadvertently processed Personal Data of a User under the age of 16, please contact us at the details provided. If we discover that we have inadvertently processed the Personal Data of any user under the age of 16, we reserve the right to delete it.

Retention Period of Personal Data

MUNUBU shall retain Personal Data during the period necessary for the purpose(s) for which it has been collected. Please note that if you want to delete your user account; your account, e-mail address, e-mails and Personal Data will be kept for a maximum of thirty days and will be deleted after the expiration of this period. MUNUBU 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 MUNUBU is required to retain Personal Data for a longer period by law.

Use of The Application

If you want to delete your user account in the Application, you can delete your deletion request from the “Settings” section of the Application.

About This Notice

MUNUBU 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 MUNUBU shall be effective as of the date of its publication on the Application. The information in this Notice may differ from person to person due to circumstances such as products and services that people benefit from or their requests and consents.

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