privacy and policy

This is where you can find out how Deha Mobil Soru Bankası collects, stores, protects and shares data about you (“Policy”). It’s best read alongside our Deha Mobil Soru Bankası Terms and Conditions, which you can find here. When you’re using our Deha Mobil Soru Bankası application ("App"), there is some information we collect about you, and you can share your information on the App with other users ("Users"). The Policy is intended to meet our duties of transparency under the “General Data Protection Regulation” or “GDPR”.

1. Collection of information

Registration Information Access to Deha Mobil Soru Bankası is granted through various means of your choice: your Facebook, Apple, Google account, your telephone number or your e-mail address . If you connect through Apple or Google, we will collect information about you from Apple or Google (as applicable), including an email address, full name and a unique ID (which allows Apple or Google to identify you as a legitimate user of the account). If you connect through Facebook, we will ask for the following access to information to be granted from your Facebook profile (which you can decline) (“Registration Information”) including: ● Name; ● Age range; ● Gender; ● Birthday; ● Hometown; ● Photographs; and/or ● Email address. In addition, if you permit us to do so, the App may access your device's geolocalisation, address book and contact lists in order to offer you certain features of our services, and this data forms part of your Registration Information. Selfie Data During our onboarding process, so that we can check whether your account is legitimate, we ask you to take a selfie, which is processed by a third-party provider. If the third-party system flags anything that may mean the photo is not of a real person (or that you do not meet the criteria required to be a member), the photo is then passed back to our team to review. Log and Usage Data Our servers automatically record information ("Log and Usage Data") created by your use of Deha Mobil Soru Bankası, which again helps us to improve our service. Log and Usage Data may include information such as your IP address, browser type, the referring domain, pages visited, access times, your mobile carrier, unique device identifier, device model, operating system, MAC address and search terms. Marketing and Communications Data We also collect information on your preferences in receiving marketing from us and your communication preferences (“Marketing and Communications Data”). Behavioural Data We collect “Behavioural Data”, which is inferred or assumed information relating to your behaviour and interests, based on your online activity. Your Content Data You can post content on the App and/or participate in chats through it. This content may contain personal data, but only what you choose to disclose. Aggregated Data We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but once in aggregated form it will not constitute considered personal data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy. No Special Categories of Personal Data We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, you have the option of providing such information in your profile or in any information you publish on our App, for instance by sharing your sexual orientation with other users. Please do not submit any Special Categories of Personal Data if you are not happy for such information to be shared publicly on your Deha Mobil Soru Bankası account. Geolocation Information Upon downloading the App, you will be asked to turn on location services. If you turn these features on, we may collect your device's geolocation data and save your device's coordinates to offer certain features to you (such as, for instance, finding users who live nearby). We may also use your device's geolocation information to personalise the App and make it easier for you to interact with other Users close by. You can control your location information settings in your Account settings and switch them off if you want to. Even if you have disabled location services, we may still determine your city, state, and country location based on your IP address (but not your exact location).

2. Uses made of the information

We will only use your personal data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will update this Policy and we will explain the legal basis which allows us to do so. What is our “legal basis” for processing your Personal Data? In respect of each of the purposes for which we use your personal data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases: ● Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”). ● Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal data for is set out in the table below. ● Where we need to comply with a legal or regulatory obligation (“Compliance with Law”). ● Where we have your specific consent to carry out the processing for the purpose in question (“Consent”). Generally, we do not rely on your Consent as a legal basis for using your personal data other than in the context of direct marketing communications. We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data. Purpose Categories of personal data involved Why do we do this Our legal basis for this use of data Account Creation and Management ● Registration Information ● Selfie Data ● Log and Usage Data ● Your Content Data To register you as a new customer, and offer you our services and features, and to allow you to participate in interactive features of our service, when you choose to do so. To notify you about changes to our service. Contractual Necessity. Customer Moderation ● Registration Information ● Selfie Data ● Log and Usage Data ● Your Content Data To allow our moderators to ensure that Users’ behaviour accords with our rules and restrictions (including our Community Guidelines) by reviewing the online content posted on the App and/or investigating complaints, and to take remedial action if it does not. Legitimate Interests. It is in our legitimate interest that the App remains safe for you, trustworthy and that Users do not abuse our services for purposes in breach of our Terms of Use or Community Guidelines. Support Registration Information To respond to any queries you raise when you contact us directly. Legitimate Interests. We have a legitimate interest in providing you with support services and answering your queries, so that we can improve our App and related services. Troubleshooting and App Development ● Log and Usage Data ● Behavioural Data To track issues that might be occurring on our systems. To carry out internal operations such as data analysis, testing, research or for statistical purposes. Legitimate Interests. It is in our legitimate interests that we are able to monitor and ensure the proper operation of our App and associated systems and services. Marketing ● Registration Information ● Marketing and Communications Data ● Behavioural Data To contact you with information about the App subject to the “Marketing” section below. Consent. Geolocation Geolocation Information To personalise the App and make it easier for you to interact with other Users close by Consent. Protecting our Legal Rights ● Registration Information ● Selfie Data ● Log and Usage Data To protect our legal rights, and to enforce our Terms of Use. Legitimate Interests. We have a legitimate interest in ensuring that you comply with your obligations under the contract between you and us, so that we can appropriately provide you and other Users our services. What happens when you do not provide necessary personal data? Where we need to process your personal data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of or access to the App). In this case, we may have to stop you using our App but we will notify you if this is the case at the time. 3. Personal data from third party sources In addition to the personal data that we collect directly from you (as described above), we also collect certain of your personal data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not. Third party data source Publicly available? Category(ies) or other types of personal data received. Social Media sites No Registration Information

4. Disclosure of your information

We will not disclose your information, except in the limited circumstances described here: ● Service Providers — We engage certain trusted third parties to perform IT and system administration functions and services. We may share your Registration Information and Log and Usage Data with these third parties, but only for the purposes of performing these functions and providing such services. As noted above, we also use a third party provider to process your Selfie Data at the onboarding stage. These Service Providers are located within the European Economic Area and/or the United States. ● Regulators and Public Authorities — We will cooperate with law enforcement enquiries received from within or outside your country of residence. This may include preserving or disclosing any of your personal data, including your Registration Information, if it is necessary to comply with a law or regulation, or to comply with a judicial proceeding, court order, or legal request, to protect the safety of any person, or to address fraud or security issues. Such Regulators or Public Authorities may be located both within or outside the European Economic Area. ● Business Transfers — In the event that Deha Mobil Soru Bankası or any of our affiliates are involved in a bankruptcy, merger, acquisition, reorganisation or sale of assets, your information may be transferred as part of that transaction. ● Professional Advisers — We may transfer your Registration Data to our lawyers, bankers, auditors and insurers and other advisers who provide consultancy, banking, legal, insurance and accounting services. Such Professional Advisers may be located either in the European Economic Area and/or the United States.

5. Where we store your personal data

Many of our external third parties are based outside of the European Economic Area (“Europe”) so their processing of your personal data will involve a transfer of data to countries based outside of Europe. We endeavour to ensure that people to whom we provide personal data hold it subject to appropriate safeguards and controls. Whenever we transfer your personal data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented ● We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries. ● Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries. ● Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.

6. Marketing

We will not send you any marketing materials. However, we may send you emails which are necessary for us to provide our services, or to announce any update of our App or Terms of service for instance.

7. What others see about you

Deha Mobil Soru Bankası is designed to make it easier for you to connect with other Users and to interact with them. Other Users of the App will see: ● General Deha Mobil Soru Bankası-submitted information: ○ your Content Data; ○ Photo and other images you upload; ○ First Name; ○ Generalized location (city/state); ○ Location ● Third party profile information: ○ When you register or login to the App using your Facebook, you may authorize us to access certain Facebook account information (as applicable), including information you make available via Facebook, your profile picture(s), your friends list, current location and those friends you have in common with other Deha Mobil Soru Bankası users, as well as information you provide through Facebook at your option (i.e., your photos, your name, gender, age, approximate location, friends you have in common with other Users and other profile information, as applicable). ○ If you login to the App using your Apple or Google account, other Users will be able to see your name. Such other Users may therefore share your profile information with individuals who may or may not be Users or via third party applications. So, please be careful about what permissions you grant through the App and what you post, particularly when it relates to your children. We want to keep you safe, but we need you to help us.

8. Our Policy Towards Age

Our App is for grown ups. You have to be at least 17 years old to use the App. We don’t market to anyone under the age of 17 either. If we discover you’re under 17, we will delete your account, sorry but we’re looking forward to welcoming you soon!

9. Removing Deha Mobil Soru Bankası access

If you want to remove Deha Mobil Soru Bankası from your Facebook, Apple or Google account at any time you can do this by visiting the application settings on your Facebook, Apple or Google profile (as applicable) and following the instructions to remove Deha Mobil Soru Bankası access permissions. Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, made public by you during your use of the App, or copied or stored by other Users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. The App may also include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your personal data. We do not control these third-party websites and are not responsible for their privacy statements. If you have given third party applications or websites access to your personal data, they may retain such information to the extent permitted under their terms of service or privacy policies.

10. Your Rights Relating to Your Personal Data

By law you have the right to: ● Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. ● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. ● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below). ● Object to processing of your personal data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. ● Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it. ● Request the transfer of your personal data. We will provide to you, or a third party you have chosen, personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. ● Withdraw consent. This right only exists where we are relying on consent to process your personal data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our App. We will advise you if this is the case at the time you withdraw your consent. How to exercise your rights If you want to exercise any of the rights described above, please contact us at feedback@dehaegitim.com. Typically, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Complaints If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at feedback@dehaegitim.com. We will reply to your complaint as soon as we can. If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the US, is the National Data Protection Authority.

11. How we keep your personal data secure

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to your personal data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We have put in place procedures to deal with any actual or suspected personal data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your personal data.

12. Changes to our privacy policy

We may revise this Policy from time to time. If we make a change to this Policy that, in our sole discretion, is material, we will notify you, for example, via an email. The revised Policy will apply from the date on which we post it on this page.

13. Cookies

We collect information by placing cookies on your mobile. A cookie is a piece of text stored on your computer or mobile by your web browser. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our App. We use two broad categories of cookies: ● first party cookies, served directly by us to your computer or mobile device; and ● third party cookies, which are served by our partners or service providers on our App. We use cookies for a number of reasons, as explained below: Cookie Functions Cookie Purposes Analytics and research We use Google Analytics to collect information about how visitors use the Deha Mobil Soru Bankası App. We use the information to compile reports and to help us improve the site and the App. The cookies collect information in an anonymous form, including the number of visitors to the site/App, where visitors have come to the site/App from and the pages they visited. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our App works. You can find out more information about Google Analytics cookies here You can find out more about how Google protects your data here. Authentication These cookies help us to identify visitors so that when you’re logged in, you can enjoy Deha Mobil Soru Bankası’s offerings and localise your experience, such as when you’ve requested to view Deha Mobil Soru Bankası’s App in your local language or when you’ve asked Deha Mobil Soru Bankası to ‘remember me’. Security and App integrity We use cookies and other devices, such as CAPTCHAs, to help keep the App and our visitors safe and secure. These cookies do things like protect visitors from spam and fraud, by ensuring the safety of personal data. We may use persistent cookies, which will help us to ensure we have identified the same device is logging into the correct account. These types of cookies also help with our anti-spam measures and may help us to prevent phishers, scammers and other unauthorised activity. Site features and services These cookies and local storage devices provide functionalities such as links to other social media sites and social plugins. In some cases, the App feature you choose may allow a third party to place cookies or local storage devices on your computer. The third party who Deha Mobil Soru Bankası recommends that you read their privacy policies. Third parties who place cookies on your device when you use Deha Mobil Soru Bankası include the following, and we have included a link to the privacy policies of Facebook and Google Performance We need to use certain cookies and local storage devices to ensure our visitors have the best possible experience. These may, for example, assist with your navigation of our App, ensure pages load up quickly and respond faster to your requests for the App’s services. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. Our use of cookies and local share devices, including the specific cookie names, may change over time, but will generally fall into the above categories. Please visit this page regularly so that you are aware of any changes. Disabling cookies You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of our App. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our App. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk . You can also prevent the use of Google Analytics relating to your use of our App by downloading and installing the browser plugin here.

14. How long we store your personal data

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out in "2. Uses made of the information", unless a longer retention period is required by law (for example for regulatory purposes). The table below shows our standard retention practices: Category of Personal Data Retention period Geolocation Information For so long as you do not opt-out of the geolocation functionality on our App, and in any event, no longer than 30 days following deletion of your Account as a back-up copy to enable restoration. Registration Data Selfie Data Log and Usage Data Your Content Data Behavioural Data Marketing; and Communications Data For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see "2. Uses made of the information") and in any event, no longer than 30 days following deletion of your Account as a back-up copy to enable restoration.

15. Contact

Deha Mobil Soru Bankası is the controller (for the purposes of the GDPR) of your personal data, and is registered in the United States.