360 Internet ve Iletişim Hizmetleri Ticaret Limited Sirketi (“Smart 360”) respects the privacy of your personal data. This privacy policy (“Privacy Policy”) explains how we can use the personal data we collect about individuals on www.smart-360.com (“Site”), with whom we can share it, and the current choices regarding the use of this data. This Privacy Policy also explains the measures we take to protect personal data, how long we protect it, how individuals can communicate with us about our privacy practices and how they can exercise their rights
- Information We Obtain
- How We Use the Information We Obtain
- Automatic Collection of Data
- Information sharing
- Data transfer
- Your Rights and Choices
- Other Online Services and Third-Party Features
- Storage of Personal Data
- Protection of Personal Data
- Children’s Personal Data
- Updates to Our Privacy Policy
- Contacting us
Information We Obtain
In connection with your use of the site, you may provide us with your personal data in various ways. The personal data we may obtain may include personal data contained in the content you submit. For example, when you send an e-mail to us by clicking on the Smart 360 e-mail address links on the Site, you may be providing personal data. You are not required to provide any personal data, but if you choose not to do so, we may not be able to provide you with some of the features of our Services and Site.
How We Use the Information We Obtain
We may use the information we obtain on the Site for the following purposes:
- To personalize your experience on the Site,
- To provide our services to you;
- To answer your requests and questions;
- To operate, evaluate and improve our business (develop new services, expand and improve our services, analyze our services, manage our communications, conduct data analysis and market research, perform accounting, auditing and other internal functions);
- Protect, detect and prevent fraud and other criminal activities and claims and other liabilities;
- To operate and ensure compliance with applicable legal requirements, relevant industry standards and our policies, including this Privacy Policy, the Smart 360 Privacy Protection Policy, and the Smart 360 Terms of Service.
As required by applicable law, we use the personal data we collect to comply with applicable legal requirements, fulfill our contractual obligations and, to the extent permitted by law, to pursue our legitimate interests (such as administering the Site, analyzing and operating the Site, evaluating and developing our business). Otherwise, we obtain consent to process personal data. We may also use the data we obtain in other ways, provided that a specific notice is given at the time of collection.
Automatic Collection of Data
When you use the site, we may obtain certain information through automated means such as browser cookies. The information we obtain in this way includes your device’s IP address, domain name, identifiers associated with your devices, device and operating system type and features, web browser features, language preferences, click data, your interactions with the Site (web pages you visit, links you click and features you use) as well as the pages that refer or refer you to the site, the dates and times of access to the Site, and other information about your use of the Site.
A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to store the visitor’s browser or information or settings in the browser. This technology helps us: (1) It helps remind you of your information so you don’t have to re-enter it; (2) We track and understand how you use and interact with the Site; (3) We can tailor the Site to your preferences; (4) We measure the usability of the Site; (5) we understand the effectiveness of our communications; and (6) we aim to manage and improve the Site.
To the extent required by applicable law, we will obtain your consent before placing cookies or similar technologies on your computer. You can stop certain types of cookies from being downloaded to your computer by selecting the appropriate settings in your web browser. Most web browsers will let you know how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie, and how to disable existing cookies. You can learn how to disable cookies for your browser by clicking “help” in your browser’s menu or by visiting www.allaboutcookies.org. The site is not designed to respond to “do not track” signals from browsers. Please note that without cookies or other automated tools, you will not be able to use all features of the Site.
We do not collect personal information about your online activities related to third-party websites, devices and other online services. We use third-party online analytics services on the site, such as Google Analytics. The service providers that manage these analytics services use automated technologies to collect data (such as email address, IP addresses, cookies and other device identifiers) to evaluate use of the Site and detect technical issues, for example. To learn more about Google Analytics, please visit www.google.com/analytics/learn/privacy.html.
Information sharing
Except as described in this Privacy Policy, we do not disclose personal information we obtain about you. Your personal information (1) with our affiliates and affiliates; (2) We may share it with Service Providers serving on our behalf for purposes such as data analysis for the purposes described in this Privacy Policy. We do not allow our Service Providers to use or disclose this information except to provide services on our behalf or to comply with legal requirements.
Information about you: (1) If we are required to do so by legal or legal process (such as a court order or subpoena), (2) in response to requests from government agencies such as law enforcement; (3) To establish, exercise or defend our legal rights; (4) When we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) In connection with an investigation into suspected or actual illegal activities; (6) we sell or transfer all or part of our business or assets (in case of reorganization, liquidation or liquidation); or (7) Apart from these, we can disclose with your consent.
Data transfer
We may transfer the personal data we collect about you to recipients in other countries (including our affiliates and affiliates and third-party service providers) located outside the country where the data was originally collected. These countries may not have the same data protection laws as the country in which you originally provided the data. When we transfer your personal data to recipients in other countries (such as the USA), we will protect that information as described in this Privacy Policy.
If you are located in the European Economic Area (“EEA”) or Switzerland, we will comply with applicable legal requirements that provide adequate protection for the transfer of personal information to recipients located outside the EEA and Switzerland. Regarding the transfer of personal data to the USA, as Smart 360, we comply with the EU-US and Swiss-US Privacy Shield Frameworks as determined by the US Department of Commerce regarding the collection, use and storage of personal information from EU member countries and Switzerland.
If you are located in Turkey, we comply with applicable legal requirements that provide adequate protection for the transfer of personal information to recipients located in other countries, the opinions of the Personal Data Protection Board and the requirements of the Personal Data Protection Law.
Your Rights and Choices
To the extent provided by Article 11 of the Law on Protection of Personal Data No. 6698 (“KVKK”) and other applicable laws, (1) To learn whether personal data is processed, (2) To learn the purpose of the processing and whether it is used in accordance with the purpose, (3) To know the persons to whom the personal data is transferred, (4 ) To request correction in case of incomplete or incorrect processing and to request the deletion of personal data if the conditions are fulfilled, and to forward these requests to third parties, (5) To object to the emergence of a result against him by analyzing the processed data exclusively through automated systems, (6) Due to unlawful processing You have the right to claim damages in case of damage.
Depending on where you are, you may have the right to file a complaint with a regulator or the Personal Data Protection Board if you are not satisfied with our response. Where required by law, we may withdraw any consent you have previously given to us or object to the processing of your personal data on legal grounds relating to your particular situation at any time, and we may apply your preferences prospectively. To help protect your privacy and maintain security, we may request some additional information or paperwork to verify your identity before granting you access to your information. To the extent permitted by applicable law, we may charge a fee before providing you with a copy of your personal information.
Other Online Services and Third-Party Features
For your convenience, the Site may link to other online services and websites (for example, Facebook, Vimeo, Instagram, LinkedIn and Twitter buttons). These services, websites, and third-party features may operate independently of us. The privacy practices of these third parties, including information about the information they may collect about you, are subject to their own privacy statements, which we strongly encourage you to review. Any online services or site features of third parties provided through the site are not managed or controlled by us, and we are not responsible for this.
Retention of Personal Information
To the extent permitted by applicable law, we retain personal information we obtain about you (1) for as long as necessary for the purposes we obtain, in accordance with the provisions of this Privacy Policy; or (2) If the data is stored for a longer period than is required for the original purpose for which it was collected, we reserve it for a legal reason.
How Do We Protect Your Personal Information?
We protect the personal data we obtain through the Site with administrative, technical and physical measures designed to protect against accidental, illegal or unauthorized destruction, data loss, alteration, unauthorized access, disclosure or use.
Children’s Personal Information
The site is designed for a general audience and is not intended for children under the age of 13. Smart 360 does not knowingly or willingly collect or solicit personal data from children under the age of 13 through the Site. If we become aware that we have collected personal data from a child under the age of 13, we will immediately delete this information from our records. If you believe that a child under the age of 13 has provided us with personal data, please contact us as set forth in the “Contact Us” section below.
Updates to Our Privacy Policy
This Privacy Policy may be updated regularly and without notice. This information will be at the top of the notification when it is last updated.
How to Contact Us
To update your preferences, update or correct your information, submit a request regarding the exercise of the rights listed in the Personal Data Protection Law No. 6698, ask a question about this Privacy Policy or exercise other applicable privacy rights, please contact http://hello@smart-360.com Contact us by e-mail or write to the address below.
The person concerned, within the scope of the rights specified in Article 11 of the Law on the Protection of Personal Data No. 6698, can submit their requests in writing or by registered electronic mail (KEP) address, secure electronic signature, mobile signature or previously notified to Smart 360 by the person concerned. It must be forwarded using the e-mail address registered in the Smart 360 system.
360 Internet ve Iletişim Hizmetleri Ticaret Limited Sirketi, registered in the registry number 890227 of the Istanbul Chamber of Commerce, with the MERSIS number 0001079261600001 and located at the address of Teşvikiye Mahallesi, Akkavak Sokak, No: 22/8 Nisantaşı, Istanbul, is the Data Controller within the scope of KVKK.